Effective Date: 30th October 2025

Last Updated: 30th October 2025

PRIVACY POLICY

This Privacy Policy outlines the scope of privacy and confidentiality protecting the information provided by users during account registration and normal use of the services, programs, and facilities of [https://innertalkz.com]/ InnerTalkz (hereinafter referred to as the "Website/ or App").

In this Privacy Policy, references to "we," "us," "our," "Website/or App" or Touchcloud Technologies Private Limited shall collectively refer to “Touchcloud”, its affiliates, and partners.

At any time, users have the right to allow or restrict the collection and use of their personal information at their discretion. [Hereinafter referred to as “Personal Information” which shall mean and include any information that can be used to identify, locate or contact you. It also includes other information that may be associated with your name or other identifiers].

Touchcloud’s legal basis for collection of Personal Information is in accordance with the applicable law in the jurisdiction of India [Hereinafter referred to as “Governing Law”]. Touchcloud also adhere to relevant international privacy regulations, where applicable.

By using this Website/or App, users provide their explicit consent to Touchcloud Technologies Private Limited (hereinafter referred to as "Touchcloud") to collect, process, use, store, and disclose their Personal Information in compliance with the provisions of this Privacy Policy and applicable data protection laws.

Touchcloud who owns and operates the Website/or App, acknowledges its responsibility to protect users’ personal and sensitive data. This Privacy Policy establishes the terms under which such Personal Information is collected, processed, stored, shared, and used. These rules apply to both personal and non-personal information collected by or through Touchcloud.

1.      SCOPE:

1.1.   This Privacy Policy sets out the information about you that Touchcloud collects through the Website/or App, how that information is used, maintained, shared, protected and how you can update it.

1.2.   This Privacy Policy applies to Personal Information received by Touchcloud, and It applies to any personal data we collect or process in digital form while providing our services to you.

1.3.   Please note that we are not obligated to observe compliances in relation to such sets of Personal Information that are excluded from the scope of applicable Governing Law (including Personal Information that has been made publicly available by the data principal to whom such data belongs or by any other person acting under a legal obligation to disclose the personal data).

 

2.      INFORMATION WE COLLECT:

2.1.   We collect information about you in two main ways when you use our Website/or App:

2.1.1.       You supply it to us or give us permission to obtain it: When you sign up for or use our products or services, you voluntarily give us certain information. This can include your name, profile photo and information that you supply, location and contact information, email address you used to sign up, and any other information you provide us.

2.1.2.       We also get technical information when you use our services or use Website/or Apps or Touchcloud’s features: Whenever you use a Website/or App, or other Internet service, certain kinds of information almost always get created and recorded automatically. The same holds true when you use our products or services. Here are some of the kinds of information we collect:

2.1.2.1. Log data: When you visit our Website/or App, we may automatically collect information about your location, computer operating system, Internet Protocol (IP) address, access times, browser type and language and the Website/or App you visited before our Website/or Apps. While this data is available to us, we access it only to understand metrics about our users in the aggregate.

2.1.2.2. Cookie: We use cookies and similar tracking technology (collectively, “cookies”) to collect and use personal information and Personal Information about you, including to serve interest-based advertising. You can set your browser to refuse all or some browser cookies, or to alert you when Website/or Apps set or access cookies. If you disable or refuse cookies, please note that some parts of this Website/or App may become inaccessible or not function properly.

2.1.2.3. Web beacon: We may also collect information using Web beacons. Web beacons are electronic images that may be used on our Sites or in our emails. We use Web beacons to deliver cookies, count visits, understand usage and campaign effectiveness, and tell whether you open an email and act upon it.

2.2.   Teens and minors. We do not knowingly target persons under the legal age of majority, and we do not collect information from such persons, without his or her legal guardian’s consent. If you learn that a minor child has provided us with personal information without his or her legal guardian’s consent, please contact us.

3.      HOW WE USE THE INFORMATION WE COLLECT:

3.1.   We will only use your Personal Information when the law allows us to. Most commonly, we will use your Personal Information in any of the following circumstances:

3.1.1.  Where you have provided your consent to use such personal data.

3.1.2.  Where we need to perform the contract, we are about to enter or have entered with you.

3.1.3.  Where it is necessary for our legitimate interests (or those of a third party) and such

interests do not override your interests or fundamental rights which require protection    of your personal data.

