Privacy Policy

1. Introduction

JBAC Innovations Private Limited ("Buzzire", "we", "us", "our"), a company incorporated under the Companies Act, 2013 (CIN: U62012GJ2026PTC173156), with its registered office in Gandhinagar, Gujarat, India, operates the Buzzire mobile application ("App") and the website at buzzire.com ("Website") (collectively, "Services").

This Privacy Policy explains how we collect, use, disclose, store, and safeguard your personal data when you use our Services, in compliance with:

• The Information Technology Act, 2000 ("IT Act")
• The Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 ("SPDI Rules")
• The Digital Personal Data Protection Act, 2023 ("DPDP Act")
• Other applicable data protection laws and regulations

By downloading, installing, registering on, or using the Buzzire App or Website, you acknowledge that you have read, understood, and agree to the collection and processing of your personal data as described in this Privacy Policy. If you do not agree with this policy, please do not use our Services.

2. Data Fiduciary Information

Under the Digital Personal Data Protection Act, 2023, JBAC Innovations Private Limited is the "Data Fiduciary" — the entity that determines the purpose and means of processing your personal data. This means we are responsible for:

• Deciding what personal data to collect and why
• Ensuring your data is processed lawfully, fairly, and transparently
• Implementing appropriate security measures to protect your data
• Responding to your requests regarding your personal data rights
• Reporting data breaches to relevant authorities where required

Data Fiduciary contact: JBAC Innovations Private Limited · CIN U62012GJ2026PTC173156 · Gandhinagar, Gujarat, India · support@buzzire.com · Grievance Officer: Akshay Chavda, Director

3. Personal Data We Collect

3.1 Information you provide directly

3.2 Information collected automatically

3.3 Information we do NOT collect

• Your contacts or address book
• Your browsing history outside the Buzzire app
• Your social media passwords or private messages on other platforms
• Your financial information or bank account details
• Your advertising ID (IDFA/GAID) — we do not participate in ad tracking
• Biometric data for purposes other than profile verification
• Health or medical information

4. How We Collect Your Data

• Direct input: When you register, create your profile, send messages, adjust settings, or contact support
• Automated collection: Through SDKs and APIs embedded in the app (Firebase Analytics, Crashlytics, Performance) that collect device and usage data
• Third-party services: When you subscribe through Apple App Store or Google Play Store, they share subscription status and transaction IDs with us — but not payment card details
• Device permissions: Camera, location services, push notifications. Each permission is requested individually and can be revoked at any time

5. Purpose of Data Processing

5.1 Core service delivery

• Account creation and authentication using your phone number, email, and name
• Profile display to potential matches based on mutual discovery preferences
• Matching algorithm using your preferences, location, activity patterns, and profile quality
• Messaging between matched users
• Subscription management for premium features

5.2 Safety & security

• Profile verification using selfie-based verification to confirm users are real
• Fraud prevention — detecting and blocking fake accounts, bots, scammers, and suspicious activity
• Content moderation — reviewing reported profiles and messages to enforce our Community Guidelines
• Account security — detecting unauthorized access attempts and protecting against account takeover

5.3 Improvement & analytics

• Analysing usage patterns to understand which features work well
• Using crash logs and error reports to resolve technical issues quickly
• Improving our matching algorithm based on aggregate interaction patterns
• A/B testing feature variations to determine the best user experience

5.4 Communication

• Transactional notifications about new matches, messages, likes, and subscription changes
• Service updates about important changes to the app, terms, or policies
• Support responses to your tickets, feedback, and inquiries

5.5 Legal compliance

• Complying with valid legal requests from law enforcement agencies
• Meeting requirements under the IT Act, DPDP Act, and other applicable laws
• Retaining necessary data to resolve disputes and enforce our Terms of Service

6. Legal Basis for Processing

• Consent (Section 6): You provide explicit consent when you create your account and accept this Privacy Policy. Consent is also obtained for specific permissions like location and camera access
• Legitimate uses (Section 7): Certain processing is deemed a "legitimate use" under the Act, including fulfilling our contractual obligations, complying with legal obligations, responding to medical emergencies involving threats to life, and employment-related processing for our internal staff

You can withdraw your consent at any time, though this may affect your ability to use certain features of the Service.

7. Data Sharing & Disclosure

7.1 With other Buzzire users

• Your public profile: First name, age, photos, bio, interests, education, occupation, and other profile fields are visible to users who encounter you in discovery
• Messages: Content you send in chats is visible to the matched user you're chatting with
• Subscription badge: If you're a Platinum member and have the badge enabled, other users may see your status
• Verification status: Your verified badge is visible to other users

7.2 With service providers

We share data with carefully selected third-party service providers who help us operate Buzzire. These providers are contractually bound to use your data only for the specific services they provide to us and must maintain appropriate security measures.

