(Last updated on Nov 2022)
- This Policy describes (i) the types of information we may collect when you install, subscribe to, access, and/or use the features of ROPOSO Platform; (ii) the types of information we may collect or that you may provide when any advertisement or survey campaign is displayed by Company on ROPOSO Platform or as part of your interaction with any advertisement services provided by Company or its’ Group, the information collected pursuant to any in-app purchases or transactions made by you;; (iii) how we use that information, and the purposes for which we collect it; and (iv) how we disclose such information.
“Group” as used in this policy, means, with respect to Company its affiliates and group entities listed here
- As used in this Policy, “ROPOSO Platform” means and refers to Company’s proprietary (application/ site or as made available in any other format) called ‘Roposo’ and which, amongst other things, enables end-users to explore, discover, watch, upload and share videos and other content including user generated content covering interesting stories, homemade videos, events, talent contests, games, etc. ROPOSO Platform also enables Ad Partners (defined below) to display advertisements, promotional offers and is a distribution platform for content creators, which facilitates commerce including marketing, selling and purchasing of products (powered by marketing platforms).
- This Policy applies only to information we obtain from you through the ROPOSO Platform. It does not apply to information that we may obtain from sources other than ROPOSO Platform who provide your information based on their privacy policies and your interaction with their offerings. ROPOSO Platform may also be permitted to collect certain information about you from the websites, applications, channels, services or landing pages (“Sites”) you access through ROPOSO Platform by the provider/owner of such Sites, in which case, we will treat such information in accordance with the privacy policies of such Sites in addition to this Policy, subject to the terms of the former. This Policy does not apply to websites or landing pages you may access through the ROPOSO Platform or your direct interaction with any third party including an advertiser even if you engage with any specific advertisement through the ROPOSO Platform, nor does it apply to information that you provide to or that is collected by any third party. We encourage you to read any such third-party terms, conditions, policies, notices etc. before providing information on or to such third parties including Sites.
We collect information from and about users of our ROPOSO Platform as stated herein.
- Information you provide to us with prompts
- If you elect to install, launch, access and/or use the ROPOSO Platform, we will ask you to provide certain information to create your account such as name, telephone number, age, gender. You may also provide the ROPOSO Platform with additional information such as content/category preferences, location, areas of interest, language, region preferences etc. in order to customize the experience for you.
- To facilitate fulfilment of orders for products placed by You through the Roposo Platform you may be asked to provide the required delivery address at the time of check-out. To facilitate refunds in case of returns, you may also be asked to provide bank account information.
- By providing the account registration data, You also consent and agree to Company’s and/or its service providers use of the same to contact You (including via calls, SMS, e-mail, WhatsApp, Telegram or other such means of business communications) for the purposes set out hereunder.
- Where you elect to engage with any games through the ROPOSO Platform, you may participate in certain reward-based programs. We urge you to refer the terms and conditions of such participation and the respective policies of any reward partners.
- ROPOSO Platform is meant for general audience and is not targeted towards users below 13 years of age, therefore, we do not knowingly request access to, collect or process personal information of any such user.
- Other Information we collect without prompts
When you access, and use the ROPOSO Platform including when you view any advertisement displayed there, the ROPOSO Platform may collect:
- ROPOSO Platform usage details. Details of your access to and use of the ROPOSO Platform, including interaction data, logs of access and usage, and other performance data and the resources that you access and use on or through the ROPOSO Platform, stories/videos/content you read, view, watch, interact with.
- Device Information. We may collect information about or on your device such as the online device identifiers, advertising identifiers, device make, IP Address, display features, operating system make, browser type, network/wifi the content type of the ad (what the ad is about, e.g. games, entertainment, news); (ii) the ad type (e.g. whether the ad is a text, image, or video based ad); (iii) where the ad is being served (e.g. the address of the site on which the ad appears); and (iv) certain information about post-click activity in relation to the ad including user interaction with such ad or other non-personal data/information.
- Location Information: The ROPOSO Platform collects information about the location of your smart device if you permit. You can choose whether or not to allow the ROPOSO Platform to collect information about your device's location by turning off the location settings on your device. If you block the use of location information, some parts of the ROPOSO Platform may then be inaccessible or not function properly. ROPOSO Platform may read your location on city level from your cellular network to enhance your experience and the content we serve you. This city level location data is solely used by our recommendation engine to serve you content.
- Third party data: This is information provided by our partners. The information provided in these cases follow the respective privacy policies of such third parties. In the context of advertising displayed on ROPOSO Platform, the Group (in their capacity as advertising partners), ad networks, advertisers or such other third-party demand partners (collectively “Ad Partners”) may also disclose to us certain personal or non-personal information they have separately collected about you so that we can effectively provide our services. They do this in accordance with their own specific privacy policies and subject to their own applicable legal requirements and, we will treat such information in accordance with the privacy policies of such Ad Partners in addition to this Policy, subject to the terms of the former. We do not use the information they provide to us for any purpose other than for providing or improving our services.
