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Batchmates Privacy Policy

Effective date: 01 June 2025

1. INTRODUCTION

This Privacy Policy (“Privacy Policy”) describes the types of data that BATCHMATES , as the Platform’s operator and as the Platform’s owner, may collect from a user (“You”, “Your”, or “User”) on or through Our website (batchmates-app.com)  (the “Site”) or one or more mobile applications (the “Batchmates”) (collectively  “Platform”), either directly (the Platform’s owner and operator are collectively referred to  as “We”/ “Us”/ ”Our”) or in connection with other services rendered by Us, (each a  “Service”, and collectively the “Services”), and how We use, process, disclose and try to protect such data. You acknowledge and agree that the Company is  responsible for the Platform’s operation and maintenance, and that any data collected and processed on the Platform is gathered and used only for the purposes of Our operations. 

 

By accessing or using Our Platform or Services, You acknowledge that You have read, comprehended and agreed to the privacy policies contained in this Privacy  Policy (and to the collection, storage and processing of Your data in accordance with them).  

 

This Privacy Policy is in compliance with the following Laws and Regulations:  

 

Digital Data Protection Act, 2023 (“DPDP Act”) 

 

Regulation 3(1) of the Information Technology (Intermediaries Guidelines and Digital  Media Ethics Code) Rules, 2021 (“Intermediaries Guidelines”);

 

Section 43A and Section 72A of the Information Technology Act, 2000 (“IT Act”); and  Rule 4 of the Information Technology (Reasonable

 

Security Practices and Procedures  and Sensitive Personal Information) Rules, 2011 (“SPDI Rules”).

 

Capitalised terms not defined here, including the terms Personal Data, shall have the  meaning stated in the Digital Data Protection Act, 2023, whose full text can be found at this link. 

 

In compliance with section 5 of the DPDP Act, this policy acts as a notice on collection  of your Personal Data and the purpose of its collection (clause 1 below); the manner in  which rights under section 6(4) & 13 and may be exercised (clause 6 below); and, the  manner in which you may make a complaint to the Board. As soon as practicable, and  by means that we deem appropriate, we may inform you of the same from time to time.

2. GENERAL TERMS

By using this Platform or Service or providing Us with Your data in any other way, You confirm that You have the legal capacity to enter into a legally binding contract under Indian law, specifically the Indian Contract Act, 1872 as set out in our [Terms of Use], and that You have read, understood, and agreed to the practises and policies outlined in this Privacy Policy and agree to abide by them. 

 

If You access or use Services on the Platform from an overseas location, You (or Your Guardian, as the case may be) are entirely responsible for compliance with any local laws. You consent to the collection, use, sharing, and disclosure of Your data in accordance with this Privacy Policy. We retain the right, in Our sole discretion, to alter, modify, add, or delete elements of this Privacy Policy at any time, and your continuing use of the App, Services, or Platform after any such amendments will be regarded as an implicit acceptance of the Privacy Policy in its revised form. You should review the Privacy Policy on a regular basis to ensure that you are informed of any modifications or updates to the policy's terms. We may also send you notifications of any significant changes to our Privacy Policy or on how we collect and handle private information. If you do not agree to any of the terms and conditions included in this Privacy Policy, please do not use this Platform, or any Services. This Privacy Policy is subject to change without notice at any time. Please check this policy on this Platform on a frequent basis to ensure that You are aware of any changes.  

3. YOUR CONSENT

By accessing our Platform and filling out our onboarding forms or clicking on any notification, SMS or other messages or by supplying your information by yourself, you agree to the collection, use, storage, disclosure, and other processing of your Personal Data on the Platform in accordance with the terms of this Privacy Policy. If you submit Personal Information about other persons, you confirm that you have the permission to do so and that you agree to let us use the information in accordance with our Privacy Policy. We may reject any submission made by you at any time without assigning any reason. You consent to us (including our affiliates and other third parties) contacting you through SMS, instant messaging apps, phone call, and/or e-mail for the reasons indicated in this Privacy Policy by giving your Personal Information on the Platform or any connected platforms or institutions.

4. DATA HANDLING

In order to provide you our Services we require you to provide contact information of friends, acquaintances and other persons that you may be interested in engaging with. By using our services you explicitly consent to providing us such contact information that is in your possession and are authorising us to contact such friends, acquaintances and other persons in order to invite them to use our Services. Due to the nature of our Services, please be aware that You may give or We may collect information that can specifically identify You or any other individual when you browse the Platform or use the Service(s). 