7.3 For legal reasons

• To comply with applicable laws, regulations, or valid legal process
• To respond to lawful requests from government or law enforcement agencies
• To protect the rights, safety, or property of Buzzire, our users, or the public
• To detect, prevent, or investigate fraud, security breaches, or technical issues
• To enforce our Terms of Service and Community Guidelines

7.4 Business transfers

In the event of a merger, acquisition, reorganisation, bankruptcy, or sale of all or a portion of our assets, your personal data may be transferred as part of that transaction. We will notify you via email and/or a prominent notice in the app before your data is transferred and becomes subject to a different privacy policy.

7.5 What we never do

• We never sell your personal data to advertisers, data brokers, or any third party
• We never share your data for third-party advertising — Buzzire does not run ads
• We never share your messages with anyone other than the intended recipient, except when investigating reported policy violations
• We never share your precise location with other users — only approximate distance is shown

8. Third-Party Service Providers

• Firebase (Google) — authentication, real-time database, cloud functions, analytics, crash reporting, performance monitoring, push notifications, cloud storage for profile photos
• RevenueCat — subscription management, receipt validation, entitlement tracking. Receives user ID, subscription status, transaction IDs. Does not receive profile data, messages, or location
• Razorpay — payment processing for Indian users. We never see or store your full card details
• Apple App Store — in-app purchases and subscription billing for iOS. We receive transaction receipts and subscription status, not payment card details
• Google Play Store — in-app purchases and subscription billing for Android. We receive purchase tokens and subscription status, not payment card details
• Expo (React Native) — over-the-air app updates. Minimal data collection limited to device type and app version

We regularly review our third-party integrations to ensure they meet our security and privacy standards. All providers are contractually required to process data in accordance with applicable law.

9. Data Storage & Transfer

Where your data is stored

Your personal data is primarily stored on Firebase (Google Cloud) servers. Google Cloud operates data centres in multiple regions globally. While we do not have a dedicated India-only server, your data may be stored in data centres located in the United States, Singapore, or other regions where Google Cloud operates.

Cross-border transfers

• Google (Firebase) maintains comprehensive data protection agreements and certifications
• All data transfers are encrypted using industry-standard TLS/SSL protocols
• Our third-party providers are contractually bound to maintain data protection standards equivalent to or exceeding Indian requirements

Encryption

• In transit: TLS 1.2 or higher
• At rest: AES-256 encryption on Firebase servers
• On device: Sensitive data such as authentication tokens is stored in secure storage

10. Data Retention

After the retention period expires, data is permanently deleted from our active systems. Backup systems may retain encrypted copies for up to an additional 30 days before automatic purging.

11. Data Security

Technical safeguards

• Encryption: All data is encrypted in transit (TLS 1.2+) and at rest (AES-256)
• Authentication: Firebase Authentication with secure token management and automatic token refresh
• Access controls: Role-based access ensures only authorized team members can access user data, and only the minimum necessary
• Firebase security rules: Database rules ensure users can only access their own data and data explicitly shared with them
• Input validation: All user inputs are validated and sanitised to prevent injection attacks
• Monitoring: Automated monitoring for suspicious activity, unusual access patterns, and potential security incidents

Organisational safeguards

• Minimal access principle: Team members only have access to the data they need
• Security reviews: Regular review of security practices and access controls
• Incident response: Documented procedures for responding to security incidents and data breaches
• Vendor assessment: Third-party providers are evaluated for security standards before integration

12. Your Rights

• Right to access: Request a summary of all personal data we hold about you, including what we collect, how we use it, and who we share it with. Provided within 30 days
• Right to correction: Have inaccurate, incomplete, or misleading data corrected. Most profile data can be updated directly in the app
• Right to erasure: Request complete deletion of your personal data. Data is fully erased within 30 days
• Right to withdraw consent: Withdraw consent at any time. This does not affect the lawfulness of processing done before withdrawal
• Right to grievance redressal: File a complaint with our Grievance Officer or the Data Protection Board of India
• Right to nominate: Nominate another person to exercise your data rights on your behalf in the event of death or incapacity

How to exercise your rights

• Email support@buzzire.com with the subject line "Data Rights Request"
• Include your registered phone number or email for identity verification
• Specify which right(s) you wish to exercise
• We will acknowledge your request within 48 hours and fulfil it within 30 days

13. Consent & Withdrawal

How we obtain consent

• Registration consent: When you create your account, you consent to the data processing described in this policy
• Permission-based consent: Camera, location, and notification permissions are requested individually with clear explanations
• Optional consent: Some features may offer additional opt-in/opt-out controls

How to withdraw consent

• Device permissions: Device Settings → Apps → Buzzire → Permissions
• Analytics opt-out: Email support@buzzire.com with subject "Analytics Opt-Out"
• Complete withdrawal: Delete your account through the app (Settings → Account → Delete Account) or email us. This withdraws all consent and triggers complete data erasure within 30 days

Withdrawing consent may affect your ability to use certain features. For example, revoking location permission means we can't show you nearby profiles.

