We, Capslock Marketplaces Private Limited (“VoiceClub”) recognise that your privacy is very important and take it seriously. This privacy policy (“Privacy Policy”) sets out how we collect, use and disclose your data when you use Voice Club’s mobile application, (“App”) and the website, ‘https://voiceclub.app/’ (“Website”). The Website and the App are collectively referred to as the “Platforms” and individually as “Platform” as the context may require. References to “we”, “our” or “us” or the “Company” shall mean the Platforms and/or VoiceClub.  Any references to “you”, “your” or “user” shall mean any person or entity using our Platforms. We will not use or share your information with anyone except as described in this Privacy Policy.

By using the Platforms, you agree to the terms and conditions of this Privacy Policy. You also consent to our use and disclosure of your Personal Information (as defined below) in the manner described in this Privacy Policy.

• THE INFORMATION WE COLLECT AND HOW WE USE IT

The following table lists the information we collect from you and how we use it:

• DISCLOSURE OF YOUR INFORMATION – We disclose your information in the following manner:

1. Content Visible to others

1. Public content i.e., any content you post on your user profile or on another user’s profile, such as a post comment, is accessible to everyone, including search engines. Any information you voluntarily disclose for posting to the Platforms, including your profile page information, is accessible to anyone. When you submit, post or share the content that you choose to make public, on the Platforms, it may be re-shared by others. You should consider who you choose to share it with, because people who can see your activity on our Platforms can choose to share it with others on and off our Platforms, including people outside the audience you shared it with. For example, when you share a post or send a message to specific users of our Platforms or accounts, they can download or re-share that content with other users across or off our Platforms. Also, when you comment on someone else’s post or like their content, your comment or like is visible to anyone who can see the other person’s content.

1. Users can also use our Platforms to create and share content about you with the audience that they choose, such as posting a photo of you, or tagging you in any of their posts. We reserve the right to share all public content on any social media site or any other online or offline Platforms. We will never rent or sell your Personal Information to third parties, except on an anonymized basis, unless expressly provided in these terms.

2.2.  Sharing with our group entities

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.

1. What you Share with others

When you share content and communicate using our Platforms, you choose the audience for what you share. For example, when you post any content from our Platforms on Facebook, you select the audience for the post, such as a friend, a group of friends or all your friends. Similarly, when you use WhatsApp or any other application on your mobile device to share the content on our Platforms, you choose who you share the content with. We do not control and hence 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 Platforms) use the information that you share with them.

1. Sharing with Third Parties

1. We may share your information (including Personal Information) with select third parties including:

1. Business partners, suppliers and subcontractors (“Affiliates”). Affiliates may use this information to help provide, understand, and improve the Service and Affiliates’ own services for the performance of any contract we enter into with you. 

1. 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.

1. We use third parties to help us operate and improve our services. These third parties assist us with various tasks, including data hosting and maintenance, analytics, customer care, marketing, advertising, payment processing and security operations. 

1. Government bodies or law enforcement agencies, if we in  good-faith believe 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.

1. We may also disclose your information (including Personal Information) to select third parties 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/users 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.

