This Privacy Policy describes the manner in which Shunya, together with its affiliates, group entities, service providers, technology partners, and authorised processors, collects, receives, stores, organises, uses, processes, shares, transfers, discloses, retains, and otherwise handles information relating to individuals who access, browse, install, register on, subscribe to, interact with, communicate through, or otherwise use the Shunya mobile application, website, APIs, and all associated digital interfaces, features, and services (collectively, the "Platform").
This Privacy Policy applies to all users of the Platform, including visitors, registered users, subscribers, participants in engagement modules, users of communication features, purchasers of premium access, and all persons who otherwise provide information to Shunya or whose information is collected through the Platform.
By accessing or using the Platform, or by submitting information to Shunya, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your information in the manner described herein, to the extent such consent is required under applicable law. Where the law requires a higher standard of consent for particular categories of processing, Shunya may seek additional, granular, express, or feature-specific consent before enabling such processing.
For the purposes of this Privacy Policy, the entity controlling your information shall be Ultrarich Entertainment Pvt. Ltd., together with such affiliates, subsidiaries, associates, and authorised processors as may be engaged in connection with the operation, hosting, maintenance, monetisation, moderation, analytics, compliance, or improvement of the Platform.
Where the Platform is technically developed, maintained, hosted, supported, or integrated by a technology developer or implementation partner, such entity may process information strictly on behalf of and under the instructions of Shunya, except where such entity independently acts as a service provider, processor, infrastructure partner, security partner, analytics partner, or legally obligated recipient under applicable law.
Shunya may collect information that you provide directly, information collected automatically through your use of the Platform, information derived or inferred from your interactions, and information obtained from third parties, platform partners, payment providers, or lawful public and private sources.
The information that you provide directly may include your name, mobile number, email address, date of birth, username, display name, password or authentication-linked details, billing and subscription details, location declarations, demographic information, support requests, grievance submissions, profile image, profile description, payment information submitted through payment processors, KYC-related details, tax-related information, declarations, consents, preferences, communication content, chat messages, comments, reviews, uploaded content, creator interaction submissions, contest or engagement participation inputs, and any other information you voluntarily choose to provide.
The information collected automatically may include device information, device model, operating system details, application version, IP address, unique identifiers, advertising identifiers, browser type, network type, telecom operator indicators, session timestamps, login activity, log files, crash reports, diagnostic information, performance reports, clickstream data, page views, content views, watch duration, scroll behaviour, interaction history, referral source, cookies, pixels, SDK signals, campaign identifiers, app event telemetry, screen flow data, transaction metadata, geolocation indicators based on IP or device permissions, and fraud-risk or anomaly indicators.
The information derived or inferred by us may include inferred language preference, likely age-band, likely territory, subscription propensity, content preference, watch patterns, likely interest categories, safety or abuse risk signals, payment risk signals, engagement profile, churn probability, ad relevance indicators, moderation risk, user segmentation data, and internal account integrity assessments.
Where communication or live interaction features are used, Shunya may collect and process audio, video, text, voice notes, call recordings, live session recordings, transcripts, attachments, metadata relating to such communications, timestamps, participating account identities, moderation flags, abuse reports, and support or compliance annotations. This is consistent with the broad communication recording and processing framework reflected in the material you provided.
If you use payment features, we or our payment partners may process billing name, billing address, payment instrument details, transaction references, gateway response codes, subscription renewal data, chargeback details, tax components, refund processing details, and fraud-screening outcomes. Sensitive payment credentials such as complete card numbers may be processed by regulated payment intermediaries and not necessarily stored directly by Shunya.
If KYC, creator onboarding, reward release, pay-out, contest verification, or legal compliance features are introduced, we may collect identity documents, PAN, GST details where applicable, bank details, address proofs, selfies, declarations, and such additional information as may be necessary for verification, tax compliance, fraud prevention, or release of benefits.
Shunya may receive information about you from third-party service providers, social login providers, app stores, operating system providers, payment gateways, analytics partners, ad networks, anti-fraud providers, cloud providers, customer support tools, moderation tools, communication vendors, marketing partners, public sources, lawful government or regulatory records, and other service providers engaged in operating the Platform.
