EFFECTIVE DATE: October 1, 2023
FlipTree Technologies (India) Private Limited ("FlipTree", “Facilitator", "we", "our", or "us") values your privacy. When you use the Platform, you trust us with your personal data. That starts with helping you understand our privacy practices. This Privacy Policy ("Policy") describes the personal data we collect, how it is used and shared, and your choices regarding this data. This Policy applies to the Platform, and all Users on the Platform. This Policy is incorporated by reference into the Terms. Any capitalized terms used and not defined in this Policy shall have the meaning given to them in the Terms. By accessing or using the Platform, you agree to this Policy. IF YOU DO NOT AGREE TO THIS POLICY, PLEASE DO NOT ACCESS OR USE THE PLATFORM.
"Platform" means all Lumi Matrimony websites, mobile or other applications, software, processes, and any other services provided by or through Lumi Matrimony Mobile App, which enable Users to connect to other Users.
"User" (each a "User" and, collectively, the "Users") means a person who voluntarily submits information to the Platform and completes the Facilitator's Account registration process on the Platform regardless of whether such person uses the Service as a free member or a paid member on the Platform.
"Member" (each a "Member" and, collectively, the "Members") means a User on the Platform.
"Candidate" (each a "Candidate" and, collectively, the "Candidates") means a User on the Platform.
"Application" (each a "Application" and, collectively, the "Applications") means mobile or other applications.
"Account" (each a "Account" and, collectively, the "Accounts") or "User Account" (each a "User Account" and, collectively, the "User Accounts") means a personal account of a User on the Platform.
"Service" (each a "Service" and, collectively, the "Services") means the matchmaking service provided by the Platform to a User where the User is matched against another User(s) on the Platform based on the User’s preferences or the Facilitator’s recommendations.
"Content" means text, graphics, images, music, software, audio, video, information or other materials, including but not limited to profile information, message threads, reviews, and other information or materials available on or through the Platform.
"Lumi Matrimony Content" means all Content the Facilitator makes available on or through the Platform, including any Content licensed from a third party, but excluding User Content.
"User Content" means all Content submitted, posted, uploaded, published, or transmitted on or through the Platform by any User or other User of the Platform, including but not limited to photographs, profile information, descriptions, postings, reviews, requests, messages, and payments made through the Platform, but excluding Lumi Matrimony Content and Feedback.
"Collective Content" means User Content and Lumi Matrimony Content together.
"Identification Number" means unique identity number issued to the citizens of India by the Government of India such as Aadhaar Number, Permanent Account Number (PAN), Driving License Number, Voter Identity Number, Passport Number etc.
"Payment Method" (each a "Payment Method" and, collectively, the "Payment Methods") means a current, valid, accepted method of payment submitted by User such as UPI, Net Banking, credit card, debit card, prepaid card, Google Pay etc. as may be updated from time to time.
"Payment Processor" means the third-party payment service provider providing payment processing services on the Platform.
"Device" (each a "Device" and, collectively, the "Devices") or "Mobile Device" (each a "Mobile Device" and, collectively, the "Mobile Devices") means Apple iOS or Android smartphone capable of accessing the Platform.
“Terms" means Lumi Matrimony Terms and Conditions.
"Internet" means internet.
The Platform collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular User or Device (collectively, the "Personal Information"). By using the Platform, you are authorizing us to collect, parse, and retain data related to the provision of the Platform. However, we also provide Users with options and choices regarding how we use and disclose some or all of your Personal Information, as set forth specifically below, including how to access, correct, and/or remove it. You may avoid further said data collection by uninstalling the Application from your Mobile Device, or otherwise not using the Platform.
When you visit or use the Platform, we collect information about you in the following general manners:
a. Data provided by Users to the Facilitator: When Users engage in the Platform, information is gathered in forms completed, images uploaded, or products and Services purchased. This includes:
Account Registration: We collect data when Users of the Platform create or update their Accounts including their name, phone number, email address, login name, address, profile picture etc. We may use the photographs submitted to verify their identities.
Identity Verification: We collect User’s identity proof document(s) to verify their identity through online authentication. Acceptable identity proof documents include any identification document issued to the User by Government of India such as Aadhaar Card, Passport, Permanent Account Number (PAN) Card, Driving License, or Voter Identity Card.
