FLUTRR – PRIVACY POLICY

1.1 Information You Provide Directly

When you create or update an account on Flutrr, you provide:

• Name
• Mobile number
• Email ID
• Date of birth
• Gender
• Profile images
• Bio/About section
• Education, employment, and lifestyle details (optional)
• Passions, interests, and personal preferences
• Location information

This information helps create your public profile and enhances the matching experience.

1.2 Aadhaar Verification via DigiLocker

To enhance authenticity and trust on the platform, Flutrr now offers Aadhaar-based identity verification through DigiLocker. This step is required for accessing chat features.

Upon your explicit consent, we may receive the following non-sensitive demographic details from DigiLocker:

• Full Name
• Date of Birth / Year of Birth
• Gender
• Father's Name
• Address
• Aadhaar-linked Photograph

We do NOT receive or store:

• Aadhaar Number
• Virtual ID (VID)
• QR codes or metadata

The Aadhaar photograph may be compared with your uploaded profile image using secure facial-recognition tools hosted on AWS for identity validation.

1.3 Data Collected Automatically

When you use the Platform, we automatically collect:

• IP address, device details, OS, browser type
• Location data
• Log data (time stamps, app activity, page visits)
• Cookie data
• Mobile analytics (usage frequency, crash logs, performance metrics)

This helps improve user experience, ensure security, and diagnose issues.

1.4 Payment Information

When you subscribe to our services, the payment is processed through Google Play Billing and Razorpay (payment gateways) which stores your credit/debit card data. It is encrypted through the Payment Card Industry Data Security Standard (PCI-DSS). The payment gateways shall be responsible for the financial transactions on Flutrr, including accepting your payment, renewal process and refund (if applicable). In this context, they will be responsible for collecting relevant financial information from you. We encourage you to review the privacy policies of the third-party providers before you use the third-party software. For more insight, you may also want to read the below mentioned policies of Google Play Billing and Razorpay.

• https://payments.google.com/payments/apis-secure/get_legal_document?ldo=0&ldt=privacynotice&ldl=en-GB
• https://razorpay.com/privacy/

1.5 User-Generated Content

This includes:

• Photos
• Profile details
• Answers to questions
• Chat interactions
• Any information you voluntarily publish on the platform

You are solely responsible for ensuring your content complies with applicable laws.

1.6 Research & Surveys

We may use anonymized or aggregated information for:

• Improving matching algorithms
• Behavioural research
• Academic studies

All such data is non-identifiable.

2.1 Provide and Improve Services

• Account creation and management
• Profile recommendations
• Match discovery
• Chat and interaction features
• Showing compatible profiles
• Safety and fraud prevention

2.2 Aadhaar / DigiLocker Verification

Information received from DigiLocker is used to:

• Verify identity
• Prevent fake or duplicate accounts
• Ensure platform trust
• Conduct facial-recognition matching (Aadhaar photo vs. profile photo)

Data is used only for verification and not for any marketing or profiling purposes.

2.3 AI-Based Personalization & Natural Language Search

Flutrr uses AI to:

• Improve match relevance
• Process natural language profile searches (e.g., "profiles that enjoy trekking")
• Personalize content and profile recommendations
• Train and enhance algorithms

AI models may use:

• Profile images
• Interests, passions, and bios
• User behaviour signals

No sensitive personal data is used for AI training.

Users may withdraw consent by deleting their account.

2.4 Communication

We use your email/mobile number to:

• Send verification codes
• Inform you about matches
• Transaction confirmations
• Provide updates, offers, and newsletters
• Security alerts

You may opt-out of promotional communication at any time.

2.5 Compliance, Safety & Legal Obligations

We may use your data to:

• Prevent fraud, abuse, and suspicious activity
• Investigate violations of policies
• Comply with court orders, law enforcement, or regulatory requests

3.1 With Other Users

Information visible on your profile may be viewed by other users.

We never share your contact number with other users without your consent.

3.2 Service Providers

Flutrr may contain links to third-party websites over which we have no control. If you follow a link to any of these websites or submit information to them, your information will be governed by their policies. We encourage you to review the privacy policies of third-party websites before you submit information to them.

We may share information on aggregated or de-identified basis with third parties for research and analysis, profiling, and similar purposes to help us improve our products and services.

• mongoDb : https://www.mongodb.com/legal/privacy/privacy-policy
• redis: https://redis.io/legal/privacy-policy/
• Google API : https://policies.google.com/privacy
• OpenAI: https://openai.com/security-and-privacy/
• Expo: https://expo.dev/privacy
• Exotel: https://exotel.com/privacy-policy/
• AWS: https://aws.amazon.com/privacy/?nc1=f_pr
• Cashfree: https://www.cashfree.com/privacypolicy/
• Meta Graph API: https://www.facebook.com/privacy/policy/?entry_point=data_policy_redirect&entry=0

3.3 For Legal & Regulatory Reasons

User acknowledges and agrees that Flutrr may disclose information that the User provides if required to do so by law, at the written request of any government or regulatory authority , or if in Flutrr's sole discretion, believe that disclosure is reasonable for the following reasons:-

• To comply with the law, requests or orders from law enforcement, or any legal process (whether or not such disclosure is required by applicable law);
• If the data relates to -
• the sovereignty, integrity, or security of the state;
• a state's friendly relations with foreign states;
• public order;
• for preventing incitement to the commission of any cognisable offence relating to the above; or
• for investigation of any offence.
• protect or defend Flutrr's, or a third party's, rights or property;
• protect someone's health or safety, such as when harm or violence against any person is threatened; or
• for investigative purposes.

3.4 Business Transfers

In case of merger, acquisition, or transfer, your information may be transferred to the new entity with appropriate notice.

4.1 Security Measures

We implement robust technical and organizational measures:

• Encryption in transit and at rest
• Access controls and monitoring
• Secure facial recognition workflows
• Bi-annual security audits
• Log monitoring and incident response procedures

Despite best efforts, no system is 100% secure.

4.2 Data Retention

We retain your data only as long as:

• Required to provide services
• Necessary for legal or regulatory compliance
• Needed to resolve disputes or enforce policies

DigiLocker verification data is retained only for verification and safety purposes.

4.3 Account Deletion

Users can delete their Flutrr profiles anytime from the app settings. The User's information will be deleted from Flutrr databases within 15 days from account deletion.

However, this information may remain in archives even after deletion or termination of User account as required by law and the handling of the same is in accordance with the provisions of the applicable law and as intimated by the government agency from time to time.

Some data may be retained in backups or as required by law

Facial recognition records are deleted unless retention is mandated legally