LETSCHAT PRIVACY POLICY

Effective Date: 15-01-2025

Last Updated: 15-01-2025

1. INTRODUCTION

1.1. LetsChat (referred to as “We,” “Us,” or “Our”) values and prioritizes the privacy of individuals using our services (“User” or “You”). This Privacy Policy outlines the ways in which we collect, handle, share, and protect your personal information when you access our website (www.letschat.in). Collectively, these are referred to as the “Platform” in this document and include any related websites, channels, or applications. By continuing to use our Platform, you agree to the practices described in this Privacy Policy. If you disagree with any terms, please refrain from using our services.

1.2. We may update this Privacy Policy at any time to reflect changes in our practices or for other operational, legal, or regulatory reasons. Updates will be communicated by revising the “effective date” of this document and providing notice seven (7) days prior to the changes being implemented, typically through a message displayed on the Platform. These updates become effective immediately once live on the Platform.

1.3. This document forms an integral part of our ‘Terms of Use’ policy and provides detailed information about how we manage, utilize, and safeguard your data.

2. INTERPRETATION AND DEFINITIONS

The terms and phrases capitalized and used within this Privacy Policy are defined below. These definitions apply uniformly, whether used in singular or plural form: 2.1 ‘Account’: Refers to a unique account created by You to access or provide Services or parts of Your Services via LetsChat.

2.2 ‘Child’: Refers to any individual under the age of eighteen years.

2.3 ‘Consent’: Refers to the explicit, free, and unambiguous consent provided by Users on the Platform, as defined under the DPDPA.

2.4 ‘Content’: Refers to the materials created by a Creator on the Platform, including or utilizing ‘LetsChat Features’.

2.5 ‘Compatible/Supported Device’: Refers to a personal computer, mobile phone, portable media player, or other electronic device that meets the system and compatibility requirements and is authorized for use with the Platform.

2.6 ‘Cookies’: Small files placed on Your computer, mobile device, or other device by a website, containing details of Your browsing history and other functionalities.

2.7 ‘Creator/Artists’: Refers to individuals, groups, or legal entities accessing or Using Our Platform to create, promote, and sell Services or products.

2.8 ‘Data Fiduciary’: Refers to LetsChat as the legal entity responsible for determining the purposes and means of processing Personal Data, as per the DPDPA.

2.9 ‘Data Principal’: Collectively refers to the Users, who hold the rights provided under the DPDPA.
2.10 ‘Data Protection Officer’: Refers to the officer appointed by LetsChat in compliance with the DPDPA (hereinafter referred to as ‘DPO’).

2.11 ‘Digital Personal Data Protection Act of 2023’: Refers to legislation effective from September 2023, safeguarding individual privacy in India (hereinafter referred to as ‘DPDPA’).

2.12 ‘Grievance Officer’: Refers to the officer appointed by LetsChat for handling User complaints and grievances.

2.13 ‘Personal Data/Information’: Refers to any information related to an identified or identifiable individual, also known as Personally Identifiable Information (PII). Under the DPDP Act, this includes Sensitive Data/Information and Personal Information.

2.14 ‘Platform’/ ‘Website’: Refers to LetsChat, accessible at www.letschat.in, and usable on devices such as computers, mobile phones, or digital tablets.

2.15 ‘Privacy Policy’: Refers to this document, which aligns with the DPDPA and demonstrates Our commitment to protecting User privacy and complying with applicable data protection laws.

2.16 ‘LetsChat Features’: Refers to LetsChat’s web-based service that enables Users to create, design, publish, and sell digital services such as content subscriptions, live events, and one-on-one interactions.

2.17 ‘Service Provider’: Refers to the Creators on the Platform.

2.18 ‘Service’: Refers to the physical or digital products or services accessed, availed, or purchased by a User.

2.19 ‘Social Media Intermediary’: Refers to an intermediary that primarily or exclusively enables online interaction between Users and facilitates the creation, upload, sharing, dissemination, modification, or access to information through its services.

2.20 ‘Subscriber’: Refers to end Users, including individuals, groups, or legal entities, accessing or using Our Platform.

2.21 ‘We’/ ‘Us’/ ‘Our’: Refers to LetsChat, a company incorporated in India.
2.22 ‘You’/ ‘Your’/ ‘User’: Refers collectively to Creators and Subscribers, including individuals, groups, or legal entities accessing or using Our Platform.