- Tracking Technologies
- Cookies or pixels (or mobile cookies/pixels). A cookie is a small file placed on your smart device. It may be possible to refuse/accept cookies by activating the appropriate setting on your smart device. However, if you select this setting you may be unable to access certain features of the ROPOSO Platform.
- Beacons. Pages of the ROPOSO Platform may contain small files known as beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permits Company to improve its services, for example, recording the popularity of certain application content, verifying system and server integrity.
- Third-Party Information Collection: When you use the ROPOSO Platform or its content, You may be provided third party information and links to other platforms that are not part of the Group. Certain third parties may use automatic information collection technologies to collect information about you or your device. These third parties may include Ad Partners, ad servers, attribution partners and analytics companies, payment gateways or social networking platforms, your device manufacturer and/or your network service provider etc.
- These third parties may use tracking technologies to collect information about you, your device and your interaction when you use the ROPOSO Platform. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites, apps, and other online services. They may use this information to provide you with interest-based (behavioural) advertising or other targeted content. While we contractually require all our partners to comply with applicable privacy laws, please note that we do not control these third parties’ tracking technologies.
- We do not directly process any payments and do not store your debit/credit card or any other financial information. Secured socket layer technology is used for processing payment transactions with third party service provider partners. After the User is directed to the payment mechanism and the payment gateway, the Company is not liable for any data stored, used or accessed by such a third-party service provider.
- Company is not responsible for any form of transmission, whatsoever, received by You from any third-party platform and accordingly does not make any representations concerning the privacy practices or other policies of such third party platforms. Under no circumstances shall Company be deemed to control or guarantee the accuracy, integrity, or quality of the information, data, text, software, sound, photographs, graphics, videos, cookies, messages or other materials available on such platforms. Any information provided by You to such third-party platforms shall be governed in accordance with the privacy policies and requirements pursuant to laws applicable to such platforms for such services. It is recommended that You review the policies and terms of such platforms prior to using such platforms.
- Information about advertisements presented on your the ROPOSO Platform: Company also collects some or all of the following information about an ad presented on your device: (i) the content type of the ad (what the ad is about, e.g. games, entertainment, news); (ii) the ad type (e.g. whether the ad is a text, image, or video based ad); (iii) where the ad is being served (e.g. the address of the site on which the ad appears); and (iv) certain information about post-click activity in relation to the ad including user interaction with such ad.
- Information provided through surveys displayed on the ROPOSO Platform
- ROPOSO Platform may display certain marketing surveys or surveys related applications to you where you are requested to fill in a survey, at your election, for services or products that you use or request to provide your opinion regarding certain products or services
- Some of the data sets mentioned in section 2 (A), (B), and (C) may be considered to be personal information/data, as per privacy laws in certain jurisdictions. Where you elect to provide such information/data, you consent to the use thereof by ROPOSO Platform by such election. To the extent such information/data is determined to be or becomes personal data/information as per privacy laws applicable to you, we will ensure compliance with such privacy laws in our collection, processing or use of the information/data including certain data subject rights, if any, that you may enjoy under such privacy laws. We do not collect, store or process sensitive information such as biometric data, sexual preference, medical information, credit card and other banking related information, etc.
We (and our partners and the Group) may use information that is collected about you or that you provide, to (collectively referred to as “Permitted Purposes”):
- Provide you with the ROPOSO Platform features and its contents, such as location-based events, featured stories, offers and any other content.
- Provide information, materials, advertisements, promotions and/or offerings that may be of interest to you or to run survey campaigns by itself, Ad Partners or the Group including targeted advertisements and monetization activities through Roposo Platform and/or advertising channels of its Ad Partners or the Group or media partners.
- Notify you about your subscription to the ROPOSO Platform, including expiration and renewal notices.
- Notify you when any relevant ROPOSO Platform updates or upgrades are available and requires notification.
- Estimate our audience size and usage patterns.
- Speed up your searches.
- Enrich, build custom audience segments or merged data sets (using the data referred herein and/or third party or the Group provided data sets) to enable ROPOSO Platform, Ad Partners or the Group to better target advertisements and offer their services.
- improve our customer services and account maintenance including to detect, deter and prevent fraud, fraudulent traffic or to protect the security of our systems.
- for supporting users to improve and maximise their experience of the ROPOSO Platform including in relation to the provision of content and/or materials for the ROPOSO Platform.
