‘Lokuttara’ (hereinafter “we”, “us”, “our”) has designed a mobile application named ‘Jai Bheem’ which shall endeavour to publish the recorded media on the mobile device of the user.

We respect the privacy of everyone who uses our Mobile Application. This privacy policy (“Privacy Policy”) describes and applies the below mentioned procedures for collecting, using and disclosing the information shared with us by the User for availing the Services or accessing the Mobile App.

When a User downloads and uses the Mobile APP, the User is not required to provide any of the Personal or confidential Information unless and until the User chooses to avail Services. In addition to this, by agreeing to avail Services and by submitting the Personal Information, the User consents to the collection, transfer, processing, storage, disclosure and other uses described in this Privacy Policy.

We use encryption techniques, network isolation and access control measures to ensure that your data is stored securely.

1. ‘Jai Bheem’, (hereinafter “the Mobile Application”, “Jai bheem”) shall mean the Mobile Application / Mobile App.

2. ‘Permissions(s)’ shall mean all types of Permissions regarding collection, transfer, processing, edit, storage, disclosure, access and other use of information that is obtained from its registered Users while using the Mobile Application.

3. ‘Personal Information’, “Confidential Information”, “Personal data” shall mean the information that can be collected, controlled or used to personally identify the Users, including but not limited to User’s name, address, telephone/mobile number, e-mail address, login id, password, personal photo, age, gender, family details, birth date, educational qualification, information in relation to the User’s business or occupation, and other information of similar nature.

4. ‘Service(s)’, shall mean the various in Mobile Application Services that are being provided to its Users.

5. ‘User(s)’, ‘customers’, ‘subscribers’ shall mean the Users who may have registered with the Mobile Application and are able to access and avail the Services of the said Mobile Application.

6. ‘You’ or ‘Your’ or ‘Yourself’ refers to the Users or viewers of this Mobile Application.

Mobile Application provides certain Services (“Services”) to registered Users (“Users”) through Jai Bheem.

This Privacy Policy applies to Personal Information collected and controlled by us, about the Users’, when they use Services and register on the Mobile Application. We recommend the Users to read this Privacy Policy in order to understand our approach towards the use of Personal Information.

When a User agrees to use the Mobile Application and thereby chooses to avail the Services, User is required to create an account with the Mobile Application by using the sign-up option available (“User Account”). During such creation of account and thereafter, User shall be required to share/upload/grant access to certain Personal Information or mobile device. User may need to mention the personal information while signing up on the Mobile Application. User shall be responsible for maintaining the confidentiality of such account and password and User agrees to accept responsibility for all activities that occur under such account. Users can change the profile information and any other details that are shared with the Mobile Application and User shall promptly update the email address listed in connection with the account to keep it accurate so that we can contact the User. User shall provide any additional information as required by the Mobile Application from time -to- time. We also reserve the right to refuse registration or sign up or delete accounts at our sole discretion. User must not set up an account on behalf of another individual or entity unless authorized. User agrees to abide by all applicable laws and regulations and are solely responsible for all acts or omissions committed by such User.

User understands that, User shall be solely responsible for the accuracy and truthfulness of the Personal Information shared with us. In the event if the User is sharing any Personal Information on behalf of a third person, the User represents and warrants that the User has the necessary authority to share such Personal Information with us and we shall not be responsible for verifying the same. The User understands and acknowledges that all Personal Information shall be subject to the terms and conditions of this Privacy Policy.

User understands, acknowledges and agrees that certain services can be availed only when you grant access to your mobile device features including but not limited to contact list, text messages, file folders on device or on SD Cards, to modify, delete content, read all content on device and SD Card, camera, photo gallery, finger prints, face recognition.

We collect information which is needed to provide You Your desired Services including but not limited to User’s name, e-mail address, login id, password of your social media accounts, you mobile service carrier, device make, data connectivity, permissions manager and any other information in relation that is required to render Service to Users and other information of similar nature. We do not obtain or collect User’s Personal data from third parties, we directly collect data from User at the time of registration with our Mobile Application.

