Cold Brew Privacy Policy

Last updated: 7th April 2019

We (Cold Brew Pvt. Ltd., or “FRND”) recognise that your privacy is very important and take it
seriously. This Privacy Policy (“Privacy Policy”) sets out how we collect, use and disclose
your data when you use mobile application called ‘FRND’ (“App”). The Website and App are
collectively referred to as the “Platform”. References to “we”, “our” or “us” or the “Company”
shall mean the Platform and/or Cold Brew Pvt. Ltd. Any references to “you”, “your” or “user”
shall mean any person or entity using our Platform. We will not use or share your information
with anyone except as described in this Privacy Policy.
By using this Platform, you agree to the terms and conditions of this Privacy Policy. You also
consent to our use and disclosure of your Personal Information (as defined below) in the
manner described in this Privacy Policy.
THE INFORMATION WE COLLECT AND HOW WE USE IT
The following table lists the information we collect from you and how we use it:

Information We Collect How We Use It

Log-in Data. User ID, mobile phone number, password, · To set up and facilitate log-in to a user account on
gender, voice recording and IP address. We may Platform;
collect an indicative age range which tells us that you · To notify you about changes to the Platform,
are of the appropriate age to access our Platform and including this Privacy Policy;
certain features of our Platform (collectively, “Log-in · To facilitate communication, including provision of
Data”). user support;
· To enforce our terms, conditions, and policies and
Additional Profile Information. Alongside the Log-in any of our rights, or the rights of our affiliate companies,
Data, we also collect your username, birth year and the or other users of the Platform;
biography provided by you on your user profile. · To develop new services and improve the existing
services and the Platform and integrate user feedback
and requests;
· To provide language and location based
personalization;
· To administer the Platform and for internal
operations, including troubleshooting, data analysis,
testing, research, security, fraud-detection, account
management, and survey purposes;
· To better understand how you use and access the
Platform and to improve the user experience on the
Platform;
- To verify your gender
· To pseudonymise and aggregate your information,
including Personal Information, for conducting user
demographic analysis on items such as region, phone
model, operating system platform, system language,
and the Platform version in order to better understand
how our users are using Platform;
Content You Share. This comprises all of the · To pseudonymise and aggregate your information,
information you make available to other users via including Personal Information, for collection of web and
Platform, comprising such as: account traffic statistics of what content and services
· Information about you or relating to you that is are used when users access third-party services on the
voluntarily shared by you on the Platform, including Platform;
without limitation, any quotes, images, political · To assess effectiveness of and improve advertising
opinions, religious views, etc. and other marketing and promotional activities.
· Any posts that you make on the Platform (including
your public profile, and photos, videos and voice
recordings and photos through your device’s camera
and/or microphone sensor), any postings from others
that you re-post and Location Data and Log Data
associated with such postings.
This also includes information about you (including
Location Data and Log Data) that other users of the
Platform share about you or any communications they
make to you.

Information we receive from other sources.We may also

be working closely with third parties (including, for
example, business partners, sub-contractors in
technical, analytics providers, search information
providers) and may receive information about you from
such sources. Such data may be shared internally and
combined with data collected on this Platform.
Log Data. "Log Data" is information that we
automatically collect when you use the Platform,
whether through the use of cookies, web beacons, log
files, scripts, including, but not limited to:
· technical information, such as your mobile
carrier-related information, configuration information
made available by your web browser or other programs
you use to access the Platform, your IP address and
your device’s version and identification number;
· information about what you have searched for and
looked at while using the Platform, such as web search
terms used, social media profiles visited, mini
applications used, and details of other information and
content accessed or requested by you while using the
Platform;
· general information about communications on the
platform, such as the identity of a user that you have
communicated with and the time, data and duration of
your communications; and
· metadata, which means information related to
items you have made available through the Platform,
such as the date, time or location that a shared
photograph or video was taken or posted.

Cookies. Our Platform uses cookies to distinguish you

from other users of our Platform. This helps us to
provide you with a good user experience when you
browse our Platform and also allows us to improve the
Platform. We collect the cookie data from the cookies
on your device. For detailed information on the cookies
we use and the purposes for which we use them see
our cookie policy

Surveys. If you choose to participate in a survey, we

may request you to provide certain Personal
Information i.e. any information that could be used to
identify you (“Personal Information”). We may use a
third-party service provider to conduct these surveys
and this will be notified to you prior to you completing
the survey.

