Privacy Policy

Last Updated on 1 June, 2021

This privacy policy (“Privacy Policy”) describes how and when Beunlu Private Limited (“Company”

 

This privacy policy (“Privacy Policy”) describes how and when Beunlu Private Limited (“Company” "We", "Us", or "Our") collects, processes, uses and shares your information when you use the “Unlu” application and [www.unlu.io] (collectively referred to as "Platform"). The Platform is provided and controlled by  Beunlu Private Limited a company incorporated under the provisions of Companies Act, 2013 having its office at 462, Tower B1, Spaze iTech Park Sohna Road, Sector 49 Gurugram, Haryana-122018, India.The Company is committed to protecting Your privacy and the information that You share while using the Platform. We value the trust You place in Us. That’s why, We maintain the highest security standards for securing the transactions and Your information. This policy explains our practices concerning the personal data we collect from you, or that you provide to us. If you do not agree with this policy, you should not use the Platform

 

The Company provides certain services to its end-users, customers who are registered with the Platform (“Users”, “You” or “Your”) which can be accessed, used and availed in according to Our terms and conditions of use/services available at (“Terms of Use”). Unlu is a technology platform that is engaged in the business of providing various services and facilities to the Users, which includes, making available the content, including, any information, text, graphics, video, sound, pictures or any other material, appearing, sent, uploaded, communicated, transmitted or otherwise made available via the Platform, and providing the celebrity engagement, which, inter alia, includes, enabling and facilitation of interactions between the Users and celebrities by bringing celebrities and fans closer to each through participation or any other form of engagement developed or offered by the Company (“Services”)

 

This Privacy Policy specifies the manner in which personal data and other information is collected, received, stored, processed, disclosed, transferred, dealt with or otherwise handled by the Company. This Privacy Policy does not apply to information that You provide to, or that is collected by, any third-party through the Platform, and any third-party sites that You access or use in connection with the Services offered on the Platform.

 

Please read the Privacy Policy carefully prior to using or registering on the Platform or accessing any material, information or availing any services through the Platform. 

 

By visiting the Platform or setting up/creating an account on the Platform for availing the Services and clicking on the “I accept” button provided on the Platform, You (You”, “Your” as applicableaccept and agree to be bound by the terms and conditions of this Privacy Policy. This Privacy Policy is incorporated into and subject to User Terms of Service and shall be read harmoniously and in conjunction with them. 

 

This Privacy Policy (i) will be considered to be an electric record under the Indian data privacy laws including the Information Technology Act, 2000 read with rules and regulations made thereunder and (ii) will not require any physical, electronic, or digital signature by the Company.  

 

If you have any questions about how we use your personal data, contact us at: hello@unlu.io

 

SUMMARY

What information do we collect about you?

 

We collect and process information you give us when you create an account and upload content to the Platform. This includes technical and behavioural information about your use of the Platform.  We also collect information about you if you download the app and interact with the Platform without creating an account.

 

How will we use the information about you?

We use your information to provide the Platform to you and to improve and administer it.  We use your information to, among other things, show you suggestions, improve and develop the Platform and ensure your safety.  Where appropriate, we will also use your personal information to serve you targeted advertising and promote the Platform.

 

Who do we share your information with?

We share your data with third party service providers who help us to deliver the Platform, such as cloud storage providers. We also share your information with business partners, other companies in the same group as Unlu or Company, content moderation services, measurement providers, advertisers, and analytics providers. Where and when required by law, we will share your information with law enforcement agencies or regulators, and with third parties pursuant to a legally binding court order.

 

How long do we keep hold of your information?

We retain your information for as long as it is necessary to provide you with the service. Where we do not need your information in order to provide the service to you, we retain it only as long as we have a legitimate business purpose in keeping such data or where we are subject to a legal obligation to retain the data. We will also retain your data if we believe it is or will be necessary for the establishment, exercise or defence of legal claims. 

 

How will we notify you of any changes to this Privacy Policy?

We will generally notify all users of any material changes to this policy through a notice on our Platform. However, you should look at this policy regularly to check for any changes. We will also update the “Last Updated” date at the top of this policy, which reflects the effective date of such policy. By accessing or using the Platform, you acknowledge that you have read this policy and that you understand your rights in relation to your personal data and how we will collect, use and process it.

