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ZUVO PRIVACY POLICY

Last Updated: [●]

This Privacy Policy explains how Junglee Games India Private Limited, a company incorporated under the laws of India (“JGIPL”, “we”, “us”, or “our”), collects, stores, uses, processes, protects and discloses the Personal Data and Information of users who access or use the Zuvo mobile application, website and related services (“Zuvo” or “Services”). This Privacy Policy forms part of and is to be read together with the Zuvo Terms of Service. By using Zuvo, you consent to the practices described in this Privacy Policy. If you do not agree, you should discontinue the use of the Services.

1. Overview

This Privacy Policy describes what Personal Data and Information we collect, why we collect it, how we use it, how we share it, the rights you may have in relation to your Personal Data and Information, and the measures we take to safeguard it. For the purposes of this Privacy Policy, “Personal Data and Information” means any information that relates to an identified or identifiable natural person, including any information that directly or indirectly identifies you such as your name, mobile number, email address, profile details, device identifiers, advertising identifiers, IP address, approximate or precise location, demographic attributes, behavioural and usage information, audio and video recordings, chat messages, livestream data, participation details, payment and transaction metadata, facial data or biometric identifiers where applicable, and any other information that directly or indirectly may be capable of identifying you.

2. What Personal Data and Information Do We Collect

We collect Personal Data and Information that you provide to us directly, that is generated or captured when you use the Services, and that we obtain from third parties. When you register on Zuvo, we collect the details necessary to create and maintain your account such as your mobile number, email address, date of birth, chosen identifiers, password credentials, profile images, and related account information. If you participate as a creator, we may collect additional information for onboarding purposes such as KYC documents, PAN details, address proof, banking details, tax information, profile material and other documentation necessary for your eligibility and payouts.

When you use Zuvo, you may generate or transmit User Content including but not limited to text messages, chat conversations, livestream audio, livestream video, comments, images, emojis, virtual gifts, throwables, room interactions, quiz answers, voice communications, screen shares and all similar forms of input or participation. Such information, including associated metadata such as timestamps and contextual data, may be collected and processed. Where the Services require identity verification or eligibility checks, we may collect identity documents, photographs or videos in order to verify authenticity, prevent impersonation or take any steps required under applicable laws.

We automatically collect certain technical and usage-related information when you access the App, including information about your device model, operating system, unique device identifiers, advertising identifiers, app version, crash logs, diagnostics, IP address, network details, language settings and session information. We also collect details about your activity on Zuvo such as rooms entered, livestreams joined, interactions with creators, duration of participation, gifting behaviour, event attendance, quiz activity, frequency of usage and other engagement metrics. Cookies, SDKs and similar technologies may be used to maintain sessions, ensure security, support analytics, and personalise your experience.

We may also receive information from third-party service providers including identity verification partners, payment processors, analytics partners, and social login providers if you choose to link such accounts. All such information is treated as Personal Data and Information under this Privacy Policy.

3. How We Use Your Personal Data and Information

We use your Personal Data and Information to provide, operate, maintain and improve the Services. This includes creating and managing your account; enabling access to interactive rooms, livestream audio and video sessions, quizzes and creator-led activities; processing your participation in events, contests, promotions, leaderboards and other features; and ensuring the smooth delivery of audio, video, chat and visual elements.

We may use your information to verify your identity, conduct KYC checks if required for payouts or regulatory compliance, and ensure that only eligible users participate in paid or reward-based activities. Personal Data and Information is also used to process payments, in-app purchases, rewards and creator payouts as applicable.

We use your Personal Data and Information to personalise your user experience such as recommending creators, rooms, events and features relevant to your activity. We analyse usage patterns to understand how users engage with different parts of the App, to identify trends, resolve technical issues, and improve audio/video quality and overall performance. We also use your information to communicate with you including sending service-related messages, updates, event reminders, promotions where permitted, support responses and other communications necessary for the functioning of the Services.

We use Personal Data and Information to safeguard the platform by detecting and preventing fraudulent behaviour, impersonation, harmful conduct, misuse of features, policy violations and any behaviour that may cause harm to users or the Services. We also use your information to comply with applicable laws, tax and regulatory requirements, enforce our Terms, respond to legal process, handle disputes, and cooperate with authorities where required.

We may use aggregated or anonymised information that does not identify you personally for analytics, research or internal purposes.

4. Recording and Transcription

Zuvo includes livestream audio and video rooms, interactive sessions, creator-led events and similar features in which your audio, video, messages, interactions and participation may be monitored, recorded, stored or transcribed. Such recordings or transcripts may be used for moderation, safety, fraud detection, compliance with law, training of moderation systems, dispute resolution and improving the Services. By participating in any livestream, room or interactive feature, you consent to such recording and retention of your communications as described in this Privacy Policy.

5. Biometric and Facial Information

Certain optional features on Zuvo may involve the processing of facial images, facial landmark data or biometric-like identifiers. These features include face filters, effects, verification mechanisms or any similar functionalities. This information is processed strictly for the limited purpose disclosed at the time of collection, such as applying a visual effect or authenticating your identity. It is retained only for the minimum duration necessary for that purpose and is not used for advertising unless explicit consent is obtained. Sensitive verification videos, where collected, are used only for verification and are not retained beyond that requirement unless mandated by law.

