Privacy Policy

Welcome to Unfyltered. This Privacy Policy explains how Unfyltered Technologies Private Limited ("Unfyltered," "we," "us," or "our"), a company incorporated under the laws of India with its registered office in Bengaluru, Karnataka, collects, uses, shares, and protects your personal data when you use our mobile application, website (unfyltered.in), and related services (collectively, the "Services"). By accessing or using our Services, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy. This policy is compliant with the Digital Personal Data Protection Act, 2023 ("DPDPA 2023"), the Information Technology Act, 2000 ("IT Act"), and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011.

1. Information We Collect

We collect the following categories of information to provide, personalise, and improve our Services:

1.1 Information You Provide Directly

• Account Registration Data: Your name, date of birth, gender, email address, and mobile phone number. Phone number verification via OTP is mandatory for all Indian users.
• Profile Information: Photographs, bio/description, education details, occupation, company name, hometown, languages spoken, height, religion, drinking and smoking preferences, and other optional details you choose to share on your profile.
• Identity Verification Data: Selfie photographs used for face verification to confirm that your profile photos are authentic. We may also collect government ID information if you opt into our verified badge programme.
• Dating Preferences: Your preferred age range, distance radius, gender preferences, and community or interest-based filters.
• Communications: Messages, voice notes, and media shared through our in-app chat feature. Content from prompts and responses used in our compatibility matching system.
• Payment Information: When you purchase a premium subscription or in-app feature, payment is processed through Google Play Billing or Apple In-App Purchase. We receive transaction confirmations and subscription status but do not directly store your credit/debit card numbers or UPI details.
• User-Generated Content: Community posts, event RSVPs, stories, feedback, and any other content you voluntarily submit.
• Support Communications: Messages, emails, and attachments you send to our support team, including reports about other users.

1.2 Information Collected Automatically

• Device Information: Device model, operating system and version, unique device identifiers (such as Android Advertising ID), app version, language settings, and time zone.
• Location Data: With your explicit permission, we collect precise geolocation data (GPS) to show you potential matches nearby and enable distance-based discovery. You can revoke location permission at any time through your device settings, though this may limit certain features.
• Usage Data: Information about how you interact with our Services, including features used, profiles viewed, swipe patterns, matches made, time spent on the app, session duration, and frequency of use.
• Log Data: IP address, access times, pages viewed, app crashes, and other system activity.
• Cookies and Similar Technologies: We use cookies, pixels, and local storage on our website to enhance your browsing experience. See Section 10 for more details.

1.3 Information from Third Parties

• Social Login: If you choose to sign up or log in using Google or Apple, we receive your name, email address, and profile picture as permitted by those platforms.
• Analytics Providers: We receive aggregated and de-identified analytics data from services such as Firebase Analytics and Mixpanel.
• Safety and Fraud Prevention: We may receive information from third-party fraud detection and identity verification services to protect our community.

2. How We Use Your Information

We use the information we collect for the following purposes:

• Providing the Service: To create and manage your account, display your profile to other users, facilitate matches based on your preferences, enable messaging between matched users, and deliver the core dating experience.
• Personalisation: To tailor your discovery feed, suggest compatible profiles, recommend communities and events relevant to your interests, and customise your in-app experience.
• Safety and Security: To verify your identity, detect and prevent fraud, enforce our Community Guidelines, investigate reports of misconduct, and protect our users from harassment, catfishing, and other harmful behaviour.
• Communications: To send you service-related notifications (match alerts, messages, security alerts), and with your consent, promotional communications about new features, events, and offers. You can opt out of marketing communications at any time.
• Payments and Subscriptions: To process your premium subscription purchases, manage billing cycles, handle refund requests, and provide purchase confirmations.
• Analytics and Improvement: To understand usage trends, measure feature performance, conduct A/B testing, debug technical issues, and continuously improve our Services.
• Legal Compliance: To comply with applicable Indian laws, respond to lawful requests from government authorities, enforce our Terms of Service, and protect our legal rights.
• Community Features: To enable participation in communities, facilitate event discovery and RSVPs, and display user-generated content within the app.

