PRIVACY POLICY FOR SHURU APP
Introduction:
Close App Private Limited (“we”, “our”, “us”) respects your privacy and is committed to protecting it. Please read this privacy policy (“Policy”) carefully to understand our practices regarding your personal information. By installing, accessing, or using the Shuru App, you grant your express consent to be governed by the terms of this Policy.
As used in this Policy, Shuru App means and refers to Company's proprietary social entertainment platform (including the mobile application/ site or as made available in any other format) called 'Shuru' and which enables users to explore, discover, watch, upload and share videos and audios and other content including content created by you, details of your business and professions, daily updates and news.
This Policy inter alia sets out: (i) the types of personal information we collect when you install and access the features of the Shuru App; (ii) how we use that information; (iii) the purposes for which we collect it; and (iv) how we disclose such information.
If you do not agree with the terms of this Privacy Policy, you must immediately cease your access to the Shuru App. Your continued access to the Shuru App indicates your acceptance of the terms set out in this Policy.
This Policy applies only to the information we obtain from you through the Shuru App. It does not apply to any information that we may obtain from sources other than the Shuru App who provide your information based on their privacy policies and your interaction with their offerings. The Policy does not apply to the other websites or landing pages that you may access through the Shuru App or your direct interaction with any third party including a user who is a business owner even if you engage specifically with that user directly through the Shuru App, nor does it apply to information that you provide to or that is collected by any third party. We encourage you to read and accept the privacy policies of all third-parties as per your discretion.
Information we collect and how we collect it:
We collect the following information from and about you:
Information you provide to us with prompts:
- If you elect to install, launch, access and/or use the Shuru App, we will ask you to provide certain information to create your account such as name, telephone number, gender, email, profile picture, location, phone contacts and access to your call logs. You may also include a description about yourself or your business and address of your business. If you elect to provide the abovementioned information, a digital visiting card will be created to the extent of the information provided to you.
- The phone contacts are accessed by Shuru App to allow the users to connect with their families and friends. A list of the contacts who are also using the Shuru App will be visible on the screen in the 'People' section only to the user. We clarify that the Shuru App will request for permission to access the phone contacts of the user, however, this is not a mandatory permission, and the user may select 'Deny' on the screen when such permission is requested.
- While you may elect to opt out of giving all other information as mentioned above, the provision of your location is essential for the usage of the Shuru App as it is a location-based application. Shuru App will optimize and create the content for your feed as per your location. There are two ways via which you can provide the location, first is where you give access to the Shuru App to locate your coordinates directly and second, where you manually enter the name of the state and the city of your location to optimize the content accordingly.
- Shuru App is not targeted towards users under 18 years of age, therefore, we do not knowingly request access to, collect or process personal information of any such user. If you continue to access the Shuru App, we assume that you are over 18 years of age.
Other Information we collect without prompts:
When you access the Shuru App we may collect:- Details of your access to and use of the Shuru App, including interaction data, logs of access and usage, and other performance data and the resources that you and use on or through the Shuru App, including stories, videos, content you read, view, watch or interact with.
- Information about or on your device such as the online device identifiers, advertising identifiers, device make, IP Address, display features, operating system make, browser type and network/wifi type.
- Cookies or pixels (or mobile cookies/pixels). A cookie is a small file placed on your smart device. It may be possible to refuse/accept cookies by activating the appropriate setting on your smart device. However, if you select this setting you may be unable to access certain features of the Shuru App.
- Pages of the Shuru App may contain small files known as beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permits the Company to improve its services, for example recording the popularity of certain application content, verifying system and server integrity.
How your Information is Used:
We (and our partners) may use information that is collected about you or that you provide, to:
- Provide you with the Shuru App features and its contents, such as location-based events, featured videos and audios, offers and any other content.
- Notify you when any relevant Shuru App updates or upgrades are available and requires notification.
- Estimate our audience size and usage patterns.
- Optimize your searches.
- Enrich, build custom audience segments or merged data sets (using the data referred herein and/or third party provided data sets) to enable the Shuru App to better offer their services.
- Improve our customer services and account maintenance including to detect, deter and prevent fraud, fraudulent traffic or to protect the security of our systems.
- Make disclosures in the event of merger, sale, other asset transfers or other relevant corporate transactions. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract. (collectively the “Permitted Purposes”).
Disclosure of your information for Permitted Purposes:
We may disclose aggregated information about our users, and information that does not identify any individual or device. We may also disclose information that we collect, or you provide:
- To our key shareholders, board, investors (debt or equity).
- For purposes of legal disclosures. We may access, preserve, and disclose any information we store associated with you to external parties, if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our or others' rights, property, or safety; enforce our policies or contracts; or assist with an investigation or prosecution of suspected or actual illegal activity.
Your Choices About Our Collection, Use and Disclosure of Your Information:
We strive to provide you with choices regarding the information you provide to us. You may elect to disable or uninstall from the Shuru App.
- Personal Information: You may opt out of the personal information collection including your name, telephone number, address, gender, or email by the Shuru App by clicking on 'Skip' when asked for such information on your device. Note, however, you mandatorily have to elect to share your location, either directly or by manually entering the city of your location as Shuru App optimizes the content on it using the location of the users as a filter and it cannot fulfil its objective if the location is not entered by the user.
- Tracking Technologies: You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent or use your settings to disable certain features. If you disable or refuse cookies or block the use of other tracking technologies, some parts of the Shuru App may then be inaccessible or not function properly.
