About this policy
IVA AI is a product of OpenPebble Labs, a brand of ZBULLET Enterprises Limited. Our registered office is at 18th Floor, A Wing, Marathon Futurex, Delisle Road, Mumbai, Maharashtra 400013, India.
We (Z Bullet Enterprises Limited, or "ZBEL") recognise that your privacy is very important and take it seriously. This Privacy Policy ("Privacy Policy") sets out how we collect, use and disclose your data when you use our website https://openpebble.in/iva/ ("Website") and/or mobile application called IVA ("App"). The Website and App are collectively referred to as the "Platform". References to "we", "our" or "us" or "ZBEL" shall mean the Platform and/or Z Bullet Enterprises Limited. Any references to "you", "your" or "user" shall mean any person or entity using our Platform. We will not use or share your information with anyone except as described in this Privacy Policy.
This Privacy Policy is a part of and is to be read with the IVA Terms of Use ("Terms"). By using this Platform, you agree to the terms and conditions of this Privacy Policy. You also consent to our use and disclosure of your Personal Information (as defined below) in the manner described in this Privacy Policy. The capitalized words used in this Privacy Policy but not defined herein, shall have the meaning given to such words in the Terms. If you do not agree with the terms and conditions of this Privacy Policy, please do not use this Platform.
Information we collect and how we use it
| Information We Collect | How We Use It |
|---|---|
Log-in Data. User ID, mobile number, OTP/password, and IP address (collectively, "Log-in Data"). Additional Profile Information. Alongside the Log-in Data, we also collect details such as your name, gender, date of birth, time of birth, and place of birth on a one-time basis for creation of your account. We may also collect an indicative age range which tells us that you are of the appropriate age to access our Platform and certain features of our Platform. Content You Share. This comprises all of the information you make available to the Platform, such as information about you or relating to you that is voluntarily shared by you on the Platform, including without limitation, any quotes, images, statements, political opinions, religious views, etc. This also includes information about you (including Location Data and Log Data) that you share with the Platform or communicate while interacting on the Platform. Information We Receive from Other Sources. We may also be working closely with third parties (including, for example, business partners, sub-contractors in technical, analytics or service providers, search information providers) and may receive information about you from such sources. Such data may be shared internally and combined with data collected on this Platform. Log Data. "Log Data" is information that we automatically collect when you use the Platform, whether through the use of cookies, web beacons, log files, scripts, including, but not limited to: Technical information, such as your mobile carrier-related information, user ID, configuration information made available by your web browser or other programs you use to access the Platform, your IP address and your device's version and identification number. General information about communications on the Platform, such as the identity of a user that you have communicated with and the time, date and duration of your communications; and metadata, which means information related to you that you have made available through the Platform, such as the date, time or location that a shared photograph or video or text shared while accessing the Service. Cookies. Our Platform uses cookies to distinguish you from other users of our Platform. This helps us to provide you with a good user experience when you browse our Platform and also allows us to improve the Platform. We collect the cookie data from the cookies on your device. Surveys. If you choose to participate in a survey, we may request you to provide certain Personal Information, i.e. any information that could be used to identify you ("Personal Information"). We may use a third-party service provider to conduct these surveys and this will be notified to you prior to you completing the survey. | To set up and facilitate log-in to a user account on the Platform. To notify you about changes to the Platform, including this Privacy Policy. To facilitate communication through the Platform, phone and email, including provision of user support and enablement of services. To enforce our terms, conditions, and policies and any of our rights, or the rights of our affiliate companies, or the Platform. To develop new services and improve the existing services and the Platform and integrate user feedback and requests. To provide language and location-based personalization. To administer the Platform and for internal operations, including troubleshooting, data analysis, testing, research, security, fraud-detection, account management, and survey purposes. To better understand how you use and access the Platform and to improve the user experience on the Platform. To pseudonymise and aggregate your information, including Personal Information, for conducting user demographic analysis on items such as region, phone model, operating system platform, system language, and the Platform version in order to better understand how our users are using the Platform. To pseudonymise and aggregate your information, including Personal Information, for collection of web and account traffic statistics of what content and services are used when users access third-party services on the Platform. To assess effectiveness of and improve advertising and other marketing and promotional activities. We may share your information, including your Personal Information, with other platforms operated by ZBEL for purposes set out in this Privacy Policy, or the privacy policies of such other platforms. |