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  1. Collection of Information
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    • You may provide or the Company may collect certain personal information while registering on the Platform and/or using the Service. This includes: [(a) your name, electronic mail address, password,  IP address, your photograph and other relevant details; (b) your content, received, uploaded or posted using the Platform, including messages, images, videos and feedback; (c) information collected via third parties such as social media website or other interactive websites/ services you may choose to connect with or sign in with, or the Company’ service providers analytics providers; (d) information you choose to upload, sync or import from the device on which the Platform is being used; and (e) Information about you or relating to you that is voluntarily shared by you on the Platform, including without limitation, any quotes, images, political opinions, religious views, profile photo, user bio and handle, inter alia (collectively “Personal Information”).] All information disclosed by you on the Platform to which you permit access shall be deemed to be shared willingly and without any coercion. No liability pertaining to the authenticity, genuineness, misrepresentation, fraud, negligence, etc. of the information disclosed by you shall lie on the Company. 

     

    • Platform is used including SDK/API/JS code version, browser, internet service provider, timestamp, application identifier, application version, application distribution channel, independent device identifier, Android ad master identifier, network card (MAC) address, and international mobile device identification code (IMEI), the equipment model, the terminal manufacturer, the terminal device operating system version, the session start / stop time, location, language, the time zone and the network state (WiFi and so on).

     

    • The Platform is a celebrity engagement platform, so most of the information you provide to the Company is information that you choose to be made public. This includes not only the content that you provide for creation of video by the celebrity, but also content that you post and information provided with such content, such as when it was posted, the videos that you watch, your interaction with other users or celebrities on the Platform and other similar information. Your public information is broadly and instantly disseminated. For instance, your profile information and public content are immediately delivered to other users of the Platform. When you share information or content via the Platform, you should think carefully about what you are making public.

     

    • In addition to profile information, you may also tell us your exact location if you choose to enable your computer or mobile device to send us location information. The Company may use and store information about your location to provide features of the Service and to improve and customize the Service.

     

    • The Company may keep track of how you interact with links across the Platform, including email notifications, third-party services, and client applications, by clicking redirect links or through other means. The Company does this to help improve the Service, for example to provide relevant advertising, and to be able to share aggregate click statistics such as how many times a particular link was clicked on, with our advertising partners.

     

    • Our servers automatically record information ("Log Data") created by your use of the Service. "Log Data" is information that we automatically collect when you use the Platform, whether through the use of cookies, web beacons, log files, scripts, including, but not limited to: technical information, such as your mobile carrier-related information, configuration information made available by your web browser or other programs you use to access the Platform, your IP address and your device’s version and identification number; information about what you have searched for and viewed while using the Platform, such as web search terms used, social media profiles visited, mini applications used, and details of other information and content accessed or requested by you while using the Platform; general information about communications on the platform, such as the identity of a user that you have communicated with and the time, data and duration of your communications; and metadata, which means information related to items you have made available through the Platform, such as the date, time or location that a shared photograph or video was taken or posted. The Company receives Log Data when you interact with the Service. The Company uses Log Data to provide Service, to measure, customize, and improve the Service, and to aid a better user experience. 

     

    • Cookies: We and our vendors and service providers use cookies and other similar technologies (e.g., web beacons, flash cookies, etc.) (“Cookies”) to automatically collect information, measure and analyze which web pages you click on and how you use the Platform, enhance your experience using the Platform, improve our services, and provide you with targeted advertising on the Platform and elsewhere across your different devices. Cookies are small files which, when placed on your device, enable the Platform to provide certain features and functionality. Web beacons are very small images or small pieces of data embedded in images, also known as “pixel tags” or “clear GIFs,” that can recognize Cookies, the time and date a page is viewed, a description of the page where the pixel tag is placed, and similar information from your computer or device. By using the Platform, you consent to our use of Cookies. If you choose to refuse, disable, or delete Cookies, some of the functionality of the Platform may no longer be available to you.
    • In case you make any payment on the Platform in relation to the Service, you understand and acknowledge that the Company only facilitates the third-party payment gateway for processing of payment and all financial information including bank account details is collected by such third-party payment gateway and not by the Company. The Company will not be liable for any acts or omissions on the part of the payment gateway. You should view the terms of service and the privacy policy of such third-party payment gateway prior to disclosing any sensitive personal information to such third-party payment gateway. 
  3. Usage of Information
  4. The information gathered by the Company as specified in Clause 1, may be used for the following purposes:

     

