1. INTRODUCTION

Influvilla (hereinafter “Influvilla”, “we”, “us”, or “our”) respects the privacy of its users (“User”, “you”, or “your”). This Privacy Policy explains how we collect, use, disclose, store, and safeguard your information when you:

  • Visit our website: www.influvilla.com, and/or
  • Use our mobile application (“Influvilla App”),

Together referred to as the “Platform” (including any other form, channel, website, or mobile application related or connected thereto). If you do not agree with the terms of this Privacy Policy, please do not access or use the Platform.

We may update this Privacy Policy from time to time. When we do:

  1. We will update the “Last Updated” date at the top of this document; and
  2. We will notify you at least seven (7) days in advance, via in-Platform notice and/or email, before changes become effective.

This Privacy Policy is an integral part of our Terms of Service and should be read together with it.

2. INTERPRETATION AND DEFINITIONS

For the purpose of this Privacy Policy:

  • Account: A unique account created by you to access and/or provide services via Influvilla.
  • Child: Any person below the age of eighteen (18) years.
  • Consent: Explicit, free, informed, specific, and unambiguous indication of the User’s wishes, as defined under the Digital Personal Data Protection Act, 2023 (“DPDPA”).
  • Content: Any content created, uploaded, or made available by a Creator on the Platform, including but not limited to videos, audio, text, images, live streams, and other digital materials.
  • Compatible/Supported Device: A personal computer, smartphone, tablet, or other electronic device that meets the system and compatibility requirements of the Platform.
  • Cookies: Small text files placed on your device by a website, used to store and track information about your browsing activity.
  • Creator / Artist / Service Provider: An individual or entity that uses Influvilla to create, promote, and sell digital services or content.
  • Data Fiduciary: Influvilla / ASG TECH SOLUTIONS, which alone or jointly determines the purposes and means of processing Personal Data under the DPDPA.
  • Data Principal: The individual to whom Personal Data relates (i.e., you as a User), having rights under the DPDPA.
  • Data Protection Officer (DPO): The designated officer appointed by Influvilla in accordance with the DPDPA to oversee data protection compliance.
  • Digital Personal Data Protection Act, 2023 (DPDPA): Indian legislation governing the protection and processing of digital personal data.
  • Grievance Officer: The officer appointed by Influvilla for handling user complaints and grievances.
  • Personal Data / Personal Information: Any data relating to an identified or identifiable individual, including but not limited to name, email, contact details, identifiers, financial information, and any other information defined as personal under applicable laws.
  • Platform / Website: The Influvilla website (e.g., www.influvilla.com) and the Influvilla App.
  • Influvilla Features: The web-based tools and services that allow creators to design, launch, and monetise digital offerings such as subscriptions, live events, services, and one-to-one interactions.
  • Service: Any digital or physical product or service accessed, availed, or purchased by a User via the Platform.
  • Subscriber: An individual or entity that purchases or consumes Content or Services from a Creator via the Platform.
  • We / Us / Our: Influvilla, operated by ASG TECH SOLUTIONS, a company incorporated in Bengaluru, Karnataka.
  • You / Your / User: Collectively refers to Creators, Subscribers, and any other individual or entity accessing or using the Platform.

For this Privacy Policy, the term “Personal Data / Information” also includes, where applicable, the meaning of “Sensitive Personal Data or Information” and “Personal Information” under Indian SPDI Rules.

3. USE OF PERSONAL DATA

We process your Personal Data for the following purposes:

  • To provide, operate, and maintain the Influvilla Services;
  • To create, verify, and manage your Account;
  • To enable you to join or access a Creator’s membership, subscription, or paid offering;
  • To process payments for Creator memberships, services, or digital products;
  • To send you service-related communications, notifications, and administrative messages;
  • To send you emails and/or newsletters based on your preferences (where allowed by law);
  • To respond to your queries, support requests, and feedback;
  • To market Influvilla and its services to you, where permitted by law and/or with your consent;
  • To understand how you use the Platform and improve our tools, user experience, and offerings;
  • To conduct research and development to improve and develop products and features;
  • To prevent, detect, and address fraud, abuse, security risks, or technical issues;
  • To ship or facilitate delivery of any merchandise or physical benefits, if applicable;
  • To provide reasonable accommodation if you notify us of a disability (where feasible);
  • To perform internal business operations, including audits, analytics, compliance, and reporting;
  • To resolve disputes, enforce our Terms, and troubleshoot operational issues.

