Privacy Policy

Last Updated: September 2, 2021

Welcome to Aadu – Short Video App (hereinafter referred to as “Platform”), a content creationPlatform owned and operated by Squash Apps Private Limited, a private limited companyhaving its registered office at No. 7A, Grand CAG Central, First Floor, Avinashi Road, NavaIndia Rd, Coimbatore – 641004, Tamil Nadu, India (hereinafter referred to as“Squash/We/Us/Our”).

This Privacy Policy (hereinafter referred to as “Policy”), helps the users, whether registered ornot (User/You/Your) of the Platform and the Service therein to understand the type ofinformation collected, the purpose for which the information is collected; how the information isused; the intended recipients of such information; and how the information is protected. We takeprotection and proper use of Your information seriously and are committed to protecting suchinformation in Our possession. We advise you to read this Policy carefully prior to Your accessof Platform, use of Services, or creation of an Account on the Platform. If You do not agree tothis Policy, please do not access Our Platform, use our Services, or create an Account in ourPlatform.

This Policy is published and shall be construed to be in accordance with the provisions of theInformation Technology (Reasonable Security Practices and Procedures and Sensitive PersonalData of Information) Rules, 2011 and Information Technology (Intermediaries Guidelines AndDigital Media Ethics Code) Rules, 2021 under the Information Technology Act, 2000 and otherapplicable laws that require publishing of the privacy notice for collection, usage, storage,disclosure and transfer of sensitive personal data or information.

Any capitalized terms used herein without definition shall have the meanings assigned to themin Our Terms of Use.

INFORMATION COLLECTED BY US

When You create an Account with us, access our Platform and/or use the Services provided byUs, we shall collect certain information from You, the details of which are provided hereinafter.The categories and sources of the Information collected by Us are as follows:

1. Personal Information: Any Information that relates to You as a natural person, which,either directly or indirectly, in combination with other information available or likely to beavailable to a body corporate, is capable of identifying You and any further information,including, without limitation, provided by You to Us while creating an Account such as Yourname, nationality, state/city of residence, residential address, e-mail address, date of birth,age, gender, contact number/mobile number, social media login credentials, username,passwords, (“Personal Information”).
2. User Content. Any information including but limited to the biometric information that couldbe obtained from the User Content that you create, import, combine, save, or upload in thePlatform. In case you apply any filters provided by us in our Platform, a version of the UserContent without such filter may also be collected by us. Content, including text, images, andvideo, found in Your device’s clipboard, with Your permission.
3. Usage Information. Any information that is not Personal Information, but informationcollected in relation to Your use of the Platform or information required for the properfunctioning and development of Platform, including, without limitation: (i) time, date andextent of Your usage of the Platform; (ii) Your usage and search history within the Platform,(iii) device keyboard settings; (iv) time zone, language, screen resolution, and other usagepreferences You select when using the Platform; (v) other User Accounts and/or UserContents You view, like, comment on, share, follow, message, and otherwise interact with,as well as the aforementioned that other Users do with respect to Your Account and/or UserContent;(vi) the URL or advertisement that may have directed You to the Platform; (vii)other device and Platform access information viz Your IP address, operating system,browser type, referring/exit pages, and other unique device identifiers, as well as Your pushnotification token.
4. Behavioral Information. We shall collect information which is connected with Your activityon the Platform across all Your devices using Your email or social media log-in details, aswell as engagement scores (“likes”, comments, repeated views), related Users based onYour Platform behavior, and opt-ins and communication preferences.
5. Metadata. When You upload User Content, You automatically upload certain metadata thatis connected to the User Content. Metadata describes other data and provides informationabout Your User Content that will not always be evident to the applicable viewer. Inconnection with Your User Content, the metadata can describe how, when and by whomthe piece of User Content was collected and how that User Content is formatted. It furtherincludes certain Personal Information, such as Your account name, that enables otherUsers to trace back the User Content to Your Account. Metadata will further consist ofadditional Personal Information that You chose to provide (e.g., any hashtags used to markkeywords to the User Content)
6. Location Data. Information about Your location when accessing and/or using the Platformif You chose to opt-in. With Your permission, We may collect Global Positioning System(GPS) data and mobile device location information. If You do not wish to share Your preciselocation with Us, You can switch off location services via the settings on Your mobiledevice.
7. We collect Your phone and social network contacts with Your permission. In case you havechosen to find other uses in your phone contacts using Our Platform, We will access andcollect the names and phone numbers and match that information against existing users ofthe Platform. If You choose to find other users through Your social network contacts, Wewill collect Your public profile information as well as names and profiles of your socialnetwork contacts.
8. We may collect Your third-party social media networks information including your contactlists for these services and information relating to your use of the Platform in relation tothese services, if You choose to link or sign up using a third-party social network or loginservice (such as Facebook, Twitter, Instagram, or Google). If you link your Account in ourPlatform to another service, We may receive information about Your use of that service.
9. Cookies. We and Our service providers and business partners use cookies and othersimilar technologies (e.g. web beacons, flash cookies, etc.) (“Cookies”) to automaticallycollect information, measure and analyze which web pages and advertisements You clickon and how You use the Platform, enhance Your experience using the Platform, improvethe Platform, provide You with advertising on the Platform and elsewhere across Yourdevices, and measure the effectiveness of advertisements. Cookies enable the Platform toprovide certain features and functionality. Web beacons are very small images or smallpieces of data embedded in images, also known as “pixel tags” or “clear GIFs,” that canrecognize Cookies, the time and date a page is viewed, a description of the page where thepixel tag is placed, and similar information from Your computer or device.