The Personal Information is collected and used to:

1. Provide and improve the Services.

2. Monitor User activity, such as keyword searches and more effectively manage traffic on the Mobile Application.

3. Create and manage User Account and to improve the quality and experience of the Mobile App and Services, including but not limited to resolving the technical issues raised by the Users

4. Customise User’s experience.

5. Measure User’s interest in our Services.

6. Manage the relationship with User.

7. Maintain and update our records.

8. Inform User about present and future online and offline offers, updates, Services etc.

9. Monitor, manage, control and prevent the suspected fraud, misconduct and unlawful activities on the Mobile Application.

You hereby authorise the Mobile Application and grant consent to it to collect this information from You. By sharing such Personal Information, the User agrees that we may also use such Information to contact User and deliver information to User that, in some cases, is targeted to User’s interests, such as targeted User advertisements, Service provider offers, promotions, notifications and communications relevant to User’s use of the Mobile Application. By accepting this Privacy Policy, User expressly agrees to receive this information.

We understand and are committed to our responsibility to safeguard your data. We use encryption techniques, network isolation and access control measures to ensure that your data is only available for access to authorized personnel.

Passwords – Your Jai Bheem User account information including email address, username and password are all password protected. Access to your User Account is secured by a unique user name and password that is known and available only to you. We encrypt customer passwords to protect it. No Lokuttara stakeholders have the right or obtain access to your password except mentioned otherwise in this policy. Neither Lokuttara employees nor any of its contractors are authorised to ask you to share your password via telephone, email or SMS or any other unsolicited manner.

Secure Data Storage and Transfer – Lokuttara stores the data collected in encrypted format and in highly secure server environment with round-the-clock surveillance, monitoring and support. This prevents any unauthorised access of your personal data. Additionally, we endeavour continued security of your data using advanced security measures including surveillance, firewall and continued protection of your data against intruders.

We value User’s Personal Information; we will ensure an adequate level of protection. We have therefore implemented technology and policies with the objective of protecting Users Personal Information from unauthorised access and improper use and will update these measures as new technology becomes available, as appropriate. All Personal Information is securely stored. As a matter of security, we take back-up of systems periodically. Although we provide appropriate firewalls and protections, our systems may be susceptible to external forces, unauthorised access, hacking, virus attacks, malware attacks. Data pilferage due to unauthorised hacking, virus attacks, malware attacks, technical issues is possible, and we take no liabilities or responsibilities for it.

Users are responsible for all actions of the User account and password. Therefore, we do not recommend User to disclose the password to any third party. If a User chooses to share the User account and password or any Personal Information with third parties, at such times the User shall be solely responsible for the same. If User loses control of the password, then the User may lose substantial control over the Personal Information and may be subject to legally binding actions.

In case the User needs to access, remove, review, and/or make changes to the Personal Information that User has provided to us, User may do so by logging into User account. User may change the Personal information. User understands that we shall not verify or authenticate the changes made by User and therefore such User take entire responsibility of such changes. User confirms that such changes shall be in accordance with the terms and conditions of this Privacy Policy. We may send User any legally required notifications and certain notifications, including but not limited to; Service related notification or alerts regarding a change to any of our policies. For example, we may notify regarding server problems or scheduled maintenance to the Mobile Application. In order to opt-out of receiving these notifications, You may do so through the Mobile Application. The User can opt out of certain e-mail communications from us, including our newsletters, if any, advice on networking on the Mobile Application. We will not change User’s preferences without their consent.

