Privacy Policy


A. Information we collect and receive

B. How we use your information

C. Your choices

D. Sharing and disclosure

E. Security

This privacy policy (“Policy”) will help you understand what information we collect at Grouple, why we collect it, how Grouple uses it, including if and how we share the information with third parties, and the choices you have. 

When we talk about “Grouple,” “we,” “our,” or “us” in this Policy, we are referring to Ghosh Technology Private Limited, the company which provides the Services.  When we talk about “you” in this Policy, we are referring to the User of the Services.

By using Grouple’s Services either offline or by accessing the Website and providing your data to Grouple, you, individually as a User, agree to the terms of this Policy, for your use of the Services. This Policy may be modified by Grouple from time to time in its sole discretion, and any modifications shall be made effective and binding upon you through posting by Grouple on the Website or through communication via e-mail/SMS to the contact details provided by the User to Grouple.

Capitalized terms used herein but not defined will have the meaning ascribed to them in the Terms of Use.


1. User Data

User Data may contain ‘sensitive personal data or information’ or ‘personal information’ as defined under the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (“Data Protection Rules”). Grouple will collect, store, use, process, and transfer such information as prescribed under the Data Protection Rules. Where Grouple collects or processes “User Data”, it does so on behalf of the User. User Data may include the following types of data, but is not restricted to: employee first and last name, billing details, employee email IDs, phone-numbers and other contact information, including profile related information, such as mobile numbers, date of birth, and/or a photo, in addition to the information mentioned in Section A.2. below.

2. Other information

Account creation information: Users provide information such as an email address and password to create an account.

Billing and other information: For purchase of the Services, our corporate affiliates and/or our third-party payment processors may collect and store billing address and credit card information on our behalf or we may do this ourselves.

Services usage information. This is information about how you are accessing and using the Services, which will include administrative and support communications with us and information about the Performers, content you have shared, your bookings etc.

Contact information: With your permission, any contact information you share is collected (such as an address book from a device) when using the Services. We may also collect your phone number and email address to contact you. You will also receive SMSs, emails, phone calls etc. regarding the Service.

Log data: When you use the Services our servers automatically record information, including information that your browser sends whenever you visit a website or your mobile app sends when you are using it. This log data may include your internet protocol address, the address of the web page you visited before using the Services, your browser type and settings, the date and time of your use of the Services, information about your browser configuration and plug-ins, language preferences, and cookie data.

Device information: We may collect information about the device you are using the Services on, including what type of device it is, what operating system you are using, device settings, application IDs, unique device identifiers, and crash data. Whether we collect some or all of this information often depends on what type of device you are using and its settings.

Geo-location information: Precise GPS location from devices may be required for effective delivery of the Services, and will as such be collected with your permission. Wi-Fi and IP addresses received from your browser or device may be used to determine approximate location.

User Content information: Text, images, data, videos, audio, and/or other material, including third party content that you share/generate using our Services including your or any third party name or username, voice, Likeness, and/or derivative work. For the purpose of this Privacy Policy and the Terms of Use, “Likeness” shall mean the User’s face, image, biographical data, name, signature, voice, photograph, persona, mannerisms, and distinctive dress patterns (“User Content”). Grouple shall have the right to use all User Content generated by the User while using the Services including User Content captured/recorded by Grouple while the User uses the Services online or offline.

Services integrations: If, when using the Services, you integrate with a third-party service, we will connect that service to ours. The third-party provider of the integration may share certain information about your account with Grouple. However, we do not receive or store your passwords for any of these third-party services.

Third party data: Grouple may also receive information from affiliates in our corporate group, our partners, or others that we use to make our own information better or more useful. This might be aggregate level information, such as which IP addresses go with which zip codes, or it might be more specific information, such as about how well an online marketing or email campaign performed.

3. Retention

The information above would be collected and retained by the following entity – Ghosh Technology Private Limited

We will not retain any sensitive personal data or information for longer than is required for the purpose for which such data or information was collected or may lawfully be used or is otherwise required under any other law for the time being in force. We may retain anonymized data for as long as is required.

4. Our Cookie Policy

Grouple uses cookies and similar technologies like single-pixel gifs and web beacons, to record log data. We use both session-based and persistent cookies. Cookies are small text files sent by us to your computer and from your computer or mobile device to us each time you visit our Website or use our desktop application/ mobile app. They are unique to your account or your browser. Session-based cookies last only while your browser is open and are automatically deleted when you close your browser. Persistent cookies last until you or your browser delete them or until they expire.

Some cookies are associated with your account and personal information in order to remember that you are logged in and which accounts you are logged into. Other cookies are not tied to your account but are unique and allow us to carry out site analytics and customization, among other similar things. If you access the Services through your browser, you can manage your cookie settings there but if you disable some or all cookies you may not be able to use the Services.

Grouple sets and accesses cookies on the domains operated by Grouple and its corporate affiliates. In addition, we use third parties like “Google Analytics” for website analytics. You may opt-out of third party cookies from Google Analytics on its website. We do not currently recognize or respond to browser-initiated “Do Not Track” signals as there is no consistent industry standard for compliance.