3.1.4.  Where we need to comply with a legal or regulatory obligation, or otherwise as required or permitted under applicable law.

3.2.   Touchcloud also collects, uses and shares aggregated data such as statistical or demographic data.

3.2.1.  Aggregated Data may be derived from your Personal Information but is not considered Personal Information in law as this data does not directly or indirectly reveal your identity.

3.2.2.  For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Website/or App feature.

3.2.3.  However, if we combine or connect Aggregated Data with your Personal Information so that it can directly or indirectly identify you, we treat the combined data as Personal Information which will be used in accordance with this Privacy Policy.

3.3.   Touchcloud may collect certain Special Categories of Personal Information or Sensitive Personal Information or Information (or such similar data known by any other term under the applicable law) about you. Such data is only collected and processed with your consent or in performance of our contract with you, unless otherwise required or permitted under the applicable law. We may collect information about criminal convictions and offences in those jurisdictions where the processing of such information is legally required.

3.4.   Except in jurisdictions that require an explicit consent of data subjects for processing certain types of personal data, usually we rely on other Lawful Basis for processing any type of personal data.

 

4.      THIRD-PARTY LINKS: Our Website/or App may include links to third-party Website/or Apps, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party Website/or Apps and are not responsible for their privacy statements. This Privacy Policy does not apply to information that is collected by any third-party Website/or App or service that you may access through the Services.

 

5.      YOUR LEGAL RIGHTS:

5.1.   The rights available to you may differ based on your geographic location. You may contact us for more information on the specific rights available to you. Some of the rights prescribed under various laws include the right to:

5.2.   Request access to your Personal Information (commonly known as a "data subject access request"). This enables you to receive a copy of the Personal Information we hold about you and to check that we are lawfully processing it.

5.3.   Request correction of the Personal Information that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. You may contact Touchcloud using the contact information provided to update or correct your Personal Information whenever necessary.

5.4.   Request erasure of your personal data. This enables you to ask us to delete or remove your Personal Information where there is no good reason for us to continue processing it. You also have the right to ask us to delete or remove your Personal Information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Information to comply with local law. Note, however, that we may not always be able to comply with your request for the erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

5.5.   Object to processing your Personal Information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object to where we are processing your Personal Information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

5.6.   Request restriction of processing your personal data. This enables you to ask us to suspend the processing of your Personal Information in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

5.7.   Request the transfer of your Personal Information to you or to a third party. We will provide you, or a third party you have chosen, with your Personal Information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided with consent for us to use or where we used the information to fulfil a contract with you.

5.8.   Withdraw consent at any time where we are relying on consent to process your personal data, by contacting us. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, Touchcloud may limit your access to the Services and/or not be able to offer or provide you with the product or services or initiate or continue any relationship with you.

 

6.      LAWFUL BASIS:

6.1.   Legitimate Interests means our interest in conducting and managing our business. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Information for our legitimate interests.

6.2.   We do not use your Personal Information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

6.3.   Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

6.4.   Legal Compliance means processing your Personal Information where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

 

7.      PRIVACY AND SECURITY:

7.1.   Touchcloud is dedicated to ensuring the highest levels of privacy and security in compliance with the applicable data protection regulations. To safeguard User information, Touchcloud follows the below measures:

7.1.1.  Data Encryption - All sensitive and personal information is encrypted to prevent unauthorized access.

7.1.2.  Secure Storage - User data is stored in secure databases with stringent access controls.

7.1.3.  Restricted Access - Only authorized personnel with a legitimate business need can access User data.

7.1.4.  Regular Security Audits - Routine security audits and vulnerability assessments are conducted to maintain data integrity.

7.1.5.  Incident Response Plan - In the event of a data breach, Touchcloud has a structured incident response plan to mitigate risks and notify affected Users as per regulatory requirements.

7.1.6.  User Authentication - OTP (One-Time Password) authentication is implemented to enhance account security. Users are encouraged to keep their OTP credentials confidential. Touchcloud shall not be held liable for security breaches arising from user negligence or third-party actions beyond its control.

