📜 PRIVACY POLICY

This Privacy Policy explains how Infinititalks Wellness Private Limited ("Infiniti Talks", "we", "us" or "our") collects, uses, stores, shares and protects personal data when a person visits our website, creates an Account, purchases or uses Credits, participates in an audio call, contacts support, or applies for or works as a Voice Companion.

By using the Platform, you acknowledge this Privacy Policy. Where processing is based on consent, you may withdraw that consent using the methods described below; withdrawal does not affect processing already lawfully completed.

1. COMPANY AND SCOPE

The data fiduciary/controller responsible for the Platform is:

Infinititalks Wellness Private Limited

• • CIN: U86900KA2026PTC221568
• • GSTIN: 29AAICI9117R1ZN
• • Registered Office: No. 2-79/16-03, Barnes Plaza, Brahmavara, Udupi, Karnataka – 576213
• • Website: www.infinititalks.com
• • Privacy and Grievance Email: partners@infinititalks.com
• • WhatsApp Support: +91 88676 47207

This Policy applies to the Infiniti Talks website, Android application, iOS application and related Company-operated services. Third-party websites, application stores and payment services have their own privacy practices.

2. PLATFORM POSITIONING

Infiniti Talks is a general wellness and companionship platform for adults. It facilitates private one-to-one audio conversations, empathetic listening and general companionship. It is not an emergency, medical, therapy, counselling or mental-health service.

Do not submit medical records, clinical reports, passwords, OTPs, UPI PINs or other information that is unnecessary for using the Platform. If you voluntarily disclose sensitive personal information during a call, the other participant may hear it, and Infiniti Talks cannot control what another person remembers or unlawfully records outside the Platform.

3. PERSONAL DATA WE COLLECT

3.1 Registered Users

• • Mobile number and OTP-verification status
• • Nickname or display name
• • Gender selected during registration
• • Age or adult-status declaration and, where requested, birth information
• • Language preferences and profile information
• • Account status, blocks, reports and rule-enforcement history
• • Support messages, complaints, feedback and communications
• • Permissions selected for microphone, camera/images and notifications

3.2 Voice Companion Applicants and Approved Voice Companions

• • Full legal name, registered mobile number and date or year of birth
• • Languages known, availability and communication-assessment information
• • Profile photograph and approved public profile information
• • PAN number, PAN-card image and identity-verification information
• • UPI ID or other approved payout information
• • Application, onboarding, agreement-acceptance and verification records
• • Call eligibility, earnings, withdrawal, payout and TDS records
• • Quality, safety, fraud-review and complaint information
• • Communications with the onboarding, operations and support teams

3.3 Payments, Credits and Tax Records

• • Credit package selected, taxable value, GST, amount paid and payment status
• • Payment gateway, bank or UPI transaction references
• • Receipt voucher, tax invoice, Credit usage and balance records
• • Failed, reversed, refunded, disputed or chargeback transaction records
• • Voice Companion TDS, payout and tax-certificate information

Infiniti Talks does not ordinarily receive or store a User's full card number, card CVV, UPI PIN, netbanking password or OTP used to authorise payment. These are processed by the relevant payment provider, bank or payment network.

3.4 Calls and Communications

• • Participant Account identifiers and selected Voice Companion profile
• • Call initiation, ringing, acceptance, start and end times
• • Connected duration, disconnection and reconnection status
• • Network quality, device or technical diagnostic information
• • Credits deducted and Voice Companion earnings calculated
• • Call reports, blocks, safety flags and investigation outcomes
• • Support communications relating to a call

Infiniti Talks does not ordinarily record or store the audio content of Voice Companion calls. Audio data is transmitted through the audio-communication provider for real-time delivery. If recording, monitoring or review of call content is introduced, it will be separately disclosed and any legally required consent will be obtained.

3.5 Device, Technical and Usage Information

• • Device type, operating system, application version and language
• • IP address, approximate network location and time zone
• • Device or advertising identifiers where permitted
• • Login, screen, feature, button and session events
• • Crash reports, error logs, performance and security signals
• • Notification token and delivery status
• • Fraud, automation, duplicate-Account and integrity signals

🎙 4. DEVICE PERMISSIONS

4.1 Microphone

Microphone permission is required for audio calls. If permission is denied or withdrawn, calling will not function. Microphone access is used during a call and is not intended to activate secretly in the background.

4.2 Camera and Images

Camera or photo-library access may be requested to capture or upload a profile image, PAN image or identity-verification image. Camera access is not used to make another participant see you during an audio-only call.