Customer Support: We may collect Personal Information such as your name, email address, phone number, mailing address, feedback, photographs, or other recordings through your communications with our Customer Support team.
Information to be published or displayed (User Content): Your User Contents are posted on and transmitted to others at your own risk. The Facilitator cannot control the actions of other Users of the Platform with whom you share your User Content.
b. Information We Collect When You Use the Platform: The Facilitator gathers Data created during use of the Platform. This includes:
Location Information: We collect precise or approximate location data through the Platform when it is used by Users if the Users' devices permit such information collection. We may collect this information when certain functionalities are used, such as selecting "my location" or navigating to a location to provide the Services. We may also collect the precise location of User's device when the Platform is running in the foreground or background of their mobile device. Users may use the Platform without enabling the Facilitator to collect location data from their mobile devices. However, this may affect some functionality available on the Platform. For example, a User who has not enabled location data collection will have to manually enter their address. We may derive a User's approximate location from the User's IP address. We also may use and disclose geo-location we collect through the Platform for other business purposes, including for legal purposes. The geo-location information obtained about a User will be retained in an identifiable manner, along with geo-location data. In addition, the location data collected from a User will be linked to the User's account, even if they have not enabled location data to be collected from their device, including for purposes of customer support, fraud detection, insurance, and litigation.
Device Information: We may collect information about your mobile device, including the hardware model, operating system/version, software names/versions, file names/versions, preferred language, unique device identifier, IP address, advertising identifiers, serial number, device motion information, and mobile network information.
Usage and Preference Information: We collect data about how Users and visitors interact with the Platform. This includes data such as access dates and times, Platform features or pages viewed, Platform crashes and other system activity, type of browser, and third-party sites or Services used before interacting with our Services. In some cases, we collect this data through cookies, pixels, tags, and similar tracking technologies that create and maintain unique identifiers. When we associate such information with specific personal information, we will treat the combination as Personal Information, as set forth herein.
Log Information: When you interact with the Platform, we collect server logs, which may include device IP addresses, access dates and times, Platform features or pages viewed, Platform crashes and other system activity, browser type, and the third-party site/service accessed immediately prior to interacting with the Platform.
Cookies and Third-Party Technologies: Like most online services and mobile applications, we and our Third-Party Providers may use cookies, web beacons, and similar tracking technologies to collect information about your activity from the computer or devices you use to access the Platform for purposes described in this Policy. A cookie is a file saved on a User's hard drive that stores certain information about User activity. Users must agree to let cookies be saved for them, and most web browsers are set to accept cookies by default. Although you can modify your browser/device settings to reject cookies if desired, this could potentially affect the availability and functionality of our Services. The Facilitator uses cookies and similar technologies for purposes such as authenticating Users, remembering User preferences and settings, determining the popularity of content, delivering and measuring the effectiveness of advertising campaigns, analyzing site traffic and trends, and generally understanding the online behaviors and interests of people who interact with the Platform.
c. Information We Collect from Third-Party Providers: The Facilitator engages with Third-Party Providers that provide information that makes it possible to run elemental aspects of the Platform. Some of the things these service providers allow for are identity verification, marketing, and other businesses. The Facilitator may combine the data collected from these sources with other data in its possession. Information we receive from these third parties includes:
Third-Party Site Account Access: If you log in to the Platform through a third-party site, such as Apple, Google or Facebook, we may collect your authentication token, registration information (including but not limited to name, email address, photograph (if any)), and account identification number and use that information to provide you with access to your Account on the Platform.
Others: At times, other Users and sources such as the media, insurance companies, and law enforcement may provide information about you or prior activities during incident research.
The information we gather from members and visitors who apply for the various Services our Website/Apps offers includes, but may not be limited to, photo of the user, email address, name, date of birth, educational qualifications, a user-specified password, mailing address, pin code and telephone/mobile number or fax number. Cookies are used to store the login information. Cookies are small files placed on your hard drive that will assist us in providing our services. You may also encounter Cookies or identical/related devices on certain pages of the website/apps that are placed by third parties. We do not control the use of cookies by third parties.
We may also use your Personal Information for verification, analysis of data, usage trends and to evaluate and improve our Platform, marketing research, prevention of frauds. In our efforts to continually improve our product and service offerings, we collect and analyze demographic and profile data about User activity on the Platform. We identify and use your IP address to help diagnose problems with our server, and to administer the Platform. Your IP address is also used to help identify you and to gather broad demographic information.