 

8.      INTERNATIONAL DATA TRANSFER

8.1.   We may transfer information that we collect about you, including personal information, to affiliated entities or to other third parties (as provided herein) across borders and from your country or jurisdiction to other countries or jurisdictions around the world.

8.2.   If you are located in a region outside India, please note that your personal information may be transferred to, stored, and processed in jurisdictions where data protection laws may differ from those in your jurisdiction.

8.3.   We take steps to ensure that such transfers comply with applicable laws and that your data receives adequate protection. These steps may include implementing safeguards such as Standard Contractual Clauses (as recognized by the European Commission or other relevant authorities) or relying on adequacy decisions where applicable.

8.4.   By using our services, you acknowledge and agree to the transfer, processing, and storage of your personal information in these jurisdictions. Where required by law, we will seek your explicit consent for such transfers.

8.5.   You retain rights under your local data protection laws, including the right to access, correct, or delete your personal information, withdraw consent (where applicable), or lodge a complaint with a supervisory authority.

 

9.      COMPLIANCE AND COOPERATION WITH REGULATORY AUTHORITIES:

9.1.   We regularly review our compliance with our Privacy Policy.

9.2.   If we receive formal written complaints, we will contact the person who made the complaint to follow up and resolve the complaint.

9.3.   We work with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of Personal Information that we cannot resolve with our users directly.

 

10.  RETENTION, DELETION, OR BLOCKING OF DATA:

10.1.  We adhere to the principles of purpose limitation and data minimization. Therefore, we only store your Personal Information for as long as it is necessary to achieve the purposes mentioned here or as long as the many storage periods are required by law.

10.2.  After discontinuation of the respective purpose or expiry of these deadlines, the corresponding data will be blocked or deleted in accordance with the statutory provisions.

10.3.  Our legal basis for the deletion or blocking of Personal Information is to safeguards and derogations relating to processing for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes and to implement data-protection principles in an effective manner, and to integrate the necessary safeguards into the processing in order to meet the requirements of the applicable laws.

 

11.  FORUMS AND INTERACTIVE SERVICES:

11.1.    There may be interactive services within the Website/or App, such as blogs, chat rooms, forums, instant messaging, etc., and other service member zones that allow them to input their data, details, materials, comments or other similar communications.

11.2.    Using such Website/or App/services, the User should realize that they are open for wide access and review, and any Personal Information that he/she published or provided during registration may become viewable by third parties.

11.3.    Touchcloud is not responsible for the security of the User’s information that is passed by the User to third parties or provided during the use of such Website/or App/services. Materials that will be placed by the User in such areas of the Website/or App will be stored in systems/devices of Touchcloud as per Touchcloud’s policy, if otherwise not directly documented in each case.

 

12.  PHISHING:

12.1.   Identity theft and the practice currently known as "phishing" are of great concern to the Website/or App. Safeguarding information to help protect User from identity theft is a top priority.

12.2. We do not and will not, at any time, request User’s credit card information or national identification numbers in a non-secure or unsolicited e-mail or telephone communication.

13.  CHANGES TO THESE RULES:

13.1.   Touchcloud reserves the right to change the rules of Privacy Policy at any time without notice. In the event of a substantial change of confidentiality rules and policies of use of the User's personal information, Touchcloud shall publish the changes on the Website/or App.

13.2. Users are advised to refer to the text of this page at each visit to the Website/or App or before availing of the Services.

13.3. Touchcloud reserves the right, in its sole discretion, to terminate your access to whole or any part of the Website/or App/Application and the related services or any portion thereof at any time without notice.

 

14.  GOVERNING LAW & JURISDICTION: This Privacy Policy shall be governed by, construed, and enforced under with the applicable law in the jurisdiction of India. Touchcloud also adhere to relevant international privacy regulations, where applicable.

 

15.  PREVAILING LANGUAGE: This Privacy Policy is prepared and executed in English and if translated into a language other than English for any purpose, the English version shall in all events prevail and be paramount in the event of any differences, questions, or disputes concerning the meaning, form, validity, or interpretation of this Privacy Policy.