PRIVACY POLICY

Last Revised: 21-05-2024

1. Who We Are

We are HeyyPal, the world's first dating app with audio, owned and operated by M/s DTW Squad Pvt. Ltd. available at B3/83, Basement. Safdarjung Enclave, New Delhi - 110029. HeyyPal is an online dating and interaction platform providing to its end users a host of features and services as set out in the “Terms of Use” availablehere.This Policy must be read in conjunction with the Terms of Use.

2. Our commitment to Privacy

At HeyyPal, we prioritize your privacy and appreciate that you repose your trust in us when you register with us or use our services by providing us with your information.

Being committed to your privacy, your privacy is at the core of the way we design and build the services and products you know and love, so that you can fully trust them and focus on building meaningful connections. We involve experts from various fields, including legal, security, engineering, product design and others to make sure that our decisions are taken with the utmost respect for your privacy. Our team is dedicated to keeping your data safe and secure. We constantly update our security practices and invest in our security efforts to enhance the safety of your information.

We appreciate that you trust us with your information and we intend to always keep that trust. This starts with making sure you understand the information we collect, why we collect it, how it is used and your choices regarding your information. This Policy describes our privacy practices in plain language, keeping legal and technical jargon to a minimum.

This Privacy Policy comes in effect from 01/04/2024.

3. Application of this Privacy Policy

This Privacy Policy applies to website(s), app(s), event(s) and/or other service(s) we operate under the “HeyyPal” brand names (collectively referred to as “services” for the sake of simplicity). The users of any of the services or any component or subset of any of the services (“user” or “users” or “you”) undertake to be bound by this Privacy Policy in toto, without exception.

By using the Service, you consent to submit your personally identifiable information as set out below, including sensitive personal data such as your financial data, if opted for our premium services; to collect, process, display and use the said information to provide the Services; and to be contacted by other Members/ users and us. If you have any objection in collecting/processing your personal data, we advise you not to register with or use our Site or the app.

If you want to withdraw this consent or if you have any objection in continuous collection or storage of your personal details, you must discontinue using our Service and delete your account by> Go to my profile > Privacy & Security > Click Delete Account, it will ask for re confirmation, click Yes Delete Account and your account will be deleted>as we shall not be able to provide you any Service without having your personally identifiable information.

4. Information We Collect

It goes without saying, we can’t help you develop meaningful connections without gathering some basic information about you, such as basic profile details. We also collect information about your use of our services such as access logs, as well as information from third parties, like when you access our services through your social media account.

You hereby provide your consent to collect, process, and share your personal information with other users/members in order to provide the services.

We gather three types of information while you are availing our services:

(i) Information submitted by you

You choose to give us certain information when using our services. This includes:

  1. Basic details pertaining to your profile such as your name, age, gender, location, email address, among others which are needed for the services to work.
  2. Precise geolocation data : If you give us your consent, we can collect your precise geolocation (latitude and longitude) from your device. The collection of your geolocation may occur in the background even when you aren’t using the services if the permission you gave us expressly permits such collection. If you decline permission for us to collect your precise geolocation, while certain services or features might be available, our services that rely on precise geolocation may not be available to you.
  3. Photo Verification data: You will need to grant us access to your camera to be able to click your picture for verification of your profile. By participating in our Photo Verification feature, you permit us to collect your face geometry data, which may be considered biometric data in some jurisdictions, to verify that you’re the real you.
  4. Your audio introduction profile which is recorded and uploaded/ added by you to your HeyyPal profile/account. To record your audio profile as well as to utilise the in-app (or app to app) call feature, you would be required to grant us access to your device microphone.
  5. You can also share additional information with us, such as details on your bio and your interests, as well as content such as photos and videos. To add certain content, like pictures or videos, you may allow us to access your camera or photo album.
  6. You can also invite your friends to the app by granting us access to your address book.
  7. Your chats and messages with other users as well as the content you publish may be processed as a part of the services.
  8. When you participate in surveys, focus groups or market studies conducted by us (if any), you give us your insights into our products and services, responses to our questions and testimonials.
  9. When you subscribe to a paid service, you provide us with information related to the purchases you make and our payment processors/ service providers/ gateways with the information such as your debit or credit card number or UPI and other financial information.
  10. Details/ data/ information/ insights shared by you with our customer care team. This information is used for monitoring, quality enhancement and/ or for training or research purposes.

Whenever you provide such data/ information to us, you consent to us using it for the purposes identified and as laid out in this Privacy Policy.

