Template notice: This document is a starting template and must be reviewed and approved by a qualified Indian lawyer before launch. Fill every [PLACEHOLDER] with the company's real details.
1.Who we are
[Company legal name] operates LiveFace - Masti and is the "Data Fiduciary" for your personal data under the DPDP Act. Contact: [privacy@yourdomain.com], [Registered address].
2.What we collect
- Account data: mobile number, name, gender, date of birth, the time you accepted the Terms and confirmed you are 18+.
- Verification selfie: required only for women to confirm gender. It is viewed by our moderation team and not shown to other users.
- Payment data: plan purchased, amount, order and payment IDs and status. Card / UPI details are handled directly by Razorpay and never reach our servers.
- Usage and safety data: call start and end times, who you were matched with (user IDs), reports you make or receive, blocks, device and browser type, IP address and log data.
- Camera and microphone: used live during calls, with your browser's permission.
3.We do not record your calls
Video and audio are transmitted in real time between participants through Agora's network. We do not record or store call audio or video. If automated safety checks analyse video frames in the future, they will be analysed momentarily for policy violations and not retained unless a violation is flagged for review. We will update this policy before introducing such checks.
4.Why we use your data
- to create and secure your account (OTP login) and match you with other users;
- to verify age and gender and to prevent fake accounts and abuse;
- to process payments, provide invoices, and meet tax and accounting laws;
- to moderate reports, enforce our Terms and cooperate with law enforcement;
- to show advertising to free users, and to improve and fix the Service.
5.Consent
We process your data based on your consent given at sign-up, and for certain legitimate uses permitted by the DPDP Act (such as legal compliance and preventing fraud). You can withdraw consent at any time by deleting your account; this may stop you from using the Service.
7.How long we keep data
- Account data: until you delete your account.
- Verification selfie: deleted on account deletion, or [90] days after a rejection.
- Payment records: up to 8 years as required by tax and company law (kept in minimal form).
- Reports and safety logs: up to [12 months], or longer where needed for legal proceedings or to keep banned users out.
8.Your rights
Under the DPDP Act you may: request a summary of the data we hold; correct or update inaccurate data; request erasure of your data; withdraw consent; nominate someone to exercise your rights if you die or become incapacitated; and file a grievance.
You can delete your account from Account → Delete account. To exercise other rights, write to [privacy@yourdomain.com]. If you are unhappy with our response, you may approach the Data Protection Board of India once it is operational.
9.Children
The Service is for adults aged 18 and over. We do not knowingly collect data from anyone under 18. If you believe a minor is using the Service, contact us immediately and we will remove the account.
10.Security
We use HTTPS encryption, hashed OTPs, access-controlled admin tools, rate limiting, and secure cookies. No system is 100% secure; if there is a personal data breach we will notify the Data Protection Board and affected users as required by law.
12.Grievances and updates
For privacy complaints contact our Grievance Officer. We may update this policy; material changes will be notified in the app or by SMS.