Privacy & Data Protection Policy

1. Recitals

This Policy sets out the principles, standards, and procedures governing the collection, use, storage, disclosure, and protection of personal data by Fyzygy, a social media platform that enables conversation and networking over shared interests and discovery, owned and operated by COGNITIVE MATERIALS PRIVATE LIMITED ("Company"/"Data Fiduciary"/"We"/"Us"/"Our"). This Policy applies to personal data processed through the mobile application, website, APIs, and related digital services (collectively, the "App"). The objective is to ensure ethical and legal data processing in compliance with the Indian Digital Personal Data Protection Act, 2023 and Rules thereunder.

2. Scope

This Policy applies to:

1. All users of the App ("Users" or "Data Principals");
2. All personal data collected through Fyzygy for the purpose of providing our "Service" as defined in the Terms of Use Policy, including during registration, onboarding, usage, support, analytics, and communications;
3. All employees, contractors, and service providers who have access to App-related personal data;
4. All processing activities carried out using digital or automated means.

3. Definitions

1. Personal Data: Any data about the user/data principal that makes such a user identifiable by or in relation to such data.
2. Data Principal: The individual to whom the personal data relates and where such individual is — (i) a child, includes the parents or lawful guardian of such a child; (ii) a person with disability, includes her lawful guardian, acting on her behalf.
3. Data Fiduciary: The Company herein, which determines the purpose and means of processing personal data.
4. Data Processor: Any person or entity that processes personal data on behalf of the Company/Data Fiduciary.
5. Processing: Any operation performed on digital personal data, including collection, recording, organisation, structuring, storage, adaptation, retrieval, use, alignment or combination, indexing, sharing, disclosure by transmission, dissemination or otherwise making available, restriction, erasure or destruction.
6. Consent: Freely given, specific, informed, unconditional, and unambiguous indication of the Data Principal's agreement to process personal data.

4. Data to be Processed & Purpose

The Company shall process personal data relating to name, phone-number, email-ids. Further, the Company shall collect the following Data:

5. Basis for Processing

The Company shall process personal data for the purpose of providing our Service on the following lawful bases:

1. Consent provided by the User upon understanding the Notice for Consent on the App;
2. Performance of a contract, including providing App features or services requested by the User;
3. Compliance with legal obligations under applicable laws;
4. Any other legitimate use expressly permitted under applicable data protection law.

6. Consent Management

1. Consent shall be obtained through clear in-app notices, checkboxes, or settings-based permissions.
2. Users shall be informed of the purpose, type of data collected, and consequences of refusal or withdrawal of consent.
3. Users may withdraw consent at any time through in-app settings or by contacting the Grievance Officer, with prospective effect.

7. Rights of Data Principals

Subject to applicable law, Data Principals have the right to:

1. Access their personal data;
2. Seek correction or updating of inaccurate data;
3. Request erasure of personal data no longer necessary for the stated purpose;
4. Withdraw consent for processing;
5. Grievance redressal in relation to processing of personal data.

8. Data Security Measures

The Company shall implement reasonable technical and organisational safeguards appropriate to the nature of the App, including:

1. Role-based access controls and least-privilege principles;
2. Encryption of data in transit and at rest, where appropriate;
3. Secure authentication mechanisms and session management;
4. Logging and monitoring of access to production systems;
5. Periodic vulnerability assessments and security testing.

9. Data Sharing and Disclosure

1. Personal data may be shared with third-party service providers (such as cloud hosting, payment processors, or communication tools) strictly on a need-to-know basis.
2. All third parties shall be engaged under written agreements imposing confidentiality, security, and data protection obligations.
3. Personal data shall not be sold or shared for advertising or profiling purposes.
4. Cross-border transfer of personal data shall comply with restrictions or conditions notified under applicable law.

10. Data Retention and Deletion

1. Personal data shall be retained on the Company's servers located in India, only for as long as necessary to fulfil the stated purpose or as required by the applicable law.
2. Upon expiry of the retention period or withdrawal of consent, personal data shall be securely deleted.

11. Data Breach Management

1. Any actual or suspected personal data breach shall be promptly escalated to the designated internal response team.
2. The Company shall within its reasonable capacity, document the nature, impact, and remedial steps taken in response to the breach.
3. Where required under law, the Company shall notify the Data Protection Board of India and affected Users within a reasonable time.

