This policy explains what personal information Prooger collects, why we collect it, who sees it, and the choices you have. We have written it to follow India's Digital Personal Data Protection Act, 2023 and, for people in the European Economic Area and the UK, the GDPR.
1Who we are
Zukudu operates Prooger. For the purposes of the DPDP Act we are the "Data Fiduciary", and for the GDPR we are the "controller". You can contact us about privacy at eas@easwars.com.
2Information we collect
We do not collect payment details, your contacts, or your precise location. We do not knowingly collect information from people under 18.
3How we use your information
- To run Prooger: create and secure your account, show your videos, and deliver comments, follows and notifications.
- To personalise your feed: using the models and styles you pick, the people you follow and what you save.
- To keep Prooger safe: review reports, prevent spam and abuse, enforce our rules and protect people.
- To communicate with you: send sign-in codes, security and service messages, and replies to your questions. We send marketing emails only if you opt in.
- To improve Prooger: understand how it is used, using aggregated data where we can.
- To meet legal duties: respond to lawful requests and keep records the law requires.
We do not sell your personal information, and Prooger does not show advertising.
4Consent and legal basis
We process your personal data with your consent, which you give when you create your account and accept this policy, and for the limited legitimate uses the DPDP Act allows (for example, where you voluntarily give us data for a purpose, or where the law requires us to keep it).
Where the GDPR applies, our legal bases are: performing our contract with you (running your account), your consent (for example, optional emails), our legitimate interests (keeping Prooger safe and secure), and legal obligation.
You can withdraw consent at any time in Settings or by contacting us. Withdrawing consent may mean we can no longer provide parts of Prooger, and does not affect what we did before.
5What other people can see
Your username, display name, profile photo, banner, bio and public videos (with their prompts) are visible to anyone. Comments you post are visible with your name. You can choose in Settings whether to show your follower count and Pro Cards, and you can set each video to public, unlisted or private. Unlisted and private videos, your saved videos, boards, settings and email address are not shown to other people.
7Transfers outside India
Our service providers may store or process your information in other countries. Where we do this, we take steps to make sure it stays protected, as the law requires.
9How long we keep it
We keep your information while your account is active. When you delete your account, we delete or anonymise your personal data within 30 days, except where the law requires us to keep it (for example, records of legal notices and moderation decisions) and in backups, which are overwritten on a regular schedule.
10Keeping it secure
We protect your information with measures such as encryption in transit, salted password hashing and limited access. No system is completely secure. If a breach affects your personal data, we will tell you and the authorities as the law requires.
11Your rights
You have the right to:
- get a summary of the personal data we hold about you, and how we use it;
- correct or update it, which you can do yourself in Settings and Customize profile;
- ask us to erase it, which you can do by deleting your account in Settings;
- withdraw your consent, and name another person to exercise your rights if you die or cannot act (DPDP Act);
- if the GDPR applies: get a portable copy of your data, restrict or object to some processing, and complain to your local data protection authority.
To use a right that Settings does not cover, contact eas@easwars.com. We aim to reply within 30 days. We may need to confirm who you are first.
12Children
Prooger is for people aged 18 and over. We do not knowingly collect information from anyone younger, and we will delete an account if we find that its owner is under 18.
13Changes to this policy
We may update this policy as Prooger changes. We will tell you about important changes, and the date at the top shows the latest version.
14Grievance Officer
If you have a complaint about how we handle your personal data or content, contact our Grievance Officer. We acknowledge complaints within 24 hours and aim to resolve them within 15 days.