Data Deletion

This Privacy Policy describes how and when (“Company”) collects, processes use, and shares your information when you use the “Thopla” application and ("Platform"). By accessing the Platform and using the services provided by the Company through the Platform the (“Service”), you agree to the terms of this Privacy Policy and hereby consent to the collection, transfer, processing, storage, disclosure, and other uses of your information as provided herein. The Company receives your information through the Platform, email notifications, and other interactions with the Service. If you do not agree with the terms of this Privacy Policy, please do not access the Platform and use the Services.


  1. Collection of Information


  1. You may provide certain information to the Company while registering on the Platform and/or using the Services. This includes the information that the Company: (a) collects from you when you access and use the Service, such as your name, electronic mail address, password, IP address, your photograph, and other relevant details; (b) collects regarding your content, received, uploaded or posted using the Platform; (c) collects 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) collects the information you choose to upload, sync or import from the device on which the Platform is being used. All information disclosed by you shall be deemed to be disclosed willingly and without any coercion. No liability about the authenticity, genuineness, misrepresentation, fraud, negligence, etc. of the information disclosed shall lie on the Company;


  1. The Company may collect non-personal information relating to your activities while accessing the Services 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).


  1. The Platform is a content sharing, social networking 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 post and information provided with such content, such as when it was posted, but also the accounts you follow, the content that you like or comment on, and other public interactions on the Services. Your public information is broadly and instantly disseminated. For instance, your profile information and public Content are immediately delivered to all users of the Platform and other services that access the Platform. When you share information or content via the Services, you should think carefully about what you are making public.


  1. 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.


  1. The Company may keep track of how you interact with links across the Service, including email notifications, third-party services, and client applications, by redirecting clicks 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.


  1. Our servers automatically record information ("Log Data") created by your use of the Services. 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 Services, to measure, customize, and improve the Services, and to aid a better user experience.


  1. In case you make any payment on the Platform, you understand and acknowledge that the Company only facilitates the third-party payment gateway for processing of the 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 a third-party payment gateway before disclosing any sensitive personal information to such a third-party payment gateway.


  1. 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 the Platform; 
  2. to confirm your identity directly and/or through third parties;
  3. helping you efficiently access your information after you sign into the Platform;
  4. remembering your personal information so that you are not required to re-enter it the next time you visit the Platform;
  5. to understand your preferences and to enhance and customize your experience of using the Platform;
  6. for providing customized user-relevant suggestion/services;
  7. to communicate with you through the mail, e-mail, and telephone, in connection with the Services;
  8. to respond to your comments, reviews, and questions and provide better Service;
  9. to communicate important notices or changes in the Services, use of the Platform and the terms/policies which govern the relationship between you and the Company;
  10. for internal purposes such as auditing, data analysis, research, and improvement relating to the Platform or the services provided through the Platform;
  11. for promotion and marketing purposes;
  12. 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 Services through the Platform;
  13. 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 that may direct you to other websites or applications not operated/maintained by the Company (the “Third Party Site”). How 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 concerning how the 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, including to enforce agreements, policies, and Terms of Use; (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 Services; 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-emails 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 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 personal information with third-party vendors, consultants, and other service providers who work for the Company, who are bound by contractual obligations to keep 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 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 proceeding. Such third parties shall be contractually bound to not disclose further, any personal information disclosed to them.


  1. Security


The Company uses reasonable security measures, at the minimum those mandated under applicable law to safeguard and protect your data and information. The Company has implemented such measures, as stated above, to protect against unauthorized access to, and unlawful interception of your information. However, security risks cannot be 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. 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 [email protected].


  1. Legal Basis for Data Processing


The Company processes personal information for the purposes set out in this Privacy Policy, as described above. The legal basis to process personal data includes processing that is: necessary for the performance of the contract with you (for example, to provide you with the services you request and to identify and authenticate you so you may use the Platform); necessary to comply with legal requirements (for example, to comply with applicable accounting rules and to make mandatory disclosures to any law enforcement agencies or authorities); necessary for the legitimate interests of the Company (for example, to manage the relationship with you, to ensure the security of the Service, to communicate with you about the Company’s products and services); and based on consent by users (for example, to share your information with third parties for advertising purposes as specified under Clause 1.5 and 4.2). In some instances, you may be required to provide the Company with personal information for processing as described above, in order for the Company to be able to provide you and for you to use all the features of the Platform.


  1. User Discretion


  1. 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.


  1. 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.


  1. 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. Should you desire to withdraw your consent, the Company requests that you close your user account and stop accessing the Platform and the Services. You can also permanently delete your account and your personal information collected by the Company by contacting the company’s grievance officer. If you are aware of 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.


  1. The Company will retain your personal information as long as needed to provide the Services, or as required or permitted by applicable laws.


  1. Grievances


In the event you have any grievances relating to the Privacy Policy, please inform the Company within 24 hours of the occurrence of the instance from which the grievance has arisen, by writing an email to the Grievance Redressal Officer as follows:


Contact information:

[email protected]


  1. Amendments


The Company retains an unconditional right to modify or amend this Privacy Policy without any requirement to notify you of the same. You can determine when this Privacy Policy was last modified by referring to the “Last Updated” legend above. It shall be your responsibility to check this Privacy Policy periodically for changes. Your continued use of the Platform following the posting of changes to this Privacy Policy on the Platform will constitute your consent and acceptance of those changes.

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