By opting to provide us with information, you understand and accept that we use your information to provide and improve the Services, as more specifically detailed below. You will, at all times, have the option to refrain from disclosing your personal information to Grouple. You will also have the option of withdrawing consent previously provided to Grouple. However, Grouple does not yet provide an option for the User to delete their account. In such cases, Grouple shall no longer be obliged to continue providing Services to you or continue to provide you with access to the Services.

1. User Data

Grouple may access and use User Data as reasonably necessary and in accordance with User’s instructions to (a) provide, maintain and improve the Services; (b) to prevent or address service, security, technical issues, or at a User’s request in connection with User support matters; (c) as required by law, and (d) as set forth in the Grouple Terms and Conditions of use or as expressly permitted in writing by the User.

2. Other information

We use other information in providing the Services. Specifically:

To understand and improve our Services: We carry out research and analyze trends to better understand how users are using the Services and improve them.

To communicate with you by: Responding to your requests: If you contact us with a problem or question, we will use your information to respond.

Sending emails and notifications: By accepting the terms of this Policy you give us the permission to send you service and administrative emails and messages including text messages. You hereby consent to receiving text messages from us, however you have the option to opt out later. We may also contact you to inform you about changes in our Services, our Service offerings, and important Service related notices, such as security and fraud notices. These emails and notifications are considered part of the Services and you may not opt-out of them. In addition, we sometimes send emails about new product features or other news about Grouple. You can opt out of these at any time.

Billing and account management: We use account data to administer accounts and keep track of billing and payments.

Communicating with you and marketing: We often need to contact you for invoicing, account management and similar reasons. We may also use your contact information (with us) for our own marketing or advertising purposes. You can opt out of these at any time. In addition, Grouple may also use the User Content for marketing, publicity, and advertising purposes.

Investigating and preventing bad things from happening: We work hard to keep the Services secure and to prevent abuse and fraud.

Analysing and ensuring that great things do happen: We work hard to make our products intelligent; and any information from you, that we can use to make our Services serve you better, we want to and will.

This policy is not intended to place any limits on what we do with data that is aggregated and/or de-identified so it is no longer associated with an identifiable user or User of the Services.


1. Inaccurate User Information

Users can review and correct any inaccurate or deficient information that the User has provided by accessing the Software Platform.

2. Other Choices

In addition, the browser you use may provide you with the ability to control cookies or other types of local data storage. Your mobile device may provide you with choices around how and whether location or other data is collected and shared. Grouple does not control these choices, or default settings, which are offered by makers of your browser or mobile device operating system.


There are times when information described in this Policy may be shared by Grouple. This section discusses how Grouple may share such information. By accepting the terms of this Policy, you consent to the sharing of such information with other third parties. These other third parties may have access to your information for the limited purpose of providing Grouple services we may have contracted them to provide us.

1. User Data

Grouple may share User Data in accordance with Grouple terms of use, including:

With third party service providers and agents: We may engage third party companies or individuals to process User Data, or in turn use it to deliver the Services more efficiently to you for use in the Services.

With affiliates: We may engage affiliates in our corporate group to process User Data for use in providing the Services.

With Performers: Grouple may, acting on our User’s behalf, share User Data with the Performers added by User to the Services. Grouple is not responsible for how the provider of an integration may collect, use, and share User Data.

2. Other information

Grouple may share other information as follows:

With third party service providers and agents: We may engage third party companies or individuals, such as third party payment processors, to process information on our behalf.

With affiliates: We may engage affiliates in our corporate group to process other information.

3. Other types of disclosure

Grouple may share or disclose User Data and other information as follows:

During changes to our business structure: If we engage in a merger, acquisition, bankruptcy, dissolution, reorganization, sale of any or all of Grouple’s assets, financing, acquisition of all or a portion of our business, a similar transaction or proceeding, or steps in contemplation of such activities (e.g. due diligence).

To comply with laws: To comply with legal or regulatory requirements and to respond to lawful requests, court orders and legal process.

To enforce our rights, prevent fraud and for safety: To protect and defend the rights, property, or safety of us or third parties, including enforcing contracts or policies, or in connection with investigating and preventing fraud.

For marketing and advertising purpose: You explicitly consent to allowing Grouple to share or disclose the User Content, to further the interests of Grouple and to enable Grouple to market the platform effectively whether through themselves or through or on the platforms of third party service providers. Grouple will, on a best efforts basis, take steps to de-anonymise the User Content which is being used by Grouple for marketing, publicity, and advertising purposes of the User. However, Grouple has the right to use the Likeness of the User for marketing, publicity, and advertising purposes as may be required to depict the Grouple platform in a positive light to the public. Grouple shall blur/remove/otherwise visually distort the name and username of the User in any content created for marketing/advertising/publicity purposes.

Further, we may disclose or use aggregate or de-identified information for any purpose. For example, we may share information with our partners or others for marketing, business development, or research purposes.


Grouple ensures the confidentiality and security of the personal information and ‘sensitive personal data and information’ provided to its Users by implementing comprehensive information security practices and standards as mandated by the Data Protection Rules.


If you have any concerns or questions in relation to this Policy, you may address them to our grievance officer whose name and email address are as follows:

Saurav Kanti Ghosh