1. Introduction

Welcome to Kindly (the "Platform"), operated by CreateTogether Foundation ("we," "us," or "our"). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about this Privacy Policy or our practices with regard to your personal information, please contact us at kindlytheproject@gmail.com.

This Privacy Policy describes how we might collect, use, store, and/or share ("process") your information when you use our services ("Services"), such as when you:

• Visit our website at kindly.club, or any website of ours that links to this privacy policy
• Engage with us in other related ways, including any sales, marketing, or events

Reading this privacy policy will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services.

2. What Information Do We Collect?

Personal Information You Disclose to Us:

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services (such as making or receiving donations, posting messages, or entering competitions, promotions, or surveys), or otherwise when you contact us.

The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

• Identity Data: Name, username, date of birth.
• Contact Data: Email address, postal address, phone number.
• Financial Data (for Donors/Beneficiaries): Payment card details (typically processed by our third-party payment processors like Razorpay), bank account information (for payouts to beneficiaries). We do not typically store full payment card numbers on our servers.
• Transaction Data: Details about donations you make or receive, including amounts, dates, and campaign information.
• Profile Data: Your username and password, profile picture, interests, preferences, feedback, and survey responses.
• User-Generated Content: Information you provide when creating campaigns, posting comments, or otherwise submitting content to the Services.
• Communications Data: Information you provide when you contact us with questions or for customer support.

Information Automatically Collected:

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies. [You should have a separate Cookie Policy or a detailed section on cookies here or linked. This needs to be created and linked if applicable.]

3. How Do We Use Your Information?

We use personal information collected via our Services for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.

• To facilitate account creation and logon process. (Legitimate Interest/Contract)
• To manage user accounts. We may use your information for the purposes of managing your account and keeping it in working order. (Contract)
• To send administrative information to you. We may use your personal information to send you product, service, and new feature information and/or information about changes to our terms, conditions, and policies. (Legitimate Interest/Contract)
• To facilitate donations and process payments. We use your information to process donations you make and to facilitate payouts to beneficiaries. (Contract/Legal Obligation)
• To enable user-to-user communications. We may use your information in order to enable user-to-user communications with each user's consent. (Consent)
• To post testimonials. We post testimonials on our Services that may contain personal information. Prior to posting a testimonial, we will obtain your consent to use your name and the content of the testimonial. (Consent)
• To request feedback. We may use your information to request feedback and to contact you about your use of our Services. (Legitimate Interest)
• To protect our Services. We may use your information as part of our efforts to keep our Services safe and secure (for example, for fraud monitoring and prevention). (Legitimate Interest/Legal Obligation)
• For data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns, and to evaluate and improve our Services, products, marketing, and your experience. (Legitimate Interest)
• To comply with legal obligations. This may include responding to legal requests and preventing harm. (Legal Obligation)
• [Add any other specific uses relevant to your platform.]

4. Will Your Information Be Shared With Anyone?

We may process or share your data that we hold based on the following legal basis:

• Consent: We may share your information if you have given us specific consent to use your personal information for a specific purpose.
• Legitimate Interests: We may share your information when it is reasonably necessary to achieve our legitimate business interests.
• Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract. (e.g., sharing donor information with a campaign creator for acknowledgment, if permitted by the donor).
• Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
• Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

More specifically, we may need to share your personal information in the following situations:

• Payment Processors: We share information with third-party payment processors like Razorpay to process donations and payouts. These processors will have their own privacy policies.
• Campaign Creators/Beneficiaries: If you donate to a campaign, we may share some of your information (e.g., your name, email, donation amount, if you haven't donated anonymously) with the creator of the campaign or the beneficiary organization for acknowledgment, and for them to provide updates on the campaign, subject to your consent where required.
• Service Providers: We may share your information with third-party vendors, service providers, contractors, or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: data analysis, email delivery, hosting services, customer service, and marketing efforts.
• Business Transfers: We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
• Affiliates: We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy policy. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.
• [Add other specific sharing scenarios.]

We do not sell your personal information to third parties.

5. How Long Do We Keep Your Information?

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this policy will require us keeping your personal information for longer than the period of time in which users have an account with us plus [e.g., 7 years for legal/audit purposes in India - this duration needs legal verification for your specific obligations].

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

6. How Do We Keep Your Information Safe?

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

7. Your Privacy Rights

In some regions (like India, the EEA, UK, and Canada), you have certain rights under applicable data protection laws. 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; (iv) if applicable, to data portability; and (v) the right to grieve or complain. In certain circumstances, you may also have the right to object to the processing of your personal information.

If we are relying on your consent to process 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.

To make such a request, please use the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws.

Account Information: You may at any time review or change the information in your account or terminate your account by logging into your account settings and updating your user account, or by contacting us using the contact information provided.

[Include specific details for GDPR/Digital Personal Data Protection Act (DPDPA - India) if applicable, e.g., Data Protection Officer contact, rights specific to those regulations, Grievance Redressal Officer details as per Indian law.]

8. Do-Not-Track Features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy policy.

9. Children's Privacy

Our Services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children under 18. If we become aware that a child under 18 has provided us with personal information without verifiable parental consent, we will take steps to delete such information. If you become aware that a child has provided us with personal information, please contact us at kindlytheproject@gmail.com.

10. Changes to This Privacy Policy

We may update this privacy policy from time to time. The updated version will be indicated by an updated "Last Updated" date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.

11. Contact Us

If you have questions or comments about this policy, or if you have a grievance you would like to redress, you may contact our Grievance Officer at:

CreateTogether Foundation

Attn: Grievance Officer

Address: Om Sainath Co-Op Hsg Society Ltd, Flat No. 1:3, Building No A-4, Sector 10, Kalamboli, Navi Mumbai, Maharashtra 410218, India

Email: kindlytheproject@gmail.com