We rely on your Consent, performance of a contract, compliance with legal obligations, and/or our legitimate interests as legal bases for processing, as permitted by applicable law.

4. CONSENT

We are committed to processing your Personal Data in line with the DPDPA and other applicable data protection laws. Your Consent is obtained in a manner that is free, informed, specific, unambiguous, and capable of being withdrawn.

Your use of the Platform and continued access after updates to this Policy constitutes your explicit Consent to the collection, use, storage, and disclosure of your Personal Data as described herein.

We may seek additional explicit Consent where:

  • We introduce new types of processing not covered in this Policy; or
  • We share your Personal Data with new categories of third parties for new purposes.

Withdrawal of Consent

You may withdraw your Consent at any time by:

  • Deleting your account on the Platform;
  • Opting out of marketing communications using the unsubscribe links provided;
  • Emailing us at support@influvilla.com to request modification or deletion of your Personal Data; or
  • Contacting our DPO (see Section 17).

Please note: Withdrawal of Consent may affect your ability to use certain features or Services on the Platform. We may continue to process certain data where required by law or for legitimate business purposes (e.g., fraud prevention, legal compliance).

5. RETENTION OF PERSONAL DATA

We retain Personal Data:

  • For as long as necessary for the purposes described in this Privacy Policy;
  • For as long as required by law, regulation, or legitimate business needs (e.g., tax, accounting, dispute resolution);
  • For up to six (6) months after account deletion or deactivation, subject to case-specific reasons such as legal, security, or audit requirements.

Once retention is no longer required: Personal Data is deleted or irreversibly anonymised, so that it can no longer identify you.

6. COLLECTION AND USAGE OF DATA

We collect and use Personal Data from Users to provide and improve the Platform and Services in alignment with their preferences.

6.1 Types of Data Collected

We may collect:

  • Identity and contact information
  • Financial and transactional information
  • Content and interaction information
  • Technical and usage information
  • Cookies and tracking information

6.2 Personal Data for Opening an Account

To open and maintain an Account, you may be required to provide:

  • Email address
  • Username
  • Mobile number
  • Legal name

For Creators (and, where applicable, for regulatory reasons), we may additionally require:

  • PAN number
  • Aadhaar number
  • Bank account and payout details

Certain fields are mandatory for Creators (especially those who receive payouts and cross compliance thresholds).

6.3 Financial / Transactional Data

To receive payouts or make payments, you may need to provide:

  • Legal name
  • Residential or billing address
  • PAN (mandatory for Creators; may be optional for Subscribers)
  • Aadhaar (mandatory for Creators where required for KYC or legal compliance)
  • UPI details, bank account details, or other payment-related information

We may also collect transaction metadata (ID, status, time, method) required for accounting, reconciliation, and compliance. Note: Payment instrument details (such as full card numbers) are typically processed by third-party payment processors, not stored by us.

6.4 Content Data

We collect data relating to the Content you create, upload, share, or interact with on the Platform, including:

  • Text, audio, images, videos, and live streams
  • Comments, messages, chat interactions
  • Engagement metrics (views, likes, purchase behaviour, etc.)

This is used for operating and maintaining the Platform, analytics, content moderation, and policy enforcement.

6.5 Additional Data We Collect

We may collect and store information based on your interactions with the Platform, including:

  • Services browsed or viewed
  • Email addresses and other contact data you provide
  • Comments or messages you post or send
  • Engagement with Creators’ pages or profiles

We may also collect, automatically or via third-party tools:

  • Device type and model
  • Operating system and browser type
  • Device identifiers and IP address
  • Pages visited, links clicked, and features used
  • Referring websites or apps
  • Search terms used on the Platform
  • Approximate geo-location based on IP address and/or self-disclosed country

6.6 Tracking Technologies & Cookies

We use Cookies and similar technologies (such as web beacons, pixel tags, and clear GIFs) to:

  • Track activity on the Platform
  • Store certain information (e.g., session state, preferences)
  • Improve user experience and performance
  • Analyse traffic and usage patterns

You can instruct your browser to refuse Cookies or to alert you when Cookies are being sent. However, if you disable Cookies, some features of the Platform may not function properly.

