Legal

Privacy Policy

Effective date: [To be finalized]

This Privacy Policy describes how Skalechat Communications Private Limited (“SkaleChat”, “we”, “us” or “our”) collects, uses, stores, processes and otherwise handles personal data when you use the SkaleChat mobile applications and related services.

SkaleChat respects the privacy of its users. An important feature of SkaleChat is that ordinary members of certain groups may communicate without being given access to specified personal or contact information of other members. This functionality does not mean that users are anonymous to SkaleChat or, where applicable, to the Administrator of a Super Group.

1. Who We Are

The Platform is operated by:

Skalechat Communications Private Limited
C/o Anjana Sharma, Gali No. 4, Uttamnagar, Rewari, Rewari, Rewari – 123401, Haryana, India
Email: support@skalechat.com

For purposes of applicable data protection law, SkaleChat determines the purposes and means by which personal data described in this Privacy Policy is processed, except where another person independently determines the purposes and means of processing.

2. Personal Data We Collect

Depending upon the manner in which you use SkaleChat, we may collect the following categories of personal data.

2.1. Registration and Account Information

When you create an account, we may collect your:

(a) name or display name;
(b) mobile number;
(c) profile photograph;
(d) OTP verification information;
(e) email address, if provided; and
(f) account identifier.

2.2. Communications and User Content

We may process information you communicate through SkaleChat, including:

(a) messages;
(b) photographs and videos;
(c) audio and voice messages;
(d) documents and attachments;
(e) shared location information;
(f) group information; and
(g) other content you choose to transmit through the Platform.

2.3. Group and Activity Information

We may process:

(a) groups of which you are a member;
(b) Super Groups you create or administer;
(c) registration date;
(d) login information;
(e) last-seen status;
(f) interactions with the Platform; and
(g) other account and usage activity.

2.4. Device and Technical Information

Depending upon your device, settings, permissions and use of the Platform, we may process:

(a) IP address;
(b) device type;
(c) operating system;
(d) application version;
(e) device identifiers;
(f) diagnostic information;
(g) crash logs;
(h) usage and analytics information; and
(i) approximate location.

2.5. Device Permissions

Where required for functionality selected by you, SkaleChat may request access to:

(a) location, to permit location sharing;
(b) photographs, videos and other media;
(c) microphone and audio functionality, including for voice messages;
(d) contacts, where a feature requiring contact access is enabled; and
(e) other device functionality reasonably necessary to provide a feature requested by you.

Permissions can generally be managed through your device settings, although disabling a permission may prevent the corresponding feature from functioning.

3. How We Use Personal Data

We may process personal data to:

(a) create, authenticate and maintain your account;
(b) verify your mobile number;
(c) provide messaging and group functionality;
(d) operate Super Groups and their privacy and administrative controls;
(e) transmit messages, media and other content;
(f) enable location, media and audio functionality requested by you;
(g) maintain security and prevent fraud, misuse and unauthorised access;
(h) investigate reports and enforce our Terms of Use;
(i) provide customer and technical support;
(j) maintain, diagnose and improve the Platform;
(k) administer subscriptions and verify purchases;
(l) comply with applicable law and lawful orders;
(m) protect the rights and safety of SkaleChat, its users and others; and
(n) provide AI-assisted features where enabled and appropriately disclosed.

4. Super Groups and Administrator Access

4.1. Super Groups are designed so that ordinary members may have restricted access to other members’ personal information.

4.2. A Super Group Administrator may, however, have access to information including:

(a) your name;
(b) mobile number;
(c) profile photograph;
(d) last-seen status;
(e) messages sent within the Super Group; and
(f) media and other content shared within the Super Group.

4.3. You should therefore understand that information concealed from other ordinary members may nevertheless be available to the Administrator.

4.4. SkaleChat does not represent that participation in a Super Group makes you anonymous to SkaleChat or its Administrator.

5. Messages and Encryption

Messages and other content are encrypted in transit and while stored on our servers. SkaleChat does not currently provide end-to-end encryption.

Because features such as Super Group administration, moderation of reported content and AI-assisted functionality require access to message content, SkaleChat’s systems are able to access the content of messages processed through the Platform. You should therefore not assume that messages are inaccessible to SkaleChat or to a Super Group Administrator.

Where a message is reported, it becomes accessible to authorised moderators for the purposes described in Section 13. Where an AI-assisted feature is enabled, message or group content may be processed as described in Section 6.

6. Artificial Intelligence Processing

Where an AI feature is enabled, messages or other group content may be processed to provide functionality including:

(a) detecting potential violations of Platform policies;
(b) identifying potential attempts to circumvent or bypass an Administrator;
(c) generating summaries; and
(d) generating notes.

AI-assisted features are provided using [AI provider to be confirmed]. Where such processing involves an external provider, relevant content may be shared with that provider solely to the extent necessary to deliver the feature, and subject to applicable contractual and legal obligations.

7. Analytics, Diagnostics, Advertising and Tracking

SkaleChat may use analytics and diagnostic technologies to understand application usage, identify crashes and technical problems, monitor performance and improve the Platform. These presently include [analytics and diagnostics providers to be confirmed]. SkaleChat does not currently serve third-party advertising.

