Your data,in plain words.

1. Introduction

GullyFame India ("we," "us," "our," or the "Company") operates the GullyFame India mobile application and related services (collectively, the "Platform"). We respect your privacy and are committed to protecting personal data in accordance with applicable Indian law, including the Digital Personal Data Protection Act, 2023 ("DPDP Act"), the Digital Personal Data Protection Rules, 2025, to the extent applicable and in force, the Information Technology Act, 2000 and applicable rules, and other applicable privacy, cybersecurity and intermediary requirements.

This Privacy Policy ("Policy") explains what personal data we collect, why we collect it, how we use and share it, how long we retain it, the choices and rights available to you, and how you can contact us.

2. Scope

This Policy applies to personal data processed through the Platform, including the mobile application, websites, APIs, integrations, creator tools, competitions, payments, support channels and related services. Where a feature has a separate privacy notice or specific terms, that notice will apply together with this Policy.

3. Definitions

For the purposes of this Policy:

• "Personal Data" means data about an identifiable individual, as defined by applicable law.
• "Data Principal" means the individual to whom the personal data relates, where that term applies under the DPDP Act.
• "Consent" means a lawful, informed, specific and unambiguous indication of the individual's wishes, where the consent is the applicable basis of processing.
• "User Content" means photos, videos, audio, text, comments, messages and other material submitted or shared through the Platform.

4. Information we collect

We collect only information reasonably necessary for the purposes described in this Policy and as permitted by applicable law.

4.1 Information you provide

• Identity data: name, date of birth, gender and profile photograph.
• Contact data: mobile number, email address and, where required, address/city/state/PIN code.
• Account data: username, password and account-security information.
• User Content: photos, videos, audio, text posts, comments, messages and other content you upload or share.
• Communications: support requests, feedback, surveys and correspondence.
• Payment/KYC data: bank account details, IFSC, UPI ID, payment information and, where legally/operationally necessary, government identification such as PAN or other permitted KYC information.

4.2 Sensitive/high-risk information

Where the Platform uses biometric authentication or processes other information that is specially regulated or otherwise high-risk, we will provide the required notice and obtain consent or rely on another lawful basis where permitted. We will not collect such information merely because it is listed in a generic category; collection will depend on the feature you use.

4.3 Information collected automatically

We may collect device and technical information such as device model, operating-system version, app version, identifiers permitted by law, IP address, logs, crash reports, performance information, timestamps and security signals. We may collect approximate or precise location only where enabled by you, required for a feature, or otherwise permitted by law, if needed.

4.4 Information from third parties

We may receive information from connected accounts, payment providers, KYC providers, fraud-prevention services, analytics providers, business partners and other lawful sources, subject to applicable law and the permissions or consents required.

5. Purposes of processing

We may process personal data to:

1. create and manage accounts;
2. authenticate users and recover accounts;
3. provide, maintain and improve the Platform;
4. personalise feeds, recommendations and features;
5. enable creator tools, competitions, rewards, tipping, commerce and payouts;
6. process payments, refunds, KYC and tax-related requirements;
7. communicate service updates, security alerts and support responses;
8. send marketing or promotional communications where required with consent or another lawful basis;
9. detect fraud, spam, abuse, manipulation and security threats;
10. moderate and protect the Platform and its community;
11. analyse usage, troubleshoot and develop products; and
12. comply with applicable law, court orders and lawful government requests.

6. Lawful basis, notice and consent

We process personal data on the basis permitted by applicable law, including consent where required, specified legitimate uses/lawful purposes where available, compliance with legal obligations, and other permitted grounds. Where consent is required, we will provide an appropriate notice and seek consent in a manner required by law.

You may withdraw consent where processing is based on consent. Withdrawal may affect features that require that processing, and we may continue processing where permitted or required by law, including for security, fraud prevention, dispute resolution, accounting, tax or legal compliance.

7. Personalisation, analytics and advertising

We may use technical, usage and preference information to understand how the Platform is used, improve products, measure performance, prevent abuse and personalise content or recommendations.

Where advertising is offered, we may use information to deliver contextual advertising and, where permitted, personalised advertising. We may work with advertising or measurement providers subject to applicable law and required permissions. We do not sell personal data in the ordinary course of business.

8. Creator content and platform rights

You retain ownership of original content that you create and submit, subject to any separate agreement you enter into. By uploading or sharing User Content, you grant GullyFame the permissions reasonably necessary to host, store, reproduce, display, transmit, distribute, format, technically modify and make the content available through the Platform and to promote the Platform using your content, subject to the Terms of Use and applicable law.

You grant GullyFame a worldwide, non-exclusive, royalty-free, transferable and sublicensable licence, for the maximum period permitted by law, to host, store, reproduce, process, adapt, edit, translate, format, publicly perform, publicly display, distribute, communicate, promote and otherwise use Your Content as reasonably necessary to operate, secure, improve, market and develop the Platform and its services.

Any separate commercial licensing, brand usage, creator monetisation arrangement or third-party exploitation of creator content will be governed by the applicable Terms, Creator & Monetisation Policy, competition rules or separate agreement. We will not interpret this Privacy Policy as granting GullyFame unlimited ownership of your original content.

9. Payments, KYC and creator monetisation

If you use tipping, creator payouts, competitions with monetary prizes, commerce or other paid features, we may process payment and KYC information necessary to provide the service, prevent fraud, comply with tax and financial obligations, verify eligibility and make lawful payouts.