(ii) Information not directly submitted by you

In addition to the information you may provide us directly, we receive other information(s), including:

  1. User activity - We collect information generated while use of the services, such as date and time you logged in, logged-in/ active duration, features you’ve been using, searches, clicks and pages visited by you, purchases made (of gifts), payment preference options, profile interests, call duration, your interaction with other users (e.g., members you connect/ match and interact with including the messages exchanged with them).
  2. Device Information- We collect information from and about the device(s) such as IP address, device ID and type, device-specification and apps settings, app error reports, browser type and version, operating system, identifiers associated with cookies or other technologies that may uniquely identify your device or browser;
  3. Information collected by cookies and similar technologies : We use and may allow others to use cookies and similar technologies (e.g., web beacons, pixels, SDKs) to recognize you and/or your device(s). Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) have a “Do Not Track” (“DNT”) feature that tells a website that a user does not want to have his or her online activity tracked. If a website that responds to a DNT signal receives a DNT signal, the browser can block that website from collecting certain information about the browser’s user. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, many businesses, including ours, do not currently respond to DNT signals.

(iii) Information received from others

In addition to the information as discussed above, we receive information about you from others, such as:

  1. Social Media - When you login to your HeyyPal account by using your social media account (such as Google/ Facebook/ Instagram), you share some information from your social media account with us.
  2. Members: Members may provide information about you as they use our services, for instance as they interact with you or if they submit a report involving you.

5. How we collect information

  1. We collect information you provide to us when you request or purchase products, services, or information from us, register with us, participate in other activities on our sites and applications, respond to surveys (if any), or otherwise interact with us using one or more devices.
  2. We may collect information through a variety of technologies, such as cookies, Flash cookies, pixels, tags, software development kits, application program interfaces, and Web beacons, including when you visit our sites and applications.
  3. We collect information using analytics tools, including when you visit our sites and applications and use the services.

6. How We Use Information

The main reason we use your information is to deliver and improve our services. Additionally, we use your info to help keep you and our community safe, and to provide you with advertising that may be of interest to you. Read on for a more detailed explanation of the various reasons for which we use your information, together with practical examples.

A. To administer your account and provide our services to you

B. To help you connect with other users

C. To provide new HeyyPal services to you

D. To provide offers and operate advertising and marketing campaigns

E. To improve our services and develop new ones

F. To prevent, detect and fight fraud and other illegal or unauthorized activities

G. To ensure legal compliance

To process your information as described in this Privacy Policy, we rely on the following legal bases:

Provide our service to you: The reason we process your information for purposes A, B and C above is to perform the contract that you have with us. For instance, as you go about using our service to build meaningful connections, we use your information to maintain your account and your profile, make it viewable to other members and recommend other members to you and to otherwise provide our free and paid features to you and other members.

Legitimate interests: We process your information for purposes D, E and F above, based on our legitimate interest. For instance, we analyze users’ behavior on our services to continuously improve our offerings, we suggest offers we think might interest you and promote our own services, we process information to help keep our members safe and we process data where necessary to enforce our rights, assist law enforcement and enable us to defend ourselves in the event of a legal action.

Comply with applicable laws and regulations: We process your information for purpose G above where it is necessary for us to comply with applicable laws and regulations and evidence our compliance with applicable laws and regulations. For example, we retain traffic data and data about transactions in line with our accounting, tax and other statutory data retention obligations and to be able to respond to valid access requests from law enforcement. We also keep data evidencing consents members give us and decisions they may have taken to opt-out of a given feature or processing.

Consent: If you choose to provide us with information that may be considered “special” or “sensitive” in certain jurisdictions, such as your sexual orientation, you’re consenting to our processing of that information in accordance with this Privacy Policy. From time to time, we may ask for your consent to collect specific information such as your precise geo-location or use your information for certain specific reasons. In some cases, you may withdraw your consent by changing your settings (for instance in relation to the collection of your precise geolocation) or by deleting your content (for instance where you entered information in your profile that may be considered “special” or “sensitive”). In any case, you may withdraw your consent at any time by contacting us at the address provided at the end of this Privacy Policy.

7. How We Share Information

Since our goal is to help you make meaningful connections, the main sharing of members’ information is, of course, with other members. Read on for more details about how your information is shared with others.

With other members

With our service providers and partners

Sharing functionality

For corporate transactions

With law enforcement / when required by law

We may disclose your information if necessary:

To enforce legal rights

We may also share information:

With your consent or at your request

8. Cross-Border Data Transfers

While we are based in India and our app is currently meant and made live, for users in India, we may choose to extend our services beyond India in near future. We rely on highly reputed third parties/vendors/ partners for hosting and storage of site and app data including the user data/ information/ content. Such third parties/vendors/ partners have global existence and have their servers at several locations across the globe. Therefore, your information may be retained, processed and transferred to locations across the globe by such third parties/ vendors/ partners. All of our service providers and partners agree to abide by strict confidentiality obligations and data protection laws and policies.