 

We may also collect Sensitive Personal Data or Information as defined under SPDI Rules about You when You use Our Service(s) on the Platform. This data includes Personal Information We receive from You or, on Your behalf, such as data or records relating to the Services availed by You through the Platform, phone number; name, school or college that you attend, access to your phone contact list (including all data saved in the contact list) and any other data inferred therefrom. 

 

We may also collect payment information such as Your payment card number, expiration date, other bank details, billing and shipping address, Your wallet information or Your UPI information as such. By using the Service, You consent to the recording, storage, and disclosure of such communications You send or receive for these purposes. 

 

The list of Information that is identified to be Sensitive Personal Data or Information under SPDI Rules includes the following: 

 

Password;

 

Financial information such as Bank account or credit card or debit card or other payment instrument details;

 

Physical, physiological and mental health condition; Gender /Sexual orientation;

 

Medical records and history;

 

Biometric information;

 

Any detail relating to the above clauses as provided to body corporate for providing service; and

 

Any of the information received under above clauses by body corporate for processing, stored or processed under lawful contract or otherwise.

 

The categories of information that We may gather are listed below:

 

Data that You provide:
Any Data You provide on Our Platform or send or furnish to Us about yourself or any one else in any other manner is received and stored by Us. We gather registration information such as your phone number, complete name, gender, your school/college details including class details, and email address (as and when collected) when you register on the Platform. We use a one-time password issued to Your phone number to validate Your phone number. 

 

We also collect and store contact information that You voluntarily provide to us in order to connect with other people who you want to invite for our Services. We may also collect data from your address book / contacts if you give us such access. We use this data to market our offers, promotions, invitations to join our Platform or any such services to the contacts in your address book or to the contacts that you explicitly provide to us. 

 

Data that we collect:
We collect data while you use the Platform and which are required for providing You Services on the Platform including but not limited to the Platform and features you use, and what actions you take in them and other subscription plans, types of content you view or interact with, and how you interact with and the like. In the event you choose to upload a profile picture / photo, do note that the same can be viewed by others. You can choose not to provide certain information including the profile pictures / photo, but You will not have access to the full extent of the features available on our Platform. This can include information in or about the content that you provide (e.g. metadata), such as the location of a picture / photo or the date a file was created. Our systems automatically process content and communications that you and others provide to analyze context and what’s in them for the purposes described below. 

 

We may obtain information about You from other sources, such as Our partners, advertisers, or third parties registered on the Platform, and add it to Our account data. 

 

We may collect data you allow us to receive through device settings that you turn on, such as access to your camera or photo information such as the operating system, hardware and software versions information about operations and behaviours performed on the device, such as whether a window is in the foreground or background, 

 

If you use our Products for purchases or other financial transactions (such as when you make a purchase in a game or make a donation), we collect information about the purchase or transaction. This includes payment information, such as your credit or debit card number and other card information, other account and authentication information, and billing, delivery and contact details. 

 

We also receive and analyze content, communications and data that other people provide when they use our Products. This can include data about You, such as when others share or comment on a photo of you, send a message to you or upload, sync or import your contact information. 

 

Such data may include content you post on the Platform (text, images, graphics, audio, visuals, etc.); Users you follow; Users who follow you on Application; Users who have visited your profile and vice versa; Information on your browser’s user agent string and server logs, including your IP address, information in the cookies and activity on the Application; URL information, time stamp, visit information, your browsing history on the Application; Device information, such as make, model and operating system of the device used for browsing the Application; Date of download and/or reinstall of the App; Events related to your actions (follows, reactions, time spent, etc); Users who send you chat requests and have chatted with you; Locational information as permitted by you etc. 

 

Third Party Tracking Technologies:
“Cookies” and other tracking technologies are used by us. A “cookie” is a little text file that is used to gather information about activities on the Site or the App, for example. Some cookies and other technologies may be used to retrieve information that a User has already indicated or provided. Most browsers and mobile device settings allow You to manage cookies, including whether or not to accept them and how to delete them. Most browsers/mobile apps allow you to be notified when a cookie is received, or you may opt to ban cookies using your browser/mobile applications. 

 

Tracking technologies may collect data such as internet domain and host names, IP addresses, browser software and operating system kinds, stream patterns, and the dates and times that Our Platform is viewed. We use cookies and other tracking technologies to enhance Our Platform, as well as Your experience. 

