PRIVACY POLICY

Effective Date: February 01, 2025

This Privacy Policy describes how Dividr ("we," "our," or "us") collects, uses, stores, and protects

the personal information of users ("you," "your," or "User") when you access or use our mobile

application (the "App") and related services. This policy is drafted in compliance with the

Information Technology Act, 2000 (India), the General Data Protection Regulation (GDPR) (EU),

and applicable policies of the Google Play Store and Apple App Store.

By accessing or using Dividr, you agree to the collection and use of your information in accordance

with this Privacy Policy. If you do not agree, please do not use the App.


1. DEFINITIONS

Personal Data: Any information that relates to an identified or identifiable individual.

Sensitive Personal Data: Data related to health, biometric details, financial information,

etc.

Data Subject: The individual whose personal data is being collected.

Data Controller: Dividr, which determines the purposes and means of processing your

data.

Data Processor: Any third party who processes personal data on behalf of Dividr.

Processing: Any operation performed on personal data including collection, use, storage,

or deletion.

2. INFORMATION WE COLLECT

We may collect and process the following types of personal and non-personal data:

2.1 Personal Information

Phone Number: Collected during registration and used exclusively for OTP (One-Time

Password) verification.

Instagram Public Data: If you are an influencer, we collect publicly visible follower and

following counts and profile information for collaboration matching. Only data from public

Instagram profiles is accessed.

YouTube Public Data: If you have a connected YouTube channel, we collect publicly

available data such as subscriber count, average likes, and average comments for the

purpose of collaboration matching and analytics.

2.2 Communication Data

Any messages, comments, or chats exchanged through the App are temporarily stored for

the purpose of facilitating communication between users.

2.3 Device and Technical Data We may collect device-specific information such as device type, operating system, IP

address, app version, and access times for analytics, security, and debugging purposes.

3. LEGAL BASIS FOR PROCESSING (GDPR COMPLIANCE)

For users based in the European Union (EU), we process your personal data under the following

lawful bases:

Consent: When you provide explicit consent for data collection (e.g., during account

setup).

Performance of Contract: To provide you with services such as matching influencers and

business owners.

Legitimate Interests: For fraud prevention, improving services, and securing user

accounts.

Compliance with Legal Obligations: To fulfill regulatory or legal requirements.

4. HOW WE USE YOUR INFORMATION

Your information is used to:

Verify your identity via OTP and manage your account;

Facilitate collaboration matching between business owners and influencers;

Enable chat and other communication features in the App;

Analyze usage trends and improve user experience;

Notify you about account activity, updates, or new features (if you opt-in);

Utilize publicly available YouTube data (such as subscriber count and engagement metrics)

to enhance influencer-business matching and insights.

Comply with applicable laws, regulations, and platform requirements.

5. DATA SHARING AND DISCLOSURE

We do not sell or rent your personal information. However, we may share your data with:

Service Providers: Third-party vendors providing services such as hosting, analytics, and

push notifications, bound by confidentiality agreements.

Legal Authorities: If required by law, regulation, legal process, or enforceable

governmental request.

Business Transfers: In case of a merger, acquisition, or asset sale, your data may be

transferred subject to this Privacy Policy.

6. DATA RETENTION POLICY

We retain your personal data only as long as necessary to fulfill the purposes stated in this Policy:

OTP verification and account details: retained while your account is active.

Chat data: retained temporarily for the purpose of communication, and deleted upon

deactivation or after a defined retention period.

Technical logs and device data: retained for security and analytics for a limited time.

If you delete your account or request data erasure, your data will be securely deleted unless

we are required to retain it for legal reasons.

7. DATA SECURITY MEASURES

We implement commercially reasonable security measures, including:

End-to-end encryption for sensitive communications;

Secure storage and restricted access controls;

Regular audits and monitoring;

Use of reputable cloud infrastructure providers with high-grade security certifications.

While we strive to protect your personal data, no method of transmission over the internet or

mobile networks is entirely secure. You acknowledge that you provide your data at your own risk.

8. YOUR RIGHTS UNDER GDPR AND INDIAN LAW

Depending on your location, you may have the following rights:

Right to Access: Obtain a copy of the personal data we hold about you.

Right to Rectification: Correct inaccurate or incomplete data.

Right to Erasure: Request deletion of your data under certain conditions.

Right to Restrict Processing: Ask us to limit how we use your data.

Right to Data Portability: Request a copy of your data in a structured format.

Right to Object: Object to data processing under specific legal grounds.

Right to Withdraw Consent: Withdraw your consent at any time without affecting the

lawfulness of prior processing.

To exercise these rights, please contact us using the details provided in the Contact section of this

Policy.

9. CHILDREN’S PRIVACY

We do not knowingly collect or solicit personal data from individuals under the age of 18. If you

are under 18, please do not attempt to register for the App or provide any personal information.

If we become aware that personal information has been collected from a user under the age of 18

without verified parental consent, we will delete such data promptly. If you believe we may have

collected such information, please contact us at admin@dividr.in

10. DATA TRANSFERS AND INTERNATIONAL PROCESSING

If you are located outside India, please be aware that your information may be transferred to,

stored, and processed in India or other countries where our servers or third-party service providers are located. We will ensure appropriate safeguards, such as Standard Contractual

Clauses (SCCs), are in place where required under GDPR to protect your personal data.

11. COOKIES AND TRACKING TECHNOLOGIES

At present, Dividr does not use cookies or browser-based tracking. However, the App may use

third-party analytics tools or SDKs (e.g., Firebase, Google Analytics for Mobile) that may collect

anonymized usage data to help us improve performance and functionality. If this changes in the

future, we will notify users and obtain consent where required.

12. THIRD-PARTY LINKS AND SERVICES

Our App may contain links to third-party websites, apps, or services. This Privacy Policy does

not apply to any information you provide to such third parties, and we are not responsible for the

privacy practices or content of those services. We encourage you to read the privacy policies of

any third-party services before interacting with them.

13. UPDATES TO THIS PRIVACY POLICY

We reserve the right to update or modify this Privacy Policy at any time. Any changes will be

reflected by an updated “Effective Date” at the top of the policy. In the case of material changes,

we will notify you via email, app notification, or other appropriate means. Continued use of the

App following the update indicates your acceptance of the revised Privacy Policy.

14. GOVERNING LAW AND JURISDICTION

This Privacy Policy shall be governed by and construed in accordance with the laws of India,

without regard to its conflict of laws principles. Any disputes arising from this Policy shall be

subject to the exclusive jurisdiction of the courts of New Delhi, India.

15. CONTACT US

If you have questions, concerns, or requests regarding this Privacy Policy or your personal data,

you may contact us at: Email: admin@dividr.in