Such information may include authentication confirmation, user identifiers, payment status, subscription validation, device risk scoring, campaign attribution data, ad identifiers, user acquisition source data, fraud-screening results, KYC verification outputs, and other information relevant to operation, security, monetisation, analytics, compliance, or support.
Shunya may collect and process your information for one or more lawful purposes connected with operating and improving the Platform and enforcing rights and obligations.
We may use your information to create, administer, authenticate, and secure your account; to enable access to the Platform and Services; to process subscriptions, purchases, renewals, cancellations, refunds, or credits; to deliver content and features; to personalise the Platform experience; to enable creator interactions, chat functions, or live features; to respond to your requests, complaints, disputes, grievances, or support tickets; to communicate with you regarding services, billing, account actions, legal notices, updates, and promotions; to verify identity, age, location, eligibility, and compliance status; to prevent fraud, abuse, collusion, impersonation, chargeback misuse, payment risk, or unlawful activity; to moderate content and enforce community rules; to conduct analytics, performance assessment, campaign measurement, A/B testing, quality control, and service optimisation; to improve interface design, recommendation systems, engagement pathways, and overall product architecture; to train, validate, test, monitor, and improve automated moderation tools, fraud controls, AI-assisted systems, machine learning models, and product intelligence systems where lawfully permitted; to conduct audits and maintain records; and to comply with contractual, legal, tax, regulatory, judicial, enforcement, and evidentiary obligations.
We may also use your information to protect the rights, safety, security, property, reputation, commercial interests, and technical systems of Shunya, its affiliates, its developer, its service providers, other users, creators, partners, and the public at large.
The broad categories of service operation, account management, legal enforcement, analytics, research, marketing, and feedback processing reflected in your uploaded materials are incorporated and expanded in this Privacy Policy.
To the extent required under applicable law, Shunya processes your information on one or more of the following legal bases: your consent; the necessity of processing for the performance of a contract or pre-contractual steps at your request; compliance with legal or regulatory obligations; the protection of legitimate business interests of Shunya, its affiliates, developer, partners, or users; the prevention and detection of fraud and abuse; the establishment, exercise, or defence of legal claims; and any other lawful basis recognised under applicable data protection laws.
Where specific processing activities require express consent, such as certain categories of communication recording, marketing, or device permission access, Shunya may obtain such consent through in-app prompts, checkbox consent flows, device permission requests, or other electronic mechanisms.
Certain features of the Platform may require access to your device camera, microphone, notifications, storage, media library, contacts, or location services. Such access is requested only where necessary to enable user-facing functionality, such as profile upload, audio/video messaging, recording sessions, live participation, creator interaction, login verification, content download, or location-based compliance checks.
If you decline a requested permission, the corresponding feature may not function correctly or may not be available at all. Shunya shall not be liable for reduced functionality resulting from the non-grant of required permissions.
Device-level permissions can generally be managed through your operating system settings, but disabling them may impair certain features or prevent continued use of specific services.
Where the Platform includes live interaction features, chat, audio, video, creator sessions, community sessions, or related communication tools, you expressly acknowledge and consent that such communications may be recorded, monitored, transcribed, reviewed, flagged, stored, and processed by Shunya for legitimate and lawful purposes.
These purposes may include platform safety, user protection, trust and security review, prevention of fraud or abuse, evidence preservation, complaint handling, support resolution, moderation, dispute resolution, legal compliance, law enforcement cooperation, product improvement, and quality assurance.
Shunya may also use communication records and transcripts to develop, test, validate, and improve moderation systems, automated risk detection tools, artificial intelligence systems, speech or language tools, recommendation systems, and related internal product systems, subject to applicable law. This reflects the communications processing model contained in the source material you provided.
If you do not consent to recording or processing that is inherently necessary for a feature, you must not use that feature.
Shunya may use cookies, local storage, SDKs, tracking pixels, tags, identifiers, analytics scripts, event logging tools, and similar technologies for authentication, remembering preferences, measuring performance, attribution, user analytics, ad targeting, campaign optimisation, fraud prevention, crash reporting, session continuity, content personalisation, and product development.