Such technologies may process device type, operating system, application version, IP address, usage events, diagnostic information and crash logs.

Where consent or another user choice is required by applicable law, the relevant processing will be subject to that choice.

8. Payments

Purchases made through SkaleChat’s mobile applications are presently processed through the Apple App Store or Google Play billing systems.

SkaleChat does not directly collect or store full card numbers, bank-account details, UPI credentials, CVV numbers or similar payment credentials where payment is processed through those systems.

SkaleChat may receive transaction information such as an order or transaction identifier, subscription status, product purchased, purchase date and renewal or expiry information necessary to administer the subscription.

9. Service Providers and Disclosure of Personal Data

SkaleChat may disclose or make personal data available to third parties only where reasonably necessary for the purposes described in this Privacy Policy, including:

(a) cloud infrastructure and hosting providers;
(b) analytics and diagnostic providers;
(c) payment and app-store providers;
(d) AI service providers, where applicable;
(e) professional advisers where reasonably necessary;
(f) competent governmental, regulatory, judicial or law-enforcement authorities where required or permitted by law; and
(g) a successor or participant in a genuine corporate restructuring, merger, acquisition or transfer of business, subject to applicable law.

Service providers processing personal data on SkaleChat’s behalf will be required to process such information consistently with applicable contractual and legal obligations.

10. Hosting and International Processing

Personal data is primarily hosted on cloud servers located in [hosting region to be confirmed]. Depending upon the confirmed server region and service providers used, personal data may be processed in a country other than the country in which you reside, subject to applicable legal requirements.

11. Data Retention and Deletion

11.1. You may request deletion of your SkaleChat account through the account-deletion functionality or other mechanism made available by SkaleChat.

11.2. Once an account is deleted, it cannot be recovered or accessed by the user.

11.3. Account data will ordinarily be retained for 30 days following account deletion, after which it will be deleted, except to the extent retention is required by applicable law or reasonably necessary for an applicable legal obligation.

11.4. Where a user deletes a message, the message is removed from our active systems and is not retained.

11.5. Residual copies of deleted content within encrypted backups are automatically overwritten within [backup retention period to be confirmed]. Security and audit logs may be retained for longer where required for legal, security or fraud-prevention purposes. Content that a Super Group Administrator exported or downloaded before deletion cannot be recovered or deleted by SkaleChat.

12. Administrator Downloads and Exports

Super Group Administrators may download content and, subject to applicable administrative controls, export conversations.

Once an administrator lawfully downloads a file onto another device, SkaleChat may not technically be capable of ensuring that it is not retained.

13. Reports and Moderation

Users may report messages, users and groups.

Where a report is submitted, authorised SkaleChat moderators may inspect the reported content to investigate the complaint, enforce the Terms of Use, protect users and comply with applicable law.

14. Security

We will implement reasonable technical and organisational safeguards appropriate to the nature of the personal data processed and the risks associated with processing.

No method of electronic transmission or storage can be represented as completely secure. Users should maintain the security of their devices, accounts and authentication mechanisms.

15. Your Choices and Rights

Subject to applicable law, you may have rights in relation to your personal data, including rights to:

(a) obtain information concerning processing of your personal data;
(b) seek correction, completion or updating of personal data;
(c) seek erasure of personal data where applicable;
(d) withdraw consent where processing is based upon consent;
(e) access grievance redressal mechanisms; and
(f) exercise such other rights as become applicable under the Digital Personal Data Protection Act, 2023 and rules made thereunder.

Where processing is based on your consent, you may withdraw that consent at any time through your in-app settings or by contacting our Grievance Officer. Withdrawal of consent will not affect the lawfulness of processing already carried out, and may be exercised without unreasonable difficulty.

16. Children’s Personal Data

SkaleChat is not intended for children under 13 years of age, and you must be at least 13 to create an account. Where required by the Digital Personal Data Protection Act, 2023, we will not knowingly process the personal data of a child without verifiable parental or guardian consent, and we do not use children’s personal data for targeted advertising or behavioural tracking.

If we become aware that a child has provided personal data without any consent required by applicable law, we will take reasonable steps to delete that information.

17. Grievances and Privacy Requests

Questions, complaints and requests concerning this Privacy Policy or your personal data may be addressed to:

Grievance Officer: Nitin Sharma
Email: support@skalechat.com
Address: C/o Anjana Sharma, Gali no. 4, Uttamnagar, Rewari, Rewari, Rewari- 123401, Haryana, India

18. Legal Disclosures

We may preserve, access or disclose information where reasonably necessary to comply with applicable law, legal process or a lawful direction of a competent authority, or to protect the rights, security and integrity of SkaleChat, our users or others, subject to applicable law.

19. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in our services, technology or applicable law.

Where required by law, we will provide notice of material changes and obtain fresh consent where the change involves processing for a new purpose requiring such consent.

20. Contact Us

For questions concerning this Privacy Policy:

Skalechat Communications Private Limited
C/o Anjana Sharma, Gali No. 4, Uttamnagar, Rewari, Rewari, Rewari – 123401, Haryana, India
Email: support@skalechat.com