We will retain User’s Personal Information as long as it is reasonably required or otherwise permitted or required by applicable law or regulatory requirements even after User’s account is terminated. We may also retain User’s Personal Information so long as it is necessary to fulfil the purposes for which it was collected (including for purposes of meeting any legal, administrative, accounting, or other reporting requirements). User’s Personal Information is safeguarded against inappropriate access and disclosure, as per this Privacy Policy. We may retain and use User’s Personal Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Consistent with these requirements, we may delete User’s Personal Information, upon reasonable request. We may also need to retain certain data for record-keeping purposes, and there may also be residual information that will remain in our databases and on other records, which will not be removed. Please note that there might be latency in deleting the Personal Information from our servers. In addition, we do not delete files that You have in common with other Users. The encrypted data stored by the user is not accessible to any employees or contractors of Lokuttara.

We do not knowingly collect Personal Information from the children who are under 18 years. Children should obtain Permissions from their parents or guardians before sharing any Personal Information about themselves to the Mobile Application. The content uploaded/ created by any children below 18 years of age would be entirely the parents’ responsibility and the Company will not be responsible for specifically offloading or censoring the same.

We may automatically collect non-Personal Information about User such as the type of internet browsers User use or social media application from which User linked to our Mobile Application. We may also aggregate details which User has submitted to the Mobile Application (for example, User’s age, the town where a User live, gender, educational qualification, business or activity etc) or we have gathered during the course of providing Services. User cannot be identified from this information and it is only used to assist us in providing an effective Service on this Mobile Application. We may from time to time supply third parties with this non-personal or aggregated Information in connection with the Services and this Mobile Application.

The details related to the aggregation of information provided by the User on the Mobile Application shall be used for our reference. But the details of individual information shall not be used by us.

The Mobile Application may seek prior permissions including but not limited to file folders on device on memory cards, read content and modify, delete the content of your SD cards and device, camera, photo gallery, finger prints, face recognition, view network connections and evaluate, receive data from internet, disable your screen lock, control vibration, google play billing service, close other apps, connect disconnect from Wi-fi, connect to VPN and use for data movement, camera access, Google sign in permission or any other personal information of the User while accessing relevant features of the Mobile Application. By Agreeing to use the mobile application you grant us permission to access such permissions. In case such permissions are not granted the Users may not be able to use all or some of the Services offered by the Mobile Application.

• Access Network State: To allow user to understand and analyse speed of network, signal strength, hotspot connections, the app requires permission to access the state of network..

• Access Wi-Fi State: This permission allows the app to confirm if the WiFi status is On/Off.

• Access Live Location: This permission allows the app to track the live location of the device at the time of creation of content and/or uploading of content online.

What Important Permissions we request

By agreeing to use this Mobile Application, you willingly provide the following permissions:

• Access to Device and Read Write External Storage: The Mobile Application requires this permission to allow users to store images on device and SD Card, read, write, delete, modify information stored thereon.

• Read Phone State: This permission is needed to help the app detect the ID of device.

• Read Write Contacts: In order for the user to initiate a data purge using Mobile Application requires permission to read their contact list.

• Access External Device: In order for the application to detect mounted devices and external storage devices

• Access Camera: In order for the application to capture photos and videos for publishing on the application

• Access Microphone: In order for the application to record audio along with the video recorded by the application

• Access Gallery Media: In order for the application to upload any media already recorded by the users and to edit any media already recorded by the user.

• Internet: Permission to connect to the internet is required in order to allow user to access features like Jai Bheem chat for secure audio and video calling, connected devices, network speed, file transfer, data theft, password protector and social accounts.

• Notifications: Review of Notifications received on the Device.

Jai Bheem enables a User to record, edit, upload and publish media content on the JAI BHEEM platform to its users at large or class of users as may be selected by the creator of the content:

Data Protection Principles:

• Your Right to Have Your Personal data Erased: As we are merely custodians of Your Personal data, account Users have the right to instruct Us to remove data permanently from our systems. To ensure that no one’s data is deleted without their consent, You must first delete Your account through an authenticated session. After Your account has been deleted, the account owner may contact us and ask for the Personal data to be expunged. Once the request is authenticated, the data will be removed from our active systems within 72 hours. However, the User understands, acknowledges and agrees that old data may still remain on the back-up storage media and servers.