9. Your Rights and Choices

We want you to be in control of your information, so we want to remind you of the following options and tools available to you:

In addition to aforesaid privacy control, depending upon the country of your residence, you may have the following rights:

Please note, however, we may need to retain certain information for record keeping purposes, to complete transactions or to comply with our legal obligations and applicable territorial laws.

If you wish to receive information relating to another user, such as a copy of any messages you received from him or her through our service, the other user will have to contact us and provide their written consent before the information is released. We may also ask them to provide proof of identity before we can answer the request.

You may have the right to withdraw your consent or to opt-out from sharing your information with our third party service providers from processing your information. Please note that withdrawing your consent or opting out means deletion of your profile as we won’t be able to provide service to you without your personally identifiable information such as your age.

Also, we may not be able to accommodate certain requests to object to the processing of personal information, notably where such requests would not allow us to provide our service to you anymore.

For your protection and the protection of all of our members, we may ask you to provide proof of identity before we can answer the above requests. Keep in mind, we may reject requests, including if we are unable to authenticate you, if the request is unlawful or invalid, or if it may infringe on trade secrets or intellectual property or the privacy or other rights of someone else

Additional Rights

California, USA

The residents of California USA, have the following additional rights:

Right to Know

You have the right to request that we disclose to you the categories of personal information we have collected about you, as well as the sources of such personal information, the purposes, and the categories of third parties with whom such personal information is shared.

Right to Access

You have the right to request, up to two times each year, access to categories and specific pieces of personal information about you that we collect, use, disclose, sell, and share.

Right to Delete

You have the right to request that we delete personal information that we collect from you, subject to applicable legal exceptions.

Right to Correct

You have the right to request that we correct inaccurate personal information that we maintain about you, subject to applicable legal exceptions.

Right to Opt Out of Sale or Sharing of Personal Information

You have the right to “opt out” of the “sale” or “sharing” of your “personal information” to or with “third parties” (as defined under applicable law(s)).

Removal of Content

If you are a California resident under the age of 18, and a registered user of any site where this policy is posted, California Business and Professions Code Section 22581 permits you to request and obtain removal of content or information you have publicly posted.

Shine the Light

California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information by us to third parties for the third parties’ direct marketing purposes.

Right Not to Receive Discriminatory Treatment

You have the right not to receive discriminatory treatment for the exercise of your privacy rights. If you choose to exercise any of these rights, you will not receive different prices or quality of services unless permitted by applicable law, including if those differences are reasonably related to your information. For example, if you exercise your right to opt out of “sale” or “sharing” of your ”personal information,” the ads you view may not be tailored to your interests.

Exercising your California Privacy Rights

To make a request to know or to make an access, deletion, correction or other request as indicated above, please visit admin@dtws.in OR the

Connecticut, Virginia & Colorado, USA

The residents of Connecticut, Virginia & Colorado, USA are conferred with the following additional rights:

Right to Access

You have the right to know and see what personal data we have collected about you in a usable format.

Right to Delete

You have the right to request that we delete the personal data we have collected about you, subject to applicable legal exceptions.

Right to Correct

You have the right to request that we correct inaccurate personal data.

Right to Opt Out of Targeted Advertising and Sale of Personal Data

You have the right to “opt out ” of “targeted advertising” and the “sale” of your “personal data” (as defined under the applicable law).

Exercising your Connecticut, Virginia and Colorado Privacy Rights

To make a request to know or to make an access, deletion, correction or other request as indicated above, please visitadmin@dtws.in OR

Utah, USA

Utah law provides Utah residents with the rights listed below:

Right to Access

You have the right to know and see what personal data we have collected about you in a usable format.

Right to Delete

You have the right to request that we delete the personal data we have collected about you, subject to applicable legal exceptions.

Right to Opt Out of Targeted Advertising

You have the right to “opt out” of “targeted advertising” (as defined under Utah law). We do not “sell” personal data as defined under Utah law.

Exercising your Utah Privacy rights

To make a request to know or to make an access, deletion, correction or other request as indicated above, please visitadmin@dtws.in OR

Please note that before completing any of the aforesaid request, we may need to verify your identity. Further, please note that we do not “sell” your personal data.

EU & UK

In certain countries, including in the EU and the UK, you have a right to lodge a complaint with the appropriate data protection authority if you have concerns about how we process your personal information. You can find information about your data protection regulator in the European Economic Area here, and in the United Kingdom here. The data protection authority you can lodge a complaint with, may be that of your habitual residence, where you work or where an alleged infringement took place.