The Platform collects information for data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns, evaluating and improving our websites or apps, products, and services, market research to ensure that we are able to fulfil your requirements and to deliver Personalized experience. We may use your information for any of the following reasons:
We may display information related to you, including your name, photograph, pictures, registered phone number, location, contact information, Services offered, license(s) and/or certification(s) (if any), publicly on your profile, except to the extent we tell you we will not display such information. If the information you provide us upon signing up for an account differs from the information you provide us as part of the verification data we collect, we have sole discretion in determining which information will be displayed publicly on your profile. We may combine information that we collect from you through the Platform with information that we obtain from affiliated and non affiliated third parties, and information derived from any other products or Services we provide. We may aggregate and/or de-identify information collected through the Platform. We may use de-identified or aggregated data for any purpose, including without limitation for research and marketing purposes and may also share such data with any third parties, including without limitation, advertisers, promotional partners, sponsors, event promoters, and/or others. We may, either directly or through third parties we engage to provide Services to us, review, scan, or analyze your communications with other Users exchanged via the Platform or as otherwise described in this Policy for fraud prevention, risk assessment, regulatory compliance, investigation, debugging, troubleshooting, product improvement, research and development, and customer support purposes.
As set forth herein, we do not rent, sell, or share Personal Information about you with other people or non affiliated companies for their direct marketing purposes unless we have your permission. We may allow access to other data collected by the Platform to enable the delivery of our online advertising on the Platform and on other websites and online services, or to send you information we think may be useful or relevant to you. We may share such identifiable information with our associates/affiliates/subsidiaries and such associates/affiliates/subsidiaries may market to you as a result of such sharing. Any information you give us is held with the utmost care and security. We are also bound to cooperate fully should a situation arise where we are required by law or legal process to provide information about a User. Where required or permitted by law, information may be provided to others, such as regulators and law enforcement agencies or to protect the rights, property or personal safety of other members or the general public. We may voluntarily share your information with law enforcement agencies/Gateway service providers/anti- fraud solution provider(s) if we feel that your transactions on the Platform are of suspicious nature. From time to time, we may consider corporate transactions such as a merger, acquisition, reorganization, asset sale, or similar. In these instances, we may transfer or allow access to information to enable the assessment and undertaking of that transaction. If we buy or sell any business or assets, personal information may be transferred to third parties involved in the transaction. Our Platform links to other websites/apps that may collect personally identifiable information about you. We are not responsible for the privacy policy or the contents of those linked websites/apps. The following are examples of how we share your information.
a. Sharing between Platform Users: We will display certain information about you to other Users, including your name, photograph, location, contact information such as registered phone number etc.
b. Sharing with Third-Party Providers for a Business Purpose:
Categories of Information We Share: To operate the Platform, including processing your transactions and supporting your activities on the Platform, we may disclose the following categories of your Personal Information with vendors, agents, and Third-Party Providers for a business purpose. We may also use the below categories of information for compliance with applicable laws and regulations, and we may combine the information we collect ("aggregate") or remove pieces of information ("de-identify") to limit or prevent identification of any particular User or Device.
Third-Party Providers: To operate the Platform, including processing your transactions, we may share your information with our agents, representatives, vendors and service providers (each a "Third-Party Provider" and, collectively, the "Third-Party Providers"). Third-Party Providers assist us with services such as identity verification, data storage, cloud services, data analytics, marketing and advertising, website hosting, fraud prevention and detection, communication services, and technical support. We share information, including Personal Information, with Third-Party Providers that process information on our behalf for our business purposes as follows:
c. Legal Obligations and Protecting the Platform and Others: We may disclose your information when required by law or when we believe in good faith that such disclosure is necessary to: (a) comply with subpoenas, court orders, regulation, operating license or agreement, legal process or governmental request, other legal process we receive or where the disclosure is otherwise appropriate due to safety or similar concerns; (b) establish or exercise our legal rights including enforcing and administering agreements with Users; or (c) defend the Facilitator against legal claims. This includes sharing personal data with law enforcement officials, public health officials, other government authorities, or other third parties as necessary to enforce our Terms, or other policies; to protect the Facilitator's rights or property or the rights, safety, or property of others; or in the event of a claim or dispute relating to the use of our services. The Facilitator may also disclose your Personal Information as part of a dispute among Users or between Users and the Facilitator to an attorney in the process of obtaining legal advice. If we are required by law to disclose your information, we will use commercially reasonable efforts to notify you unless: (a) we believe in our sole discretion that providing notice could create a risk of injury or death, or that harm or fraud could be directed to the Facilitator or Users; or (b) we are precluded from providing notice by law. We will attempt to provide the notice by email if you have given us an email address. While you may challenge the disclosure request, please be advised that we may still be legally required to turn over your information. We may disclose your information to whomever necessary when we believe it is appropriate to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of the Terms or any other legal terms governing use of the Platform, and/or to protect our rights and property and the rights and property of other Users.
