1. Introduction

Crimzo, a sole proprietorship based in Chennai, Tamil Nadu, India ("Crimzo", "we", "our" or "us"), operates the Crimzo and Crimzo Studio mobile applications, the website https://crimzo.app and related features (together, the "Services"). We are committed to protecting your privacy. This Privacy Policy ("Policy") explains how we collect, use, share and protect information that relates to you when you use the Services, and the choices you have.

For the purposes of the Digital Personal Data Protection Act, 2023, Crimzo is the Data Fiduciary for the Personal Data described in this Policy. This Policy forms part of our Terms of Use. By using the Services, you acknowledge that you have read this Policy.

2. What data we collect

"Personal Data" means any information that identifies you or can reasonably be used to identify you. We collect the following categories:

2.1. Account information. When you register, we collect your name, mobile number, profile picture or avatar, languages and the other details you enter on the registration screens, such as gender and date of birth. Creators may also provide a username, bio, photos and other profile information.

2.2. Sign-in information. If you sign in using a third-party service (such as Google, Truecaller or Telegram), we receive the information you allow that service to share with us, such as your name, mobile number, email address and an account identifier.

2.3. Payment information. Purchases of Coins are processed by the app store. We receive transaction details such as an order identifier, the product purchased, the price and the time of purchase. We do not receive or store your card or bank details used for purchases. Creators who request payouts provide payout details, such as bank account or UPI details and tax identifiers (for example, PAN).

2.4. Identity and age verification. Creators may be required to complete identity and age verification, which may include a selfie or a short video, before using certain features.

2.5. Device identifiers and device data. We collect information about the device you use, such as device model, operating system, app version, device identifiers, IP address and notification tokens.

2.6. Approximate location. If you choose to share it, we use your device's approximate location to determine your general area (such as your district). We do not track your precise location.

2.7. Usage and log data. We collect information about how you use the Services, such as calls made and received, their time, duration and charges, features used, sign-in history, and technical logs and crash reports.

2.8. Content. We process the Content you make available through the Services, such as photos, messages, ratings and reviews. Live audio and video are transmitted through the Services to deliver calls and may be processed as described in Section 4.

2.9. Communication data. When you contact us, submit a report or raise a grievance, we collect the information you provide.

2.10. Derived information. We may generate information from the data above, such as account levels, ratings, preferences and fraud or risk signals.

3. Analytics and similar technologies

We use analytics, crash reporting and similar technologies, including software development kits provided by our service providers, to understand how the Services are used, to measure performance, to fix problems and to keep the Services secure. These technologies may collect device and usage information as described above. We do not use your Personal Data to show you third-party advertising.

4. Why we process your Personal Data

Purpose	Description
Provision of our Services; customer support	To create and manage your account, sign you in, connect calls, deliver messages, display profiles, and respond to your requests.
Payments and payouts	To process Coin purchases, maintain balances and transaction records, and to pay creators, including verification of payout details and tax compliance.
Improving our Services	To understand usage, fix problems, develop new features and improve the quality of the Services.
Integrity and safety	To verify users, enforce our Terms and Community Guidelines, moderate Content (using automated and manual review), prevent fraud and abuse, and protect the safety of users and the public.
Compliance with law; assistance to authorities	To comply with applicable laws, respond to lawful requests from government and law enforcement authorities, and establish or defend legal claims.

We process your Personal Data on the basis of your consent, given when you use the Services, and for the legitimate uses permitted under applicable law. You may withdraw your consent at any time as described in Section 10; this may mean that you can no longer use some or all of the Services.

5. With whom we share Personal Data

We do not sell your Personal Data. We share Personal Data only as described below:

5.1. Other users. Information on your profile, and information needed to make a call or send a message, is visible to the users you interact with in accordance with the features of the Services. Your mobile number is not shown to other users.

5.2. Service providers. We use trusted third parties to host our servers and data, carry live audio and video, store media, send notifications and SMS, provide sign-in, analytics and crash reporting, and help with safety and verification. They process Personal Data on our behalf and under appropriate obligations of confidentiality and security.

5.3. Payment processors and banks. App stores process purchases, and banks or payment service providers process creator payouts.

5.4. Auditors and advisers. Our accountants, auditors and legal advisers, where needed for accounting, tax and legal purposes.

5.5. Law enforcement, government and regulatory bodies. Where we believe disclosure is required by law, or is necessary to respond to legal process, to protect the rights, property or safety of Crimzo, our users or the public, or to prevent or investigate illegal activity.

5.6. Business transfers. In connection with a reorganisation, sale or transfer of all or part of our business, subject to this Policy.

6. Where your data is processed

Our servers are located in India. Some of our service providers may store or process Personal Data in other countries. Where this happens, we take reasonable steps to ensure that your Personal Data receives an appropriate level of protection and is handled in accordance with this Policy and applicable law.

7. Third-party services

The Services may link to or integrate third-party services, such as sign-in providers and app stores. Their privacy practices are governed by their own policies, not this Policy. We encourage you to review their policies before you use them.

8. Minors

IF YOU ARE UNDER 18 YEARS OF AGE, YOU MAY NOT USE OR ACCESS THE SERVICES. The Services are not directed at children, and we do not knowingly collect Personal Data from anyone under eighteen (18). If we learn that an account belongs to a person under eighteen (18), we will close the account and delete the associated Personal Data, except where we are required by law to retain it. If you believe a child has provided us with Personal Data, please contact us.

9. Retention of Personal Data

We retain Personal Data for as long as necessary to provide the Services and for the purposes described in this Policy, including to comply with our legal, tax and accounting obligations, resolve disputes, prevent fraud and abuse, and enforce our policies. Retention periods depend on the type of data and the purpose for which it is held. When Personal Data is no longer needed, we delete or anonymise it. We may retain limited information, such as records of suspended accounts, in a form that helps prevent repeated abuse.

10. Your rights

Subject to applicable law, including the Digital Personal Data Protection Act, 2023, you have the right to:

• obtain a summary of the Personal Data we process about you and the processing activities;
• correct, complete or update your Personal Data (much of which you can do directly in the App);
• request erasure of your Personal Data;
• withdraw your consent;
• nominate another person to exercise your rights in the event of your death or incapacity; and
• have your grievance addressed by us, and, if you are not satisfied, to complain to the Data Protection Board of India.

To exercise these rights, write to [email protected] from, or quoting, the mobile number linked to your account. We may need to verify your identity before acting on your request.

11. How to delete your account and data

You may delete your account at any time from the App settings, or by following the steps on our Delete your account page. Deletion requests are processed within thirty (30) days, during which you may restore your account by signing in again. After this period, your account and associated Personal Data are permanently deleted and cannot be recovered, except for information we must retain as described in Section 9.

12. How we protect your data

We use administrative, technical and physical safeguards designed to protect Personal Data against unauthorised access, use, alteration and disclosure, including encryption of data in transit and of sensitive data at rest, and restricted access. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security. In the event of a personal data breach, we will notify affected users and the authorities as required by applicable law.

13. Updates to this Policy

We may change this Policy from time to time. The current version will always be available on the Website, with the "Last updated" date at the top. Where changes are material, we will notify you through the Services. Your continued use of the Services after the changes take effect means you accept the updated Policy.

This Policy is written in English. Any translation is provided for convenience only, and the English version prevails in case of any difference.

14. How to contact us

For any questions about this Policy or our handling of your Personal Data, please contact us at [email protected]. Grievances may be addressed to our Grievance Officer, Harishudhan A R, at the same address (Chennai, Tamil Nadu, India).