• THIRD PARTY STORES; PREMIUM SERVICES; IN-APP PURCHASES

• We may make certain products and/or services available to users of the App in consideration of a subscription fee or other fees (“Premium Services”), including the ability to purchase products, services and enhancements, such as virtual goods like wallpaper, frames for your display picture, stickers packages, more chances to participate (“In-App Products”). If you choose to use Premium Services and/or purchase In-App Products, you acknowledge and agree that additional terms may apply to your use of, access to and purchase of such Premium Services and/or In-App Products, and such additional terms are incorporated herein by reference. You may purchase Premium Services and/or In-App Products through the following payment methods (each, a “Premium Payment Method”): (a) making a purchase through the Google Play or other mobile or web application platforms or storefronts authorised by us (each, a “Third Party Store”), (b) paying with your credit card or debit card, which will be processed by a third-party processor. Once you have requested a Premium Service or In-App Product, you authorise us to charge your chosen Premium Payment Method and your payment is non-refundable. If payment is not received by us from your chosen Premium Payment Method, you agree to promptly pay all amounts due upon demand by us. If you want to cancel or change your Premium Payment Method at any time, you can do so either via the payment settings option under your profile or by contacting your mobile service provider. In the event of a conflict between a Third-Party Store’s terms and conditions and these terms, the terms and conditions of the Third-Party Store or service provider shall govern and control. We are not responsible and have no liability whatsoever for goods or services you obtain through the Third-Party Store, our third-party service providers or other web sites or web pages. We encourage you to make whatever investigation you feel necessary or appropriate before proceeding with any online transaction with any of these third parties.

• If you choose to purchase an In-App Product, you will be prompted to enter details for your account with the Third-Party Store you are using (e.g., Android, etc.) (“Mobile Platform Account”), and your Mobile Platform Account will be charged for the Premium Service and/or In-App Product in accordance with the terms disclosed to you at the time of purchase, as well as the general terms applicable to all other in-app purchases made through your Mobile Platform Account (e.g., Android etc.). The pricing may vary due to a number of factors, such as (but not limited to) promotional offers, loyalty bonuses and other discounts that might apply to your age group.

• In all cases, we are not responsible and have no liability whatsoever for any payment processing errors (including card processing, identity verification, analysis and regulatory compliance) or fees or other service-related issues, including those issues that may arise from inaccurate account information, or products or goods you obtain through your Mobile Platform Account or Third-Party Stores. Further, we do not guarantee that product descriptions or other content and products will be available, accurate, complete, reliable, current or error-free. Descriptions and images of, and references to, products or services (including Premium Services or In-App Products) do not imply our or any of our affiliates’ endorsement of such products or services. Moreover, we and our third-party operational service providers reserve the right, with or without prior notice, for any or no reason, to change product descriptions, images, and references; to limit the available quantity of any product; to honour, or impose conditions on the honouring of, any coupon, coupon code, promotional code or other similar promotions; to bar any user from conducting any or all transaction(s); and/or to refuse to provide any user with any product. Further, if we terminate your use of or registration to the App because you have breached these terms, you shall not be entitled to a refund of any unused portion of any fees, payments or other consideration. We encourage you to review the terms and conditions of the applicable third-party payment processors, Third-Party Store and/or your Mobile Platform Account before you make any In-App Products or Premium Service purchases.

1. 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 and password which enables you to access the Platforms, you are responsible for keeping these details confidential. We ask you not to share your password with anyone. 

• 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) and also on Google Cloud Platform provided by Google LLC (headquartered at 1101 S Flower St, Burbank, California 91502, USA) on their servers located in India .Both Amazon Web Services and Google Cloud Platform implement security measures to protect the loss, misuse and alteration of the information, details of which are available at https://aws.amazon.com/ and https://cloud.google.com. The privacy policies adopted by Amazon Web Services and Google Cloud Platform are available at https://aws.amazon.com/privacy/?nc1=f_pr  and  https://policies.google.com/privacy.

• CHANGES TO THIS POLICY

The Company may periodically update this Privacy Policy. Whenever we make any changes to this Privacy Policy that are important for you to know about, we will post the updated Privacy Policy at this link. It is your responsibility to keep checking this page from time to time in order to be aware of any changes made to this Privacy Policy.

• DISCLAIMER

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Information, we cannot guarantee the security of your data transmitted to the Platforms; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.

• YOUR RIGHTS

1. 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 Platforms remains available to us.

1. You may correct, amend, add or delete Personal Information from your account at any time by logging in and visiting your profile page. You may receive notifications and emails from us on the contact address/es or mobile number registered with us. 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 such as non-marketing communications (including but not limited to security alerts, administrative messages and information about changes to our Privacy Policy).