3. Legal Basis for Processing

Under the Digital Personal Data Protection Act, 2023 (DPDPA), we process your personal data based on the following lawful grounds:

• Consent: We obtain your explicit, free, specific, informed, and unambiguous consent before collecting and processing your personal data. When you create an account on Unfyltered, you provide consent to the processing described in this Privacy Policy. You may withdraw your consent at any time by contacting us at privacy@unfyltered.in or by deleting your account through the app settings. Withdrawal of consent shall not affect the lawfulness of processing carried out prior to such withdrawal.
• Contractual Necessity: Processing necessary to perform our contract with you, i.e., our Terms of Service, including providing the dating service, facilitating matches, enabling communication, and managing your subscription.
• Legitimate Uses: As permitted under Section 7 of the DPDPA 2023, we may process your data for certain legitimate uses without explicit consent, such as responding to a medical emergency, ensuring safety during a disaster, or complying with a court order or legal obligation under Indian law.
• Legal Obligation: Where we are required to process your data to comply with Indian law, including the IT Act 2000 and rules thereunder, court orders, or directions from government authorities.

4. Data Sharing and Disclosure

We do not sell your personal data. We may share your information in the following limited circumstances:

• With Other Users: Your profile information (name, photos, bio, age, and other details you choose to share) is visible to other Unfyltered users as part of the core service. Messages are shared only with your matched connections.
• Service Providers: We engage trusted third-party companies to perform services on our behalf, including cloud hosting (Google Cloud Platform / AWS with servers in Mumbai, India), payment processing, push notification delivery (Firebase Cloud Messaging), analytics (Firebase Analytics, Mixpanel), customer support tools, email delivery, SMS/OTP verification, identity verification, and content moderation. These providers are contractually bound to use your data solely for the purposes we specify and are required to maintain appropriate security measures.
• Safety and Legal Requirements: We may disclose your information if we believe in good faith that such disclosure is necessary to: (a) comply with applicable law, regulation, or legal process (including requests from Indian law enforcement or government agencies); (b) protect the safety of any person or the public; (c) prevent fraud or address security or technical issues; (d) enforce our Terms of Service or Community Guidelines; or (e) protect the rights, property, or safety of Unfyltered, our users, or others.
• Business Transfers: In the event of a merger, acquisition, reorganisation, 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 in-app notification or email before your data is transferred and becomes subject to a different privacy policy.
• With Your Consent: We may share your information with third parties when you have given us explicit consent to do so.
• Aggregated and De-identified Data: We may share aggregated, anonymised, or de-identified data that cannot reasonably be used to identify you with partners, advertisers, or the public for industry analysis, demographic profiling, and other purposes.

5. Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable Indian law:

• Active Accounts: Your profile data, preferences, and activity history are retained for as long as your account remains active.
• Deleted Accounts: When you delete your account, we initiate the deletion of your personal data within 30 days. Certain data may be retained for up to 90 days in our backup systems before being permanently erased. Your profile is immediately removed from visibility to other users upon deletion.
• Chat Messages: Messages between users are retained for the duration of the match. If either user unmatches or deletes their account, the conversation is removed from both users' views. Server-side copies may be retained for up to 90 days for safety and legal compliance purposes.
• Safety and Legal Holds: If your account has been involved in a reported safety incident or is subject to a legal hold, investigation, or legal proceeding, we may retain relevant data for a longer period as required by law or to protect the safety of our community.
• Transaction Records: Payment and subscription records are retained for a minimum of 8 years in accordance with Indian tax and accounting regulations.
• Anonymised Data: Aggregated and anonymised data that can no longer identify you may be retained indefinitely for analytics and service improvement purposes.

6. Your Rights Under DPDPA 2023

As a Data Principal under the Digital Personal Data Protection Act, 2023, you have the following rights:

• Right to Access: You have the right to obtain a summary of your personal data being processed by us and the processing activities undertaken. You can access most of your data directly through the app settings.
• Right to Correction and Erasure: You have the right to request correction of inaccurate or misleading personal data, completion of incomplete data, and erasure of your personal data that is no longer necessary for the purpose for which it was collected. You can edit your profile information directly in the app, or contact us for data that is not user-editable.
• Right to Withdraw Consent: You have the right to withdraw your consent for data processing at any time. You can do so by adjusting your privacy settings within the app, revoking specific permissions (such as location access) through your device settings, or by contacting us at privacy@unfyltered.in. Please note that withdrawing consent may affect your ability to use certain features of the Service.
• Right to Grievance Redressal: You have the right to register a grievance with us regarding our data processing practices. We will acknowledge your grievance and respond within the timeframe prescribed by law. If you are not satisfied with our response, you have the right to file a complaint with the Data Protection Board of India.
• Right to Nominate: You have the right to nominate another individual who may exercise your rights in the event of your death or incapacity, as provided under the DPDPA 2023.