These tools may be operated by Shunya or by authorised third-party providers acting on our behalf. Depending on your jurisdiction, you may be offered cookie controls, consent management tools, or opt-out mechanisms for certain categories of tracking.
Disabling cookies or identifiers may affect platform performance, content relevance, session continuity, or the availability of certain services.
Shunya may share or disclose your information where reasonably necessary for the purposes described in this Privacy Policy.
We may share information with our affiliates, group entities, developer, cloud and hosting providers, payment processors, payment gateways, anti-fraud partners, analytics providers, communication vendors, CRM vendors, ad-tech partners, campaign attribution partners, identity verification service providers, moderation service providers, customer support tools, legal and professional advisors, tax and accounting advisors, insurers, auditors, content licensors, creator-management partners, platform integrators, and other processors or service providers engaged for legitimate business purposes.
We may disclose information to courts, tribunals, regulators, statutory authorities, law-enforcement agencies, government authorities, tax authorities, financial institutions, payment networks, banks, fraud prevention agencies, or other legally authorised entities where required by law, lawful process, judicial order, investigation requirement, regulatory mandate, or where reasonably necessary to detect, prevent, investigate, report, or prosecute suspected fraud, abuse, cyber incidents, unlawful acts, or violations of our rights.
We may also share your information in connection with any merger, acquisition, restructuring, investment, financing, assignment, business transfer, corporate reorganisation, sale of assets, insolvency-related process, or change of control involving Shunya or a relevant business line, subject to applicable law.
Where user-generated content, profile data, public usernames, display images, badges, creator interactions, community posts, comments, or participation records are intended to be visible to other users or the public through the Platform, such information may be displayed as part of the functioning of the relevant feature. You are responsible for understanding the public or semi-public nature of any content you choose to publish.
Your information may be transferred to, stored in, or processed in jurisdictions other than the one in which you are located, including where our affiliates, hosting providers, infrastructure providers, analytics vendors, support teams, or processing partners operate. Where such cross-border transfer occurs, Shunya shall take such reasonable contractual, technical, and organisational measures as may be required or appropriate under applicable law to ensure an adequate level of protection for your information.
By using the Platform and providing your information, you consent, to the extent permitted by law, to such transfer, storage, and processing.
Shunya does not retain information longer than is reasonably necessary for the purposes for which it was collected, unless longer retention is required or permitted by law, contract, evidentiary need, fraud prevention need, tax and accounting obligations, legitimate business interest, or the defence or exercise of legal claims.
Retention periods may vary depending on the type of data, the purpose of processing, the nature of the Service used, whether the data relates to an active or inactive account, whether a complaint or dispute exists, whether a chargeback or investigation is ongoing, whether moderation records are required for repeat-abuse tracking, whether tax or KYC records must be preserved, and whether back-up systems, archival systems, or legal hold requirements apply.
Even where deletion is requested, certain information may be retained where necessary to comply with law, preserve evidence, defend claims, enforce rights, prevent fraud, comply with financial or tax recordkeeping obligations, or ensure platform safety. The retention logic reflected in the source material you shared has been incorporated and expanded here.
Shunya implements commercially reasonable technical, administrative, organisational, and contractual measures intended to protect information against unauthorised access, alteration, disclosure, loss, misuse, destruction, or accidental compromise. Such measures may include access restrictions, encryption where appropriate, tokenisation, credential controls, logging, vendor due diligence, environment controls, fraud controls, secure development practices, risk screening, and incident response processes.
However, no digital system, transmission method, or storage architecture can be guaranteed to be completely secure. Accordingly, while Shunya strives to protect information, it cannot warrant absolute security and disclaims, to the fullest extent permitted by law, any guarantee that the Platform, communications, or stored data will be entirely immune from attacks, errors, unlawful interception, breaches, malware, infrastructure failure, or other compromise.
Users are responsible for maintaining confidentiality of their credentials, keeping devices secure, avoiding suspicious links, using updated software, and promptly informing Shunya if they suspect compromise.
The Platform is not intended for children and is designed for persons who are legally capable of entering into binding contracts under applicable law. Shunya does not knowingly permit minors to create accounts or use age-restricted services where such access is prohibited under the Terms or applicable law.