d. Merger, Sale, or Other Asset Transfers: If we are involved in a merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company, your information may be sold or transferred as part of such a transaction as permitted by law and/or contract. We cannot control how such entities may use or disclose such information.
e. App Store Providers. We may provide your identity and mobile device identifier to third-party app store providers (for e.g., the Apple App Store or Google Play Store) to allow you to download our mobile apps.
f. Academics and Research. We may provide information about Users to third parties for academic and research purposes, in anonymized or aggregated form.
g. With Your Permission: We may also disclose your Personal Information with your permission as set forth herein.
We invite you to post Content on or through our Platform, including, but not limited to, your comments, photographs, pictures, User profile, and any other information. However, please be careful and responsible whenever you are online. If you choose to post User Content on or through the Platform, such as through intra-User messaging or through our review boards, forums, blogs, or other postings, that information: (a) may be or may become publicly available; (b) may be collected and used by third parties with or without our knowledge; and (c) may be used in a manner that may violate this Policy, the law, or your personal privacy.
a. Information Retention: The Facilitator retains User profile, transaction, and other personal data for as long as a User maintains their Account. The Facilitator may retain certain User data after receiving an Account cancellation request if necessary, such as to comply with legal requirements. To preserve the integrity of our databases, standard procedure calls for us to retain information submitted by Users for an indefinite length of time. You agree that we may store the information we collect for this indefinite length of time.
b. Our Security Precautions: Your Account is linked to your phone number so that only you and authorized Facilitator employees have access to your Account information. In order to maintain this protection, do not give your Account password to anyone. The Facilitator staff will never proactively reach out to you and ask for any personal Account information, including your password. If you share a Mobile Device or computer, in order to protect your information entered on public terminals from disclosure to third parties, you should sign out of your Account before someone else logs on. We employ physical, procedural, and technological security measures to help protect your Personal Information from unauthorized access or disclosure. The Facilitator may use encryption, passwords, and physical security measures to help protect your Personal Information against unauthorized access and disclosure. You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, keeping your log-in and password private, and not recycling passwords from other websites or accounts. The Facilitator is not responsible for the unauthorized use of your information nor for any lost, stolen, or compromised passwords, or for any activity on your Account via unauthorized password activity.
c. As stipulated in the Privacy Policy we will retain the information we collect from Users for as long as the Users subscribe to our Services to meet their suitable purpose(s) for which it was collected, for the sake of enforcing agreements, for performing audits, for resolving any form of disputes, for establishing legal defenses, for pursuing legitimate businesses and to comply with the relevant applicable laws.
The Facilitator takes steps to ensure that your information is secure on its system. No security measures, however, are 100% failsafe. As a result, the Facilitator cannot guarantee the security of any information you transmit to us, and you do so at your own risk. The Facilitator EXPRESSLY DISCLAIMS ANY REPRESENTATION OR WARRANTY, WHETHER EXPRESSED OR IMPLIED, WITH RESPECT TO ENSURING, GUARANTEEING, OR OTHERWISE OFFERING ANY DEFINITIVE PROMISE OF SECURITY IN CONNECTION WITH YOUR PERSONAL INFORMATION OR USAGE INFORMATION AND FURTHER DISCLAIMS ANY LIABILITY THAT MAY ARISE SHOULD ANY OTHER INDIVIDUALS OBTAIN THE INFORMATION YOU SUBMIT TO THE PLATFORM.
Our Services are not designed for minors (Less than 18 years for females or less than 21 years for males). If we discover that a minor has registered on the Platform with false information, we will close the Account. We may, where permitted by law, retain certain information internally for purposes described in this Policy.
