Privacy Policy

This Privacy Policy explains how Shanty (“Ember”, “we”, “us”) collects, uses, discloses, retains, and protects your personal data when you use the Ember Connect mobile application and related services (the “Platform”). We act as the Data Fiduciary under India's Digital Personal Data Protection Act, 2023 (“DPDP Act”). By creating an account and providing consent, you agree to the practices described here. This notice is provided in English; you may request a summary in any language listed in the Eighth Schedule to the Constitution of India by contacting our Grievance Officer.

1. Data We Collect

• Account & identity: mobile phone number (via OTP), and the role you select (connect / earn).
• Profile: display name, age (18+), gender, bio, city, profession, height, relationship status, languages, interests, and profile photos.
• Verification (earners): a short verification video and passphrase used to confirm identity. Verification videos are reviewed manually by our staff; we do not perform automated biometric or facial-recognition matching on them.
• Usage & calls: connection requests, call metadata (participants, timestamps, duration), subscriptions, and earnings. The audio and video of your calls are transmitted in real time and are not recorded or stored by us.
• Chat messages: the text content and timestamps of messages you exchange with a connected user through the in-app chat feature. Unlike calls, message text is stored on our servers (not just relayed) so both participants can view the conversation.
• Payments: transaction identifiers for subscriptions. Card and payment credentials you use to pay are handled by our payment processor (Razorpay) and are never stored by us.
• Payout details (earners only): if you choose to receive earnings, the payout account you provide — either your UPI ID, or your bank account holder name, account number and IFSC code — and the time and version of the consent you gave when adding it.
• Device & technical: push-notification (FCM) token, IP address, and app/diagnostic logs.
• Advertising: your device's resettable advertising identifier (Google Advertising ID) and coarse, non-precise ad-related signals, collected by Google AdMob to serve and measure in-app ads (see Section 5).

2. Purposes & Legal Basis

We process your personal data on the basis of the consent you provide at sign-up (and, where applicable, for the performance of our services and to meet legal obligations). We use your data to:

• authenticate you and secure your account;
• build your public profile and power discovery and matching;
• facilitate video/voice calls and enforce call time limits;
• facilitate text messaging between connected users and enforce free-message limits;
• process subscriptions, commissions, and earner payouts;
• pay your earnings to the payout account you provide, and keep records of those payments;
• send service and safety notifications;
• show and measure in-app advertising;
• prevent fraud, abuse, and violations of our Terms; and
• comply with applicable law.

3. App Permissions

The app requests the following device permissions, each only for the stated purpose:

• Camera & Microphone: required for video/voice calls and for recording the earner verification video. Never accessed outside a call or verification you initiate.
• Photos / media: to let you choose profile photos for upload.
• Notifications: to alert you to incoming calls, connection requests, and service messages, including full-screen incoming-call alerts.
• Phone / call integration: to display incoming Ember calls using your device's native call screen.

You can revoke any permission in your device settings; related features will stop working but the rest of the app remains usable.

4. Consent & Withdrawal

We record the consent you give at registration, including the policy version and the time of consent, as evidence required under the DPDP Act. You may withdraw consent at any time from within the app (Profile → Privacy & Data) or by contacting our Grievance Officer. Withdrawing consent will require us to stop most processing and may mean you can no longer use the Platform. Withdrawal does not affect processing already carried out lawfully.

Payout details are collected only with a separate, specific consent that you give on the Payout details screen when you add or change them. We record the time and the version of the wording you agreed to. You can change your payout details at any time; you can withdraw this consent by contacting our Grievance Officer, in which case we will stop using the details and will be unable to pay further earnings until new details are provided.

5. Advertising

We show in-app advertisements served by Google AdMob. AdMob may collect and process your device's advertising identifier, IP address, and app-interaction signals to serve, personalise (where permitted), and measure ads, as described in Google's Privacy Policy and how Google uses data from partner apps. You can opt out of ad personalisation and reset or delete your advertising identifier at any time in your device settings (Android: Settings → Google → Ads; iOS: Settings → Privacy & Security → Tracking / Apple Advertising). We do not share your profile, call, or payment data with advertisers.

6. Sharing & Third-Party Processors

We do not sell your personal data. We share it only with service providers (Data Processors) who process it on our behalf under contract, and where required by law or to protect rights and safety (including responding to lawful requests from law-enforcement and government agencies). Our key processors are:

Other users of the Platform can see the profile information you choose to publish (name, photos, bio, and similar profile fields). Your phone number is never shown to other users. Your payout details are used only to pay you; they are never shown to other users and never shared with advertisers.

7. International Transfers

Some processors listed above store or process data on servers outside India. Where this happens, we take reasonable steps to ensure your data continues to be protected and that transfers comply with the DPDP Act and any restrictions notified by the Government of India.

