1. INTRODUCTION:

Montray Digital Pvt. Ltd., offers it’s mobile based application Guftgu (App), through it’s allied partners, service providers, subsidiaries, joint ventures and/or other entities under it’s common control and or any of it’s directors, agents, representatives, consultants, directors hereinafter (MDPL),

MDPL is committed to protect the privacy of it’s Users/You, including but not limited to the onboard Consultants, customers/members whether registered or not registered).

2. PURPOSE:

This Privacy Policy is published in accordance with Rule 3(1) of the Information Technology (Intermediaries Guidelines) Rules, 2011 and Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 that require publishing of the Privacy policy, Terms of Usage etc., for collection, use, storage and transfer of sensitive personal data or information.

Please read this privacy policy carefully to understand how MDPL/Guftgu uses information supplied by you on/through the App. This Privacy Policy is a computer system generated format which does not require any signatures, however, Your direct/indirect usage of the App, constitutes your express consent to have understood and agreed the terms of this Privacy Policy at all time of such use.

MDPL reserve the right to make changes to this Privacy Policy at any time and for any reason. MDPL will alert you about any changes by updating the “Last updated” date of this Privacy Policy. You are encouraged/advised to periodically review this Privacy Policy to stay informed of updates. You will be deemed to aware of, will be subject to, and will be deemed to have accepted the changes in any revised Privacy Policy, in future, by your continued use of the App after the date such revision and posting.

This Privacy Policy does not apply to any third-party online/mobile store from which you install the Application or make payments, including any in-game virtual items, which may also collect and use data about you. We are not responsible for any of the data collected by any such third party.

3. INFORMATION COLLECTION/USE:

MDPL may collect information about you in a variety of ways. The information we may collect via the Application depends on the content and materials you use, and includes:

Personal Data: The information as voluntarily provided by the User, while choosing to participate in/opt for the services provided by the App, and collected by the App, in the form of demographics, and other Personally Identifiable Information (PII), which means and connotes information, which identifies a specific user. Any such data for the use of services provided on the App, such as chat, posting messages in comment sections or in App forums, interactivity, liking posts, sending feedback, and responding to comments/surveys would collectively form PII. If you voluntarily choose to share data about yourself via your profile, online chat, or other interactive areas of the Application, please be advised that all data you disclose is in public, will be deemed to be in public domain and as such be accessible to anyone who accesses the App.

Derivative Data: Information our servers automatically collect when you access the App, such as your in App actions being integral to the App, including liking, re-blogging, or replying to a post, as well as other interactions with the Application and other users via server log files. MDPL recommends and encourages You to carefully discern the information you disclose about yourself. You are cautioned against putting your email addresses, URLs, instant messaging details, phone numbers, full names or addresses, credit card details, national identity numbers, drivers' licence details and other SPDI on your profile which may be open to abuse and misuse.

Financial Data: Information, such as data related to your payment method (e.g. valid credit card number, card brand, expiration date) that the App collects while you register, purchase services, order, exchange, or request information about our services on the App. MDPL stores only very limited, if any, financial information that the App collects. All such financial information is stored/used by the App’s payment processor, RazorPay, and you are encouraged to review their privacy policy and contact them directly for responses to your questions.

SPDI: Any Sensitive Personal Data or Information (SPDI) as defined in Rule 3, under the Information Technology (Reasonable Security Practices And Procedures And Sensitive Personal Data Of Information) Rules, 2011, enacted under the Information Technology Act, 2000, and or any other applicable law, rules and regulation as applicable, will also apply to the details/information as required by the App during registration. Notwithstanding the foregoing, any information that is freely available or accessible in public domain or furnished under the Right to Information Act, 2005 or any other law for the time being in force will not be regarded as SPDI.

Data from Social Networks: User information from social networking sites, that your mobile app connects to, including your name, your social network username, location, gender, birth date, email address, profile picture, and public data for contacts, also gets connected, if you connect your account to such social networks. This information may also include the contact information of anyone you invite to use and/or join the App.

Other Data: Other such Information which qualifies as personal may also include birth details, addresses, place of work, profession, health issues, trauma, medication etc. and used for the services provided by the App using the information so collected.