We and Our service providers and business partners may link Your contact or accountinformation with Your activity on and off Our Platform across all your devices, using Youremail or other log-in or device information. Our service providers and business partners may use this information to display advertisements on Our Platform and elsewhere onlineand across Your devices tailored to Your interests, preferences, and characteristics. We arenot responsible for the privacy practices of these service providers and business partners,and the information practices of these service providers and business partners are notcovered by this Policy.

Image and Audio Information. Information about the images and audio that are a part ofYour User Content, such as identifying the objects and scenery that appear, the existenceand location within an image of face and body features and attributes, the nature of theaudio, and the text of the words spoken in Your User Content. We may collect thisinformation to enable special video effects, for content moderation, for demographicclassification, for content and ad recommendations, and for other non-personally identifyingoperations

Biometric information. Biometric information and biometric identifiers, such as face printsand voiceprints, from Your User Content. Where required by law, We will seek any requiredpermissions from You prior to any such collection.

DeviceInformation. We collect information about computers, phones, connected TVs, andother devices with a web connection and the presence of Our Platform and Services andintegrate this information with the various devices You use. This information includes:device features such asinformation about operating system, hardware and softwareversions, battery status, signal availability, available storage space, browser type, app orfile names and types, and plug-ins, deviceactivitiessuch as information about the activityand behavior of the device, for example in the background or in front of a window or withmouse movements (which help to distinguish humans from boats), unique identifiers,device ID, games, apps, or accounts you use, Bluetooth signals and information aboutnearby WiFi access points, beacons and cell towers, Information that we are permitted tocollect by turning on access in device configuration, as well as providing access to GPSlocation, camera or photo, information such asyour mobile operator’s name or ISP,language, time zone, mobile phone number, IP address, connection speed, andotherdevices near Your device or on the network so that We can help You with the streaming ofthe User Content on your device.

Messages. We may collect and process (which includes scanning and analyzing)information You provide, including any Personal Information, in the context of composing,sending, or receiving messages (that means the content as well as information about whenthe message has been sent, received and/or read and the participants of thecommunication) through Our Service’s messaging functionality, in order to prevent potentialcrimes. Please be aware that messages sent to other Users of Our Service will beaccessible by those other Users and that We are not responsible for the manner in whichthose Users use or disclose messages.

Payment Information. Information related to payment, including payment card numbers orother third-party payment information (such as PayPal, Paytm, etc.) where required for thepurpose of payment.

Third partyInformation. Information about You that We may receive from third partiesservices, such as advertising partners, data providers, and analytics providers.

Information from other Users and other sources. Sometimes other Users of the Platformmay provide Us information about You, including through customer service inquiries. Thiscan include information about You, such as when others share or comment on a photo ofYou, send a message to You or upload, sync or import Your contact information. Further,We may also collect information about You from other publicly available sources.