1. We reserve the right to verify your identity in connection with any requests regarding Personal Information to help ensure that we provide the information we maintain to the individuals to whom it pertains and allow only those individuals or their authorized representatives to exercise rights with respect to that information. If you are an authorized agent making a request on behalf of a user, we may require and request additional information to verify that you are authorized to make that request.

1. We reserve the right to deny your request if we cannot verify your identity. Where we deny your request in whole or in part, we will endeavour to inform you of the denial and provide an explanation of our actions and the reasons for the denial.

1. Under Rule 5(6) of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (“Rules”), you have a right to ask us to review, correct and amend the information we collect about you at any point in time. Under Rule 5(7) of the Rules, you also have the right to revoke your consent to the collection of your information going forward. However, please note that revoking your consent may negatively affect your use of the Platforms. For instance, we need access to your mobile device’s media folder and camera so that you can click pictures from your mobile device and post them on the Platforms, which functionality will not be available to you if you do not provide us such access. You may also ask us not to process your personal data for marketing purposes. You can exercise any of these rights at any time by contacting us at [email protected]. However, we require a reasonable period of 30 (thirty) days to comply with any of your requests.

• DATA RETENTION

We do not retain your Sensitive Personal Information (defined below in this paragraph) for longer than is reasonably required for the purposes for which the information may be lawfully used or as required by applicable law or regulatory requirements for the time being in force. We may also retain your Sensitive Personal Information so long as it is necessary to fulfil the purposes for which it was collected (including for purposes of meeting any legal, administrative, accounting, or other reporting requirements). 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 Platforms, 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 Personal data or Information under Rule 3 of the Rules.

• THIRD PARTY LINKS

The Platforms 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.

• THIRD-PARTY EMBEDS  

1. What Are Third Party Embeds

Some of the content that you see displayed on the Platforms is not hosted by the Platforms. These “embeds” are hosted by a third-party and embedded in the Platforms. 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 Platforms. These files send data to the hosted site just as if you were visiting that site directly (for example, when you load a Platforms post page with a YouTube video embedded in it, YouTube receives data about your activity).

1. Privacy Concerns with Third Party Embeds

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

1. 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 Platforms. However, if you choose to submit your information to a third party this way, we do not know what they may do with it and assume no responsibly or liability in this regard. As explained above, their actions are not covered by this Privacy Policy. So, please be careful when you see embedded forms on the Platforms 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.

1. Creating Your Own Third Party Embed

If you embed a form that allows submission of Personal Information by users, you must provide near the embedded form a prominent link to an applicable Privacy Policy 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.

• PLATFORMS ARE NOT FOR MINORS

The Platforms should only be used or accessed by persons who are competent to enter into a legally binding contract under the Indian Contract, 1872. If you are a minor (i.e., you are under the age of 18 years), you may use the Platforms only with the involvement of your parent or guardian. We do not knowingly collect or use any information from minors. We do not knowingly allow minors to communicate with us or use any of the services on the Platforms. If you are a parent and become aware that your child has provided us with information, please contact us on the website or by e-mailing us at [email protected]. 

• COMMUNICATIONS FROM US

We may from time to time send you service-related announcements when we consider it necessary to do so (such as when we temporarily suspend the Platforms for maintenance, security, privacy, or administrative-related communications). We send these to you via SMS. You may not opt-out of these service-related announcements, which are not promotional in nature and used solely to protect your account and keep you informed of important changes to the Platforms.

• COOKIE POLICY

The capitalized terms used in this Cookie Policy, but not defined herein, shall have the meaning given to such terms in these terms. 

1. What are cookies, pixels, and local storage?

1. Cookies are small files that the websites place on your computer as you browse the web. Like many websites, we use cookies to discover how people are using our Platforms and to make them work better.

1. A pixel is a small amount of code on a web page or in an email notification. As many other websites do, we use pixels to learn whether you have interacted with certain web or email content. This helps us measure and improve our Platforms and personalize your experience on our Platforms.