    • for your registration, To set up and facilitate log-in to a user account on Platform and management of your account on the Platform;  
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    • To notify you about changes to the Platform, including this Privacy Policy;
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    • to confirm your identity directly and/or through third parties;
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    • to provide you Services;
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    • helping you efficiently access your information after you sign into the Platform and To facilitate communication, including provision of user support;
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    • remembering your Personal Information so that you are not required to re-enter it the next time you visit the Platform;
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    • to understand your preferences and to enhance and customize your experience of using the Service and the Platform;
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    • for providing customized user relevant suggestion / Services;
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    • to communicate with you through mail, e-mail and telephone, in connection with the Service, or other products or services of the Company;
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    • to respond to your comments, reviews and questions and provide better Service;
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    • to communicate important notices or changes in the Service, use of the Platform and the terms/policies which govern the relationship between you and the Company;
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    • for internal purposes such as auditing, data analysis, research and improvement relating to the Platform or the Service;
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    • for promotion and marketing purposes and To assess effectiveness of and improve advertising and other marketing and promotional activities;
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    • for sharing such information with any third party, including any service providers and any group companies of the Company, in the course of providing the Service through the Platform; 
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    • to transfer data to the regulatory authorities or other appropriate authorities as required by law.
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    • To enforce our terms, conditions, and policies and any of our rights, or the rights of our affiliate companies, or other users of the Platform;
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    • To develop new services and improve the existing services and the Platform and integrate user feedback and requests;
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    • To provide language and location based personalization;
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    • To administer the Platform and for internal operations, including troubleshooting, data analysis, testing, research, security, fraud-detection, account management, and survey purposes;
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    • To better understand how you use and access the Platform and to improve the user experience on the Platform;
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    • To pseudonymise and aggregate your information, including Personal Information, for conducting user demographic analysis on items such as region, phone model, operating system platform, system language, and the Platform version in order to better understand how our users are using the Platform;
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    • To pseudonymise and aggregate your information, including Personal Information, for collection of web and account traffic statistics of what content and services are used when users access third-party services on the Platform;
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    The data gathered from you may also be used for any reason incidental to the reasons listed above; and for any other purpose with your consent.

     

  5. Collection of Information by Third-Party Sites and Advertisers
  6.  

    When you use the Platform, there may be certain links which may direct you to other websites or applications not operated/maintained by the Company (“Third Party Site”). The manner in which your information is collected, received, stored, processed, disclosed, transferred, dealt with and handled by such Third Party Site(s) is governed by the terms and conditions and privacy policy of the respective Third Party Site(s). The Company hereby expressly disclaims all liabilities with respect to the manner in which any Third Party Site collects and/or uses your information. 

     