- The submission of your information to the Shuru App and your acceptance of this Policy will have an overriding effect on any registration of your mobile number with the National Do Not Call Registry of the Telecom Regulatory Authority of India and any other Do Not Call Registry operated by any other service provider.
- You can unsubscribe or opt-out from receiving non-transactional e-mail communications from Shuru App at any time by clicking the 'Unsubscribe' option available at the bottom of each such e-mail communication. [NOTE FOR CLIENT: Please confirm if this is applicable.]
Data Security:
We have implemented suitable technical and organizational measures to secure your personal information in compliance with our legal and privacy requirements.
Data Retention Period:
We will retain your information for as long as necessary to continue providing you with access to the Shuru App, and as otherwise required by law or applicable contract. After the applicable retention period, the Company may retain and use such data in an aggregated format, as necessary for internal analytical purposes, to comply with its legal obligations, resolve disputes, if any, and enforce agreements.
Refund & Cancellation Policy:
Changes to Our Privacy Policy:
We may update our privacy policy from time to time. If we make any material changes, we will notify you by means of a notice on the Shuru App prior to the change becoming effective. Please check our Privacy Policy regularly to ensure you have read the latest version.
Contact Information:
Please feel free to contact our Data Protection Officer “Harsh Chhabra” at info@shuru.co.in with any questions regarding the Policy, or security of your personal information, or if you have any concerns, requests, or comments.
Annexure
Shuru is a location-based social networking platform that helps its members discover content and connect with people based on their location.
This hyper-local approach of this open platform helps members reach out for support in real-time in their neighborhood, raise local concerns, run community-driven initiatives, work towards bringing in social impact, promote small businesses in the area, organize local events, and together create a better, safe and supportive living environment for all.
Data we collect & Use:
User's Personal information:
Shuru app is a social community app, In order to validate the members' identity on the Shuru app, the app asks for the member's Name, Phone number or email, and location.
Use of this information:
- Whenever a user posts anything, their name, profile picture(if added by the user), abstract location is visible along with their content/post/comment on the app.
- Whenever any user lists their business and services on the Shuru app, and if and only if the user has permitted to show their personal information(Phone Numbers and Complete business address) then only their complete personal information is displayed on their profile and digital visiting card.
Member's content:
Shuru app is a user generated content & discussion platform, any registered user can post and add comments in Shuru app. Users can post about their business, product, services and ask questions. All content posted inside the Shuru app is collected and stored with the company.
Member's Phone Contact List:
Users on the Shuru app can find their friends who are already on the Shuru app. This is an optional feature(Not mandatory) for users to sync their phone contacts and find friends.
On allowing access to this feature users will be able to connect with their friends, visit their profile on Shuru, and will be able to invite their friends, existing customers on the Shuru to grow their reach to conduct discussions, and may be able to grow popularity and income.
Syncing phone contacts is an optional step, users can choose to not sync their phone contacts.
Information Flow inside the app for contact sync:
- On click of Skip: By clicking on 'Skip' button users can continue using the app and rest of the features of the app the same way as before.
- On giving contact access(Two steps user consent process): This is a two step user consent process, first they will have to click on 'Allow Access' after that Android's Contact Permission dialog will ask for final confirmation to give access to the phone contacts. By allowing access to their contact all phone contacts will be read from the user's device and stored on the server.
Use of phone contacts:
- Users are automatically connected with their friends, family and existing customers who are already on the Shuru app on giving access to their contacts.
- They can visit their profile anytime from the 'My Friends on Shuru' app section.
- Users are automatically connected with their friends, family and existing customers who are already on the Shuru app on giving access to their contacts.
- They can visit their profile anytime from the 'My Friends on Shuru' app section.
User's location:
Shuru is a location based app, where people from the same area or from their neighborhood can connect with each other for discussions, business and questions. Adding a location is a mandatory step to access all features of the app.
Users can provide access to location by allowing us to read their location OR they can choose not to give location access permission and can enter manually their area/city/state. All location information is stored on our servers, situated in India, Mumbai Region.
Use of location information:
- All use cases in the Shuru apps are bound around location, we use provided location information to display content to the user. Users can discover nearby services, shops, cafes, restaurants, and other users registered on the Shuru app.
- An abstract location information is displayed on the user's content(Posts and comments). Complete location information(Complete address or coordinates) is never shown to other users on user's generated content.
- However, some users/businesses can choose to display their complete address information on their profile and digital visiting card. This is an optional feature, which gives businesses an option to allow their potential customers to contact them or to navigate to their business address through Google Maps.
How do we protect your personal information?
Apart from details mentioned in 'Data we collect & Use' section, all data is protected in private servers, hosted in India, Mumbai Region. No database server is accessible from any public IP address.
We do not share any of our user's personal information with any third-party services/agency or other users of the platform. We do not pass any of the user's personal information to any data analytics tools and services.
However, the users themselves can share their information publicly for their personal purposes inside the content, Shuru does not stop their users from sharing their opinion, statements publicly. The Shuru is not liable for any harm/damage caused to any user from the information listed inside the app.
All information in this app is shared by the user, the user who posts the content is the owner of their content.
Whom to approach if you have further queries about our Privacy Policy?
If you have any questions about this Privacy Policy or if you would like to provide comments, please contact us at the address and/or e-mail given at info@shuru.co.in