6.7 Types of Cookies Used

We use several categories of cookies:

  • Necessary or Essential Cookies (Session Cookies)
    Administered by: Influvilla — Enable core Platform functionality, authenticate Users, prevent fraudulent use of accounts.
  • Cookie Policy / Notice Acceptance Cookies (Persistent Cookies)
    Administered by: Influvilla — Store whether a User has accepted the Cookie Policy.
  • Functionality Cookies (Persistent Cookies)
    Administered by: Influvilla — Remember preferences such as login, language, and display settings.
  • Tracking and Performance Cookies (Persistent Cookies)
    Administered by: Influvilla and/or analytics providers — Collect information about traffic and usage to help test new pages or features and understand how Users interact with the Platform.

For more information, please refer to our Cookie Policy, if provided separately.

6.8 Other Websites

Creators and other Users may share links to third-party websites or services that are not operated by Influvilla. If you click on a third-party link, you will be directed to that website. We strongly advise you to review the Privacy Policy of each website you visit. Influvilla is not responsible for the content, privacy practices, or data security policies of third-party websites or services.

7. TRANSFER OF PERSONAL DATA

Your information, including Personal Data, may be stored on our cloud infrastructure, including servers located in Mumbai, India; and may be transferred to and processed in other jurisdictions where our service providers or partners are located. We will take reasonable steps to ensure that such transfers comply with applicable data protection laws and that your Personal Data is treated securely.

8. SHARING OF YOUR PERSONAL DATA

We may share your Personal Data under the following circumstances:

8.1 With Creators

When you subscribe to, purchase from, or otherwise engage with a Creator, we may share:

  • Your name
  • Profile details visible on the Platform
  • Your country or location (as needed for tax or delivery)
  • Shipping or delivery details for physical merchandise or benefits
  • The content of messages you send to that Creator via the Platform

We may also share aggregated, anonymised data about how users interact with a Creator’s Content, which cannot be linked back to you individually.

8.2 With Subscribers and Other Users

If you are a Creator or public-facing User, others may see:

  • Your full name or display name
  • Your profile picture (if uploaded)
  • The Content you post or make publicly available
  • Certain public engagement metrics

8.3 Third-Party Service Providers

We may share your Personal Data with third parties that perform services for us or on our behalf, such as payment processing, data analytics, email and SMS delivery, hosting and cloud infrastructure, customer support tools, and marketing or promotional services. These third-party service providers are generally bound by contract to use Personal Data only for the purposes specified and implement reasonable data protection measures.

We may also share your information with third parties for marketing purposes where permitted by law and, if required, where you have provided Consent.

9. DISCLOSURE OF YOUR PERSONAL DATA

9.1 Business Transactions / Partners / Investors / Mergers

Your Personal Data may be disclosed or transferred as part of any merger, acquisition, financing, or sale of assets involving Influvilla or ASG TECH SOLUTIONS; or to business partners or investors for general business analysis or due diligence (typically in aggregated or anonymised form, where feasible). We will notify you if your Personal Data is subject to a different Privacy Policy as a result of such a transaction.

9.2 Law Enforcement or Government Agencies / Legal Requirements

We may disclose your Personal Data to law enforcement or governmental authorities, courts, tribunals, regulatory bodies, or the Data Protection Board of India when required to comply with applicable laws or legal processes, respond to valid legal requests, investigate or enforce violations of our Terms or policies, or protect the rights, property, or safety of Influvilla, our Users, or the public. This may include exchanging information with other organisations for fraud protection and credit risk reduction.

10. SECURITY OF YOUR PERSONAL DATA

We implement administrative, technical, and physical safeguards to protect your Personal Data. These include, as appropriate:

  • Access controls and authentication
  • Encryption and secure transmission (where implemented)
  • Regular security reviews and monitoring

However, please note: No method of transmission over the Internet or electronic storage is 100% secure; We cannot guarantee absolute security of your Personal Data. Despite our reasonable efforts, if Personal Data entrusted to Influvilla is compromised as a result of a breach of security measures, we will take appropriate remedial actions and comply with applicable legal obligations, including breach notifications where required.

10.1 Storage of Personal Data

The information collected is securely stored on controlled infrastructure, including servers located in Mumbai, India, and possibly other regions via our cloud providers, as required for operational efficiency and redundancy.

10.2 Internal Reviews and DPIA

We may use anonymised or aggregated data for internal reviews and reporting, Data Protection Impact Assessments (DPIA), improving Platform security and features, and understanding user behaviour at a non-identifiable level. We will ensure such anonymised data is not reasonably capable of identifying a specific individual. You may contact our DPO if you wish to object to certain processing activities, where allowed by law.

