Privacy Policy

Last Updated on 1 June, 2021

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.com] (collectively referred to as "Platform"). 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 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 (“Services”). 

 

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.  


  • Collection of Information

 

  • 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; and (d) information you choose to upload, sync or import from the device on which the Platform is being used (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. 

 

  • The Company may collect non-personal information relating to your activities while accessing the Service or other information from and about the devices through which the 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.

  1. Our servers automatically record information ("Log Data") created by your use of the Service. Log Data may include information such as your IP address, operating system, the referring web page, pages visited, location, your mobile carrier, device and application IDs, search terms. 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. 

 

  1. 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. 

 

  • Usage of Information

 

The information gathered by the Company as specified in Clause 1, may be used for the following purposes:

 

  1. for your registration, login and management of account on the Platform;  
  2. to confirm your identity directly and/or through third parties;
  3. to provide you Services;
  4. helping you efficiently access your information after you sign into the Platform;
  5. remembering your Personal Information so that you are not required to re-enter it the next time you visit the Platform;
  6. to understand your preferences and to enhance and customize your experience of using the Service and the Platform;
  7. for providing customized user relevant suggestion / Services;
  8. to communicate with you through mail, e-mail and telephone, in connection with the Service, or other products or services of the Company;
  9. to respond to your comments, reviews and questions and provide better Service;
  10. 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;
  11. for internal purposes such as auditing, data analysis, research and improvement relating to the Platform or the Service;
  12. for promotion and marketing purposes;
  13. 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; 
  14. to transfer data to the regulatory authorities or other appropriate authorities as required by law.

 

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.

 

  1. Collection of Information by Third-Party Sites and Advertisers

 

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. 

 

  1. Disclosure to Third Parties

 

  1. 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. 

 

  1. 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. 

  1. The Company may also share aggregated (and de-identified) information with third parties at its discretion.

  1. 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. 

  1. 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.

 

  • Security 

 

  1. 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.

 

  1. 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.

 

  1. Policy Towards Children

 

The Platform is intended for a general audience and [not for use by anyone younger than the age of 18. The Company does not knowingly collect personal information from children younger than the age of 18 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 hello@unlu.io.


  • User Discretion

 

  • 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.

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. 


  • Grievances

 

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: Vipul Agrawal

Contact information: hello@unlu.io

  1. 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.