You can contact our EU Representative/ DPO for EU & UK atadmin@dtws.in

10. Date Security, Integrity & Retention

The security, integrity, and confidentiality of your information are extremely important to us. We have implemented technical, administrative, and physical security measures that are designed to protect user information from unauthorized access, disclosure, use, and modification. We regularly review our security procedures to consider appropriate new technology and methods. Please be aware that, despite our best efforts, no security measures are perfect or impenetrable. We will retain your personal information for the length of time needed to fulfill the purposes outlined in this privacy policy unless a longer retention period is required or permitted by law.

11. How Long We Retain Your Information

We keep your personal information only as long as we need it for legitimate business purposes and as permitted by applicable law. If you decide to stop using our services, you can close your account and your profile will stop being visible to other members. After your account is closed, we will delete your personal information, as laid out below:

  1. We maintain limited data to comply with legal data retention obligations: in particular, we keep transaction data for ten years to comply with tax and accounting legal requirements, credit card information for the duration the user may challenge the transaction and “traffic data” / logs for one year to comply with legal data retention obligations. We also keep records of consent(s) members give us for five years to evidence our compliance with applicable law.
  2. We maintain limited information on the basis of our legitimate interest: we keep customer care records and supporting data as well as imprecise location of download/purchase for five years to support our customer care decisions, enforce our rights and enable us to defend ourselves in the event of a claim; information on the existence of past accounts and subscriptions, which we delete three years after the closure of your last account to ensure proper and accurate financial forecasting and reporting; profile data for three years in anticipation of potential litigation, for the establishment, exercise or defence of legal claims, and data necessary to prevent members who were banned from opening a new account, for as long as necessary to ensure the safety and vital interests of our members.
  3. Finally, we maintain information on the basis of our legitimate interest where there is an outstanding or potential issue, claim or dispute requiring us to keep information [in particular if we receive a valid legal subpoena or request asking us to preserve data (in which case we would need to keep the data to comply with our legal obligations) or if data would otherwise be necessary as part of legal proceedings].

12. Competence

To register as a Member of HeyyPal or use this Site, you must be legally competent. The Services are available only to individuals who:

  1. are at least 18 years old, however, if a law requires that you must be older in order for HeyyPal to lawfully provide the Services to you (including the collection, storage, and use of your information) or for you to receive the services offered by HeyyPal, then the minimum age is such older age; and
  2. possess the legal capacity to accept the Terms of Use and this Privacy Policy and to form a binding agreement under any applicable law.

HeyyPal is only an intermediary facilitating personal advertisement for potential matchmaking, dating and interaction between persons who are legally competent to use the site and app and to utilise the services. By using the site and app, you represent and warrant that you have the right, consent, authority, and legal capacity to enter into this Agreement; submit relevant information to us; and that you are not prohibited or prevented by any applicable law for the time being in force or any order or decree or injunction from any court, tribunal or any such competent authority restraining you, in any manner, from the use of the site and app or utilise any of the services.

Further, if you suspect that a member is under the age of 18, please use the reporting mechanism available on the service.< Click on the Profile details Go to the profile top right hand corner > Click on Report within the drop down > Click OK on the pop-up appearing on your screen seeking confirmation from you on “Are you sure you want to report this person?” > The Profile will be successfully reported to the Admins >

13. Changes to Privacy Policy

From time to time, we may change this privacy policy to accommodate new technologies, industry practices, regulatory requirements or for other purposes. We reserve the right, at our discretion, to make changes to this privacy policy at any time. We may do this for a variety of reasons including to promote safe practices, to accommodate new technologies, industry practices, regulatory requirements or for other purposes. The most updated version is available on our app and website with the date of last revision. Users are requested to keep themselves updated with the periodical changes brought about in the policy. We will provide notice to you if these changes are material and, where required by applicable law, we will obtain your consent. Notice may be by email to you at the email address you provided to us, by posting notice of such changes on our sites and applications, or by other means, consistent with applicable law. Such material changes will take effect after a reasonable period of seven (7) days from the date of effecting such revision. All other changes (non-material) to this policy are effective w.e.f. the "Last Revised" date reflected on the policy and your continued use of the Site and/or the Service on or after the Last Revised date will constitute acceptance of, and agreement to be bound by, those changes. In the event that the policy is to be amended to comply with any legal requirement, the amendments may take effect immediately, or as required by the law and without any prior notice.

14. How to Contact Us

For addressing any concern or grievance pertaining to this Privacy Policy, you may contact us at:

Online- admin@dtws.in

Offline- B3/83, Basement. Safdarjung Enclave, New Delhi - 110029