4.3 Notifications

Notification permission may be used for incoming-call alerts, missed calls, Credit and payout updates, security messages, service notices and, where legally permitted, promotional communication. Permission can be changed in device settings.

5. HOW WE COLLECT PERSONAL DATA

• • Directly from you during registration, application, onboarding, payment, support or a complaint
• • Automatically from your device and use of the Platform
• • From another User or Voice Companion who submits a report or complaint
• • From Razorpay, banks, UPI networks and payout providers concerning transaction status
• • From ZEGOCLOUD for call connectivity and technical information
• • From 2Factor.in for OTP transmission and delivery status
• • From Amazon Web Services (AWS) for cloud hosting, storage, system logs, backups and security operations
• • From analytics, security and notification service providers
• • From app stores and attribution providers where permitted
• • From lawful authorities or publicly available sources where legally permitted and necessary

💡 6. PURPOSES OF PROCESSING

• • Create, verify, secure and administer Accounts
• • Confirm adult eligibility and prevent minors from using the Platform
• • Display permitted Voice Companion profiles and availability
• • Connect and operate one-to-one audio calls
• • Calculate call duration, Credit consumption and Voice Companion earnings
• • Process payments, recharges, withdrawals, refunds, tax documents and TDS
• • Conduct Voice Companion application, identity, PAN and payout verification
• • Respond to support, privacy, payment and grievance requests
• • Detect fraud, automation, duplicate Accounts, collusive calls, scams and abuse
• • Investigate safety complaints, enforce Platform rules and protect participants
• • Maintain, troubleshoot, analyse and improve the Platform
• • Send operational, security and legally required communications
• • Send promotional communications only where legally permitted and subject to required consent
• • Comply with tax, accounting, consumer, cybersecurity, court, government and law-enforcement obligations
• • Establish, exercise or defend legal claims

We do not sell, rent, or share user data with advertisers or analytics firms beyond what is described in this Policy.

7. LAWFUL GROUNDS AND CONSENT

Depending on the applicable law and processing activity, we process personal data based on consent, performance of the User's request or contract, compliance with law, and certain legitimate uses recognised by applicable Indian law. We request only data reasonably necessary for the stated purpose.

Consent is requested through clear notices, Account actions, permission prompts, checkboxes, OTP verification or another recorded electronic method. Consent may be withdrawn by changing device permissions, using an available Account setting or contacting us. Withdrawal may prevent continued use of a feature that requires the relevant data.

Essential Account, security, payment, tax, safety and legal communications are not promotional communications and may continue while the Account is active or while records must lawfully be maintained.

🤝 8. HOW WE SHARE PERSONAL DATA

We do not sell personal data. We may share the minimum necessary information with the following recipients for the stated purposes:

9. INFORMATION VISIBLE TO OTHER PARTICIPANTS

A User may see an approved Voice Companion's profile image, nickname or approved display name, languages, profile description and availability. A Voice Companion may receive limited information required to handle the call, such as the User's nickname or Account identifier.

Mobile numbers, PAN images, UPI details, identity documents and payment information are not ordinarily displayed to the other call participant. Participants must not request or exchange private contact information, payments, passwords or OTPs.

10. CLOUD HOSTING AND CROSS-BORDER PROCESSING

Infiniti Talks uses Amazon Web Services (AWS) for cloud hosting and may use AWS services for application servers, databases, storage, logs, backups, security and system availability. The specific AWS service location or processing location may depend on the Company's technical configuration and the services used from time to time.

ZEGOCLOUD, Razorpay, 2Factor.in, AWS or another authorised service provider may process information through infrastructure located in India or another country, subject to the provider's service configuration. Where cross-border processing occurs, Infiniti Talks will use reasonable contractual, security and access controls and comply with restrictions or requirements notified under applicable Indian law. Information will not knowingly be transferred to a country or territory prohibited by the Government of India.

🗑 11. DATA RETENTION

We retain personal data only for as long as reasonably necessary for the stated purpose and applicable legal obligations. Indicative periods are below; a longer period may apply for an unresolved complaint, fraud investigation, tax requirement, litigation hold, court order or lawful government request.

When retention is no longer necessary, we will delete, securely dispose of or anonymise the information, subject to technical backup cycles and applicable law.