The Platform may contain links to other websites or resources over which the Facilitator does not have any control. Such links do not constitute an endorsement by the Facilitator of those external websites. You acknowledge that the Facilitator is providing these links to you only as a convenience, and further agree that the Facilitator is not responsible for the content of such external websites or the protection and privacy of information you provide while visiting such external websites.
The Facilitator enables Users to access and control the data that the Facilitator collects, including through:
a. Changing or Updating Information: The Facilitator provides you with the ability to access, review and edit your Personal Information. Sign into the Platform, and then edit your Account information. So that we can protect the integrity of sensitive data, there are certain pieces of information, such as your name, age, gender, identity information that you cannot alter yourself. Please contact us at privacy@lumimatrimony.com to change information you cannot access through your Account.
b. Push Notifications: You can deactivate push notifications intended for marketing purposes. Push notifications for important updates regarding your appointments and Account activity are required for proper functioning of the Platform.
c. Location Information: You can stop your Device from sharing Device location information via the Device system settings, although this could impact the full range of Services and features available through the Platform.
d. Device Permissions: Most mobile device platforms (iOS, Android, etc.) have defined certain types of device data that apps cannot access without the device owner's permission, and these platforms have different methods for how that permission can be obtained. iOS devices notify users the first time the Platform requests permission to access certain types of data and gives users the option to grant or refuse permission. Android devices notify users of the permissions that the Platform seeks before their first use of the app, and use of the Platform constitutes a grant of such permission.
e. Email Communications: We may send periodic emails to you. To opt out of promotional emails, you may submit a request to privacy@lumimatrimony.com. If you opt out of receiving promotional emails, we may still send you emails about your Account or any Services you have requested or received from us.
f. Cookies and Third-Party Technologies: Like most online services and mobile applications, we and our Third-Party Providers may use cookies, web beacons, and similar tracking technologies to collect information about your activity from the computer or devices you use to access the Platform for purposes described in this Policy. A cookie is a file saved on a User's hard drive that stores certain information about User activity. Users must agree to let cookies be saved for them, and most web browsers are set to accept cookies by default. Although you can modify your browser/device settings to reject cookies if desired, this could potentially affect the availability and functionality of our Services. The Facilitator uses cookies and similar technologies for purposes such as authenticating Users, remembering User preferences and settings, determining the popularity of content, delivering and measuring the effectiveness of advertising campaigns, analyzing site traffic and trends, and generally understanding the online behaviors and interests of people who interact with the Platform.
Any third-party with whom we are allowed to share your Personal Information is authorized to use your Personal Information in accordance with our contractual arrangements with such third parties and in accordance with their own privacy policies, over which we have no control. You agree that we are not responsible or liable for any of their actions or omissions. Those who contact you will need to be instructed directly by you regarding your preferences for the use of your Personal Information by them.
g. In some regions (like the EEA, UK, certain parts of US), you have certain rights under applicable data protection laws. You will be asked to provide consent to the collection, processing, and sharing of your personal information. These may include the right (i) to request access and obtain a copy of your personal information; (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. You have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent. If you are a resident in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here. If you are a resident in Switzerland, the contact details for the data protection authorities are available here.
Your personal information may be stored in databases located outside of the EU including in India. Where we transfer personal data outside of EU, we either transfer personal information to countries that provide an adequate level of protection, or we have appropriate safeguards in place. We may require proof of or need to verify your identity before we can give effect to these rights. To request to review, update, or delete your personal information, please submit a request form by sending an email to privacy@lumimatrimony.com. We may share your information with third-party anti-fraud solution provider(s). They help us to ensure we keep you safe from scammers and fraudsters.
This Policy is current as of the effective date set forth above. The Facilitator may, in its sole and absolute discretion, change this Policy at any time to the extent permitted by law. The Facilitator will post its updated Policy on the platform and update the Policy effective date. The Facilitator encourages you to review this Policy regularly for any changes. Your continued access to or use of the Platform after such posting will constitute your acceptance of such changes. IF YOU DO NOT AGREE, YOU MAY NOT ACCESS OR USE THE PLATFORM.
As a User if you have any grievance regarding the Platform or the Service, you can contact our Grievance Officer Mr. Shanu V Shaji at No. 4/461, 2nd Floor, Suite No.1327, Valamkottil Towers, Judgemukku, Kakkanad, Kochi, Kerala, India – 682021 or by sending an email to grievance@lumimatrimony.com