11. PROCESSING OF YOUR PERSONAL DATA

Our vendors and third-party service providers may have access to your Personal Data as needed to perform services on our behalf, consistent with this Policy.

11.1 Legal Basis for Processing under DPDPA

We process Personal Data under one or more of the following legal grounds: Your Consent; Performance of a contract or pre-contractual measures; Compliance with legal obligations; Legitimate interests (e.g., fraud prevention, service improvement, analytics), provided such interests do not override your fundamental rights and freedoms.

11.2 Cookies and Analytics

We may use third-party analytics tools to monitor and analyse usage of the Platform to enhance user experience and product performance.

11.3 Email Marketing

We may use your Personal Data to send you newsletters, updates about services or features, and promotional materials or offers. You can opt out of such communications by clicking the “unsubscribe” link in any marketing email or contacting us at support@influvilla.com.

11.4 Payment Services

When you make payments, your payment details are processed directly by third-party payment processors. We do not store your complete financial information (e.g., full card numbers). Payment processors’ use of your Personal Data is governed by their own privacy policies and compliance requirements (e.g., PCI-DSS standards).

12. YOUR RIGHTS UNDER THE DPDP ACT, 2023

If you are within the territorial scope of the DPDPA, you may have the following rights as a Data Principal:

  • Right to Access: Request a summary of your Personal Data being processed.
  • Right to Correction: Request correction or completion of inaccurate or incomplete Personal Data.
  • Right to Erasure: Request deletion of your Personal Data where there is no legitimate need to continue processing it.
  • Right to Nominate: Nominate another person (above 18 years and not disqualified by law) to exercise your rights in the event of death or incapacity.
  • Right to Withdraw Consent: Withdraw your Consent at any time for specific processing.
  • Right to Object: Object to certain types of processing, including direct marketing, where applicable.

Exercising Your Rights: You may exercise your rights by using account settings (where available) or contacting us or our DPO using the contact details in Section 17. We may ask you to verify your identity before processing your request; we may decline certain requests where allowed or required by law (e.g., ongoing legal obligations), while informing you of the reasons when feasible. You also have the right to file a complaint with the Data Protection Board of India regarding any perceived violation of your data protection rights under the DPDPA.

13. APPLICABLE LAWS AND GOVERNING JURISDICTION

This Privacy Policy is intended to comply with the Digital Personal Data Protection Act, 2023; The Information Technology Act, 2000; relevant rules, notifications, and amendments; and other applicable data protection and consumer laws, as relevant to our operations and your location.

In the event of a dispute related to this Privacy Policy and the processing of Personal Data relating to Users in India: The laws of the Republic of India shall apply; and courts situated at Bengaluru, Karnataka (India) may have jurisdiction, subject to applicable contractual provisions and any overriding agreement under the Terms of Service.

14. CHILDREN’S PRIVACY

The Platform is not intended for use by individuals under 18 years of age. We do not knowingly solicit, collect, or process Personal Data from anyone under 18. If we learn that Personal Data of a Child has been collected in violation of this Policy, we will take reasonable steps to delete such data. If you are a parent or legal guardian and believe that a Child has provided Personal Data to us: Please contact us immediately using the details in Section 17.

15. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy as necessary. Any material changes will be communicated via the Platform and/or email at least seven (7) days before they become effective. The “Last Updated” date at the top of this Policy will be revised accordingly. Your continued use of the Platform after such changes constitutes your acceptance of the updated Policy. For any queries regarding this Policy or changes to it, you may contact us at: support@influvilla.com

16. GRIEVANCE REDRESSAL

If you have any complaints, concerns, or questions regarding content on the Platform, handling of your Personal Data, or alleged breach of this Privacy Policy, you may contact our Grievance Officer:

Name: Mr. Amit (Grievance Officer)
Website: https://www.influvilla.com
Address: ASG TECH SOLUTIONS, 5th Floor, Kokarya, Jayanagar 5th Block, Bengaluru, Karnataka
Email: support@influvilla.com
Phone: +91 7019 50266

17. CONTACT US / DATA PROTECTION OFFICER (DPO)

For questions, requests, or complaints relating to your Personal Data, this Privacy Policy, or your rights under applicable data protection laws, you may contact our Data Protection Officer (DPO):

Name: Mr. Amit
Address: ASG TECH SOLUTIONS, 5th Floor, Kokarya, Jayanagar 5th Block, Bengaluru, Karnataka
Email: support@influvilla.com
Phone: +91 7019 50266