To exercise any of these rights, please contact us at privacy@unfyltered.in. We will respond to your request within 30 days, or within such other timeframe as may be prescribed by the Data Protection Board of India.

7. Children's Privacy

Unfyltered is strictly intended for users who are 18 years of age or older. We do not knowingly collect, use, or process personal data from anyone under the age of 18. Our registration process requires date of birth verification, and users must confirm that they are at least 18 years old to create an account.

In accordance with the DPDPA 2023 provisions regarding children's data, if we discover that we have inadvertently collected personal data from a user under 18, we will take immediate steps to delete such data from our systems and terminate the associated account. If you believe that a minor has created an account on Unfyltered, please report it immediately to safety@unfyltered.in or use the in-app reporting feature.

We do not engage in tracking, behavioural monitoring, or targeted advertising directed at children, and we do not process children's data in any manner that could cause harm to a child.

8. Security Measures

We take the security of your personal data seriously and implement industry-standard technical and organisational measures to protect it against unauthorised access, alteration, disclosure, or destruction. Our security practices include:

• Encryption: All data transmitted between your device and our servers is encrypted using TLS 1.3 (Transport Layer Security). Sensitive data at rest, including authentication tokens and verification data, is encrypted using AES-256 encryption.
• Infrastructure Security: Our servers are hosted on leading cloud platforms with data centres in India (Mumbai region), certified under ISO 27001, SOC 2 Type II, and other internationally recognised security standards. We employ firewalls, intrusion detection systems, and regular vulnerability assessments.
• Access Controls: Access to user personal data is restricted to authorised Unfyltered employees and contractors who need it to perform their job functions. All access is logged and audited. Employees undergo background checks and are bound by confidentiality obligations.
• Application Security: We conduct regular security audits, penetration testing, and code reviews. We follow secure development lifecycle (SDLC) practices and promptly patch known vulnerabilities.
• Incident Response: We maintain a comprehensive data breach response plan. In the event of a personal data breach that is likely to cause harm to Data Principals, we will notify the Data Protection Board of India and affected users as required under the DPDPA 2023.
• Photo Protection: We implement measures to discourage unauthorised screenshots and screen recordings of user profiles and conversations. While no technical measure can guarantee complete prevention, we employ reasonable safeguards.

While we strive to protect your personal data, no method of transmission over the Internet or method of electronic storage is 100% secure. We encourage you to use strong, unique passwords and to keep your login credentials confidential.

9. International Data Transfers

Unfyltered primarily stores and processes your personal data on servers located in India. However, some of our third-party service providers may process data outside India for specific purposes such as cloud infrastructure redundancy, analytics processing, or customer support operations.

When your personal data is transferred outside India, we ensure that:

• The transfer is made only to countries or territories notified by the Central Government of India as permissible under the DPDPA 2023.
• Appropriate contractual safeguards are in place, including standard contractual clauses that require the receiving party to maintain data protection standards equivalent to those applicable in India.
• The transfer is necessary for the performance of our contract with you or for other lawful purposes as permitted under applicable law.

We do not transfer your personal data to any country or entity that has been restricted by the Central Government under the DPDPA 2023 or any other applicable law.

10. Cookies and Tracking

Our website (unfyltered.in) uses cookies and similar tracking technologies to enhance your browsing experience:

• Essential Cookies: These are necessary for the website to function properly. They enable core features such as page navigation, secure access, and session management. You cannot opt out of essential cookies.
• Analytics Cookies: We use tools such as Google Analytics and Mixpanel to understand how visitors interact with our website. These cookies collect information such as pages visited, time spent, referral sources, and device type. This data is aggregated and anonymised.
• Functional Cookies: These remember your preferences and settings (such as language or region) to provide a more personalised experience on return visits.
• Marketing Cookies: With your consent, we may use cookies to deliver relevant advertisements on third-party platforms (such as Google Ads or Meta Ads). These cookies track your browsing activity across websites to build a profile of your interests. You can opt out of marketing cookies at any time through our cookie preference centre or your browser settings.