4. ACCOUNT REGISTRATION: You in order to avail the services of the App is required to open an account using Your mobile phone number and/or email id. The App sends You a One Time Password (OTP) a verification code for confirmation. PII provided by you to create Your account shall include, Full name, Address, Telephone Number, Email-address, Date of Birth, Gender, Location, Photograph, and any other information as may be needed from time to time for Your identification. E-mail address/phone number together with a password or OTP, as a combination of information is used for securing User’s profile. MDPL may not be able to provide services due to non-availability of PII of the User, in case no registration is done by the User,

5. AUTOMATIC TRACKING PROCESS/COOKIES: App collects certain information automatically information which is stored on your mobile phone through cookies, by Your browser, and logs generic information about Your Session Data. App may store temporary or permanent ‘cookies’ on Your mobile phone, and allow the App’s server to recognize the User mobile phone every time You return to the App, tracks/keep the logs pertaining to the time and date of Your visit, duration of time spent on the App, verify registration or password information etc about Your account, in the form of log files, Your IP addresses etc.. You may choose to block most of these cookies by turning the same off in Your device settings. However, any such blocking may impair the use of certain features of the App. It is clarified that the App uses the cookies only to personalize Your experience on the App, according to Your preferences set by You. Also there may be certain third party cookies on the App. You are also advised to read their specific Privacy Policies as the same may neither apply to us nor is governed by us.

6. PUBLIC DOMAIN: The App further tracks User feedback, comments, etc. as disclosed/informed/mentioned on any article/blog or groups/forums or other pages which the User may have accessed while visiting the App. Such information, in public domain is generic and is accessible to all Users and visitors of the App. You are advised to carefully exercise your discretion, before all/every disclosure made online, as such information is susceptible to misuse.

7. MISCELLANEOUS ACTIVITIES: Certain other information which may not necessarily be disclosed and further may receive any other information with regard to specific services availed from the App, such information may not be made part of the User/Member’s Profile, but shall be used only for addressing the specific need or concern of the User.

8. MISCELLANEOUS ACTIVITIES: Certain other information which may not necessarily be disclosed and further may receive any other information with regard to specific services availed from the App, such information may not be made part of the User/Member’s Profile, but shall be used only for addressing the specific need or concern of the User.

9. DATA FROM CONTESTS, GIVEAWAYS, AND SURVEYS Personal and other information you may provide when entering contests or giveaways and/or responding to surveys.

10. USE OF YOUR INFORMATION: Having accurate information about you permits the App to provide You with a seamless, efficient, and customized user-experience. MDPL may use information collected about you via the App for: -administer the App -create and manage your account. -generate a personal profile about You to make future visits to the Application more personalized. -enable User-to-Consultant communications. -notify you of updates to the Application. -deliver targeted coupons, newsletters, and other information regarding promotions and the App to You. to hold promotions, contests, loyalty benefits etc. -compile anonymous statistical data and analysis for use internally or with third parties. -troubleshoot connection problems -fulfil and manage Your purchases, orders, payments, and other transactions for App service. send you push notifications regarding your account or the Application. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings. -offer You new products, services, mobile applications, and/or recommendations. -request feedback and contact you about your use of the Application. -increase the efficiency and operation of the Application. -monitor and analyse usage and trends to improve your experience with the Application. -perform other business activities as needed. -prevent fraudulent transactions, monitor against theft, and protect against criminal activity. -process payments and refunds. -resolve disputes and troubleshoot problems. -respond to product and customer service requests. -send you a newsletter. -solicit support for the Application. -assist law enforcement agencies and respond to court, within stipulated time periods as defined from time to time.

11. DISCLOSURE OF INFORMATION: MDPL may share the collected information about You in certain situations:.

Where mandated by Law or to Protect Rights, if it is believed the the release of information about You is necessary to respond to legal process, to investigate or remedy potential violations of App policies, or to protect App rights, property, and safety of others, MDPL reserves it’s right to share Your information as permitted or required by any applicable law, rule, or regulation. This includes exchanging information with other entities for fraud protection and credit risk reduction.

Third-Party Service Providers, who perform services for MDPL, including payment processing, data analysis, email delivery, hosting services, customer service, and marketing assistance.

Marketing Communications: With Your consent, or with an opportunity for You to withdraw consent, MDPL may share your information with third parties for marketing purposes, as permitted by law.

Affiliates: MDPL may share your information with it’s affiliates, if such affiliates agrees to honour this Privacy Policy. Affiliates include MDPL, any subsidiaries, joint venture partners or other companies that under MDPL’s control.

Business Partners: MDPL may share your information with it’s business partners to offer you certain products, services or promotions.

