Privacy Policy

Effective Date: 21-April-2025
Last Updated: 21-April-2025

1. INTRODUCTION

Nyburs is, a company having its registered office at HD-101, WeWork Salarpuria Symbiosis, Arekere Village, Begur Hobli, Bannerghatta Road, Kothanur, Bangalore, Karnataka, India - 560077, Bangalore, Karnataka. This Privacy Policy ("Policy") describes how we collect, use, process, store, share, and protect your personal data when you use our Platform and Services.

This Policy is prepared in compliance with the Digital Personal Data Protection Act, 2023 ("DPDP Act"), the Information Technology Act, 2000 ("IT Act"), the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 ("SPDI Rules"), and the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021 ("IT Rules 2021").

By accessing or using Nyburs, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy. If you do not agree with any part of this Policy, please do not use our Platform.

2. INFORMATION WE COLLECT

2.1 Personal Data Collected

We collect the following categories of personal data from users:

a) Mandatory Information:

• Mobile number (for account verification and authentication)
• Full name
• Gender

b) Profile Information:

• Profile picture (optional)
• Bio/description (optional)
• Location preferences
• Interest categories

c) Technical and Usage Data:

• Device information (device model, operating system, unique device identifiers)
• IP address and network information
• App usage statistics and interaction data
• Crash reports and error logs
• Session information and timestamps
• Location data (with explicit consent)
• Analytics data through third-party services

d) Event-Related Data:

• Events created, attended, or shown interest in
• Event check-ins and participation records
• Event feedback and ratings

e) Communication Data:

• Messages sent through the Platform
• Support communications
• Feedback and survey responses

2.2 Information from Third Parties

We may receive information about you from:

• Social media platforms (if you choose to link accounts)
• Public databases and directories
• Analytics and advertising partners
• Other users of the Platform (when they share content involving you)

3. PURPOSE AND LAWFUL BASIS FOR PROCESSING

3.1 Purposes of Data Processing

Your personal data is processed for the following purposes:

a) Service Provision:

• Creating and managing user accounts
• Enabling profile creation and customization
• Facilitating connections between users
• Managing event creation, discovery, and participation
• Providing customer support and technical assistance

b) Legal and Safety Requirements:

• Age verification and parental consent compliance
• Identity verification and fraud prevention
• Compliance with applicable laws and regulations
• Responding to legal requests and court orders
• Ensuring platform safety and security

c) Platform Improvement and Analytics:

• Analyzing user behavior and platform usage patterns
• Improving app functionality and user experience
• Conducting research and development
• Performance monitoring and optimization

d) Communication and Marketing:

• Sending service-related notifications
• Sharing platform updates and announcements
• Conducting user surveys and feedback collection
• Marketing communications (with explicit consent)

3.2 Lawful Basis under DPDP Act 2023

We process your personal data based on:

• Consent: Where you have provided explicit consent
• Contract Performance: To fulfill our obligations under the Terms of Service
• Legal Obligation: To comply with applicable laws and regulations
• Legitimate Interests: For platform security, fraud prevention, and service improvement

4. DATA SHARING AND DISCLOSURE

4.1 General Principle

We do not sell, rent, or trade your personal data to third parties for commercial purposes. However, we may share your information in the following circumstances:

4.2 Service Providers and Business Partners

We may share your data with:

• Cloud Infrastructure Providers: AWS India and Microsoft Azure India for data hosting and storage
• Analytics Providers: Google Play Services for usage analytics
• Communication Service Providers: For SMS/email delivery
• Payment Processors: For future monetization features
• Technical Service Providers: For app maintenance and development

All service providers are bound by data protection agreements and process data only as instructed by us.

4.3 Legal Requirements

We may disclose your information when required by:

• Court orders, legal processes, or government requests
• Law enforcement agencies are investigating legal violations
• Regulatory authorities under applicable Indian laws
• Legal proceedings where disclosure is necessary

4.4 Business Transfers

In case of merger, acquisition, or sale of business assets, your data may be transferred as part of the transaction, subject to appropriate safeguards.

4.5 Public Information

Certain information you choose to make public (profile information, event participation) may be visible to other users and the general public.

5. DATA STORAGE, SECURITY, AND RETENTION

5.1 Data Storage Location

Your personal data is stored on secure servers located in India through:

• Amazon Web Services (AWS) India
• Microsoft Azure India

We ensure that all data processing and storage comply with Indian data localization requirements.