USAGE OF YOUR INFORMATION

1. As explained below, We use Your information to improve, support and administer thePlatform, to allow You to use its functionalities, and to fulfill and enforce Our Terms of Use.We may also use Your information to, among other things, show You suggestions, promotethe Platform, and customize Your ad experience.
2. We generally use the information We collect:

1. to fulfill requests for services, Platform functionality, support and information forinternal operations, including troubleshooting, data analysis, testing, research,statistical, and survey purposes and to solicit Your feedback;
2. to communicate with You, including to notify You about changes in Our services;
3. to improve and develop Our Platform and conduct service development;
4. to customize the content You see when You use the Platform ;
5. to enforce Our terms, conditions, and policies;
6. to prove Your identity in order to use certain features,
7. to combine all the information We collect or receive about You for any of the foregoingpurposes;
8. to maintain security and help Us detect abuse, fraud, and illegal activity on thePlatform;
9. to understand how You use the Platform, including across Your devices;
10. to use User Content as part of Our advertising and marketing campaigns to promotethe Platform;
11. to support the social functions of the Platform, including to permit You and otherUsers to connect with each other through the Platform and for You and other Users toshare, download, and otherwise interact with User Content posted through thePlatform;
12. to make suggestions and provide a customized ad experience;
13. to send promotional materials from Us or on behalf of Our affiliates and trusted thirdparties;
14. to measure and understand the effectiveness of the advertising We serve to You andothers and to deliver advertising;
15. consistent with Your permissions, to provide You with location-based services, suchas advertising and other personalized content;
16. to sell or rent Your Information to anyone, for any reason, at any time or any othercommercial purposes.
17. for any other purposes disclosed to You at the time We collect Your information orpursuant to Your consent;

SHARING YOUR INFORMATION

We want You to understand when and with whom We may share the information We collect forbusiness purposes. Your information is shared with others in the following ways:

1. Public Information. Personal Information that You upload to the Platform (such as certainAccount profile information), certain User Content (such as a video or sound recording clipthat You upload to the Platform), and certain Platform usage information (such as UserContent You “like”), will automatically, or upon Your selection, be made publicly availableto other Users on the Platform. You acknowledge and agree that certain Accountinformation (such as Your Account profile name, picture, and/or User Content, etc.) thatYou provide in connection with (i) the registration of Your Account and (ii) Your general use of the Platform, such as uploading User Content, will be publicly viewable by all Usersof the Platform. Do not post to Interactive Areas any information, including, withoutlimitation, personal information, that You do not want to publicly available.
2. Content that others share or reshare about you. You should consider who You chooseto share with, because people who can see Your activity on Our Services can choose toshare it with others on and off Our Services, including people and businesses outside theaudience that You shared with. People can also use our Services to create and sharecontent about You with the audience they choose. If You are uncomfortable with whatothers have shared about You on Our Services, You can learn how to report the UserContent.
3. Legal Reasons. We may disclose any of the information We collect to respond tosummons, court orders, legal process, law enforcement requests, legal claims, orgovernment inquiries, and to protect and defend the rights, interests, safety, and securityof Squash, the Platform, our affiliates, Users, or the public. We may also share any of theInformation We collect to enforce any terms applicable to the Platform, to exercise ordefend any legal claims, and comply with any applicable law.
4. Sale, Merger, or Other Business Transfer. We may share all of the Information Wecollect in connection with a substantial corporate transaction, such as the sale of awebsite, a merger, consolidation, asset sales, or in the unlikely event of bankruptcy.
5. Service Providers, Business Partners. We share the categories of personal informationlisted above with service providers and business partners to help Us perform businessoperations and for business purposes, including research, payment processing andtransaction fulfillment, database maintenance, administering contests and special offers,technology services, deliveries, sending communications, advertising, analytics,measurement, data storage and hosting, disaster recovery, search engine optimization,marketing, and data processing. These service providers and business partners mayinclude:

1. Advertising, marketing, and analytics vendors, who may receive the informationYou choose to provide, the information We obtain from other sources, and theinformation We collect automatically but would not receive Your paymentinformation or message data.
2. Payment processors and transaction fulfillment providers, who may receive theinformation You choose to provide, the information We obtain from other sources,and the information We collect automatically but who do not receive Your messagedata.
3. Cloud providers, who may receive the information You choose to provide, theinformation We obtain from other sources, and the information We collectautomatically.
4. Research providers, who may receive the information You choose to provide, theinformation We obtain from other sources, and the information We collectautomatically but would not receive Your payment information or message data.
5. Customer and technical support providers, who may receive the information Youchoose to provide, the information We obtain from other sources, and theinformation We collect automatically.

