Privacy Policy | Kumpanio

Official Kumpanio policy

1. Introduction

Kumpanio (“Kumpanio,” “Company,” “we,” “us,” or “our”) is committed to protecting the privacy and personal information of every User and Companion who accesses or uses our Platform. This Privacy Policy explains how we collect, use, store, disclose, and protect personal information when you access our website, mobile application, or services.

By creating an account, completing verification, making or accepting a Booking, or otherwise using the Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal information in accordance with applicable laws.

2. Scope

This Privacy Policy applies to all visitors, registered Users, Companions, applicants, and any other individuals who interact with Kumpanio through its website, mobile applications, customer support channels, or other services.

This Privacy Policy should be read together with our Terms of Service and any other policies published by Kumpanio.

3. Information We Collect

Kumpanio collects information necessary to operate the Platform, facilitate Bookings, verify identities, improve user safety, comply with legal obligations, and provide customer support.

The information we collect may include personal information provided directly by you, information collected automatically through your use of the Platform, verification information, Booking information, payment information, and communications exchanged with Kumpanio.

4. Information You Provide

Depending on how you use the Platform, you may provide information including:

Full name
Date of birth
Mobile number
Email address
Profile photograph
Gender and preferences
City and location details

Biography and profile information
Emergency contact information, where applicable
Identity verification documents
Government issued identification
Communication with customer support
Reviews, ratings, feedback, and other content submitted through the Platform

You are responsible for ensuring that the information you provide is accurate, complete, and kept up to date.

5. Information Collected Automatically

When you access or use the Platform, we may automatically collect certain technical and usage information , including:

Device information
IP address
Operating system
Browser type
Mobile device identifiers
Application version
Login activity
Session information
Device diagnostics
Crash reports
Platform usage statistics
Cookies and similar technologies, where applicable

This information helps us maintain Platform security, detect fraud, improve performance, and enhance the user experience.

1. Location Information

Kumpanio may collect approximate or precise location in formation, subject to your device settings and permissions, to facilitate Bookings, improve matching, verify meeting locations, enhance Platform safety, detect fraudulent activity, and provide location based services. You may disable location permissions through your device settings; however, certain Platform features may become unavailable or function with limited capability.

2. Device Permissions

Depending on the features you use, Kumpanio may request access to certain device permissions, including th e camera, photo gallery, location services, microphone, notifications, and other permissions necessary for the operation of the Platform. Such permissions are requested only for legitimate Platform functions and may be managed or revoked through your device settings, although doing so may affect certain features or Services.

3. Automated Systems and Artificial Intelligence

Kumpanio may use automated systems, artificial intelligence, machine learning, and similar technologies to improve matching, detect fraudulent activity, identify suspicious behaviour, moderate content, enhance Platform safety, improve customer support, and optimize user experience. Where appropriate and required by applicable law, significant decisions affecting users may be subject to human review.

4. Profile Visibility

Certain profile information may be visible to other Users or Companions to facilitate Bookings and improve transparency on the Platform. Visible information may include your first name, profile photograph, biography , ratings, reviews, and other profile details that you choose to share. Sensitive personal information, including identity verification documents, government issued identification, payment information, email addresses, phone numbers, and similar confidential information, will not be publicly displayed except where necessary to facilitate a Booking or as otherwise permitted by applicable law.

5. Safety Reports and Incident Information

Where Users or Companions submit safety reports or complaints, Kumpani o may collect and process additional information voluntarily provided, including photographs, screenshots, communication records, witness information, police complaint details, medical documentation, or other supporting evidence, solely for the purposes of investigating incidents, protecting Platform safety, resolving disputes, and complying with legal obligations.

6. Fraud Prevention and Security Monitoring

Kumpanio may process personal information to detect, investigate, prevent, and respond to fraudulent activity, fake accounts, identity misuse, duplicate registrations, suspicious payment activity, unusual Booking behaviour, Platform abuse, security incidents, or other activities that may compromise the integrity or safety of the Platform.

7. Data Retention Following Suspension or Termination

Where an account is suspended, restricted, or terminated, Kumpanio may continue to retain certain personal information for a reasonable period where necessary to comply with legal obligations, investigate fraud or safety incidents, resolve disputes, enforce contractual obligations, respond to lawful requests, or protect the rights, safety, and security of the Company, Users, Companions, and the public.

8. User Generated Content

Users and Companions remain responsible for the accuracy, legality, and appropriateness of the content they upload or publish on the Platform, including profile information, photographs, re views, ratings, comments, and other submissions. Kumpanio reserves the right to remove content that violates applicable laws, our Terms of Service, or Platform policies.

9. Business Transfers

In the event of a merger, acquisition, investment, corporate restructuring, financing transaction, sale of assets, or other business transfer involving Kumpanio, personal information may be transferred as part of the transaction, subject to appropriate confidentiality obligations and applicable data protection laws . Kumpanio will take reasonable steps to ensure that your personal information continues to receive an appropriate level of protection.