  7. Disclosure to Third Parties
  8.  

    • The Company may need to disclose your information, if required to do so by law and if such action is necessary to: (a) comply with a legal obligation; (b) protect and defend the rights or property of the Company, and other Users including to enforce agreements, policies, User Terms of Service and Celebrity Terms of Service; (c) protect the personal safety of the Company, the users of the Platform, or any person, in an emergency; (d) protect the Company from incurring any legal liability; (e) firms representing the Company in judicial proceedings and/or any legal, accounting and auditing firms providing services to the Company; and (f) for reasons incidental to the above. In such an event the Company shall be under no obligation to inform you or seek your approval or consent. 
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    • The Company shall be at liberty to disclose your information to: (i) any third party to facilitate the provision of the Service; and (ii) any third parties who provide services, such as auditing, data analysis, platform improvement and assistance with delivery of content, relevant marketing messages and advertisements. If you provide a mobile phone number and/or e-mail address, the Company or the third-party service providers or the persons authorized by them, may send you text messages/e-mails in relation to your use of the Platform. The Company contractually requires these third parties to keep such information confidential and use it only for the purposes for which the Company discloses it to them. These third parties may view, edit, or set their own cookies or may place beacons on your personal information. 
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    • The Company may also share aggregated (and de-identified) information with third parties at its discretion.
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    • The Company may share your personal information with third-party vendors, consultants, and other service providers who work for the Company and are bound by contractual obligations to keep such personal information confidential and use it only for the purposes for which the Company discloses it to them. 
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    • The Company may disclose or transfer your information (personal or otherwise) to any subsidiary or affiliate, and to a third party if the Company sells, transfers or divests all or a significant portion of the Company’s business or assets to another company in connection with or during negotiation of any merger, financing, acquisition, bankruptcy, dissolution, transaction, or other similar proceeding. Such third parties shall be contractually bound to not disclose further, any personal information disclosed to them.
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    • Sharing with our Group of Companies- We may share your Personal Information with any member of our Group. The term “Group” shall mean any entity that is controlled by us, or any entity that is in control of us, or any entity that is under common control with us, whether directly or indirectly.
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    • What you Share with Others- When you share content and communicate using our Platform, you choose the audience who can view such content. For example, when you post any content from our Platform on Facebook, you select the audience for the post, such as a friend, a group of friends or all of your friends. Similarly, when you use WhatsApp or any other application on your mobile device to share the content on our Platform, you choose who you share the content with. We do not control and shall not be liable for the manner, in which such persons (with whom you choose to share content via any sharing options, such as WhatsApp or Facebook, available on the Platform) use the information that you share with them.
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    • Sharing with Third Parties- We may share your information (including Personal Information) with select third parties including: Business partners, suppliers and subcontractors (“Affiliates”). 
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    • Affiliates may use this information to help provide, understand, and improve the Service and Affiliates’ own services for the performance of any contract that we enter into with you. 
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    • Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users (for example, we may inform them that any given number of women in a specified age group clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target. 
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    • Government bodies or law enforcement agencies, if we have good-faith belief that it is reasonably necessary to share your personal data or information in order to comply with any legal obligation or any government request; or to protect the rights or prevent any harm to the property, or safety of the Company, our customers, or public; or to detect, prevent or otherwise address public safety, fraud, security or technical issues. 
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    • We may also disclose your information (including Personal Information) to select third parties in the following circumstances:  If the Company or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets. If we are involved in a merger, acquisition, bankruptcy, reorganization, or sale of assets such that your information would be transferred or become subject to a different Privacy Policy, we will notify you in advance so you can opt out of any such new policy by deleting your account before transfer.
  9. Security 
    • The Company uses reasonable security measures, at the minimum those mandated under applicable laws to safeguard and protect your data and information. The Company has implemented measures to protect against unauthorized access to, and unlawful interception of your information. However, security risk cannot be completely eliminated while using the internet.  The Company assumes no liability or responsibility for disclosure of your information due to errors in transmission, unauthorized third-party access, or other causes beyond its control. You play an important role in keeping your personal information secure. You should not share your user name, password, or other security information for your account with anyone. You accept the inherent security implications of providing information over the internet and agree not to hold the Company responsible for any breach of security or the disclosure of personal information unless the Company has been grossly and wilfully negligent.
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    • By accepting the terms of this Privacy Policy, You undertake to exercise utmost confidentiality of all data you access by virtue of being a user of our Platform. You undertake not to divulge, share, manipulate, sale or use information collected or accessed in a manner of inconsistent with this Privacy Policy and the interests of the Company.
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    • SECURITY PRACTICES
    • We have in place appropriate technical and security measures to secure the information collected by us. Where we have given you (or where you have chosen) a username which enables you to access the Platform, you are responsible for keeping these details confidential. We ask you not to share your password with anyone.

       

      5.4 WHERE WE STORE YOUR PERSONAL INFORMATION

      We store your data with Amazon Web Services cloud platform provided by Amazon Web Services, Inc. (headquartered at 410 Terry Ave. N Seattle, Washington 98109, USA)   on their servers located in India and abroad. Amazon Web Services implement security measures to protect the loss, misuse and alteration of the information, details of which are available at https://aws.amazon.com/. The privacy policies adopted by Amazon Web Services and Google Cloud Platform are available at https://aws.amazon.com/privacy/?nc1=f_pr.

       

  10. Policy Towards Children
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    The Platform is intended for a general audience and [not for use by anyone younger than the age of ….. The Company does not knowingly collect personal information from children younger than the age of …. without the consent of a parent or legal guardian; if the Company learns that it has done so, the Company will promptly remove the information from all active databases. If you are a parent or legal guardian who believes that the Company has collected or used their child’s personal information, please contact the Company at ………..