12. Grievance Redressal Mechanism

1. The Company shall appoint a Grievance Officer as required under the DPDP Act, 2023.
2. Users may submit grievances relating to personal data processing through the App or reach out to grievance@fyzygy.com.
3. Grievances shall be acknowledged and resolved within 90 days from the date of receiving the Complaint.

13. Review and Amendments

This Policy shall be reviewed periodically and updated to reflect changes in law, technology, or the Company's practices.

Contact Information

support@fyzygy.com

Terms of Use

These Terms of Use ("Terms") govern your access to and use of Fyzygy. By accessing, following, commenting, reposting or any other form of engagement with Fyzygy, you agree to be bound by these Terms.

1. About Us

Fyzygy is operated and managed by COGNITIVE MATERIALS PRIVATE LIMITED ("we", "us", "our").

2. Fyzygy Service

We agree to provide you with the Fyzygy Service which includes all of the Fyzygy products, features, applications, services, technologies, and software that we provide to advance this service — of bringing you closer to the people, entertainment, media content, and things you love.

The Service is made up of the following aspects:

1. Offering personalized opportunities to create, connect, communicate, discover and share.
2. We offer you different types of accounts and features to help you create, share, grow your presence, and communicate with people on and off Fyzygy.

3. How Our Service Is Funded

Fyzygy provides you with an unpaid service and by using the Service covered by these Terms, you acknowledge that we can show you ads that businesses and organizations pay us to promote on Fyzygy. In lieu of the same, we may use your personal data, such as information about your activity and interests, to show you relevant ads and other sponsored content.

However, we do not sell your personal data to any third parties, including advertisers. Advertisers tell us their business goals and the target audience for their products/services. We then show their ads to the people who might be interested.

We may however, report to the advertisers about the performance of their ads, with anonymised and aggregated data of the general demographic and interest based on user interactions with their Ads or sponsored content on and off Fyzygy.

4. Eligibility

Our Service is open and inclusive for all. However, in order to maintain some safety, security and legal compliances, you must be at least 18 years old in order to engage with Fyzygy.

You need not disclose your identity on Fyzygy, but you cannot impersonate others or create an account on behalf of others unless they have given you express consent to do so. You must provide us with accurate and up-to-date information.

5. User-Generated Content

By posting content on Fyzygy, you:

• Retain ownership of your content and are free to share your content with anyone else wherever you want.
• Grant us a non-exclusive, royalty-free, worldwide licence to use, reproduce, display, share, and repost such content for availing our services. We need certain such legal permissions from you to provide the Service.

6. Intellectual Property

The Company's / Fyzygy's communication or branding materials or application code — including text, images, graphics, videos, logos, and designs — is protected by applicable intellectual property laws. You may not reproduce, modify, or commercially exploit communication or branding materials or application code under any circumstances, stated or otherwise.

While we recognise your ownership of the content you post, when you share, post, or upload content that is covered by intellectual property rights (like photos or videos) on or in connection with our Service, you hereby grant to us a non-exclusive, royalty-free, transferable, sub-licensable, worldwide license to host, use, distribute, run, copy, publicly perform or display, translate user-generated content (consistent with your privacy and application settings).

This license will end when your content is deleted from our systems. You can delete content individually or all at once by deleting your account.

However, you are liable for any third-party content you may re-share on Fyzygy especially if they are in violation of any applicable Intellectual Property Laws.

Further, if you select a username or similar identifier for your account, we may change it if we believe it is appropriate or necessary (for example, if it infringes someone's intellectual property or impersonates another user).

7. Privacy and Data Protection

We are committed to protecting privacy and handling personal data responsibly. Our Privacy and Data Protection Policy explains how we process your data. You must consent to the said Policy in order to use the Fyzygy service.

8. User Conduct

We encourage engagement that is:

• Respectful and reasoned;
• Non-abusive;

Prohibited Conduct

In addition to the restrictions set out in Clause 4, the following are strictly prohibited:

• Threats, incitement to violence, harassment, or content that promotes or glorifies self-harm;
• Posting obscene, sexually explicit, or otherwise harmful content;
• Casteist, sexist, communal, racist, or ableist language;

Moderation Measures

Content moderation decisions may include removal of content, disabling comments or blocking users, reporting to the platform, or other proportionate measures necessary to maintain a safe space. Moderation decisions are taken in good faith and are final.