10. Personal Data Breaches

In the event of a personal data breach that is likely to affect the rights or interests o f Users or Companions, Kumpanio may notify affected individuals and relevant regulatory authorities, where required under applicable law, and take appropriate measures to investigate, contain, mitigate, and remediate the incident.

11. Offline Interactions

Kumpanio facilitates introductions and Bookings between Users and Companions but does not monitor, supervise, or record offline interactions that occur outside the Platform. Information relating to offline interactions may be collected only where voluntarily submitted by Users or Companions during safety reports, customer support requests, dispute resolution, or where otherwise required or permitted by applicable law.

6. Identity Verification (KYC)

To maintain a trusted marketplace and comply with applicable legal and regulatory requirements, Kumpanio may require Users to complete identity verification before accessing certain features or participating in Bookings.

Verification may include the collection of government issued identifica tion, proof of age, selfie verification, facial matching, address verification, live verification, contact verification, payment verification, and any additional documentation reasonably required for fraud prevention, legal compliance, or user safety.

Completion of KYC does not guarantee approval or continued access to the Platform.

1. Verification Call Recordings

Kumpanio may record verification calls for identity verification, fraud prevention, compliance, and Platform safety.

By proceeding with verification, you consent to such recordings.

7. Companion Verification

Individuals applying to become Companions may be required to undergo enhanced verification procedures in addition to standard KYC.

Such verification may include identity verification, age verification, profile review, photograph verification, video verification, communication assessment, behavioural assessment, background verification where legally permissible, and other onboarding procedures established by Kumpanio.

Verification is conducted solely for trust and safety purposes and does not constitute a guarantee, endorsement, certification, or representation regarding any individual's conduct, suitability, or character.

8. Booking Information

When a Booking is requested or completed, Kumpanio may collect information including:

Booking date and time
Booking duration
Meeting location
Booking status
OTP verification records
Companion assignment
Cancellation records
Ratings and reviews
Customer support interactions relating to the Booking

This information enables us to facilitate Bookings, improve service quality, resolve disputes, and enhance Platform safety.

9. Payment Information

Payments made through the Platform are processed using authorized third party payment service providers.

Kumpanio may collect and maintain transaction related information including payment status, transaction identifiers, billing details, refunds, payout information, and payment history.

Kumpanio does not st ore complete payment card information. Payment information is processed securely by authorized payment processors in accordance with their own security standards and privacy practices.

10. Communications

When you communicate with Kumpanio, we may collect and retain information relating to those communications, including:

Customer support requests
Emails
Chat messages
Phone call records, where permitted
Safety reports
Complaints
Feedback
Verification communications
Booking related notifications

These communications help us provide customer support, improve our services, investigate incidents, and comply with legal obligations.

11. How We Use Your Information

Kumpanio may use your personal information to:

Create and manage your account
Verify your identity
Facilitate Bookings
Process payments and payouts
Detect and prevent fraud
Maintain Platform security
Communicate with Users and Companions
Respond to customer support requests
Improve Platform features and user experience
Enforce our Terms of Service
Comply with applicable laws and regulatory obligations
Protect the safety, rights, and legitimate interests of Users, Companions, and Kumpanio

12. Legal Bases for Processing

Kumpanio processes personal information only where permitted under applicable laws, including the Digital Personal Data Protection Act, 2023.

Depending on the circumstances, we may process personal information based on:

Your consent
Performance of our contractual obligations
Compliance with applicable legal obligations
Protection of legitimate business interests
Fraud prevention
Platform security
Protection of the rights, safety, and security of Users, Companions, and the public

By accessing or using the Platform, creating an account, completing verification, making or accepting a Booking, or otherwise interacting with Kumpanio, you consent to the collection, use, storage, and processing of your personal information in accordance with this Privacy Policy.

Where required by applicable law, you may withdraw your consent at any time, subject to legal, contractual, or operational limitations.

Withdrawal of consent may affect your ability to access certain Platform features or continue using the Services.

Kumpanio does not sell your personal information.

We may share personal information only where reasonably necessary with:

Verified Users and Companions to facilitate Bookings
Identity verification providers
Payment service providers
Cloud infrastructure providers
Customer support providers
Analytics and security service providers
Professional advisers
Regulatory authorities
Law enforcement agencies where required by law
Courts or government authorities pursuant to valid legal requests

All recipients are expected to protect personal information in accordance with applicable laws and appropriate confidentiality obligations.

15. Third Party Service Providers

Kumpanio relies on carefully selected third party service providers to operate and improve the Platform. These providers may assist with payment processing, cloud hosting, identity verification, communications, analytics, fraud detection, customer support, and other operational functions.