Payment and KYC information may be processed by payment gateways, banks, KYC providers and other service providers acting on our behalf. We may retain financial/KYC records for the period required by applicable law, accounting, tax, fraud-prevention or dispute-resolution requirements.

10. Competitions, rewards and integrity

Where the Platform operates competitions or rewards, we may process account, content, engagement, voting, judging, referral, payment and verification information to administer the competition, detect manipulation, verify eligibility, determine winners, make payouts and handle disputes.

We may use automated systems and human review to detect bots, purchased engagement, multiple-account abuse, coordinated or automated voting, fraudulent referrals and other manipulation. We may restrict, suspend, disqualify or withhold rewards where permitted under the applicable competition rules.

11. AI, deepfakes and synthetic content

GullyFame may process content and technical signals to identify or manage AI-generated, synthetically generated or materially manipulated content where required for safety, transparency, legal compliance or Platform integrity.

Users must comply with applicable requirements concerning disclosure, labelling or other treatment of synthetically generated information as detailed in the FAQs. Content that impersonates a real person, deceives users, facilitates fraud, or otherwise violates applicable law or Platform rules may be labelled, restricted or removed.

GullyFame may use automated detection, provenance or moderation technologies and may require additional disclosures or verification where appropriate. Specific AI-content rules will also be set out in the Community Guidelines and Terms of Use.

Any violation will lead to immediate content deletion, temporary account suspension, or permanent termination, along with forfeiture of account rights.

Upon receiving actual knowledge, court orders or government notices, the Platform reserves the right to remove or disable access to unlawful content within 3 hours, without prior notice. GullyFame is legally obligated to cooperate with law enforcement (under Sections 78 and 80 of the IT Act) and may preserve and share user logs, metadata, or device information during criminal investigations.

12. Sharing and disclosure

We may share personal data with:

1. hosting, cloud, analytics, moderation, customer-support, payment, KYC and security service providers acting on our behalf;
2. affiliates where permitted and necessary for operations;
3. business partners for features you choose to use, subject to applicable requirements;
4. advertising or measurement providers as permitted by law; and
5. law-enforcement, regulators, courts or government authorities where legally required or permitted.

We require appropriate contractual, technical or organisational safeguards from relevant processors/service providers where required. We do not sell personal data in the ordinary course of business.

13. Data retention

We retain personal data only for as long as reasonably necessary for the purposes for which it was collected, for the operation and security of the Platform, and for applicable legal, tax, accounting, fraud-prevention, dispute-resolution and enforcement requirements.

Retention varies by category. Account data may be retained while an account is active and for a limited period thereafter; payment/KYC and tax records may be retained for periods required by law; security and fraud logs may be retained for as long as reasonably necessary to protect the Platform; and support or dispute records may be retained for a reasonable period to resolve and evidence the matter.

When retention is no longer necessary and no legal exception applies, we will delete or anonymise the relevant personal data.

14. Data deletion and account closure

Where the Platform provides account deletion, you may initiate deletion through the account/settings process or by contacting us through the privacy contact below. Deletion may not immediately remove information that must be retained by law or is required for security, fraud prevention, financial records, disputes or legal claims.

Public content, competition records, transaction records or information already lawfully shared with third parties may be subject to separate deletion, retention or archival rules described in the relevant terms.

15. User rights

Subject to applicable law, users may have rights to access information about processing, request correction or updating, request erasure where applicable, withdraw consent where consent is the basis, exercise nomination rights where applicable, and raise grievances with GullyFame and/or the competent authority as provided by law.

Requests should be made through the contact details below. We may need to verify identity before completing a request and may decline or limit a request where permitted by law.

16. Data security

We implement reasonable and appropriate technical and organisational safeguards designed to protect personal data against unauthorised access, alteration, disclosure, loss, misuse and destruction. Measures may include encryption in transit and at rest where appropriate, access controls, authentication, logging, monitoring, vulnerability management, incident response and vendor due diligence.

No electronic system is completely secure. Users are responsible for protecting their passwords, devices and account credentials and should promptly report suspected unauthorised access.

17. Data breaches and incident response

If a personal-data breach occurs, GullyFame will assess and respond in accordance with applicable law, including required notifications to affected users, authorities or other parties where legally required. We may take immediate measures such as account restrictions, credential resets, content restrictions or other security controls to contain an incident.

18. Cross-border transfers

Where personal data is processed or transferred outside India, GullyFame will do so in accordance with applicable Indian law, including any restrictions, safeguards or government requirements that apply to the relevant transfer or recipient.

19. Grievance officer and contact

For privacy-related queries, complaints, or requests, contact:

Data Protection Officer / Privacy Officer
Name: [Name of Data Protection Officer]
Email: [Privacy contact email]
Address: [Postal address]

GullyFame India will acknowledge and address grievances within timelines prescribed by applicable law and the applicable Grievance Redressal Policy.

20. Changes to this policy

We may update this Policy to reflect changes in law, technology, Platform features or business practices. Where required, we will provide notice of material changes and obtain consent where legally necessary. The latest version will be made available through the Platform or other appropriate channel.

21. Governing law

This Policy is intended to operate under the laws of India and applicable rules and regulations. Any dispute relating specifically to privacy will be handled in accordance with applicable law and the Platform's Terms of Use.

22. Related policies

This Privacy Policy should be read together with the GullyFame India Terms of Use, Community Guidelines, Grievance Redressal Policy, Content Removal Policy, Creator & Monetisation Policy, Competition & Rewards Policy and Copyright / IP Policy, as applicable.