User Search Data. Any searches you make on the Platform. | To provide you quick access to your previous interaction on the Platform. To use analytics for personalization and showing you targeted advertisements. |
Additional Account Security. We collect your phone number and request access to the SMSs on your phone by sending you a One-Time-Password ("OTP"), which you confirm by entering the OTP to confirm your identity, while registering with our Platform. | To verify your identity and for maintaining your account security. |
Location Information. "Location Data" is information that is derived from your GPS, IP address that contains location information. You will disclose certain location information to us:• When you use certain location-based features on the Platform, and/or any other feature or mini applications that we may introduce on our Platform from time to time.• When you access the Platform, as we derive location information from your IP address, device or internet service to prevent multiple or fraudulent log-ins to your account. | For security, fraud-detection and account management (such as to ensure that there are no multiple log-ins or suspicious log-ins on your account). To provide you with location-based services that you choose to use, including mini applications that may be made available on the Platform from time to time, which may require such information based on the services that they provide (if you choose to disclose your location to any mini application). To provide language and location customisation. |
Customer Support Information. Any information that you provide to our customer support team regarding any assistance or support that you may require for using our Platform from time to time. | To investigate your support issue. |
Device Data. "Device Data" includes without limitation, the following: Device attributes: Information such as the operating system, hardware and software versions, battery level, signal strength, available storage space, browser type, app and file names and types, and plugins. Device operations: information about operations and behaviours performed on the device, such as whether a window is foregrounded or backgrounded. Identifiers: unique identifiers, device IDs, and other identifiers, such as from games, apps or accounts you use. Device signals: We may collect your Bluetooth signals, and information about nearby Wi-Fi access points, beacons, and cell towers. Data from device settings: information you allow us to receive through device settings you turn on, such as access to your GPS location, camera or photos. Network and connections: information such as the name of your mobile operator or ISP, language, time zone, mobile phone number, IP address and connection speed. Application: Any mobile applications that are stored on your mobile device. Media: We access the media gallery on your mobile device, including without limitation, images, texts, videos and audio files and the storage space on your phone. However, we shall always obtain your consent before accessing your images and you shall have the option to deny us such access. | To facilitate the sharing of any media such as audios, texts, videos, and images using the Platform; To customise our Platform to suit your mobile device; To optimise your user experience on our Platform; To facilitate the sharing of any content on the Platform via the applications downloaded on your mobile device; To verify your identity so as to enforce our terms, conditions, and policies; To improve the Platform. |
Internal training
We may use submitted conversations, feedback and related usage data for internal training, evaluation and improvement of our AI systems, subject to applicable law and any consent or choices presented in the app.
Disclosure of Your Information
We disclose your information in the following manner:
Content Visible to Others
Any information you voluntarily disclose to the Platform, including your interaction to avail Service, texts or your Profile Information, is accessible to the Platform.
We will never rent or sell your Personal Information to third parties, except on an anonymized basis, unless expressly provided in these Terms.
Sharing with Our Group of Companies
We may share your Personal Information with any member of our Group. The term "Group" shall mean any entity that is controlled by us, or any entity that is in control of us, or any entity that is under common control with us, whether directly or indirectly.
Sharing with Third Parties
We may share your information (including Personal Information) with select third parties including:
Business partners, suppliers and sub-contractors ("Affiliates"). Affiliates may use this information to help provide, understand, and improve the Service and Affiliates' own services. Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users (for example, we may inform them that any given number of women in a specified age group clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target.
Government bodies or law enforcement agencies, if we have good-faith belief that it is reasonably necessary to share your personal data or information in order to comply with any legal obligation or any government request; or to protect the rights or prevent any harm to the property, or safety of ZBEL, our customers, or public; or to detect, prevent or otherwise address public safety, fraud, security or technical issues.
We may also disclose your information (including Personal Information) to select third parties in the following circumstances:
If ZBEL or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets. If we are involved in a merger, acquisition, bankruptcy, reorganization or sale of assets such that your information would be transferred or become subject to a different Privacy Policy, we will notify you in advance so you can opt out of any such new policy by deleting your account before transfer. In order to enforce or apply our Terms and/or any other agreements.