For the purpose of this Privacy Policy, ‘Personal Data/Information’ also encompasses ‘Sensitive Data/Information’ and ‘Personal Information’ as defined in the SPDI Rules of 2011. These definitions are subject to amendments or modifications based on relevant legislative or regulatory changes.

3. USE OF PERSONAL DATA

3.1 We process your information to:

a. Provide LetsChat services to You;

b. Allow You to sign in to Your Account;

c. Enable You to join a Creator’s membership program on LetsChat;

d. Process a Creator’s membership payments;

e. Send You emails and/or newsletters relevant to Your usage, as determined by Your email preferences;

f. Respond to Your questions, queries, or requests;

g. Market LetsChat to You;

h. Understand how You use the Service/Platform and develop improved tools for Creators to serve Subscribers better;

i. Conduct research and development to enhance LetsChat and develop future products;

j. Prevent fraud and abuse on LetsChat;

k. Ship merchandise to You if a benefit includes it;

l. Provide reasonable accommodations if You notify Us of a disability;

m. Perform other business activities;

n. Resolve disputes and troubleshoot problems within the Platform or software.

3.2 For the aforementioned purposes of processing Your information, You shall be required to provide Your explicit consent while registering on the Platform.

4. CONSENT

4.1 We are dedicated to safeguarding Your privacy in full compliance with the Digital Personal Data Protection Act of 2023 (DPDPA). Under the DPDPA, You have rights to access, erase, withdraw consent, nominate, and restrict the processing of Your Personal Data.

4.2 Consent obtained from Users complies with the DPDPA. The Consent You provide is freely given, informed, unambiguous, and specific. By continuing to use this Platform, You explicitly Consent to the collection, usage, storage, sharing, and disclosure of Your Personal Data.

4.3 We may share or disclose Your Personal Data or other relevant information for purposes not outlined in this Privacy Policy, but only after notifying You and obtaining Your explicit Consent.

4.4 You can withdraw Your Consent at any time by:

a. Deleting Your profile and account on Our Platform;

b. Opting out of communications by emailing the grievance officer or DPO (refer to the details provided at the end of this Privacy Policy);

c. Contacting Us at provided email address on the website to request data modification or erasure.

4.5 Users are advised that withdrawing Consent may limit Your ability to use certain features of the Platform.

4.6 We may revise this Consent Clause periodically. For any questions related to this clause, please reach out to our DPO.

5. RETENTION OF PERSONAL DATA

5.1 We retain the Personal Data of Our Users for a period of six (6) months following the deletion or deactivation of an account by the account holder on Our Platform. The retention period for Personal Data may also vary depending on specific circumstances and case-by-case considerations.

5.2 LetsChat will retain Your Personal Data only for as long as necessary to fulfill the purposes outlined in this Privacy Policy. This includes retaining and using Your Personal Data to comply with legal obligations under applicable laws, address disputes or complaints, and enforce legally binding agreements and policies.

6. COLLECTION AND USAGE

6.1 Personal Data for Opening an Account

6.1.1. Personal Data: This includes any information You provide to Us, such as text inputs, payment details, and benefits. Any data that can identify, relate to, or be associated with a specific person, group, or legal entity, directly or indirectly, is considered Personal Data.

6.1.2. The type of information collected varies based on whether You create an account, become a Subscriber, or join as a Creator. When setting up an account on our Platform, You are required to consent to providing the following mandatory details:

a. Email address

b. Username

c. Mobile Number

d. PAN Number

e. Aadhaar Number

f. Bank Account Details

6.2 Financial/Transactional Data

To receive payouts, You must share Your preferred payment method details, such as UPI or Bank Transfer. Additional information may also be required for tax purposes:

a. Legal name

b. Address Proof

c. PAN Card (not mandatory for Subscribers)

d. Aadhaar Card (not mandatory for Subscribers)

Note: Creators must provide PAN Card and Aadhaar Card information as mandatory requirements.

6.3. Content Data

6.3.1. We collect information related to the content uploaded by Creators, which may be interacted with by Subscribers or general Users. This includes text, images, videos, comments, and other related data. This data is collected to facilitate internal analysis, support platform growth, and ensure proper regulation. Additional Data Collected

6.4 We collect, use, and store information from User interactions on Our Platform, including services browsed, email addresses, comments, and relevant profile details. We also gather and store data if You interact with a Creator’s educational service website.