1. Local storage is an industry-standard technology that allows a website or application to store information locally on your computer or mobile device. We use local storage to customize what we show you based on your past interactions with our Platforms.

1. Why do we use these technologies?

1. We may use these technologies to show you relevant content, improve your experience and help protect us and our users. We may use these to provide you with services on our Platforms, that are easier and faster to use, and enable you to easily navigate our Platforms and use its features. We may use these to retain authentication information in order to provide certain services to you, to retain your language preference and to provide mapping and location-based services which require your location. We may use these technologies to store information about how you use our Platforms, for instance, what pages you visit most often, and if visiting some pages gives you error messages. We may use these technologies to collect information on the total number of visitors to our Platforms on an ongoing basis. We may, along with our advertising partners, use these technologies to deliver, understand and improve advertisements that you see.

1. We cannot identify you personally from the information these cookies collect. Only for functionality purposes, personally identifiable information that you disclose like your username and profile picture may be collected. We ensure complete transparency with you about what information is collected, how it is going to be used and with whom it is shared. 

1. What types of cookies do we use?

1. Two types of cookies may be used on our Platforms- “session cookies” and “persistent cookies”. Session cookies are temporary cookies that remain on your device until you leave our Platforms. A persistent cookie remains on your device for much longer or until you manually delete it (how long the cookie remains on your device will depend on the duration or “lifetime” of the specific cookie and your app settings).

1. Some of the pages you visit may also collect information using pixel tags (also called clear gifs) that may be shared with third parties which directly support our promotional activities and Platforms development. For example, usage information about visitors of our Platforms may be shared with our third-party advertising agency to better target internet banner advertisements on Platforms. The information is not, however, personally identifiable, although it could be linked to your personal information.

1. Cookies used on the Platforms

1. Where are these technologies used?

We use these technologies on our own Platforms and on other websites that may have integrated our services. This includes our advertising and Platforms partners. Third parties may also use these technologies, for example, when you interact with their content from within Platforms, like when you click a link or stream media on our Platforms from a third-party service, and to help with the delivery of advertisements that may be shown on and off our Platforms.

1. Do we use Third Party Cookies?

1. We use a number of suppliers that may also set cookies on your device on our behalf when you visit our Platforms, to allow such third parties to deliver the services that they are providing.

1. When you visit our Platforms, you may receive cookies from third party websites or domains. We endeavour to identify these cookies before they are used so that you can decide whether or not you wish to accept them. More information about these cookies may be available on the relevant third party’s website.

1. How can I control Cookies?

1. Most internet browsers are initially set up to automatically accept cookies. You can change the settings to block cookies or to alert you when cookies are being sent to your device. There are a number of ways to manage cookies. Please refer to our Platforms instructions or help screen to learn more about how to adjust or modify your app settings.

1. If you disable the cookies that we use, this may impact your experience while on the Platforms, for example you may not be able to visit certain areas of our Platforms or you may not receive personalized information when you visit our Platforms.

1. If you use different devices to view and access the Platforms (e.g., your computer, smartphone, tablet etc.) you will need to ensure that each browser on each device is adjusted to suit your cookie preferences.

1. Changes to this Cookie Policy

1. We will occasionally update this Cookie Policy to reflect changes on our Platforms and services. If we make any material changes in the way we collect, use, or share information held in cookies, we will post these changes to this Cookie Policy and revise the “Last Updated” date at the top of the Cookie Policy.

1. Cookies that have been set in the past, if you have disabled one or more cookies, we may still use information collected from cookies prior to your disabled preference being set. However, we will stop using the disabled cookie to collect any further information.

• GRIEVANCE OFFICER

1. In accordance with the Rules, the name and contact details of our Grievance Officer are provided below:

1. The Grievance Officer shall acknowledge the complaint within 3 (Three) business days and dispose of such complaint within a period of 1 (One) month from the date of its receipt.