 

You may refuse all cookies on Your browser or the App at any time by adjusting Your settings to the extent permitted on Your device. However, by doing so, You may be unable to access some Platform features or fully benefit from all products and preference-based advertising. You may delete cookies by following the instructions in your mobile device’s “help” file or the browser.

 

Our App makes use of third-party Software Development Kits (SDKs). The majority of them are various payment methods via which You may pay for an order. To improve Your personal and overall experience, some tools are included. 

 

When You engage with Us, we receive and retain certain sorts of information. For example, when Your web browser visits the Platform or advertising and other content offered by or on behalf of the Platform on other web sites, We collect certain kinds of information. Additionally, we may receive/store information on Your mobile device, such as a unique device identifier. We may analyse this data internally and use it to offer You with location based services such as advertising, search results, and other tailored content. 

 

The IT Act and the SPDI Rules govern the collection, use, retention, and disclosure of personal information, which is defined by the SPDI Rules as any information relating to a natural person that, when combined with other information available or likely to be available to a body corporate, is capable of identifying such a person. 

 

You acknowledge that You are freely submitting all information, including SPDI, to Us. Your affirmative consent is required for the collection, use, and dissemination of personal information and SPDI. You are giving Us permission to use, collect, and disclose your personal information and SPDI. 

 

Important: You may opt not to supply Us with personal information and SPDI; but, if You do, We will be unable to provide You with access to Our Platform, or to offer items or provide Services through Our Platform.

6. USAGE OF YOUR DATA

To fulfil Our duties in connection with Your requests for goods and services via the Platform; 

 

To run and maintain the Platform in order to enhance the user experience and the overall health of Our company;  

 

For the purpose of processing and delivering Your purchase with Us; 

 

To give You with access to Our Platform in order to buy items and services; 

 

Data analysis, trend monitoring, algorithm development, and database creation for rating systems, recommendation engines, and similar applications;

 

We use the information You give to react to Your requests, to Your requests, improve Our Platform, and communicate with You.

 

For goals other than targeting, such as frequency limiting, compliance,  payment,  ad reporting or delivery, market research, or product development; 

 

To adhere to all relevant laws; 

 

To carry out audits and quality control processes;  To analyse how Our resources are being used, fix issues, and improve Our Products  and Services, by using information about Your mobile device and software.  Contacting users throughout and after a purchase to provide updates, resolve  customer service issues, confirm order information, or promote new items or  services;  To investigate, prevent, or take action regarding unlawful activity, suspected fraud,  circumstances posing a danger to any person’s safety, breaches of the provisions of  this Privacy Policy, or as otherwise required by law;  To respond to any inquiries You may have and to communicate information to You, such as notifications of any promotions or alerts, changes/updates to the Site, or the  introduction of any future fees or charges that We may collect from You in connection  with the purchase of products or provision of Our Services; or  To contact You from time to time by SMS, email, and phone calls to solicit Your useful  comments on Our goods and services as they presently exist and/or any future  products and services that may be provided.  We may use “cookies” information and “automatically collected” information We  collect on the Platform to do the following:  Personalize the Services that We provide by remembering Your information so that  You do not have to enter it again during Your visit or the next time You use the  Service;  Monitor and assess the success of the Service and third-party marketing initiatives;  Keep track of aggregate site use metrics like total number of visitors and pages viewed;  and  Maintain a record of your entries, contributions, and status in any promotions or  other activity on the Service.  We may access or keep Your information if it is required to identify, prevent, or resolve  fraud and other criminal behavior, or to protect the Platform’s or others’ safety,  property, or rights .  We may use information regarding Your location or the location of Your device  through which You access the Service for a number of purposes, including without  limitation to confirm You are located in a jurisdiction in which the Service is offered  and to identify an appropriate delivery partner for conducting the Service effectively.  We may collect, analyze, utilize, publish and produce de-identified information, which  may include Your personal or sensitive personal information, for any business or other  purpose permissible under applicable law, including research and marketing.  (collectively referred to as “Purposes”).

7. USER RIGHTS

We want to ensure that you are fully empowered on our platform and are completely aware of the rights that you are entitled to in the course of using our platform. In accordance with sections 11, 12,13 & 14 of the DPDP Act, You have a number of rights in relation to the information we hold about you and We are fully committed to provide you the best and reasonably practicable means of exercising these rights.