User Search Data. Any searches you make on the To provide you quick access to your previous searches.
Platform. To use analytics for personalization and showing you
targeted advertisements.
Additional Account Security. We collect your phone To verify your identity and for maintaining your account
number and request access to the SMS your phone by security.
sending you a One-Time-Password (“OTP”), which you
confirm by entering the OTP to confirm your identity,
while registering with our Platform.

Contacts List. We access the contacts list on your · To connect you with other Platform users through
mobile device. We always ask for your consent before “Invite users’’ features of the Platform;
accessing your contacts list and you have the option to
deny us the access to your contacts list.

Location Information. "Location Data" is information that · For security, fraud-detection and account
is derived from your GPS, IP address, and/or public management (such as to ensure that there are no
posts that contain location information. You will disclose multiple log-ins or suspicious log-ins on your account);
certain location information to us and to other Platform · To provide you with location-based services that
users: you choose to use:

· when you use certain location-based features on ● mini applications that may be made available on
the Platform, or mini applications that we may introduce the Platform from time to time, which may
on our Platform from time to time, and when you share require such information based on the services
your location with other Platform users; and that they provide (if you choose to disclose your
· when you access the Platform, as we derive location to any mini application);
location information from your IP address, device, or ● To provide language and location customisation.
internet service to prevent multiple or fraudulent log-ins
to your account.

Customer Support Information. Any information that you To investigate your support issue.
provide to our customer support team regarding any
assistance or support that you may require for using our
Platform from time to time.
Device Data. “Device Data” includes without limitation, · To facilitate the sharing of any media such as
the following: audios, videos, and images using the Platform;
§ Device attributes: information such as the operating · To customise our Platform to suit your mobile
system, hardware and software versions, battery level, device;
signal strength, available storage space, browser type, · Understand whether there is enough storage
app and file names and types, and plugins. space on your device to be able to download any
§ Device operations: information about operations and content from the Platform for the purposes of sharing
behaviours performed on the device, such as whether a via WhatsApp and/or Facebook;
window is foregrounded or backgrounded. · To optimise your user experience on our Platform;
§ Identifiers: unique identifiers, device IDs, and other · To facilitate the sharing of any content on the
identifiers, such as from games, apps or accounts you Platform via the applications downloaded on your
use. mobile device;
§ Device signals: We may collect your Bluetooth · To verify your identity so as to enforce our terms,
signals, and information about nearby Wi-Fi access conditions, and policies;
points, beacons, and cell towers. · To improve the Platform.
§ Data from device settings: information you allow us
to receive through device settings you turn on, such as
access to your GPS location, camera or photos.
§ Network and connections: information such as the
name of your mobile operator or ISP, language, time
zone, mobile phone number, IP address and
connection speed.
§ Application: Any mobile applications that are stored
on your mobile device.
§ Media: We access the media gallery on your mobile
device, including without limitation, images, videos and
audio files and the storage space on your phone.
However, we shall always obtain your consent before
accessing your images and you shall have the option to
deny us such access.

We also process and analyse your chats with other - To improve your chat suggestion
users as well as the content you publish, as part of the - To improve your future matches
operation of the services, users you connect and
interact with, time and date of your exchanges, number
of messages you send and receive).

Contest Information. Any information that you provide to · To facilitate your participation in the contest;
us in submitting an entry to any contest which may be · To award prizes, if applicable.
offered on the Platform from time to time.