6. How We Share Your Personal Data and Information

We may share your Personal Data and Information with service providers who assist us in operating Zuvo, including cloud hosting providers, audio/video delivery partners, identity verification vendors, payment processors, moderation partners, analytics providers and customer support service providers. These partners are authorised to process information only for the purposes of performing their services for us and are bound by contractual obligations to protect such data.

We may share limited information with creators solely for the purpose of managing interactive sessions, such as displaying usernames, gifting activity or participation status within their rooms. We may share information with our corporate affiliates for internal operations, compliance, audit and technology purposes. We may disclose Personal Data and Information to regulators, law enforcement or governmental authorities where required under law or pursuant to legal process. In the event of a merger, acquisition, restructuring or sale of assets, user information may be transferred to the acquiring or successor entity subject to appropriate safeguards. Content or information you choose to make public on Zuvo, such as in public rooms or livestreams, may be visible to other users.

We do not sell your Personal Data and Information.

7. Links to Third-Party Sites

Zuvo may contain or make available links, integrations or redirections to third-party websites, applications, advertisements, plug-ins, payment gateways, content, tools or services. These third-party resources operate independently of Zuvo and are governed by their own terms and privacy practices. We do not own, control, operate or endorse such third-party resources, nor do we make any representation or warranty regarding the accuracy, safety, reliability, security or data practices of such third parties. When you click on, access or interact with any link or integration that leads you outside the Zuvo environment, the Personal Data and Information that you share, provide or that may be collected automatically by such third parties is governed solely by their respective privacy policies and practices, and not by this Privacy Policy. We do not monitor, supervise or take responsibility for how such parties collect, store, use or disclose your data, nor can we guarantee that they will maintain the same level of protection or safeguards that we implement.

Your interactions with third-party websites or applications, including any transactions you undertake, any permissions you grant, any information you provide, any purchases you make or any content you view or share, are entirely voluntary and carried out at your own discretion and risk. You are strongly advised to review the applicable terms and privacy policies of any third-party resources before accessing or using them, and to exercise caution when providing Personal Data and Information in such environments. If you choose to engage with third-party services through Zuvo, you acknowledge and agree that such engagement is solely between you and the respective third party, and that JGIPL shall not be liable for any loss, misuse, damage, disclosure, harm or claim arising from or relating to such third-party interactions.

8. Data Security

We implement reasonable security practices and procedures intended to safeguard your Personal Data and Information against unauthorised access, loss, misuse, alteration or disclosure. These may include encryption in transit, access restrictions, secure storage, logging and monitoring. While we strive to protect your data, no method of transmission over the internet or electronic storage is completely secure. You are responsible for maintaining the confidentiality of your login credentials and restricting access to your device.

9. Your Choices

You may choose to manage or limit certain types of data collection by adjusting your device or App settings. For example, you may disable access to your camera, microphone, location services, notifications or advertising identifiers. You may choose not to provide optional information or permissions, although some features may not function properly without them. You may opt out of marketing communications by following the instructions provided in such communications. You may also request deletion of content you have shared on Zuvo subject to technical and legal limitations.

10. Your Rights

Subject to applicable laws, you may have the right to request access to your Personal Data and Information, request correction or updates to inaccurate information, request deletion of certain data, withdraw consent for optional processing activities, object to certain processing where allowed, or request restrictions on processing. You may exercise these rights by contacting us at [email protected]. We may require verification of your identity before responding to your request and may deny certain requests where permitted under law, including where retention is required for legal or regulatory purposes.

11. Accessing and Updating Your Personal Data and Information

You may review, update or correct your account information through the Account Settings section of the App or by contacting customer support. We encourage you to keep your information accurate and current to ensure seamless access to the Services.

12. Data Retention

We retain Personal Data and Information for as long as necessary to provide the Services, meet legal and regulatory requirements, address disputes, enforce our Terms, maintain the security and integrity of the platform and comply with tax, audit and statutory obligations. Certain information may remain in backups or archives for a limited duration even after deletion requests, but such information is not used for active operations except where required for safety, legal or compliance purposes.

13. Children

Zuvo is intended for individuals aged eighteen (18) years and above. We do not knowingly collect Personal Data and Information from persons under 18. If we become aware that information belonging to a minor has been inadvertently collected, we will take steps to delete such information in accordance with applicable law.

14. Changes to This Privacy Policy

We may update or modify this Privacy Policy from time to time. Any changes will be posted within the App. Your continued use of the Services after publication of a revised Privacy Policy constitutes your acceptance of the updated terms. The “Last Updated” date at the top of this document reflects the version in effect.

15. Contact Information

If you have any questions, concerns or requests relating to this Privacy Policy or the handling of your Personal Data and Information, you may contact us at [email protected] or write to us at our registered address provided in the App.

17. Governing Law

This Privacy Policy is governed by and shall be construed in accordance with the laws of India. Any disputes arising from or relating to this Privacy Policy shall be subject to the exclusive jurisdiction of the courts located in Bengaluru, Karnataka.