8. Data Retention

We retain personal data only for as long as necessary for the purposes above. In particular:

• Profile and account data: for the life of your account.
• Call, subscription, and transaction records: retained while your account is active and thereafter as required for financial, tax, and legal compliance.
• Chat messages: retained while the connection and both accounts remain active; deleted or irreversibly anonymised on account deletion, except where retention is legally required.
• Verification media: retained while your account is active and deleted after account closure.
• Payout details: kept while your earner account is active; deleted when you delete your account. Records of payouts already made (amount, date, reference) are kept as required for financial and tax compliance.
• Server and diagnostic logs: retained for up to 12 months, or longer where needed for an ongoing security or legal matter.

When you delete your account, we erase your profile, photos, and verification media, and delete or irreversibly anonymise associated records, except where retention is legally required (e.g. financial records).

9. Your Rights

Under the DPDP Act you have the right to:

• Access a summary of the personal data we process about you — available in-app from Profile → Privacy & Data → View my data;
• Correct or update inaccurate or incomplete data (editable in-app);
• Erase your data by deleting your account in-app;
• Withdraw consent as described in Section 4;
• Nominate another individual to exercise your rights in the event of death or incapacity; and
• Grievance redressal — raise a complaint with our Grievance Officer (Section 12) and, if unsatisfied, with the Data Protection Board of India.

10. Security

We use reasonable technical and organisational safeguards, including encrypted transport (HTTPS), secrets held in a managed secret store, access controls and role-based admin permissions, signed time-limited URLs for sensitive media, and audit logging of administrative actions. Payout details receive additional protection: the UPI ID, account number and account holder name are encrypted with AES-256 before they are stored, and the encryption key is held separately from the database. You only ever see them in masked form (for example, ••••1234). Our finance staff can view them in full only after re-verifying their identity with a one-time password, the full details are hidden again automatically after a short time, and every such view is recorded in an audit log. We notify you whenever your payout details are changed. No system is perfectly secure; in the event of a personal-data breach we will notify the Data Protection Board and affected users as required by law.

11. Child Safety Standards & Anti-CSAE Policy

Ember Connect maintains a strict zero-tolerance policy against Child Sexual Abuse Material (CSAM) and Child Sexual Abuse and Exploitation (CSAE). The Platform is strictly for adult users aged 18 and older. Minors under 18 years of age are strictly prohibited from creating accounts, accessing, or using Ember Connect.

11.1 Prohibition of Child Sexual Abuse & Exploitation (CSAE)

Ember Connect explicitly prohibits any user from creating, uploading, sharing, streaming, soliciting, or distributing content or engaging in conduct that constitutes or promotes Child Sexual Abuse Material (CSAM), Child Sexual Abuse and Exploitation (CSAE), child grooming, or any form of child endangerment or harm.

11.2 Safety Mechanisms & In-App Reporting

We employ active moderation, technical safeguards, and reporting mechanisms to protect users and prevent misuse:

• In-App Reporting & Blocking: Users can instantly report any suspicious activity, user, or profile via the in-app report control available on profile screens, the active call screen, and the chat screen, and can independently block another user to immediately prevent further messages, calls, or connection requests between the two accounts.
• Proactive Review: Reported accounts and media are flagged for administrative review and moderation.
• Account Suspension & Permanent Termination: Accounts involved in any CSAE/CSAM violation or underage usage are immediately suspended and permanently banned.

11.3 Law Enforcement Reporting

In accordance with applicable global child protection laws and regulations, Ember Connect promptly reports any identified instance of CSAM/CSAE to relevant legal and law enforcement authorities, including the National Center for Missing & Exploited Children (NCMEC) and Indian Cyber Crime reporting portals.

11.4 Dedicated Child Safety Contact Point

For inquiries, concerns, or urgent reporting regarding child safety or CSAE violations on Ember Connect, please contact our dedicated Child Safety Officer:

Child Safety Officer: Prince Yadav
App / Developer Name: Ember Connect (Shanty)
Child Safety Contact Email: naitiksolution304@gmail.com
Grievance Office Address: First Floor, House No. 375, Yadav Mohalla, Rajokri, New Delhi - 110038

12. Grievance Officer

In accordance with the DPDP Act and the Information Technology Act, the contact details of our Grievance Officer are:

Prince Yadav
Email: naitiksolution304@gmail.com
Shanty

We will acknowledge complaints within 24 hours and resolve them within 15 days. If you are not satisfied with our response, you may complain to the Data Protection Board of India.

13. Changes to this Policy

We may update this Policy from time to time. Material changes will be notified in-app and the version number above will change. Continued use after an update, or re-affirming consent when prompted, constitutes acceptance of the revised Policy.