DISCLOSURE OF YOUR INFORMATION

We disclose your information in the following manner:
Content Visible to Others
Public content i.e. any content you post on your user profile or on another user’s profile,
such as a post comment, is accessible to everyone, including search engines. Any
information you voluntarily disclose for posting to the Platform, including your profile page
information, is accessible to anyone. When you submit, post or share the content that you
choose to make public, on the Platform, it may be re-shared by others.You should consider
who you choose to share it with, because people who can see your activity on our Platform
can choose to share it with others on and off our Platform, including people outside the
audience you shared it with. For example, when you share a post or send a message to
specific users of our Platform or accounts, they can download or re-share that content with
other users across or off our Platform. Also, when you comment on someone else's post or
like their content, your comment or like is visible to anyone who can see the other person's
content.
Users can also use our Platform to create and share content about you with the audience
that they choose, such as posting a photo of you, or tagging you in any of their posts. We
reserve the right to share all public content on any social media site or any other online or
offline platform. We will never rent or sell your Personal Information to third parties, except
on an anonymized basis, unless expressly provided in these Terms.
Sharing with our Group of Companies
We may share your Personal Information with any member of our Group. The term “Group”
shall mean any entity that is controlled by us, or any entity that is in control of us, or any
entity that is under common control with us, whether directly or indirectly.
What you Share with Others
When you share content and communicate using our Platform, you choose the audience for
what you share. For example, when you post any content from our Platform on Facebook,
you select the audience for the post, such as a friend, a group of friends or all of your
friends. Similarly, when you use WhatsApp or any other application on your mobile device to
share the content on our Platform, you choose who you share the content with. We do not
control and shall not be liable for the manner, in which such persons (with whom you choose
to share content via any sharing options, such as WhatsApp or Facebook, available on the
Platform) use the information that you share with them.
Sharing with Third Parties
We may share your information (including Personal Information) with select third parties
including:
· Business partners, suppliers and sub-contractors (“Affiliates”). Affiliates may use this
information to help provide, understand, and improve the Service and Affiliates’ own services
for the performance of any contract we enter into with you.
· Advertisers and advertising networks that require the data to select and serve relevant
adverts to you and others. We do not disclose information about identifiable individuals to
our advertisers, but we may provide them with aggregate information about our users (for
example, we may inform them that any given number of women in a specified age group
clicked on their advertisement on any given day). We may also use such aggregate
information to help advertisers reach the kind of audience they want to target.
· Government bodies or law enforcement agencies, if we have good-faith belief that it is
reasonably necessary to share your personal data or information in order to comply with any
legal obligation or any government request; or to protect the rights or prevent any harm to
the property, or safety of the Company, our customers, or public; or to detect, prevent or
otherwise address public safety, fraud, security or technical issues.

We may also disclose your information (including Personal Information) to select third parties
in the following circumstances:
· If the Company or substantially all of its assets are acquired by a third party, in which
case personal data held by it about its customers will be one of the transferred assets. If we
are involved in a merger, acquisition, bankruptcy, reorganization or sale of assets such that
your information would be transferred or become subject to a different Privacy Policy, we will
notify you in advance so you can opt out of any such new policy by deleting your account
before transfer.

SECURITY PRACTICES

We have in place appropriate technical and security measures to secure the information
collected by us. Where we have given you (or where you have chosen) a username and
password which enables you to access the Platform, you are responsible for keeping these
details confidential. We ask you not to share your password with anyone.

WHERE WE STORE YOUR PERSONAL INFORMATION

We store your data with Amazon Web Services cloud platform provided by Amazon Web
Services, Inc. (headquartered at 410 Terry Ave. N Seattle, Washington 98109, USA) and
also on Google Cloud Platform provided by Google LLC (headquartered at 1101 S Flower
St, Burbank, California 91502, USA) on their servers located in India and abroad. Both
Amazon Web Services and Google Cloud Platform implement security measures to protect
the loss, misuse and alteration of the information, details of which are available at
https://aws.amazon.com/​ and h ​ ttps://cloud.google.com​. The privacy policies adopted by
Amazon Web Services and Google Cloud Platform are available at
https://aws.amazon.com/privacy/?nc1=f_pr​ and ​https://policies.google.com/privacy​.

CHANGES TO THIS POLICY

The Company may periodically update this Privacy Policy. Whenever we make any changes
to this Privacy Policy that are important for you to know about, we will post the updated
Privacy Policy at this link. It is your responsibility to keep checking this page from time to
time in order to be aware of any changes made to this Privacy Policy.

DISCLAIMER
Unfortunately, the transmission of information via the internet is not completely secure.
Although we will do our best to protect your Personal Information, we cannot guarantee the
security of your data transmitted to the Platform; any transmission is at your own risk. Once
we have received your information, we will use strict procedures and security features to try
to prevent unauthorised access.

YOUR RIGHTS
You are free to remove or delete content from your user account/profile and your account/
profile at any point in time. However, the history of your activities and account on our
Platform remains available to us.
You may correct, amend, add or delete Personal Information from your account at any time
by logging in and visiting your profile page. As noted above, you may opt out from unwanted
e-mail communications from us by following the instructions in the message. However, until
your account is deleted you will continue to receive all system e-mails.
Under Section 5(6) of the Information Technology (Reasonable Security Practices and
Procedures and Sensitive Personal Data or Information) Rules, 2011 (“Rules”), you have a
right to ask us to review, correct and amend the information we collect about you at any
point in time. Under Section 5(7) of the Rules, you also have the right to revoke your consent
to the collection of your information going forward. However, please note that revoking your
consent may negatively affect your use of the Platform. For instance, we need access to
your mobile device’s media folder and camera so that you can click pictures from your
mobile device and post them on the Platform, which functionality will not be available to you
if you do not provide us such access. You may also ask us not to process your personal data
for marketing purposes. You can exercise any of these rights at any time by contacting us at
[email protected]. However, we require a reasonable period of 30 (thirty) days to
comply with any of your requests.