• Your right to access and control Your personal data: You can also make choices about collection and use of Your data by Us. You can control Your personal data and exercise Your data protection rights by contacting Lokuttara by email at hello@jaibheem.live. You can add, remove, edit or change any data that are in the Password Protector vault.

In case of any purchases, subscriptions of other applications within the Mobile Application, we may transfer User’s information to third parties as a part of that purchase or subscriptions after receiving Your consent. The payment mode for any transaction made by User shall be online and via debit or credit cards, Net Banking or any other supported billing method etc.

The User hereby shall grant consent to have read the limitations regarding such purchases, subscriptions as to what have been included and/ or excluded in such purchase or subscription and privacy policy and terms of use of that particular mobile application.

1. We may share or provide the Personal information or links to third party applications or Service providers as a convenience to User, such as User’s browser capabilities, asset views, operating systems etc that we have collected in order to better understand which advertisements and Services may interest the User.

2. We may have links to other mobile applications, or a User is referred to our Mobile Application through a link from another website or mobile applications. We shall not be responsible for the privacy policies and practices of such websites or mobile applications. The content is subject to their terms of use and any additional guidelines and privacy information provided in relation to that use on their website or mobile applications.

3. We recommend that the User to check the policies of such website and mobile application while accessing, to better understand User’s rights and obligations especially when a User is submitting any type of content on those third-party websites or mobile applications. The User shall contact the owner or operator of such websites or mobile applications in case of any questions or concerns.

The User hereby understands and acknowledges that we are not responsible for the way those third parties use the information, hence the User shall make sure that User engages with such website or mobile applications by own volition and does not rely on any representation made by us whether implied or otherwise.

We may set “cookies” on the use of the Mobile Application by Users. Cookies are small encrypted files, that a Mobile Application transfers to User’s mobile device that enables Mobile Application to recognise User’s choices, preferences, selections, and stores to remember such information to enhance User’s experience and cater to User’s needs better.

Users may set their mobile device to refuse all or some Cookies. If User disables or refuses Cookies, please note that some features of our Mobile Application may not function adequately or may no longer be accessible.

We may use the uploaded activity data, in an aggregated manner, that would not personally identify a User, for enhancing the quality of our Services. Keeping in mind the rules regarding Privacy Policy, we may send, rent, share, distribute, lease or otherwise provide or disclose User’s Personal Information to third parties in the following circumstances –

• Administrators – We may provide access to User’s Personal Information to any of our authorised administrator for an internal business purpose, who shall be under confidentiality obligations towards the same.

• Affiliates – We may provide Personal Information that we collect to our affiliates. For example, we may disclose Personal Information to our affiliates in order to respond to User’s requests for information or Services and for such other obligations.

• Third Party Applications – We may share Your information to third party application, for example when You choose to access any such third party application. You understand and acknowledge that we are not responsible for the way those third parties use Your information, so You should make sure You trust the application and that it has a Privacy Policy acceptable to You.

• Joint marketing arrangements – Where permitted by law, we may share User’s Personal Information with joint marketers with whom we have a marketing arrangement, we would require all such joint marketers to have written contracts with us that specify appropriate use of User’s Personal Information, require them to safeguard Your Personal Information and prohibit them from making unauthorized or unlawful use of Your Personal Information.

• Legal and regulatory authorities – We may be required to disclose User’s Personal Information due to legal or regulatory requirements. In such instances, we reserve the right to disclose such Personal Information as required in order to comply with our legal obligations, including but not limited to complying with court orders, warrants, or discovery requests. We may also disclose User’s Personal Information to law enforcement officers or others, in the good faith and belief that such disclosure is reasonably necessary; respond to claims that any Personal Information violates the rights of third-parties; or protect the rights, property, or personal safety of us, our Users or the general public. User agrees and acknowledges that we may not inform a User prior to or after disclosures made according to this section. Along with Personal Information we may, if required under applicable law, disclose other information which shall include but not limited to technical information about make of your device, location, browser and device information, app usage data, pixel tags and other technologies, demographic information and other information provided by You or collected by us.