5.2 Security Measures

We implement appropriate technical and organizational security measures, including:

• Encryption: Data encryption in transit and at rest
• Access Controls: Role-based access with multi-factor authentication
• Network Security: Firewalls, intrusion detection, and monitoring
• Regular Audits: Security assessments and vulnerability testing
• Staff Training: Data protection training for all personnel
• Incident Response: Comprehensive breach response procedures

5.3 Data Retention

• Current Policy: We retain personal data indefinitely to maintain service continuity and comply with legal obligations
• Future Updates: This retention policy may be updated to specify defined retention periods
• Deletion Requests: Users may request data deletion, subject to legal retention requirements
• Backup Data: Backups may be retained for security, disaster recovery, and compliance purposes

6. YOUR RIGHTS UNDER DPDP ACT 2023

As a data principal under the DPDP Act 2023, you have the following rights:

6.1 Right to Information

• Right to receive information about personal data processing
• Right to obtain a summary of personal data being processed

6.2 Right to Correction and Erasure

• Right to correct inaccurate or misleading personal data
• Right to complete incomplete personal data
• Right to request erasure of personal data (subject to legal obligations)

6.3 Right to Grievance Redressal

• Right to file grievances regarding personal data processing
• Right to have grievances addressed within prescribed timelines

6.4 Right to Nominate

Right to nominate another person to exercise your rights in case of death or incapacity

6.5 Exercising Your Rights

To exercise any of these rights, please contact our Grievance Officer at the details provided below. We will respond to your requests within the timelines prescribed under applicable law.

7. COOKIES AND TRACKING TECHNOLOGIES

7.1 Types of Tracking Technologies

We use various tracking technologies, including:

• Session Cookies: For user authentication and session management
• Analytics Cookies: Through Google Play Services
• Performance Cookies: For app performance monitoring
• Functional Cookies: To remember user preferences

7.2 Third-Party Services

Google Play Services: For app distribution and basic analytics

7.3 Managing Cookies

You can control cookies through your device settings. However, disabling certain cookies may limit platform functionality.

8. CHILDREN'S PRIVACY

8.1 Age Requirements

• Minimum age for platform use: 13 years
• Users aged 13-17 require verifiable parental consent
• Users 18+ can use the platform independently

8.2 Parental Consent Process

For users under 18:

• Verifiable parental consent must be obtained before account creation
• Parents have the right to review, modify, or delete their child's information
• Parents can revoke consent at any time

8.3 Special Protections

We implement additional safeguards for users under 18, including enhanced content moderation and restricted communication features.

9. INTERNATIONAL DATA TRANSFERS

Currently, all data processing occurs within India. If we engage international service providers in the future, we will ensure:

• Adequate data protection safeguards
• Compliance with Indian data transfer regulations
• User notification of any changes to data processing locations

10. GRIEVANCE REDRESSAL MECHANISM

10.1 Grievance Officer

Name: Vishal Chaudhary
Designation: Director
Email: info@nyburs.com
Office Address: HD-101, WeWork Salarpuria Symbiosis, Arekere Village, Begur Hobli, Bannerghatta Road, Kothanur, Bangalore, Karnataka, India - 560077

10.2 Complaint Process

• Submission: Complaints can be submitted via email or written communication
• Acknowledgment: All complaints will be acknowledged within 24 hours
• Resolution: Complaints will be resolved within 15 days as per IT Rules 2021
• Escalation: Unresolved complaints can be escalated to the Data Protection Board

11. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy periodically to reflect changes in:

• Legal requirements and regulations
• Platform features and functionality
• Business practices and procedures

11.1 Notification Process

• Advance Notice: Significant changes will be notified at least 30 days in advance
• Prominent Display: Updated policies will be prominently displayed on the Platform
• User Consent: Material changes may require renewed user consent

12. CONTACT INFORMATION

For any privacy-related queries, concerns, or requests, please contact:

Grievance Officer: Vishal Chaudhary, Director
Email: vishal@nyburs.com
Address: HD-101, WeWork Salarpuria Symbiosis, Arekere Village, Begur Hobli, Bannerghatta Road, Kothanur, Bangalore, Karnataka, India - 560077

13. GOVERNING LAW AND JURISDICTION

This Privacy Policy is governed by the laws of India. Any disputes arising from this Policy shall be subject to the exclusive jurisdiction of the courts in Bangalore, Karnataka, India.

By using Nyburs, you acknowledge that you have read, understood, and agree to this Privacy Policy.