Within the Unfyltered mobile app, we use device identifiers and analytics SDKs (such as Firebase Analytics) to collect usage data as described in Section 1.2. You can limit ad tracking through your device settings (e.g., "Limit Ad Tracking" on iOS or "Opt out of Ads Personalisation" on Android).

For more information, please refer to our Cookie Policy.

11. Third-Party Links

Our Services may contain links to third-party websites, apps, or services that are not operated by Unfyltered. This includes, but is not limited to, links shared by other users in their profiles or messages, external event pages, social media profiles, and partner websites.

We are not responsible for the privacy practices or content of these third-party services. We encourage you to review the privacy policy of every third-party service you interact with. The inclusion of a link does not imply endorsement by Unfyltered.

Certain features of our Service may integrate with third-party platforms (such as Spotify for music preferences or Instagram for photo imports). When you choose to use these integrations, the third-party platform's privacy policy governs their collection and use of your data. We only receive the specific data you authorise through the integration.

12. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or for other operational reasons. When we make material changes to this policy, we will:

• Update the "Last updated" date at the top of this page.
• Notify you through the app via a prominent in-app notification or push notification.
• For significant changes that affect how we process your personal data, we will seek your renewed consent where required under the DPDPA 2023.
• Provide you with a reasonable period to review the changes before they take effect.

We encourage you to review this Privacy Policy periodically. Your continued use of the Services after the effective date of any changes constitutes your acceptance of the revised policy. If you do not agree with the updated terms, you should discontinue use of the Services and delete your account.

13. Consent Management

Unfyltered employs a clear and transparent consent framework in compliance with the DPDPA 2023:

• Granular Consent: We seek your consent separately for distinct processing activities. For example, consent for location access is separate from consent for push notifications or marketing communications.
• Informed Consent: Before collecting your data, we provide clear, plain-language descriptions of what data is being collected, why it is needed, and how it will be used.
• Easy Withdrawal: You can withdraw consent for specific processing activities at any time through the Privacy Settings section within the app, by adjusting device-level permissions, or by contacting us at privacy@unfyltered.in.
• No Bundled Consent: We do not bundle consent for the core service with consent for non-essential processing activities. You can use Unfyltered's basic features without consenting to optional data processing such as marketing communications or analytics tracking.

14. Contact Our Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or our data protection practices, please contact our Data Protection Officer:

• Email: privacy@unfyltered.in
• Subject Line: Please include "Privacy Enquiry" or "Data Request" in the subject line for faster routing.
• Postal Address:
  Data Protection Officer
  Unfyltered Technologies Private Limited
  Bengaluru, Karnataka 560001
  India

We aim to respond to all legitimate enquiries within 30 days. In certain cases, we may need to verify your identity before processing your request. If your request is particularly complex or voluminous, we will inform you of any extension needed and the reasons for it.

15. Grievance Officer (as per IT Act 2000)

In accordance with the Information Technology Act, 2000 and the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021, we have appointed a Grievance Officer to address your concerns and complaints regarding the processing of your personal data:

• Name: Grievance Officer, Unfyltered Technologies Private Limited
• Email: grievance@unfyltered.in
• Postal Address:
  Grievance Officer
  Unfyltered Technologies Private Limited
  Bengaluru, Karnataka 560001
  India
• Working Hours: Monday to Friday, 10:00 AM to 6:00 PM IST (excluding public holidays)

The Grievance Officer will acknowledge your complaint within 24 hours of receipt and resolve it within 15 days from the date of receipt, in accordance with the timelines prescribed under the IT Act and applicable rules. If you are not satisfied with the resolution provided, you may escalate your complaint to the Data Protection Board of India as established under the DPDPA 2023, or approach the appropriate judicial or regulatory authority.

You also have the right to file a complaint directly with the Data Protection Board of India if you believe that your personal data has been processed in violation of the DPDPA 2023.