Notwithstanding anything mentioned hereinabove, we shall not be responsible for the actions or omissions of the parties (including but not limited to the entities listed above) with whom the Personal Information is shared, nor shall we be responsible and/or liable for any additional information User may chooses to provide directly to any third party.

We are interested in User’s views, and we value the Feedback (defined below) we receive from a User. However, we do not have control or are responsible for any such Feedback or the Personal Information which User makes available through the Mobile Application. We encourage the User to be careful regarding the Personal Information so disclosed. Subject to any applicable law, any communication or feedback sent by You to the Mobile Application (including without limitation testimonials, contents, images, audio, feedback etc. collectively “Feedback”) is on a non-confidential basis, and we are under no obligation to refrain from reproducing, publishing or otherwise using it in any way or for purpose. We can use the feedback including without limitation any ideas, inventions, concepts, techniques or know-how disclosed therein, for any purpose including without limitation developing, manufacturing and/or marketing Services. User shall not assert any ownership right of any kind in the Feedback (including without limitation copyright, patent, trademark, unfair competition, moral rights, or implied contract) and User hereby irrevocably waive the right to receive any financial or other consideration in connection with the Feedback, including without limitation acknowledgment of You as the source of the Feedback. User’s submission of any Feedback shall constitute an assignment to us of all worldwide rights, titles and interests in all copyrights and other intellectual property rights in the Feedback. For this reason, we ask that the User not to send us any Feedback wherein a User do not wish to assign to us, including any confidential information, Personal Information or any original creative materials. User shall be responsible for the content and information contained in any Feedback sent by such User to the Mobile Application or otherwise to us, including without limitation for its truthfulness and accuracy.

Mobile Application will not be liable for any damages, direct or indirect, incidental or consequential, and all liabilities (including for negligence, loss or damage such as loss of revenue, unavailability of system or loss of data and loss of Your Personal Information) and for use of or inability to use Services of any kind that is offered or to provide indemnity or any other remedy to the User or any third party.

In addition to the indemnification commitment provided in Terms of Use, User agrees to indemnify us, our partners, affiliates, officers, agents and employees and hold us harmless from and against any claims and demand, including reasonable attorney’s fees, made by any third party due to arising out of or relating to:

1. Inaccuracies and/or incorrectness of Personal Information and contents that User submits to the Mobile Application;

2. User’s violation of this Privacy Policy;

3. User’s violation of any rights of another User.

All rights not expressly granted in this Privacy Policy are reserved by us. Nothing contained in this Privacy Policy shall be construed as conferring by implication, estoppels or otherwise any license or right under any copyright, patent, trademark or other intellectual property right or any other person or to User.

This Privacy Policy is governed by the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules 2011 and modifications and revisions from time to time, which is designed to protect Personal Information; other relevant laws, and policies of Mobile Application and other applicable laws in India. The Governing Laws in whatsoever case shall be Indian Laws and regulations and Mumbai, Maharashtra, India shall have sole and exclusive jurisdiction over such disputes.

From time to time we may update this Privacy Policy. If we make any substantial changes to this Privacy Policy and the way in which we use the Personal Information of the User, we will post these changes on this page and it shall be User’s responsibility to be aware of any significant changes. Please check our Privacy Policy on a regular basis. The changes are effective immediately after the same posted on Mobile Application.

If You have questions or concerns or grievances regarding this Privacy Policy, You can contact us at hello@jaibheem.live

You agree and acknowledge that the Mobile Application provides Services in India. There are certain privacy related regulations applicable to certain specific geographies outside India, such privacy related regulations and protections may not be applicable in India. The Privacy rules, regulations and rights may differ from Your local geographical legal systems and You may not receive the same privacy protection benefits or rights in India.