Draft for you to finish. This page was written to match how Capzul really works, but it is a starting point, not legal advice. Fill in every yellow gap, make the decisions marked in yellow, have a lawyer check it, then delete this box. Capzul's launch check will not call you ready while yellow gaps remain.
Privacy Policy
Last updated: [ADD: date]
Capzul is run by [ADD: your legal name, and your registered address] (“we”). This explains what we collect, why, who sees it, and how you can delete it. Capzul is for adults only (18+).
What we collect
- Your account: nickname, avatar, your email or phone number, your password (kept only as a one-way scramble that nobody can read back), your Google sign-in id if you use it, your date of birth (only to check you are 18 or older), and, if you choose to give it, your gender (used for who you choose to meet).
- How you use Capzul: the moods you pick, your language and matching choices, when calls happen and how long they last, feedback you give, reports and blocks, your friends and friend requests, streaks and bonus minutes. Other people only ever see your nickname and avatar.
- Messages between friends: text only. They are deleted automatically after [ADD: keep this number in step with MESSAGE_RETENTION_DAYS, currently 90] days.
- Payments: handled by Razorpay. We receive the order and payment ids, the plan, the amount and whether it worked. We never see your card, UPI or bank details.
- Notifications: if you allow them, an address from your browser that lets us send you a notification.
- Technical: your IP address is used by our server to keep the service safe (for example to slow down abuse) and may appear in our hosting provider’s logs [ADD: name your hosting provider and how long its logs are kept]. One sign-in cookie keeps you logged in. We use no advertising or tracking cookies.
- Fonts: the app loads the Poppins font from Google Fonts, so Google’s servers see your IP address when a page loads. [ADD: delete this line if you host the font yourself]
Being found by other people
- Anyone with a (non-guest) account can search for you by nickname, or by your nickname and tag (like "Asha#4821"), if "Let people find me" is on in Settings. It is on by default for new accounts and you can turn it off at any time. {A("confirm with your lawyer whether on-by-default is acceptable for your users, or switch the default off with DISCOVERABLE_DEFAULT=0")}
- When someone finds you they can see only your nickname, avatar, tag, listener level and the month you joined. They cannot see your email, phone number, date of birth, gender, moods, calls, friends or when you are online.
- Anyone you have blocked, and anyone who has blocked you, never sees you in search and cannot send you a request. You can choose that only people you have talked to may send you requests.
- If you decline a request we remember that for {A("same as DECLINE_COOLDOWN_DAYS, currently 30")} days, so the same person cannot keep asking. They are not told.
- Guest accounts cannot be found and cannot search.
Voice calls
- We do not record calls and we do not store what you say.
- Audio goes straight between the two phones when it can. If a network blocks that, it passes through a relay run by our relay provider [ADD: name your relay provider, for example ExpressTURN, and where it runs]. WebRTC encrypts the voice between the two phones even when it is relayed.
- Text you send (in chat and messages) is checked automatically for links, phone numbers, emails and words that suggest someone may be in crisis, to keep people safe.
Why we use your information
To run matching and calls, keep people safe, take payments, understand how the service is doing (we look at totals, not at individuals), and meet legal duties. We do not sell personal information and we do not show advertising.
Who else sees it
- Razorpay, to take payments.
- Our voice relay provider, only when a call needs a relay (it sees encrypted voice packets and network addresses, not what is said).
- Our hosting provider, who stores the data [ADD: name, and where its servers are].
- Your browser’s push service (Google, Apple or Mozilla), only to deliver notifications you allowed.
- The authorities, only when the law requires it.
How long we keep it
- Messages: [ADD: same number as above] days.
- If you delete your account (Settings in the app), your login details, date of birth, friends, activity, messages and notification subscriptions are removed straight away and your profile becomes “Deleted user”.
- Your choice about being found, and declined requests (for the number of days above), are removed when you delete your account. We keep payment records for [ADD: how long the law requires you to keep accounting records], and safety reports for [ADD: how long you keep reports]. After deletion these are no longer linked to a name.
Your rights
Under India’s Digital Personal Data Protection Act, 2023 you can ask what we hold about you, ask us to correct it, ask us to erase it, complain, and name someone to act for you if you cannot. Delete your account yourself in Settings, or write to [ADD: privacy email address]. We will reply within [ADD: a number of days you can keep].
Complaints
Grievance Officer: [ADD: name], [ADD: email]. [ADD: response time you promise]
Children
Capzul is not for anyone under 18. If we find an account belonging to someone younger, we remove it.
Changes
If we change this page in a way that matters, we will tell you in the app before it takes effect. These terms are governed by the laws of India. [ADD: the city whose courts you choose, with your lawyer]