6.5 Information is collected automatically as You navigate the Platform or through third-party analytics providers. We may store usage data such as:

a. The type of device You use to access LetsChat;

b. Your operating system and browser type;

c. The IP Address and device ID associated with Your device;

d. The pages You visit or request to view;

e. Links clicked;

f. Referring sites;

g. User interactions;

h. Your search terms and keywords;

i. Your geo-location based on Your disclosed country or IP Address. Tracking Tech & Cookies

6.6 Our Platform utilizes Cookies and web beacons as tracking technologies to monitor activity and store specific information. These tools are employed to collect data, improve, and analyze Our Platform. Below is a brief overview of these technologies:

A) Cookies/Browser Cookies: A ‘Cookie’ is a small file placed on Your device. You can configure Your browser to reject all Cookies or notify You when a Cookie is being sent. However, disabling Cookies may restrict access to some Platform features offered by Us or the Creators. Unless Your browser is set to refuse Cookies, Our Platform may utilize them. Cookies are categorized as:

• “Persistent” Cookies: These remain on Your device even when offline.

• “Session” Cookies: These are removed when You close Your web browser.

B) Web Beacons: Certain sections of Our Platform and emails may contain small electronic files known as ‘web beacons’ (also called ‘clear gifs,’ ‘pixel tags,’ or ‘single-pixel gifs’). These allow LetsChat to, for example, count the number of Users who have visited specific accounts, pages, or opened an email, as well as gather related website statistics.

6.7 Creators on Our Platform may share links to external websites that are not managed or operated by Us. If You choose to click on or follow such third-party links, You will be directed to the respective third-party’s website. We strongly recommend that You carefully review the Privacy Policy of any external website You visit.

6.8 We are not responsible for the content, privacy policies, or data security measures of any third-party websites or service platforms.

6.9 Additionally, We do not have control over the links shared by Creators on their pages or by Subscribers in comment sections, discussions, or live chat features.

7. TRANSFER OF PERSONAL DATA

7.1 Your information, including Personal Data, is transferred to and stored on our cloud database server.

8. SHARING OF YOUR PERSONAL DATA

8.1 We may share Your Personal Data under specific circumstances as detailed below

8.2 With Creators or Artists 8.2.1. If a Subscriber avails the subscription or enrolment of a Creator, You Consent to the sharing of the following information with the Creator:

a. Basic Information: Your name.

b. Profile Information: Your profile information as displayed on the Platform.

c. Payment Information: Your shipping address, physical location, and country if You purchase a digital benefit or product.

d. Messages You Send: The contents of any messages You send to a Creator through LetsChat will be shared with the recipient.

e. Aggregated and anonymized data about how You use LetsChat, which cannot be traced back to You or any individual User.

8.3 With Subscribers and Other Users

Users who subscribe to a Creator account, purchase a product, or engage with a Creator’s content on the Platform Consent to sharing the following Personal Data:

a. Your Full Name

b. Your Profile Picture

c. The content You view, etc.

8.4 Third-Party Service Providers

8.4.1 We may share Your information with third-party service providers who perform services on Our behalf, such as payment processing, data analysis, email delivery, hosting services, customer support, and marketing assistance.

8.4.2 Additionally, Your information may be shared with third parties for marketing purposes as allowed under Indian law.

9. DISCLOSURE OF YOUR PERSONAL DATA

9.1 We may share or disclose Your information collected by Us under specific circumstances or contexts. Your information may be disclosed in the following scenarios:

9.2 Business Analysis/Partnerships/Investor Transactions/Mergers

9.2.1 In the event that LetsChat as a Platform undergoes a merger, acquisition, or asset sale, Your Personal Data may be transferred. You will be notified before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

9.2.2. We may share Your information with our business partners to offer You specific products, services, or promotions.

9.2.3. We may also share Your information with business investors for general business analysis purposes.

9.3 Law Enforcement, Government Agencies, or Other Legal Requirements

9.3.1. Under certain conditions, we reserve the right to disclose Your Personal Data or Sensitive Data to law enforcement agencies, the Data Protection Board of India, judicial bodies, or state and central government authorities. This may occur in response to valid requests to investigate or address potential violations of our policies, or to safeguard the rights, property, and safety of others. Information sharing will comply with applicable laws, rules, or regulations.