1. We may use third parties to outsource one or more aspects of Our business and/orPlatform operations (such as email or customer service functions, data processing,web analytics, maintenance, online advertising, and security execution andclearing services), in which case, We may provide Your Personal Information tosuch third parties in connection with the performance of such activities. Such thirdparties will only use Your Personal Information to the extent necessary to performtheir functions and will be contractually bound to process Your PersonalInformation only on Our behalf and in compliance with Our requests.
2. We will also share Your information with any member, subsidiary, parent or affiliateof Our corporate group, to assist in the improvement and optimization of thePlatform, in order to prevent illegal uses, increase user numbers, development,engineering and analysis of information or for Our internal business purposes.
3. In the unlikely event of Our bankruptcy, insolvency, reorganization, receivership, orassignment for the benefit of creditors, or the application of laws or equitableprinciples affecting creditors’ rights generally, We may not be able to control howYour Personal Information is treated, transferred, or used.

YOUR RIGHTS

1. The right to request proper rectification, removal or restriction of Your PersonalInformation;
2. The right to require free of charge (i) confirmation of whether We process YourPersonal Information and (ii) access to a copy of the Personal Information retained;
3. The right to take legal actions in relation to any breach of Your rights regarding theprocessing of the Personal Information, as well as to lodge complaints before thecompetent data protection regulators.
4. The right not to be subject to any automatic individual decisions which produces legaleffects on You or similarly significantly affects You;
5. Where the processing of Your Personal Information is based on Your consent, theright to withdraw Your consent at any time without impact to data processing activitiesthat have taken place before such withdrawal or to any other existing legal justificationof the processing activity in question;
6. Where processing of Your Personal Information is either based on Your consent ornecessary for the performance of a contract with You and processing is carried out byautomated means, the right to receive the Personal Information concerning You in astructured, commonly used and machine-readable format or to have Your PersonalInformation transmitted directly to another company, where technically feasible (dataportability);

2. As far as We process Your Personal Information on the basis of Our legitimate interests,You can object to processing at any time. You can find a detailed description of Ourprocessing activities and the legal basis in the sections above. If You object to suchprocessing, We ask You to state the grounds of Your objection in order for Us to examinethe processing of Your Personal Information and decide whether to adjust the processingaccordingly

SECURITY

1. We follow generally accepted standards to protect the Personal Information submitted toUs, both during transmission and once We receive it. Since no method of transmission overthe Internet, or method of electronic storage, is 100% secure, therefore, We cannotguarantee its absolute security. If You have any questions about security on Our Platform,You can contact Us at [aadu@suashapps.com].
2. We use a combination of firewalls, encryption techniques and authentication procedures,among others, to maintain the security of Your online session and to protect Our onlineaccounts and systems from unauthorized access.
3. When You register for the service, We require a password from You for Your privacy. Wetransmit information such as Your login credentials for Platform or account credentialssecurely.
4. Our servers are in secure facilities where access requires multiple levels of authentication,including an identity card and biometrics recognition procedures. Security personnelmonitor the facilities 7 days a week, 24 hours a day.
5. Our databases are protected from general employee access both physically and logically.We encrypt Your Service password so that Your password cannot be recovered, even byUs. All backup drives and tapes also are encrypted.
6. We enforce physical access controls to Our buildings. No employee can put PersonalInformation on any insecure machine (i.e., nothing can be taken from the database and puton an insecure laptop). We permit only authorized employees who are trained in the properhandling of customer information, to have access to aforesaid Personal Information.