If Shunya becomes aware that a minor has unlawfully provided personal information or accessed restricted services, Shunya may suspend or delete the account, remove related information, and take such other measures as may be appropriate or required by law.
Parents and guardians are encouraged to supervise online activity and ensure that minors do not disclose personal information or access inappropriate content or services.
Subject to applicable law, you may have rights in relation to your information, including the right to access information held about you, request correction or updating of inaccurate or incomplete information, request deletion of information that is no longer necessary or lawfully retainable, withdraw consent for future processing based on consent, object to or restrict certain categories of processing, request information about sharing or processing practices, and request portability where recognised by law and technically feasible.
These rights are not absolute. Shunya may decline, defer, or limit compliance with any request where such request is frivolous, repetitive, technically infeasible, unlawful, affects the rights of another person, undermines fraud prevention or safety systems, interferes with legal compliance, affects evidence preservation, or where the information must be retained for contractual, regulatory, tax, dispute, risk, or legal reasons.
Withdrawal of consent will ordinarily operate prospectively and will not invalidate prior lawful processing. Where withdrawal of consent or deletion of data makes continued provision of a service impossible, unsafe, unlawful, or commercially unreasonable, Shunya may suspend or terminate access to the relevant feature or the Platform itself.
Account deletion request can be made through the settings page in the app. However, please note that some data may still be retained for legal, security, or operational purposes as described in the Account Closure and Deletion Consequences section below.
If you close your account or request deletion, certain data may remain in backups, archives, legal-hold systems, security logs, fraud records, compliance records, accounting systems, or support records for as long as necessary for legitimate and lawful purposes. Comments, public content, moderation logs, communication evidence, or records necessary to protect the platform ecosystem may continue to be retained and may not always be fully removable from every downstream or archival system immediately.
If your account is suspended, banned, restricted, or terminated for breach of the Terms, some or all associated data may be preserved for enforcement, evidence, repeat-abuse tracking, fraud prevention, or legal defence.
Shunya may send you service communications and, where permitted by law, promotional and marketing communications relating to content, features, offers, campaigns, subscriptions, updates, events, and affiliated business offerings. You may opt out of non-essential promotional communications through the opt-out mechanism made available in the communication or on the Platform, subject to continued receipt of essential service, legal, billing, security, and account-related communications.
The Platform may contain links to third-party websites, creators, merchants, payment providers, app-store pages, social networks, or external services. This Privacy Policy does not apply to third-party sites or services that Shunya does not control. Your interactions with such services are governed by their own terms and privacy policies, and Shunya is not responsible for their privacy practices, content, or conduct.
In the event of a merger, demerger, restructuring, acquisition, financing, assignment, sale of assets, insolvency process, strategic investment, or transfer of the Platform or relevant business line, your information may be transferred or disclosed as part of due diligence, transition, or completion of the transaction, subject to applicable law and reasonable confidentiality protections.
If you have questions, complaints, requests, or concerns relating to this Privacy Policy or the handling of your information, you may contact:
Grievance Officer / Privacy Contact
Name: Vishal Bihani
Email: vishal@shunya.app
Address: Mumbai, Maharashtra
Phone: +91 6239 589 115
Shunya may require verification of identity before responding to certain requests.
Shunya may amend, revise, update, supplement, or replace this Privacy Policy at any time. Any revised version may be published on the Platform, communicated in-app, or otherwise notified through reasonable means. Unless otherwise stated, changes become effective upon publication. Continued use of the Platform after such publication shall constitute your acknowledgment of the revised Privacy Policy.
This Privacy Policy shall be interpreted in a manner consistent with the Shunya Terms and Conditions / Master User Agreement. In the event of any inconsistency between this Privacy Policy and the Terms regarding privacy-related operational rights, both documents shall be read harmoniously to the maximum extent possible so as to preserve legal compliance, platform safety, commercial operability, fraud prevention capacity, evidentiary preservation, and the lawful rights and interests of Shunya and its developer.
By using the Platform, creating an account, subscribing to services, submitting information, enabling device permissions, or participating in any communication-based or interactive feature, you confirm that you have read and understood this Privacy Policy and agree to the collection and processing of your information in the manner described herein, to the extent permitted by applicable law.