  12. User Discretion
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    • Subject to limitations in applicable law, you are entitled to object to or request the restriction of processing of your Personal Information, and to request access to, rectification, erasure and portability of your own Personal Information. However, some information may be needed to register on the Platform or to take advantage of some of the features of the Platform. Hence, by choosing not to provide us with the above-mentioned information, you may be unable to access the Service/use the Platform, partially or at all.
    • If you are a registered user of the Platform, the Platform provides you with tools and account settings to access or modify the profile information you have provided and is associated with your account. You are free to remove or delete content from your user account/profile and your account/ profile at any point in time. However, the history of your activities and account on our Platform remains available to us. You may correct, amend, add or delete Personal Information from your account at any time by logging in and visiting your profile page. As noted above, you may opt out from unwanted e-mail communications from us by following the instructions in the message. However, until your account is deleted you will continue to receive all system e-mails.
    • Where the use of your information is based on consent, you can withdraw this consent at any time without affecting the lawfulness of processing based on consent before its withdrawal. In the event you desire to withdraw your consent or delete your Personal Information collected by the Company, you can do so by contacting hello@unlu.io. If you are aware of any changes or inaccuracies in your information, you should inform the Company of such changes so that the records of the Company may be updated or corrected. The Company will respond to your request as soon as possible under relevant regulation. 

     

  14. DISCLAIMER
  15.  Unfortunately, the transmission of information via the internet may not always be completely secure. Although we will do our best to protect your Personal Information, we cannot guarantee the security of your data transmitted to the Platform; any transmission is at your own risk. Once we have received your information, we use strict procedures and security features to prevent unauthorised access to the best of our abilities.

  16. DATA RETENTION
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    We do not retain your Sensitive Personal Information (defined below in this paragraph) for longer than is required for the purposes for which the information may be lawfully used. For any other content, we will entertain your request for deletion, however, there is a strong possibility that copies of any public content will be retained indefinitely in our systems, including in cached and archived pages of the Platform, or if other users have copied or saved that information. In addition, due to the nature of the internet, copies of your content, including content that you have removed or deleted from your account, may also exist elsewhere on the Internet and be retained indefinitely. “Sensitive Personal Information” shall mean passwords and any other information that is classified as sensitive under Rule 3 of the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011.

     

  18. THIRD PARTY LINKS
  19.  

    The Platform may, from time to time, contain links to and from the websites of our partner networks, advertisers, Affiliates and/or any other websites or mobile applications. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies.  Please check these policies before you submit any personal data to these websites or mobile applications.

     

  20. THIRD-PARTY EMBEDS
    • What Are Third Party Embeds?
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      Some of the content that you see displayed on the Platform is not hosted by the Platform. These “embeds” are hosted by a third-party and embedded in the Platform. For example: YouTube or Vimeo videos, Imgur or Giphy gifs, SoundCloud audio files, Twitter tweets, or Scribd documents that appear within a post on the Platform. These files send data to the hosted site just as if you were visiting that site directly (for example, when you load a Platform post page with a YouTube video embedded in it, YouTube receives data about your activity).

       

    • Privacy Concerns with Third Party Embeds
    • The Platform does not control what data third parties collect or what they will do with it. So, third-party embeds on the Platform are not covered by this Privacy Policy. They are covered by the privacy policy of the third-party service.

       

    • Sharing Personal Information with Third Party Embeds
    • Some embeds may ask you for Personal Information, such as your email address, through a form. We do our best to keep bad actors off the Platform. As explained above, their actions are not covered by this Privacy Policy. So, please be careful when you see embedded forms on the Platform asking for your email address or any other Personal Information. Make sure you understand who you are submitting your information to and what they say they plan to do with it. We suggest that you do not submit Personal Information to any third-party through an embedded form.

       

    • Creating Your Own Third Party Embed
    • If you embed a form that allows submission of Personal Information by users, you must provide a prominent link to an applicable Privacy Policy next to the embedded form that clearly states how you intend to use any information collected. Failure to do so may lead the Company to disable the post or take other action to limit or disable your account.

  21. Grievances
  22. In the event you have any grievances relating to the Privacy Policy, please inform the Company within 24 hours of occurrence of the instance from which the grievance has arisen, by writing an email to the Grievance Redressal Officer as follows:

     

    [Name of the Grievance Redressal Officer: [Manish Trivedi] 

     

    Contact information: [manish@unlu.io]

     

  23. Amendments

 

We reserve the unconditional right to change, modify, add, or remove portions of this Privacy Policy at any time, without specifically notifying You of such changes. Any changes or updates will be effective immediately. You should review this Privacy Policy regularly for changes. You can determine if changes have been made by checking the “Last Updated” legend above. Your acceptance of the amended Privacy Policy shall signify Your consent to such changes and agreement to be legally bound by the same.