14. Children's Privacy

Buzzire is intended exclusively for users aged 18 years and above. We do not knowingly collect personal data from anyone under the age of 18.

• Age is verified during registration. Users who do not meet the minimum age requirement cannot create an account
• If we discover that we have inadvertently collected data from a minor, we will immediately delete the account and all associated data
• If you believe a minor has created a Buzzire account, report it immediately to support@buzzire.com
• In accordance with the DPDP Act, we treat all users under 18 as children whose data requires special protection

15. Cookies & Tracking Technologies

We use cookies and similar tracking technologies on our website and in our app. For a full explanation, see our Cookie Policy. In summary:

• Essential cookies: Required for core functionality (authentication, security)
• Analytics cookies: Help us understand usage patterns
• Preference cookies: Remember your settings
• No advertising cookies: We do not use marketing or advertising tracking

16. Push Notifications & Communications

Push notifications

With your permission, we send notifications for new matches and likes, new messages, greetings, subscription status changes, important security alerts, and major app updates. Manage these in the app (Settings → Notifications) or disable them through your device settings.

Email communications

We may send emails for account verification and password recovery, subscription receipts and billing notifications, responses to support tickets, important policy or terms changes, and security alerts. We do not send promotional marketing emails — all email is transactional or service-related.

17. Location Data

What we collect

• GPS coordinates: When you grant location permission
• IP-based location: When GPS is unavailable, city-level accuracy

How we use it

• Discovery radius: To show profiles within your selected distance range
• Distance display: To show approximate distance to other users. We never show your exact location or address
• Location-based matching: Proximity is a factor in our matching algorithm

How we protect it

• Your exact coordinates are never shared with other users
• Other users only see approximate distance rounded to the nearest kilometre
• Location data is updated only when you actively use the app — we do not track your location in the background
• You can revoke location permission at any time through your device settings
• Without location permission, the app continues to work but cannot show nearby profiles

18. Account Deletion & Data Erasure

You have the right to delete your account and have all your personal data erased. For instructions, see our Delete Account page.

• Immediate: Your profile is removed from discovery — no one can see or find you
• Immediate: All your matches and conversations are deleted
• Within 24 hours: Your profile photos are removed from our cloud storage
• Within 30 days: All personal data is permanently erased from all active systems
• Within 60 days: Encrypted backup copies are automatically purged

What we may retain after deletion

• Anonymised analytics data that cannot be linked back to you
• Legal hold data if required by an active legal proceeding, court order, or law enforcement request
• Financial records as required by Indian tax and accounting regulations (typically 7 years)
• Safety records: If your account was banned for serious violations, we retain a hashed identifier to prevent re-registration

19. International Users

• Your data will be transferred to and processed on servers that may be located outside your country of residence
• By using Buzzire, you consent to this cross-border data transfer
• We apply the same data protection standards to all users regardless of location
• If you are in the EEA, United Kingdom, or other jurisdictions with data protection laws, we respect your additional rights under those laws to the extent applicable
• Data transfers from the EEA are protected by Standard Contractual Clauses where applicable

20. Grievance Redressal

In accordance with the Information Technology Act, 2000, and the DPDP Act, 2023, we have appointed a Grievance Officer to address any concerns or complaints regarding your personal data.

• Name: Akshay Chavda
• Designation: Director, JBAC Innovations Private Limited
• Email: support@buzzire.com (Subject: "Privacy Grievance")
• Address: Gandhinagar, Gujarat, India

Resolution process

• Complaints are acknowledged within 48 hours of receipt
• We aim to resolve all grievances within 30 days
• If we need additional time due to complexity, we will inform you of the expected timeline
• You will receive a written response detailing the outcome and any action taken

If you are not satisfied with our response, you may escalate your complaint to the Data Protection Board of India as established under the DPDP Act, 2023.

21. Changes to This Policy

• Minor changes: We will update the "Last updated" date at the top of this page
• Significant changes: We will notify you through in-app push notifications, email, or a prominent notice within the app at least 7 days before the changes take effect
• Material changes to data collection: If we introduce new categories of personal data collection or new purposes for processing, we will seek your explicit consent before proceeding

Continued use of Buzzire after the effective date of changes constitutes your acceptance of the updated policy. Previous versions are archived and available upon request.

22. Contact Us

• General privacy inquiries: support@buzzire.com (Subject: "Privacy Inquiry")
• Data rights requests: support@buzzire.com (Subject: "Data Rights Request")
• Grievances: support@buzzire.com (Subject: "Privacy Grievance")
• Response time: Within 24–48 hours for acknowledgement; 30 days for data rights fulfilment

JBAC Innovations Private Limited
CIN: U62012GJ2026PTC173156
Gandhinagar, Gujarat, India