 

Access – The right to access the information we hold about you, and to obtain details of the processing. You also have the right to access a list of all the third parties that have your Personal Information through us.

 

Correction – The right to seek, correct, update and modify the information available with us, to ensure accuracy.

 

Erasure – The right to seek to cancel or erase, free of charge, your personal data when it is inadequate, excessive, or unnecessary. This shall be subject to lawful processing measures and any legal prescriptions.

 

Objection – The right to withdraw your consent to our continued processing of the information, at any point of time, subject only to any legitimate reason for continued processing in certain circumstances.

 

Nomination – The right to nominate an individual who shall in the event of Your death or incapacity exercise Your rights in accordance with the provisions of the DPDP Act.

 

Grievance Redressal – You may report any act or omission in exercise of your rights using our Grievance Form or by writing to us or by such means as may be prescribed by law. 

 

You may exercise any of these rights by filling out the Grievance Form –. This shall be subject to the legal requirements, and our internal procedure. 

 

The Platform provides You with access to a wide range of information regarding Your account and Your activities with the Platform solely for the purpose of seeing and, in certain situations, amending or deleting information supplied on the App or the Site. You have the ability to opt-out of optional services as well, and if you want to opt-in to such services when you join up, you can do so. The Platform provides You with access to a wide range of information regarding Your account and Your activities with the Platform solely for the purpose of seeing and, in certain situations, amending or deleting information supplied on the App or the Site. You have the ability to opt-out of optional services as well, and if you want to opt-in to such services when you join up, you can do so. 

8. WHAT ARE OUR DATA SECURITY PRACTICES?

We implement appropriate technical and organisational security measures to ensure that your personal data is protected to a level commensurate with the risk, taking into account state-of-the-art technologies, implementation costs, the nature, scope, context, and purposes of processing, as well as the likelihood and degree of risk. Personal data is generally transferred encrypted between your end device and us. Third-party access cannot be ruled out if you connect with us by email or through internet service providers or broadband connections. All Personal Information is encrypted in motion and in storage.

We implement appropriate technical and organisational security measures to ensure that your personal data is protected to a level commensurate with the risk, taking into account state-of-the-art technologies, implementation costs, the nature, scope, context, and purposes of processing, as well as the likelihood and degree of risk. Personal data is generally transferred encrypted between your end device and us. Third-party access cannot be ruled out if you connect with us by email or through internet service providers or broadband connections. All Personal Information is encrypted in motion and in storage.

9. HOW SECURE IS THE INFORMATION THAT YOU PROVIDE?

In connection with the collection, storage, and disclosure of personal information, we maintain adequate technological, physical, and procedural measures (including SPDI). Due to our security processes, We may occasionally seek verification of identification before disclosing personal information to You. 

 

We limit access to personal information to Our employees and agents who need to know that information to process it for Us and who are subject to strict contractual confidentiality obligations and may be disciplined or have their relationship with Us terminated if they fail to meet these obligations. 

 

No employee or administrator will have access to Your password or Your account information on the Site or the App. It is critical that You safeguard Your account from unauthorized access to Your password and mobile phone, as specified in the Site/’User App’s Account, Password, and Security’ section. You must remember to log out of the Site or the App once you have done using it. We accept no responsibility for any unauthorized use of Your account or password. If You suspect any unauthorized use of Your account, You must tell Us immediately by sending an email to the contact information listed in the contact section. You agree to compensate Us for any losses incurred as a result of such unauthorized use of Your account or password. 

 

We will not be able to obtain Your prior consent before disclosing Your information in certain circumstances, including but not limited to information demanded by government agencies or otherwise mandated by law to obtain SPDI, or during investigations of cyber incidents, prosecution of offences, or any other requirement deemed necessary by the Company.

 

Furthermore, We shall not be liable for any breach of security or for any third-party actions or events beyond Our reasonable control, including but not limited to acts of government, computer hacking, unauthorized access to computer data and storage devices, computer crashes, breach of security and encryption, poor quality of internet service or telephone service provided by the User etc.

