Privacy policy

This Privacy Policy applies on the effective date [2023/06/09]. The previous version of this Privacy Policy will apply until then.

We, [Nirkum Entertainment Private Limited] and our affiliates (referred as, “we” or “us”) respect the data of our users (referred as “you”) and take responsibility for protecting your information provided to us in the course of using our Services. By this Privacy Policy (referred to as “Policy”), we intend to inform you:

  1. This Policy does not apply to services provided by other third parties, nor to products and services with a separate privacy policy provided by us.
  2. This Policy explains the data protection practices adopted by us and should be read in conjunction with our terms of service (“ToS”). Please read and understand this Policy carefully before using our Services. When you use our Services, you agree to be bound by these terms and conditions. If you have any enquiries or suggestions regarding the Policy, you are free to contact us through any means made available to you.
  3. This Policy is applicable to any individuals who use our websites, apps, events and other services operated by us (“Services”). Users agree to be bound by the terms and conditions of this Policy and the ToS and consent to inter alia, our collection, use, processing and disclosure of personal information provided by yourselves in accordance with this Policy.
  4. We reserve the right, at our discretion, to amend this Policy over time and modify content within the Services. The new version of the Policy will be accessible on the Software and you are requested to review the same. If you continue to use the Services after the changes are posted, it is deemed that you agree with and acknowledge the changes or revisions, and the new Policy shall apply to your continued use of the Services. Otherwise, if you do not agree to the terms of the Policy or any future updated version of the Policy, then you must not access or use, and must cease all access and use of any of our Services.

This Policy will help you understand the following: 1. How we collect information 2. How we use information 3. Cookies and other similar data collection technologies 4. How the information is shared 5. How we protect your information 6. How you manage your own information 7. Rights of users to request access to and update information 8. How we protect the information of underage users 9 How we operate and transfer data as part of our global services 10. Data retention 11. How to contact us

  1. How we collect information

To provide Services, we must process information about you. Please note that information is collected from you only for lawful purposes and necessary conditions. You have the option not to provide any data or info sought to be collected and in such cases you may not consent to this Policy. Correspondingly, we have the right not to provide the Services as far as you are concerned.

We collect information in the following ways:

1.1 Information and content you provide

(a) We collect profiles, messages and other info you provided when you use our Services, including when you register for an account, create or share content or communicate with other users. This may include further info in or about the content you provided, such as metadata, the location of a photo or the date a file was created. With your consent, we will also collect contact information you choose to upload, sync or import from your device to the Services offered by us.

1.2 Information and content we collect with user’s consent

(a) Your usage. We collect info generated as you use our Services as well as info from third parties (like when you access our Services through a social media account), such as your mobile phone number and password; the types of content you view or engage with; the features you use; the actions you take; the time, frequency and duration of your activities; and your feedback, for example, the access logs, photos and videos you viewed, or games you played while utilising our Services.

(b) Information other users provide about you. We also receive and analyze content and information that other users provided about you when they use our Services.

(c) Device information. We collect and record information regarding and from the devices you used according to access you have granted when installing and using our Services. We will strictly abide by the rules and regulations for data collection as to respect and protect your rights and interests. Information we obtain from these devices may include:

(i) Device attributes: information such as the operating system, hardware and software versions, battery level, signal strength, available storage space, browser type, app and file names and types, and plugins.

(ii) Device operations: information about operations and behaviors performed on the devices, such as whether a window is foregrounded or backgrounded, or mouse movements (which can help distinguish humans from bots).

(iii) Device identifiers: device IDs obtained from games, apps or accounts you use.

(iv) Device signals: bluetooth signals, information about nearby Wi-Fi access points, beacons, or cell towers.

(v) Data from device settings: information you allowed us to receive through device settings you activated, such as access to your GPS location, camera or photos.

(vi) Network and connections: information such as the name of your mobile operator or ISP, language, time zone, mobile phone number, IP address, connection speed and, in some cases, information about other devices that are nearby or on your network.

(vii) Cookie data: data from cookies stored on your device, including cookie IDs and settings.

1.3 Information our partners provide

You can use products or services through links on your account provided by our affiliates, advertisers and app developers. In order to deliver and improve our Services, we will display and recommend information that you may find interesting, including live streaming and gaming contents, which can be discovered and used from our Services. By using the above Services, you grant us permission to receive, gather and analyse personal and transactional info from our affiliates, advertisers and app developers pursuant to your express consent provided to these entities while using their services.