9.3.2. This may include sharing Your information with other entities for fraud protection and credit risk reduction.

10. SECURITY OF YOUR PERSONAL DATA

10.1 We implement administrative, technical, and physical security measures to safeguard Your Personal Data. Despite our efforts to protect the information You provide, no security measure is entirely foolproof, and no method of data transmission can be guaranteed against interception or misuse.

10.2 As a result, while we strive to employ commercially acceptable means to protect Your Personal Data, complete security cannot be assured. Any information shared online remains vulnerable to unauthorized access or misuse.

10.3 In the unlikely event that Personal Data entrusted to LetsChat is compromised due to a breach of our security measures, despite our reasonable efforts to prevent such occurrences, Users agree to indemnify, defend, and hold Us harmless from and against any claims, damages, losses, liabilities, costs, and expenses (including reasonable attorney fees and court costs) arising from such breaches. Under no circumstances shall We be liable for any compromise or breach of privacy under this Privacy Policy or otherwise.

10.4. Storage of Personal Data

10.4.1. The information collected by Us is securely stored within Our controlled database server.

10.5 Internal Reviews and DPIA

10.5.1. Personal Data and other information collected by Us may be anonymized and utilized for internal reviews, surveys, and Data Protection Impact Assessments (DPIA) as permitted under the DPDPA. Any anonymized data maintained (due to exceptional circumstances or otherwise) will only be used for this purpose and will not be identifiable to any specific individual.

10.5.2. These activities allow Us to:

a. Identify and Mitigate Potential Privacy Risks: By analyzing anonymized usage data, we can detect potential privacy risks and proactively address them, enhancing overall privacy protection.

b. Enhance the Platform and Security: Anonymized data helps Us understand User behavior and preferences, enabling improvements in the Platform’s functionality, User experience, and security features.

c. Develop New Features and Services: By analyzing User interactions with the Platform, we can design new features and services tailored to better meet Your needs.

10.5.3 You retain the right to object to the processing of Your Personal Data for these purposes. To exercise Your rights, please contact our DPO at datasage.in@gmail.com

11. PROCESSING OF YOUR PERSONAL DATA

11.1. Our vendors and third-party service providers may have access to Your Personal Data. These third-party vendors collect, store, use, process, and transfer information about Your activity on Our Platform in accordance with their respective Privacy Policies.

11.2. Legitimate Reasons for Processing Your Personal Data under DPDPA

11.2.1. We process data in compliance with the provisions of the DPDPA. All the reasons mentioned within this Privacy Policy serve a lawful purpose.

11.2.2. We strive to process only the data for which Data Principals have provided their explicit Consent.

11.3. Cookies and Analytics

11.3.1. We may utilize third-party service providers to monitor and analyze the use of Our Platform.

11.4. Email Marketing

11.4.1. We may use Your Personal Data to contact You regarding subscriptions to services and channels based on Your activity and preferences, newsletters, promotional materials, and other information that might interest You.

11.4.2. You have the option to opt out of receiving any, or all, of these communications by clicking the ‘unsubscribe’ link or following the instructions provided in Our emails, or by reaching out to Us directly.

11.5. Payment Services

11.5.1 We and/or Creators on Our Platform may offer paid services or products. To access these services or products, You might need to provide financial information. In such cases, We use third-party services for payment processing.

11.5.2 We do not collect or store Your financial information. This information is directly provided to Our third-party payment processors, who handle it according to their Privacy Policies. These processors adhere to PCI-DSS standards, ensuring secure handling of financial information used for payments.

12. YOUR RIGHTS UNDER DPDPA, 2023

12.1. Creators, Artists, Subscribers, and other Users of LetsChat’s Platform are entitled to exercise their rights as Data Principals. As a Data Principal, You are guaranteed rights under the DPDPA.