🔒 12. SECURITY SAFEGUARDS

We use reasonable technical and organisational safeguards appropriate to the nature of the information, including access controls, role-based permissions, encryption or secure transmission where appropriate, logging, monitoring, backups, vendor controls and incident-response procedures.

No internet, mobile or storage system is completely secure. Users and Voice Companions must protect their OTPs, devices and Account access, must not share UPI PINs or passwords, and must promptly report suspected unauthorised access.

13. PERSONAL DATA BREACHES

On becoming aware of a personal data breach, we will take reasonable steps to contain, investigate, remediate and reduce its impact. Where required by applicable law, we will notify affected individuals and the Data Protection Board of India in the prescribed manner and timelines, including any initial notification required without delay and further particulars required within 72 hours.

We may also report applicable cybersecurity incidents to CERT-In and cooperate with authorised agencies as required by law.

14. YOUR PRIVACY RIGHTS

Subject to provisions of applicable law that are in force, you may request:

• • Information about personal data processed and the processing activities
• • Correction of inaccurate or misleading personal data
• • Completion or updating of incomplete or outdated personal data
• • Erasure of personal data that is no longer necessary and need not be retained by law
• • Withdrawal of consent for consent-based processing
• • Grievance redressal concerning personal data
• • Nomination of another eligible individual to exercise applicable rights in the event of death or incapacity

To protect privacy, we may verify the requester's identity and Account connection before acting. A request may be refused or limited where retention or processing is required for taxation, fraud prevention, safety, legal claims, court orders or another lawful purpose.

15. ACCOUNT DELETION

A User or Voice Companion may request Account deletion through an available in-app option or by contacting partners@infinititalks.com from or with reference to the registered mobile number.

Deletion may deactivate the profile and prevent further use. It does not require immediate deletion of records that must be retained for tax, accounting, payments, fraud prevention, safety, disputes, enforcement, backups or legal compliance. Promotional Credits may be cancelled; purchased Credits and valid Voice Companion earnings will be handled under the Terms and applicable law.

👶 16. CHILDREN

The Platform is intended only for persons aged 18 years and above. We do not knowingly permit a person below 18 to register, use calls or become a Voice Companion. If we learn that a minor has registered or submitted personal data, we may suspend the Account, request verification and delete eligible information, subject to legal retention obligations.

A parent or guardian who believes a minor has provided personal data should contact the Grievance Officer with sufficient information to identify the Account. Do not send unnecessary identity documents before we request them.

17. PROMOTIONAL COMMUNICATIONS

Promotional messages will be sent only where permitted by applicable law and based on any consent legally required. A person may withdraw promotional consent using an unsubscribe or opt-out method provided in the communication or by contacting support. Opting out of promotions does not stop essential OTP, Account, security, call, payment, payout, safety or legal notices.

18. AUTOMATED AND ANALYTICS PROCESSING

We may use automated signals or analytics to detect suspicious activity, duplicate Accounts, abnormal call patterns, fraud, system abuse and technical problems. Such tools support operational review. We do not intend to make a fully automated decision producing a legal or similarly significant effect without an avenue for human review where required by applicable law.

19. THIRD-PARTY LINKS AND SERVICES

The Platform may link to application stores, payment providers or external websites. Their processing is governed by their own privacy policies. Infiniti Talks is not responsible for a third party's independent privacy practices, but we seek to use service providers appropriate for the relevant processing purpose.

20. CHANGES TO THIS POLICY

We may update this Privacy Policy to reflect legal, security, operational or feature changes. The updated version will state its effective date and will be made available through the website or Application. Where legally required or materially appropriate, we may provide an in-app, push, SMS, WhatsApp or email notice and request renewed consent.

📩 21. PRIVACY AND GRIEVANCE CONTACT

For privacy questions, access/correction/deletion requests, complaints, payment-data concerns or suspected unauthorised Account access, contact:

Grievance Officer: J. Vinay Kumar — Founder & Chief Executive Officer; Grievance Officer

• • Company: Infinititalks Wellness Private Limited
• • 📧 Email: partners@infinititalks.com
• • 📱 WhatsApp: +91 88676 47207
• • Address: No. 2-79/16-03, Barnes Plaza, Brahmavara, Udupi, Karnataka – 576213

Include the registered mobile number, type of request, relevant transaction or call details and sufficient supporting information. Never send an OTP, password, card CVV or UPI PIN.

Complaints under the applicable IT Rules will be acknowledged and resolved within the statutory timelines. Privacy requests will be handled within the period prescribed by the data-protection provisions in force from time to time.