Therefore, by using our Service you agree not to post, share, upload, or engage in any content or behaviour that:

• Is unlawful, abusive, threatening, defamatory, obscene, hateful, or discriminatory especially on the grounds of sex, gender, caste, sexual orientation, race, colour, religion, disability, etc.;
• Promotes violence, discrimination, harassment, or intimidation on the grounds of sex, gender, caste, sexual orientation, race, colour, religion, disability, etc.;
• Violates the dignity, privacy, or fundamental rights of any individual or group;
• Infringes intellectual property rights or proprietary rights of others;
• Contains misinformation, impersonation, or deceptive practices;
• Disrupts, spams, or interferes with meaningful discussion.

We reserve the right to remove any content or restrict access at our sole discretion, without prior notice.

9. Content Removal and Disabling or Terminating Your Account

We reserve our right to remove any content or information you share on the Service if we believe that it violates these Terms, our policies, or we are permitted or required to do so by any applicable laws.

We may refuse to provide or stop providing all or part of the Service to you if you create risk or legal exposure for us, violate these Terms or any of our other policies. If you repeatedly infringe other people's intellectual property rights, or where we are permitted or required to do so by law.

We may also terminate or change the Service, remove or block content or information shared on our Service, or stop providing all or part of the Service if we determine that doing so is reasonably necessary to avoid or mitigate adverse legal or regulatory impacts on us.

You may also request for removal of content or deletion of your account and related data. When you request to delete content or your account, the deletion process will automatically begin no more than 30 days after your request. It may take up to 90 days to delete content after the deletion process begins. While the deletion process for such content is being undertaken, the content is no longer visible to other users, but remains subject to these Terms and our Privacy Policy. After the content is deleted, it may take us up to another 90 days to remove it from our backups.

10. Reporting Concerns

If you believe any content violates these Terms or applicable law, you may report it through the relevant platform's reporting tools or contact the Grievance Officer.

11. Limitation of Liability

We shall not be liable for:

• Perfect functionality of the Service.
• Temporary or permanent unavailability of the Service.
• User-generated content posted by third parties;
• Any loss, harm, or damage arising from reliance on content shared on Fyzygy;

To the extent permitted by law, we also disclaim all warranties, whether express or implied, including the implied warranties of merchantability, fitness for a particular purpose, title, and non-infringement. Engagement is at your own risk.

12. Indemnity

You agree to indemnify and hold us harmless from any claims, liabilities, damages, losses, or expenses arising out of your violation of these Terms or applicable law.

13. Governing Law and Jurisdiction

If you are a User, the laws of the country in which you reside will apply to any claim, cause of action, or dispute you have against us that arises out of or relates to these Terms ("claim"), and you may resolve your claim in any competent court in that country that has jurisdiction over the claim.

In all other cases, these Terms shall be governed by and construed in accordance with the laws of India. Courts having jurisdiction at Bengaluru, Karnataka, shall have exclusive jurisdiction.

Without prejudice to the foregoing, you agree that, in its sole discretion, Cognitive Materials Pvt. Ltd. may also bring any claim we have against you related to efforts to abuse, interfere, or engage with our products in unauthorized ways in the country in which you reside that has jurisdiction over the claim.

14. Changes to Terms

We may update these Terms from time to time. Unless otherwise required by law, we will notify you (for example, through our Service) before we make changes to these Terms and give you an opportunity to review them before they go into effect. Continued engagement with Fyzygy after changes are posted constitutes acceptance of the revised Terms.

If you do not agree to any updated Terms or wish to terminate your agreement to this contract, you can do so by deleting your account and no longer accessing or using any part of the Fyzygy Service.

15. Contact

For questions or concerns regarding these Terms, please contact: support@fyzygy.com

delete your account & data

how to request deletion

you can request account and data deletion in two ways — directly inside the fyzygy app, or by emailing us.

what data is deleted

when your account deletion is processed, the following data is permanently deleted from our systems:

how long does it take

once your request is submitted, deletion happens in stages as required by our obligations under the Digital Personal Data Protection Act, 2023.

questions or concerns

if you have any questions about the deletion process or your data rights, reach out to our support team or grievance officer:

support: support@fyzygy.com
grievance officer: grievance@fyzygy.com

grievances are acknowledged and resolved within 90 days as required under the DPDP Act, 2023.