These providers are authorized to process personal information only for the purposes instructed by Kumpanio and are required to implement appropriate security and confidentiality measures. Kumpanio is not responsible for the independent privacy practices or policies of third party websites, applications, or services that are not owned or controlled by the Company.

16. Payment Processors

Payments made through the Platform are processed by authorized third party payment service providers.

Kumpanio does not store complete payment card or banking credentials. Payment processors collect, use, and protect payment information in accordance with their own privacy policies and applicable laws. Kumpanio is not responsible for the independent privacy or security practices of such providers.

17. Government and Law Enforcement Requests

Kumpanio may disclose personal information where required to comp ly with applicable laws, court orders, regulatory requirements, lawful requests from government authorities, or to protect the rights, safety, security, or property of Kumpanio, its Users, Companions, or the public. Where legally permitted, Kumpanio may no tify the affected individual before disclosing such information.

18. Data Retention

Kumpanio retains personal information only for as long as necessary to provide the Services, comply with legal and regulatory obligations, resolve disputes, enforce our a greements, prevent fraud, and protect the security and integrity of the Platform.

When personal information is no longer required, it will be securely deleted, anonymized, or otherwise disposed of in accordance with applicable laws and Kumpanio's internal data retention practices.

19. Data Security

Kumpanio implements reasonable technical, administrative, and organizational safeguards designed to protect personal information against unauthorized access, disclosure, alteration, loss, misuse, or destruction.

While we strive to maintain appropriate security measures, no method of electronic storage or transmission over the internet can be guaranteed to be completely secure. Users are responsible for maintaining the confidentiality of their account credentials and promptly notifying Kumpanio of any suspected unauthorized access.

20. Your Rights under the Digital Personal Data Protection Act, 2023

Subject to applicable law, you may have the right to:

Access your personal information.
Request correction or updating of inaccurate information.
Request deletion of personal information where legally permissible.
Withdraw consent for processing, where processing is based on consent.
Nominate another individual to exercise applicable rights on your behalf, where permitted by law.
Submit a grievance regarding the processing of your personal information.

Kumpanio will respond to such requests in accordance with applicable legal requirements.

Where processing is based on your consent, you may withdraw such consent at any time by contacting Kumpanio or using available account settings, where applicable.

Withdrawal of consent shall not affect the lawfulness of processing carried out before the withdrawal and may limit or prevent your ability to access certain Platform features or continue using the Services.

22. Cookies and Analytics

Kumpanio may use cookies, similar technologies, and analytics tools to improve Platform performance, understand user interactions, enhance security, remember user preferences, and measure the effectiveness of our services.

You may manage or disable cookies through your browser or device settings; however, doing so may affect the functionality of certain features of the Platform.

23. Marketing Communications

With your consent where required by applicable law, Kumpanio may send promotional communications, product updates, newsletters, offers, or other marketing materials.

You may opt out of marketing communications at any time by using the uns ubscribe option included in the communication or by contacting Kumpanio. Service related communications necessary for operating the Platform may continue even if you opt out of marketing messages.

24. Children's Privacy

Kumpanio is intended exclusively for individuals who are at least twenty two (22) years of age.

The Platform does not knowingly collect personal information from minors or permit them to register or use the Services. If Kumpanio becomes aware that personal information relating to a minor h as been collected, such information may be deleted and the associated account may be suspended or terminated in accordance with applicable laws.

25. International Data Transfers

Kumpanio may process or store personal information using cloud infrastructure or service providers located within or outside India, subject to applicable laws and appropriate contractual, organizational, and technical safeguards.

By using the Platform, you acknowledge that your personal information may be transferred, processed, or stored in jurisdictions that may have different data protection laws than those applicable in your place of residence.

26. Changes to this Privacy Policy

Kumpanio may update this Privacy Policy from time to time to reflect changes in our business operations, Platform features, legal requirements, or privacy practices.

Updated versions will be published on the Platform with a revised “Last Updated” date. Continued use of the Platform after the updated Privacy Policy becomes effective constitutes your acknowledgment of the revised Privacy Policy.

27. Contact Information

If you have any questions, concerns, requests, or complaints regarding this Privacy Policy or Kumpanio's processing of personal information, you may contact us using the details provided below.

28. Grievance Officer

In accordance with applicable Indian laws, Kumpanio has appointed a Grievance Officer to address privacy related concerns, complaints, and requests.

Name: Kunal Singal Designation: Grievance Officer & CTO Email: policy@kumpanio.com The Grievance Officer will acknowledge and address grievances within the timelines prescribed under applicable laws.

— End of Privacy Policy —

Kumpanio is committed to protecting your privacy and handling your personal information responsibly. We continuously review and improve our privacy practices to ensure compliance with applicable laws, enhance user safety, and maintain the security of our Platform.

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal information, please contact our Grievance Officer or reach out to us using the contact details provided above.

Thank you for trusting Kumpanio.