Social Media Contact: If You connect to the Application through a social network, Your contacts on the social network will see your name, profile photo, and descriptions of your activity.

Sale or Bankruptcy: If MDPL reorganize or sell all or a portion of it’s assets, undergo a merger, or are acquired by another entity, it may transfer Your information to the successor entity. If MDPL goes out of business or enter bankruptcy, Your information would be an asset transferred or acquired by a third party. You acknowledge that such transfers may occur and that the transferee may decline to honour commitments as made by MDPL, in this Privacy Policy. MDPL will not be responsible for the actions of third parties with whom You share personal or sensitive data. MDPL has no authority to manage or control third-party solicitations. If You no longer wish to receive correspondence, emails or other communications from third parties, You are responsible for contacting the third party directly or to disassociate at will.

12. REPRESENTATION BY THE USER: The User hereby represent and confirms that the information provided is authentic, correct, current and updated. MDPL/App and its affiliates shall not be responsible for the authenticity of the information that the User may provide. The User shall be personally liable and indemnify MDPL, and keep MDPL indemnified for the breach of any provision

13. SECURITY MEASURES:

The security of the personal information supplied by the User is very important to the MDPL. For the purpose of securing such information the App takes various measures inclusive of taking reasonable steps such as physical and electronic security measures to guard against the unauthorized access to the information.

The personal information of a user is collected on a secured server. The payment details are entered on the Payment Gateway’s or Bank’s page on a secured SSL. The data is transferred between Bank’s page and payment’s gateways in an encrypted manner. However please note that no data transmission can be guaranteed to be completely secure. Hence the user is advised to take precaution and care against any sharing of the details submitted on the App included the log-in details as generated after registration. MDPL will not be responsible for the security or confidentiality of communications the User may send through the internet.

14. PROTECTION OF PRIVACY:

MDPL endeavours/intends to protect the privacy of all Users, visiting/using the App/it’s services, irrespective whether the User is registered or merely a visitor. Every user is duly advised to understand what types of Personally Identifiable information is collected and employed for due provision of services. The information will be used explicitly for the purpose of the App. It is guaranteed that no direct or indirect misuse of such information will be permitted. It is further clarified that MDPL does not in any manner deal in selling or renting the information received through the App, but for the limited purposes as detailed herein before.

MDPL explicitly refrain to treat or provide solutions for Users with weak mental health, including but not limited to any such User who may have thoughts related to committing suicide, self-destruction etc. Such Users are cautioned/advised to immediately stop the use of the App. Any continued use of the App by such person would solely be at the User’s risk and MDPL shall have no liability for any untoward event in such scenario. MDPL declares that the information provided by such kind of User will be shared, if required, with law enforcement authorities, as such information so shared, is not protected or privileged from any kind of non-disclosure or confidential agreements either with MDPL or with any third-party involved herein.

MDPL disclaims any warranty, guarantee, accuracy of the consultancy received by any User, in any manner whatsoever. MDPL does not take any guarantee/responsibility/liability regarding the reliability or reality of consultancy/advice by any Consultant on board, and the User is advised/cautioned to carefully discern the same before applying the same. The User is free to seek consultancy from other Consultants as a second opinion, in case of any apprehension/doubt.

15. ACCOUNT INFORMATION: You may at any time review or change the information in your account or terminate your account by: -Logging into Your account settings and updating Your account, or
-Contacting MDPL through the App at guftgu.care@montraydigital.com
Upon your request to terminate Your account, MDPL will deactivate or delete your account and information from our active databases. However, You agree that some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with legal requirements.

CONFIDENTIALITY: MDPL respects and duly safeguards all information provided by its Users which may be termed as confidential. Only the information used for the purposes of the App as detailed herein above, is disclosed exclusively on need to know basis. All such information which is not required to be disclosed for the purposes of the App, is excluded from the definition of Personal Identifiable Information and shall not be collected/used. The Confidential information of the User shall never be disclosed, divulged or shared by MDPL, its employees, its agents or any third-party contractors except where MDPL believes, that such Confidential information is required to be shared with the investigating agencies, or in terms of any court order/direction, or in any manner under law.

MDPL from time to time push messages/reminders to the Users calling upon the Users to necessarily comply/be aware/synced with the MDPL/intermediary's Terms of Usage at least once a month

I HEREBY CONFIRM AND DECLARE THAT I HAVE READ THE TERMS OF PRIVACY POLICY AND ACCEPT THEM UNEQUIVOCALLY.