12.2. The LetsChat Platform is committed to maintaining the confidentiality of Your Personal Data. Under this Privacy Policy, and by law if You are domiciled in India, You are entitled to:

12.3. List of Rights

a) Access to Your Personal Data: You have the right to access, update, or delete the information We have about You. Whenever possible, You can access, update, or request the deletion of Your Personal Data directly within Your account settings. If You are unable to perform these actions yourself, please contact Us for assistance.

b) Request Correction of Personal Data: You have the right to request corrections to any incomplete or inaccurate information We hold about You.

c) Request Erasure of Personal Data: You have the right to ask Us to delete or remove Your Personal Data when there is no valid reason for Us to continue processing it.

d) Right to Nominate: You have the right to nominate an individual who is (a) known to You, (b) above the age of 18, and

(c) not a serious criminal offender. This nominated individual will act as Your Legal Guardian and be given access to Your Personal Data on the Platform in case of (a) Your death or (b) Your permanent disability.

e) Right to Withdraw Consent: You have the right to withdraw Your consent for the use of Your Personal Data. If You withdraw or modify Your consent, We may be unable to provide You with access to certain features or functionalities of the services on Our Platform.

f) Object to Processing of Personal Data: You have the right to object to the processing of Your Personal Data if We are relying on a legitimate interest as the legal basis for processing. This includes objections to processing for direct marketing purposes or if the processing affects Your particular circumstances.

12.4. Exercising Your Rights

12.4.1. You may exercise Your rights to access, be informed, rectify, cancel, erase, object, withdraw consent, and oppose automated decisions and profiling by contacting Us. We ensure the Personal Data We collect is accurate, complete, and up-to-date. If the data serves no further purpose, it will be permanently deleted.

12.4.2. Your rights are subject to certain conditions and territorial applicability. If You believe Your rights have been violated or have a query regarding Your rights, You can file a complaint. We may request identity verification before responding to Your request.

12.4.3. You also have the right to file a complaint with the Data Protection Board of India about Our collection and use of Your Personal Data. For more information, contact the Data Protection Board’s appointed Consent Manager.

13. APPLICABLE LAWS AND GOVERNING JURISDICTION

13.1. This Policy is governed by the laws of the Republic of India.

13.2. Relevant laws include, but are not limited to, the Information Technology Act, 2000, the Digital Personal Data Protection Act, 2023, the Consumer Protection Act, 2019, and applicable criminal laws and their amendments. In case of disputes, the jurisdiction will be the courts in Bengaluru, Karnataka, India. We aim to resolve any concerns amicably through informal negotiations. If a resolution cannot be reached, formal court proceedings will follow.

14. CHILDREN’S PRIVACY

14.1. No individual under the age of 18 is permitted to register as a User or access services on Our Platform. We do not knowingly collect, address, or market to anyone under the age of 18.

14.2. If You are a parent or guardian and become aware that a child under 13 has provided Personal Data, please contact Us. If We discover that We have collected Personal Data from a child under 13 without appropriate consent, We will take steps to delete that information from Our systems.

14.3. Children aged 13-17 cannot become Users, Creators, or Subscribers on Our Platform. It is the responsibility of parents or guardians to supervise children in this age group. If We inadvertently collect, use, or store Personal Data from a child in this category, We will promptly remove it.

15. CHANGES TO THIS PRIVACY POLICY

15.1. We may revise Our Privacy Policy periodically. Any updates will be posted on this page, and You will be notified via email and/or a prominent notice on Our Platform before the changes take effect. Additionally, the “Last updated” date at the top of this Privacy Policy will be modified.

15.2. We recommend that You review this Privacy Policy regularly to stay informed about any updates. Changes to this Privacy Policy become effective immediately after being displayed on Our Platform for a period of 7 (seven) days prior to their implementation. If You have any questions or concerns regarding the Privacy Policy, please contact Us at datasage.in@gmail.com.

15.3. By continuing to use the Platform after updates have been made effective, You acknowledge and accept the revised terms of the Privacy Policy.

16. GRIEVANCE REDRESSAL

Any complaints, concerns, or instances of abuse regarding content, comments, or breaches of these terms should be promptly directed to the designated Grievance Officer. You may contact the Grievance Officer in writing or via email signed with an electronic signature as follows: "Grievance Officer"

Name: Mr. Ajinkkyaa Naik (Grievance Officer)

Address: Sneh building, Panchmarg, Versova, Andher(w), Mumbai 400061 Email: datasage.in@gmail.com

Ph: 9769949948

CONTACT US/ DPO

If You have any questions, requests, or complaints regarding actions required for Your Personal Data or this Privacy Policy, please contact our DPO at:

Name of the DPO: Mr. Ajinkkyaa Naik

Address: Sneh building, Panchmarg, Versova, Andher(w) Email: datasage.in@gmail.com

Ph: 9769949948