Advertisers, app developers, and publishers (like Adjust, Facebook, Google, etc.) can send us information via tools they use, including but not limited to APIs and SDKs. Your use of our Services is subject to privacy policy of these entities and we request you to read and understand the privacy policy of these service providers before using our Services. These partners provide information about your activities while you use our Services, including info about websites you visit, purchases you make, advertisements you see, and other relevant data, no matter whether you have an account for our Services or not. For example, an authorized game developer could use our API to inform us what games you play, or a business partner could inform us about a purchase you made in its stores. We also receive info about your online and offline actions and purchases from third parties who have the rights to provide us with your information so far as you may have provided consent in this regard.

We require each of these partners to have your consent and lawful rights to collect, use and share your data before providing any data to us.

  1. How we use information

We use the information to provide and support the Services and the information will be processed only for the purposes set out in this Policy. Please refer to the following on how we use this information:

(a) To provide and optimize our Services

We use the information made available to us so as to deliver, develop, test and improve our Services, including but without limitation to identify the legality via image recognition and classification, develop research, test and troubleshoot new Services and features.

(b) To display and promote products or Services

To better provide you with personalized browsing and transaction Services, we will display and push info such as ads according to your browsing and search record, device information, search preference, behaviors and habits, and location.

(c) To enhance safety, integrity and security

We process the info we obtained to verify accounts and activities, combat harmful conduct, detect and prevent spam and other bad experiences to maintain the integrity of our Services and enhance your safety and data security.

(d) To communicate with you

We use the info we obtained to send you marketing messages, communicate with you about our Services, and allow you to understand our policies and terms. We also use your info to effectively respond when you contact us.

For personal data transferred from the United Kingdom, the European Union and Switzerland, Brazil or jurisdictions where similar legal requirements may apply, this section as detailed below will apply. For users located in other territories, please refer to other privacy clauses in this policy and our Terms of Service

We rely on several legal grounds to process information about you. For example, we will process information about you where:

(1)   we have your consent to do so;

(2)   we have a legitimate interest to do so;

(3)   the processing of information is necessary for the performance of the Agreement with you; and

(4)   we have a legal obligation to process your information.

For example, we rely on our legitimate interests to serve targeted marketing and on contractual necessity to process information when you create an account. You can always contact our customer service to learn more about our legal basis to process your information.

  1. Cookies and other similar data collection technologies

3.1 Cookies

In order to ensure proper operations of the Services and to provide you with personalized and better user experience, we will recommend meaningful connections. We will collect information from your mobile devices, and store information such as your preference in data folders through the usage of cookies (“Cookies”). In essence, Cookies allow us to serve you better and more efficiently. You can control how and whether Cookies are utilized by changing the options on your device or using functionalities available to you. However, blocking cookies related to our Services may disable certain features of our Services and may otherwise hinder seamless and excellent user experience.

3.2 Other Similar Technologies

In addition to Cookies, we may also use other similar data collection technologies. For example, when you click the link sent by us through email, we can track this click and your preferences and thus optimize our customer service experience.

  1. How the information is shared

With your prior permission i.e. acceptance of this Policy, we will share or allow third parties to collect your information from our Services under the following circumstances and shall also contractually obligate such parties not to share your information with any other party.

4.1 In response to a legal request

We may share your information according to Laws and Regulations, dispute resolution and litigation purposes or legal requests from administrative agencies and judiciary institutions. We will share your information when necessary to achieve the following actions: to detect, prevent and address fraud, violations of our terms or policies, or other harmful or illegal activities; to protect ourselves (our rights, property or Services), you or others (individuals involved in investigations or regulatory inquiries); or to prevent death or imminent harm.

4.2 Sharing with affiliates

We may share your information with our affiliates in order to provide you with better Services (recommending information tailored to your interest) or to protect the assets of other users and the public.

4.3 Change of ownership

We may transfer your information to the new owner, controller or acquisitor when merger, acquisition or bankruptcy liquidation occurs.

4.4 Sharing with third-party Partners

We work with third-party partners who favor us provide and improve our Services to offer you high-quality Services. The following are the types of third parties we share information with:

(a) Partners who use our analytics services

We provide aggregated statistics and insights that help users and merchants to understand how users engage with our Services.