DATA RETENTION
We do not retain your Sensitive Personal Information (defined below in this paragraph) for
longer than is required for the purposes for which the information may be lawfully used. For
any other content, we will entertain your request for deletion, however, there is a strong
possibility that copies of any public content will be retained indefinitely in our systems,
including in cached and archived pages of the Platform, or if other users have copied or
saved that information. In addition, due to the nature of the internet, copies of your content,
including content that you have removed or deleted from your account, may also exist
elsewhere on the Internet and be retained indefinitely. “Sensitive Personal Information” shall
mean passwords and any other information that is classified as sensitive under Section 3 of
the Rules.

THIRD PARTY LINKS

The Platform may, from time to time, contain links to and from the websites of our partner
networks, advertisers, Affiliates and/or any other websites or mobile applications. If you
follow a link to any of these websites, please note that these websites have their own privacy
policies and that we do not accept any responsibility or liability for these policies. Please
check these policies before you submit any personal data to these websites or mobile
applications.
THIRD-PARTY EMBEDS
What Are Third Party Embeds?
Some of the content that you see displayed on the Platform is not hosted by the Platform.
These “embeds” are hosted by a third-party and embedded in the Platform. For example:
YouTube or Vimeo videos, Imgur or Giphy gifs, SoundCloud audio files, Twitter tweets, or
Scribd documents that appear within a post on the Platform. These files send data to the
hosted site just as if you were visiting that site directly (for example, when you load a
Platform post page with a YouTube video embedded in it, YouTube receives data about your
activity).
Privacy Concerns With Third Party Embeds
The Platform does not control what data third parties collect or what they will do with it. So,
third-party embeds on the Platform are not covered by this Privacy Policy. They are covered
by the privacy policy of the third-party service.
Sharing Personal Information With Third Party Embeds
Some embeds may ask you for Personal Information, such as your email address, through a
form. We do our best to keep bad actors off of the Platform. However, if you choose to
submit your information to a third party this way, we don’t know what they may do with it. As
explained above, their actions are not covered by this Privacy Policy. So, please be careful
when you see embedded forms on the Platform asking for your email address or any other
Personal Information. Make sure you understand who you are submitting your information to
and what they say they plan to do with it. We suggest that you do not submit Personal
Information to any third-party through an embedded form.
Creating Your Own Third Party Embed
If you embed a form that allows submission of Personal Information by users, you must
provide near the embedded form a prominent link to an applicable Privacy Policy that clearly
states how you intend to use any information collected. Failure to do so may lead the
Company to disable the post or take other action to limit or disable your account.

COMMUNICATIONS FROM US
We may from time to time send you service-related announcements when we consider it
necessary to do so (such as when we temporarily suspend the Platform for maintenance, or
security, privacy, or administrative-related communications). We send these to you via SMS.
You may not opt-out of these service-related announcements, which are not promotional in
nature and used solely to protect your account and keep you informed of important changes
to the Platform.

Cookie Policy

The capitalized terms used in this Cookie Policy, but not defined herein, shall have the
meaning given to such terms in the Terms.

What are cookies, pixels, and local storage?

Cookies are small files that the websites place on your computer as you browse the web.
Like many websites, we use cookies to discover how people are using our Platform and to
make them work better.

A pixel is a small amount of code on a web page or in an email notification. As many other
websites do, we use pixels to learn whether you’ve interacted with certain web or email
content. This helps us measure and improve our Platform and personalize your experience
on our Platform.
Local storage is an industry-standard technology that allows a website or application to store
information locally on your computer or mobile device. We use local storage to customize
what we show you based on your past interactions with our Platform.

Why do we use these technologies?

We may use these technologies to show you relevant content, improve your experience and
help protect us and our users. We may use these to provide you with services on our
Platform, that are easier and faster to use, and enable you to easily navigate our Platform
and use its features. We may use these to retain authentication information in order to
provide certain services to you, to retain your language preference and to provide mapping
and location-based services which require your location. We may use these technologies to
store information about how you use our Platform, for instance, what pages you visit most
often, and if visiting some pages gives you error messages. We may use these technologies
to collect information on the total number of visitors to our Platform on an ongoing basis. We
may, along with our advertising partners, use these technologies to deliver, understand and
improve advertisements that you see.
We cannot identify you personally from the information these cookies collect. Only for
functionality purposes, personally identifiable information that you disclose like your
username and profile picture may be collected. We ensure complete transparency with you
about what information is collected, how it is going to be used and with whom it is shared.