Security Practices
We have in place appropriate technical and security measures to secure the information collected by us. Where we have given you (or where you have chosen) a username and password which enables you to access the Platform, you are responsible for keeping these details confidential. We ask you not to share your password with anyone.
Where we store your Personal Information
We store your data with Google Cloud Platform provided by Google LLC (headquartered at 1101 S Flower St, Burbank, California 91502, USA) on their servers located in India and abroad. Google Cloud Platform implements security measures to protect the loss, misuse and alteration of the information, details of which are available at . The privacy policy adopted by Google Cloud Platform are available at Privacy Policy – Privacy & Terms – Google .
Changes To this policy
ZBEL may periodically update this Privacy Policy. Whenever we make any changes to this Privacy Policy that are important for you to know about, we will post the updated Privacy Policy at this link. It is your responsibility to keep checking this page from time to time in order to be aware of any changes made to this Privacy Policy.
Disclaimer
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Information, we cannot guarantee the security of your data https://cloud.google.com transmitted to the Platform; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Your Rights
You are free to remove or delete your account information or your account/profile at any point in time. However, the history of your activities and account on our Platform remains available to us, including when we delete your account or content as per our data retention policies.
You may correct, amend, add or delete Personal Information from your account at any time by logging in and visiting your profile page. As noted above, you may opt out from unwanted e-mail communications from us by following the instructions in the message. However, until your account is deleted you will continue to receive all system e-mails. Under Section 5(6) of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 ("Rules"), you have a right to ask us to review, correct and amend the information we collect about you at any point in time. Under Section 5(7) of the Rules, you also have the right to revoke your consent to the collection of your information going forward. However, please note that revoking your consent may negatively affect your use of the Platform. For instance, we need to send you a notification for which we need access to your mobile device so that you can allow us for notification, which functionality will not be available to you if you do not provide us such access. You may also ask us not to process your personal data for marketing purposes. You can exercise any of these rights at any time by contacting us at . However, we require a reasonable period of 30 (thirty) days to comply with any of your requests.
Additionally, for deleting your account from the Platform and removing your data, please go to the settings of your App and click on the 'Delete Account' option. For more information, please refer to the FAQs on Account Deletion and our data retention policies.
Data Retention
We do not retain your Sensitive Personal Information (defined below in this paragraph) for longer than is required for the purposes for which the information may be lawfully used. We may further retain user content including but not limited to chat recordings etc for the performance of contract with certain third parties, Platform's business purposes, provision of products offered on the Platform, and for compliance of applicable law. For any other content, we will entertain your request for deletion. You can also choose to delete your account. Upon such deletion, the account shall be deactivated and retention period of upto thirty (30) days shall commence from such date of deletion. You may request us to reactivate your account. Upon expiry of such retention period, the account and associated data shall be permanently deleted for you. Further your account may be auto deleted due to inactivity. There is also a possibility that copies of any public content may be retained in our systems, including in cached and archived pages of the Platform, or if other users have copied or saved that information. In addition, due to the support@bulletshorts.com nature of the Internet, copies of your content, including content that we/you have removed or deleted from your account, may also exist elsewhere on the Internet and be retained indefinitely. "Sensitive Personal Information" shall mean passwords and any other information that is classified as sensitive under Section 3 of the Rules.
Third Party Links
The Platform may, from time to time, contain links to and from the websites of our partner networks, advertisers, Affiliates and/or any other websites or mobile applications. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites or mobile applications.
In the event of any conflict or inconsistency as to the applicability of the policies, the terms of service of such third parties shall govern the usage of the third party product/services and the ZBEL Platform policies available here shall govern the content available on the Platform and the services provided by ZBEL.
Communications from us
We may from time to time send you service-related announcements when we consider it necessary to do so (such as when we temporarily suspend the Platform for maintenance, or security, privacy, or administrative-related communications). We send these to you via SMS. You may not opt-out of these service-related announcements, which are not promotional in nature and used solely to protect your account and keep you informed of important changes to the Platform.
Email:
Note - Kindly send all user related grievances to the above mentioned email ID, in order for us to process and resolve the same in an expeditious manner. support@bulletshorts.com