(b) Measurement agencies

We share information about you with agencies that aggregate it to provide analytics and measurement reports to our partners.

(c) Other partners such as vendors and service providers

We provide information and content to vendors and service providers, such as those who provide technical services, analyze how our Services are used, offer customer service, facilitate payments and conduct surveys, etc.

  1. How we protect your information

We endeavour to protect you from unauthorized access or alteration, disclosure or destruction of your information through responsible and feasible security measures that are universal within the industry. We have implemented reasonable security practices and documented information security policies which comprise all relevant security control measures that are commensurate with the protection of the information assets (including your data). However, despite our commercially reasonable efforts to safeguard your information, it is difficult and impossible for any entity to promise complete security to your personal data. If you deem that your account or information is no longer secure, please notify us (in accordance with section 11 below) immediately and we will take necessary actions as expeditiously as possible.

You must be careful and cautious before uploading text, images and others when engaging in our Services since your voluntarily or publicly sharing of information may involve personal data about you or others.

  1. How you manage your own information

Unless required otherwise by Laws and Regulations, you reserve the right to access, rectify, add and erase your personal information. After deleting information on our Software, the corresponding information will be removed or anonymized with the backup system update if unable to be removed immediately.

You can also modify the scope of your authorization. We will no longer process your information upon your withdrawn access. Please note that your decision has no effect on the prior information displayed and processed. Please be aware that functions of our Services may require certain data to operate and thus modifying your scope of authorization may lead to the inability to use our Services.

  1. Rights of users to request access to and update information

You may access your personal information by sending a request to our Grievance Officer. You may also seek to correct your inaccurate or deficient personal information or delete such information. You may withdraw your consent to provide any or all information or decline to provide the same as may be required from time to time. Whereas you choose to do so then your access to the Services may be limited, or we might not be able to provide the Services to you.

  1. How we protect the information of underage users

Our Services are restricted to adults only. We do not permit minors on our Software and we do not knowingly collect personal information from any minors. If you suspect that a user is not an adult, please use the reporting mechanism available through the Services.

  1. How we operate and transfer data as part of our global services

As part of our international operations, we transfer, transmit, store or process your information globally to our affiliates or business partners under the guidance of local Laws and Regulations as well as in accordance with this Policy. You acknowledge and agree that, to the extent permissible under applicable Laws and Regulations, we may transfer or disclose your information to any other entities within or outside your country of residence for providing Services to you. In such cases, we place contractual obligations on the recipients to ensure that your information is not disclosed, shared or transferred further to any other parties. Moreover, we contractually oblige the recipients to take protective measures of the same level as that adhered to your data by us under the reasonable security practices set out in section 5.

  1. Data retention and delete the account

We generally retain your data for as long as we need it for the performance of our Services and to comply with our legal obligations.

We may keep it to evidence our compliance with applicable Laws and Regulations; there is an outstanding issue, claim or dispute requiring us to keep the relevant information until it is resolved; or the information must be kept for our legitimate business interests. However, even though our systems are designed to carry out data deletion enquiries and processes, we cannot promise that all data will be deleted within a specific time frame due to technical constraints and legitimate reasons.

If you no longer want to use our Services and would like your account deleted, you can delete your account by taking one of the following measures:

(1)   go to setting -> privacy setting and follow our in-app instructions to delete your account; or.

(2) contact us via our customer service or via email:

[]. We will provide you with assistance and guidance throughout the deletion process.

Some of our Services may not have an in-app portal to delete your account. In that case, please contact our customer service or email us directly.

After taking the steps to delete your account, it will first be deactivated for 30 days. While your account is deactivated, your will not be able to use the Services and you can log back in to the platform within the deactivating period. After the deactivating 30 days, your account will be permanently deleted.and YOU MAY NOT BE ABLE TO RECOVER YOUR ACCOUNT OR RETRIEVE ANY CONTENT OR INFORMATION REGARDING YOUR DELETED ACCOUNT.

  1. How to contact us

If you have any questions or grievances within this Policy relating to the processing of your information, or you would like to exercise any of your rights, please do not hesitate to reach out to our Grievance Officer whose contact details are set out below. We endeavour to redress all grievances received on an expeditious basis.

You can contact our Grievance Officer via online customer service or via email: [].