What types of cookies do we use?

Two types of cookies may be used on our Platform- "session cookies" and "persistent
cookies". Session cookies are temporary cookies that remain on your device until you leave
our Platform. A persistent cookie remains on your device for much longer or until you
manually delete it (how long the cookie remains on your device will depend on the duration
or "lifetime" of the specific cookie and your app settings).
Some of the pages you visit may also collect information using pixel tags (also called clear
gifs) that may be shared with third parties which directly support our promotional activities
and Platform development. For example, usage information about visitors of our Platform
may be shared with our third party advertising agency to better target internet banner
advertisements on Platform. The information is not, however, personally identifiable,
although it could be linked to your personal information.

Cookies used on the Platform

Type of What do they do? Do these cookies collect my personal
Cookie data / identify me?
Necessary These cookies are essential to make our These cookies don’t identify you as an
Platform work correctly and to enable individual.
you to use some of its features, like
authenticate log-in, secure our Platform
and your information, and prevent
fraudulent, criminal or other suspect
activities. Without these cookies, our
Platform will not be able to remember
your previous actions and therefore will
not be able to enable you to navigate
back to a page in the same session.
Performanc These cookies enable us to analyze how These cookies do not identify you as
e our Platform is used that helps us to an individual. All data is collected and
continually improve its performance. aggregated anonymously.
These cookies help us understand how
visitors interact with our Platform by
providing information about the areas
visited, the time spent on our Platform,
and about any issues encountered, such
as error messages.
Functionalit These cookies help the Platform The information these cookies collect
y remember the choices you make (such may include personally identifiable
as your language preference, the information that you have disclosed,
settings you have applied), store such as your username or profile
accessibility options, show when you are picture. We will always be transparent
logged in, and tailor our Platform for you. with you about what information we
This ensures that the Platform provides collect, what we do with it and with
you with services that you have asked whom we share it.
for.
If you do not accept these cookies, it
may affect the performance and
functionality of the Platform and may
restrict access to content on it.
Targeting / These cookies are used to deliver Most types of these cookies track
advertising content that is more relevant to you and consumers via their IP address so may
your interests. They may be used to collect some personal identifiable
deliver targeted advertising or to limit the information.
number of times you see an
advertisement. They also help us
measure the effectiveness of advertising
campaigns.
We may use these cookies to remember
pages or websites you have visited and
we may share this information with other
parties, including advertisers and our
agencies.

Where are these technologies used?

We use these technologies on our own Platform and on other websites that may have
integrated our services. This includes our advertising and platform partners. Third parties
may also use these technologies, for example, when you interact with their content from
within Platform, like when you click a link or stream media on our Platform from a third-party
service, and to help with the delivery of advertisements that may be shown on and off of our
Platform.

Do we use Third Party Cookies?

We use a number of suppliers that may also set cookies on your device on our behalf when
you visit our Platform, to allow such third parties to deliver the services that they are
providing.
When you visit our Platform, you may receive cookies from third party websites or domains.
We endeavor to identify these cookies before they are used so that you can decide whether
or not you wish to accept them. More information about these cookies may be available on
the relevant third party's website.

How can I control Cookies?

Most internet browsers are initially set up to automatically accept cookies. You can change
the settings to block cookies or to alert you when cookies are being sent to your device.
There are a number of ways to manage cookies. Please refer to our Platform instructions or
help screen to learn more about how to adjust or modify your app settings.
If you disable the cookies that we use, this may impact your experience while on the
Platform, for example you may not be able to visit certain areas of our Platform or you may
not receive personalized information when you visit our Platform.
If you use different devices to view and access the Platform (e.g. your computer,
smartphone, tablet etc.) you will need to ensure that each browser on each device is
adjusted to suit your cookie preferences.

Changes to this Cookie Policy

We will occasionally update this Cookie Policy to reflect changes on our Platform and
services. If we make any material changes in the way we collect, use, or share information
held in cookies, we will post these changes to this Cookie Policy and revise the “Last
Updated” date at the top of the Cookie Policy.

Cookies that have been set in the past

If you have disabled one or more cookies, we may still use information collected from
cookies prior to your disabled preference being set. However, we will stop using the disabled
cookie to collect any further information.

Contact us
If you have any questions or comments about our privacy policy, you can contact us our
Grievance Officer at the following coordinate -

Name: Harshvardhan Chhangani

Email ID: [email protected]