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10. IF YOU ARE A MINOR

The Platform is accessible exclusively to those who are legally capable of entering into a legally binding contract under the Indian Contract Act, 1872. We implement security measures, including processing Personal Information provided by you, to verify your age. We will restrict Your access to the Platform if you are a Minor and have not provided consent from your lawful guardian under section 9 of the DPDP Act. We shall implement such measures as prescribed by the DPDP Act for the purposes of confirming whether you are a minor and on such confirmation seeking the consent of your parent or legal guardian. If You are a parent or guardian and discover that Your child under the age of 18 has created an account on the Service or has accessed it in any other way without your permission, You may contact Us {{contact email}} and request that We delete that minor’s Personal Information information from Our systems.

11. INFORMATION RETENTION AND PURGE

In relation to SPDI Personal Information, we store them for certain predetermined periods on the basis of Statutory and legal requirements (especially the Intermediary Rules, 2021) industry guidelines, De-identified or pseudonymised data sets to be used in an aggregated format for scientific, statistical or historical purposes. 

 

We will delete your information whenever you request us to do so. However, we may archive and/or retain some information for legal purposes. Any other information which is processed by us for analytical purposes, will only be processed in an aggregated or non identifiable basis.

 

Additionally, We have safeguards in place to ensure that Your SPDI is deleted and/or anonymized as soon as it is reasonable to anticipate that: 

 

The reasons for collecting Your SPDI have been met; and 

 

Retention is no longer required by law or for any other reason. 

 

We reserve the right, however, to preserve and maintain Your personal information for Our business reasons, regardless of whether such information has been erased. Your data may be anonymized and aggregated after a period of time and then retained by Us for as long as required to allow the purchase of items and provision of Services, or for analytics purposes. 

 

If You wish to revoke Your consent to the processing of Your personal information and SPDI, cancel Your account, or request that We stop using Your personal information and SPDI to deliver Our products or provide You with services, please contact Us using the contact information provided in the contact section. Please keep in mind, however, that withdrawing permission or cancelling your account may result in Our inability to supply goods or offer services to You, or in the termination of any existing relationship We may have with You. 

 

Please note that uninstalling the App WILL NOT result in deletion of Your personal information or SPDI.

12. CHANGES TO YOUR INFORMATION

By logging into Your account, You may check, correct, update, and modify the information You’ve given. You are not, however, entitled to erase any portion of your personal information or other information created on the Platform. You may request that We erase the information. You may amend Your information at any time by writing to Us at the contact information shown below. 

 

If You choose to update or modify Your personal information or SPDI in a way that is not verifiable by Us or results in such information being incorrect, We will be unable to provide You with access to Our Site, App, or the Services, as described in the terms of this Privacy Policy, and such modification may be interpreted as the User requesting to discontinue access to Our Site, App, or the Services. 

 

We have the right to verify and validate Your identity and personal information to guarantee that goods and services are delivered accurately. We may deny or restrict access to, or correction, update, or deletion of, Your personal information or SPDI if doing so would violate the rights of another person and/or is not otherwise authorised by applicable law. 

13. NOTICES

If You have any concerns or complaints regarding the Site or the App, please contact Us with a detailed explanation and We will attempt to address the matter for You. You may submit your request using this Grievance Form –(link to form ). If You have any concerns or questions in relation to this Privacy Policy, You may also address them to Our grievance officer at: 

 

Name: Purshottam Singh 

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Address: {{address}}

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Phone: {{phone no}}

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E-mail: {{grievance email}}

 

We shall endeavor to resolve Your grievances within 1 (one) month from the date of receipt of such grievances. 

14. MISCELLANEOUS

You agree and undertake to compensate Us in the event of any third-party claim or dispute arising out of Your disclosure of information to third parties, whether via Our Platform or elsewhere, and Your use and access to third-party websites, apps, and resources. We disclaim any duty for third-party activities involving Your personal information or SPDI that You may have supplied to such third parties. 

 

Unless otherwise specifically stated or implied by the context of this Privacy Policy, each clause of this Privacy Policy will be and remain distinct from, independent of, and severable from, all other provisions hereof. The determination or declaration of nullity or voidance of one or more sections shall have no impact on the other provisions of this Privacy Policy. 

 

We cannot guarantee that Your personal information and SPDI will never be disclosed in methods not explicitly stated in this Privacy Policy. As a result, although We are dedicated to safeguarding Your privacy, We cannot guarantee that Your information or private conversations will always stay private, and You should not anticipate that they will. As a User of the Site or the App, You acknowledge and accept that You are solely responsible and liable for Your use of the Site or the App, the internet in general, and the information You post or access, as well as for Your behavior on and off the Site or the App.

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