- Analyze and provide our Ad Partners with reports on the effectiveness of advertisements and campaigns run on ROPOSO Platform.
- sending You important information regarding the Platform including sending you texts or messages via other platforms (which you have authorised) to reactivate your account or such other promotional message;
- sending You surveys and marketing communications that we believe may be of interest to You;
- process your survey responses and share the response data with the brands who are our customers/marketers.
- facilitating successful purchase of products from the Platform;
- responding to Your queries or complaints or to fulfil Your requests for information about the services and solutions that We offer and the process relating to the same;
- Make disclosures in the event of merger, sale, other asset transfers or other relevant corporate transactions. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.
If you decide to opt-in to our mailing list, you will receive emails that may include Company news, updates, related product or service information, etc. If at any time you would like to unsubscribe from receiving future emails, please follow the detailed unsubscribe instructions at the bottom of each email or you may contact us via our ROPOSO Platform customer support handle at firstname.lastname@example.org.
4. Disclosure of your information for Permitted Purpose
We may disclose aggregated information about our users, and information that does not identify any individual or device. We may also disclose information that we collect, or you provide:
- To our key shareholders, board, investors (debt or equity), subsidiaries and the Group. Group may use the information for the permitted purposes set out in Section 3.
- Partners. We may share your data with our Ad Partners, vendors, customers, data partners, measurement companies, influencer marketing agencies and/or brand partners for influencer marketing, and other third parties we partner with for providing our products and services including for facilitating and fulfilling your purchase of products from the Platform. If an advertisement or monetization transactions are made available to you through advertising channels of Company and/or its Group, Company may share your data obtained by Company with the Group for such advertising purposes.
- Legal Disclosures. We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.
- To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, due diligence, financing, acquisition, or other sale or transfer of some or all of Company assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which information held by Company about Roposo Platform users is among the assets transferred.
You acknowledge that some of the recipients of your information may be located outside your country of residence. Where we transfer your information to such third parties, we will endeavour to ensure that your information remains secure from unauthorized disclosure or theft. To the extent required under data privacy laws of the applicable jurisdiction, we may transfer such information pursuant to consent or through applicable data protection agreements or other mechanisms permitted under such laws.5. Your Choices About Our Collection, Use, and Disclosure of Your Information
We strive to provide you with choices regarding the information you provide to us. You may elect to disable, uninstall or unsubscribe from the ROPOSO Platform.
- Location data collection: You may opt out of the location data collection by ROPOSO Platform by turning off the location settings on your device. Note, however, that opting out of the ROPOSO Platform’s collection of location information will cause its location-based features to be disabled. ROPOSO Platform may read your location on city level from your cellular network to enhance your experience and the content we serve you. This city level location data is solely used by our recommendation engine to serve you content.
- Interest-based advertising: If you want to be certain that no interest-based advertisements are sent to you, please use “Opt out of interest-based ads” on your Android device or on your iPhone or iPad use: iPhone Settings > Privacy > Apple Advertising and turn off the Personalized Ads toggle; or “Limit Ad Tracking” or such other opt-out mechanisms made available on your device. You can opt out of receiving certain targeted ads by visiting the respective Ad Partners’ websites with whose advertisements you interact with; Please note that if you opt-out of interest-based advertising you will still receive "generic" ads.
- WhatsApp messaging: By using the ROPOSO Platform, you are also opting-in to receive transactional information and promotional content via WhatsApp. In case, you do not wish to receive any communications via WhatsApp, please give us a missed call on (+91) 9029048926 to opt-out of this facility.
We have implemented suitable technical and organizational measures to secure your personal information in compliance with our legal and privacy requirements and contractual obligations. We also seek appropriate contractual protection from our partners regarding their collection, use or treatment of user data. Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure.7. Data Retention Period
Company may retain device information for a period of up to 48 months, unless otherwise required by law or applicable contract.
With respect to the account information, registration data and/or addresses provided for facilitating purchase of products, the same will be retained until your specific instructions to delete such data. You can place this request to delete your data by writing to us at email@example.com.
Company may retain the information it obtains about you as per the instructions of its customers or partners who provide such information or as required to fulfil our contractual obligations. In case any information is provided by you in participation of a survey, Company will only retain your personal data for as long as necessary to fulfil the purposes it collected the information for.
After the applicable retention period, Company may retain and use such data in an aggregated format, as necessary for internal analytical purposes, to comply with its legal obligations, resolve disputes (including billing) and enforce agreements.
9. Contact Information
To ask questions, exercise applicable data subject rights, seek deletion of your data, or comment about this Policy and our privacy practices, please e-mail us at firstname.lastname@example.org.
10. Order of Prevalence:
Subject to applicable laws, the English language version of this Policy will prevail over any other language version issued by us for your benefit.