STORAGE AND TRANSFER OF INFORMATION

1. Information collected by Us may be stored and processed in India or any other country inwhich We or Our agents maintain facilities. By using the Platform, You expressly consent toany such transfer and storage of information outside of Your country of residence, wheredata protection laws may be different and/or less stringent. However, We will endeavor to take reasonable measures to keep up an adequate level of data protection also whensharing Your Personal Information with such countries
2. We make no representation or warranty with respect to any duty to permanently store anyinformation You may provide or that We otherwise collect about You except as required bythe laws in India.
3. We strive to keep Our processing activities with respect to Your Personal Information aslimited as possible. In the absence of specific retention periods set out in this Policy, YourPersonal Information will be retained only for as long as We need it to fulfil the purpose forwhich We have collected it and, if applicable, as long as required by statutory retentionrequirements. Typically, this means We retain Your Personal Information for as long asYour Account is active and for up to 180 days following deletion of Your Account. Pleasenote that statutory storage obligations or the need for legal actions that may arise frommisconduct within the Platform can lead to a longer retention of Your Personal Information.By using the Platform and providing Us with information (including Personal Information),You waive any claims that may arise under Your own or any other local or national laws,rules or regulations or international treaties. We may from time to time transfer or mergeYour information collected off-line to Our online databases or store off-line information in anelectronic format. This Policy applies to Your information for as long as Your information isin Our possession, even if You terminate or discontinue Your use of the Platform.
4. In the event that We undergo re-organization, are sold to, or merged with a third party, orsell all or substantially all of Our assets, any Personal Information We hold about You maybe transferred to that re-organized entity or third party in compliance with applicable law.
5. In the unlikely event of Our bankruptcy, insolvency, reorganization, receivership, orassignment for the benefit of creditors, or the application of laws or equitable principlesaffecting creditors’ rights generally, We may not be able to control how Your PersonalInformation is treated, transferred, or used.

LINK TO THIRD PARTY WEBSITES

The Platform may include links to other websites, mobile applications, or services (“Third PartySites”), whose privacy practices may differ from those set forth herein. Such links are not anendorsement by Us of those third-party Sites and/or the products or services they offer. If Youvisit Third Party Sites or submit Information to any of those Third-Party Sites, Your visit andInformation is governed by their privacy policy. We encourage You to carefully read the privacypolicy of any Third-Party Site You visit, as it may differ substantially from that of this Policy. Wemake no representations or warranties with respect to, nor are We responsible for the privacypolicies of, any Third-Party Sites. If You decide to click on any such links or access any Third-Party Sites appearing on the Platform, You do so at Your own risk.

EMAIL NOTIFICATIONS AND OPT-OUT

We maintain a strict “no-spam” policy. Unless You requested otherwise in Your account settingsat the time of Your initial registration or specifically opt out as provided herein, by accepting theTerms of Use and this Policy, You expressly agree that We may use Your information to contactYou by email in order to deliver You information that is relevant to Your use of the Platform suchas administrative notices, product/service enhancements or “newsletters”, or that, in somecases, is targeted to Your interests, such as information about User Content orService/functionalities offerings that We believe You may be interested in learning more about.In the event of an intellectual property claim, we may transfer your contact details with theclaimant for contacting You to resolve the infringement claim directly with You. You may choose to stop receiving these email communications from Us by following the “unsubscribe”instructions included in such communications. If a third-party vendor provides such newsletters,You may unsubscribe in accordance with the instructions provided by such third party. If Youare having problems unsubscribing, please contact us at[aadu@suashapps.com](and You willbe removed within seven (7) business days. Please note that We will not process anyunsubscribe requests submitted as direct replies to any newsletter.

CONFIDENTIALITY OF YOUR LOGIN ID AND PASSWORD

You are responsible for maintaining the security of Your login ID and Password and must notprovide these credentials to any third party. If You believe that they have been stolen or beenmade known to others, You must contact Us immediately at [aadu@suashapps.com]. We arenot responsible if someone else accesses Your account through the login credential they haveobtained from You or through a violation by You of this Policy or the Our Terms of Use. If Youhave any security related concern, please contact Us at [aadu@suashapps.com]. We will workclosely with You to ensure a rapid and personal response to Your concerns.

CHANGES TO POLICY

We may update this Policy from time to time. When We update the Policy, We will notify You byupdating the “Last Updated” date at the top of this Policy and posting the new Policy andproviding any other notice required by applicable law. We recommend that You review thePolicy each time You visit the Platform to stay informed of Our privacy practices.

CONTACT US

In the event that You wish to make a complaint or request concerning Your PersonalInformation or Our privacy practices, or have questions, concerns, or comments about thisPolicy, please contact Us at [aadu@suashapps.com] and We will endeavor to deal with Yourrequest as soon as possible. This is without prejudice to Your right to launch a claim with Yourdata protection authority or follow the dispute process set forth in the Terms of Use.