Privacy Policy

1. Introduction

Neko Club ("we," "our," or "us") is a mobile application operated by Aeos Ventures Pvt Ltd, a company incorporated under the laws of India, with its registered office in Bengaluru, Karnataka, India. Neko Club connects content creators with brand campaigns and is available on the iOS App Store and Google Play Store in India.

This Privacy Policy explains how we collect, use, store, and protect your personal data when you use our app. It is drafted in accordance with the Digital Personal Data Protection Act, 2023 (DPDPA) and other applicable Indian laws.

By registering for or using Neko Club, you consent to the collection and processing of your personal data as described in this policy. If you do not agree with this policy, please do not use the app.

2. Information We Collect

We collect the following categories of personal data from creators who use our platform:

a) Account & Identity Information

• Name, email address, and phone number provided during registration
• Social media handles and profile links (e.g., Instagram)

b) Social Media & Content Data

• We access certain data from social media platforms (including Instagram) through authorised APIs when you connect your account. This may include account identifiers, public media, and performance metrics (such as view counts and engagement data).
• Links to reels and content you submit through the app for campaign verification
• We store access tokens securely and use them solely to verify submissions and calculate payouts.

c) Payment Information

• UPI IDs or bank account details necessary to process your earnings. We do not store complete financial credentials; payment processing is handled through secure third-party payment service providers.

d) Device & Technical Data

• Device type, model, operating system, and version
• IP address and approximate location (city/region level)

3. Purpose of Data Collection

We process your personal data for the following purposes:

• Verifying your identity and participation in brand campaigns
• Tracking view counts and calculating your earnings based on performance
• Processing and disbursing payments for your completed campaigns
• Communicating with you about campaigns, payments, and app updates
• Maintaining app security, diagnosing technical issues, and preventing fraud
• Improving our services, features, and user experience
• Complying with legal and regulatory obligations

We process your data based on your consent, which you provide when you register and use the app.

4. Data Sharing & Third-Party Service Providers

We do not sell or rent your personal data to any third party. However, in order to operate the Neko Club platform, we share limited data with the following categories of trusted service providers who assist us in delivering our services:

• Cloud Infrastructure Providers (e.g., Amazon Web Services): For hosting, data storage, and computing services. Our primary servers are located in India (AWS Mumbai region).
• Analytics & App Performance Services (e.g., Firebase/Google): For crash reporting, app analytics, push notifications, and performance monitoring.
• Social Media Platform APIs (e.g., Instagram/Meta Graph API): To retrieve performance metrics on content you submit, verify reel submissions, and calculate payouts.
• Payment Service Providers: To securely process UPI transfers and disburse your earnings. We share only the minimum information required to complete transactions.

These service providers are contractually obligated to protect your data and may only use it for the purposes we specify. We do not share your data with brand partners or advertisers in any personally identifiable form.

We may also disclose your information if required by law, court order, or government authority in India.

5. Cross-Border Data Transfers

While our primary data storage is on servers located in India (AWS Mumbai region), some of our third-party service providers—including Firebase (Google Cloud), Instagram/Meta APIs, and certain payment partners—may process or store data on servers located outside India.

Where your personal data is transferred outside India, we ensure that such transfers comply with the DPDPA and that adequate safeguards are in place. We only transfer data to jurisdictions or service providers that maintain appropriate levels of data protection, and such transfers are limited to the minimum data necessary to provide our services.

6. Data Storage & Security

We take the security of your personal data seriously and implement industry-standard technical and organisational measures to protect it, including:

• Encryption: Data is encrypted in transit using TLS/SSL protocols and at rest using AES-256 encryption
• Access Controls: Role-based access controls ensuring only authorised personnel can access personal data, enforced through multi-factor authentication
• Secure Token Storage: Social media access tokens and API credentials are stored using secure, encrypted vaults and are never exposed in application logs
• Infrastructure Security: Our cloud infrastructure is protected by firewalls, intrusion detection systems, and regular security audits
• Payment Security: Financial data is handled through PCI-DSS compliant payment partners; we do not store complete financial credentials on our servers
• Monitoring & Incident Response: We maintain logging and monitoring systems to detect and respond to potential security incidents promptly

While we strive to protect your data using commercially reasonable measures, no method of electronic transmission or storage is 100% secure. We cannot guarantee absolute security but are committed to promptly addressing any vulnerabilities or incidents.

7. Data Breach Notification

In the event of a personal data breach that is likely to cause harm to affected individuals, we will:

• Notify the Data Protection Board of India as required under the DPDPA
• Inform affected users without unreasonable delay through email or in-app notification

8. Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes outlined in this policy, or as required under Indian law (including tax and financial record-keeping obligations). Once your data is no longer needed, we will securely delete or anonymise it.

Aggregated, anonymised data that cannot identify you may be retained indefinitely for analytics and service improvement purposes.

9. Your Rights

Under the DPDPA, you have the following rights:

• Right to Access: Request confirmation of whether we are processing your data and obtain a summary of your personal data
• Right to Correction: Request correction of inaccurate or incomplete personal data
• Right to Erasure: Request deletion of your personal data, subject to legal retention requirements
• Right to Grievance Redressal: Lodge a complaint if you are unsatisfied with our response
• Right to Nominate: Nominate another individual to exercise your rights in case of death or incapacity

To exercise any of these rights, please contact our Grievance Officer at the details provided below.

10. Consent Withdrawal

You may withdraw your consent to the processing of your personal data at any time by contacting us at the details provided below. Please note that withdrawing consent may limit or prevent your ability to use certain features of the app, including campaign participation and payout processing.

Withdrawal of consent does not affect the lawfulness of processing carried out prior to the withdrawal, nor does it affect processing that is required for compliance with legal obligations.

11. Account Deletion

You may request deletion of your account and associated personal data at any time by:

• Using the account deletion option available in in-app settings
• Contacting our support team at the email address provided below

Upon receiving a valid deletion request, we will delete your personal data within 30 days, except where retention is required by law (e.g., tax records, pending payout settlements). We will confirm the completion of deletion via email.

12. Payouts, View Metrics & Disputes

Creator payouts on Neko Club are calculated based on view counts and performance metrics retrieved from third-party social media platforms (such as Instagram). Please note:

• View Fluctuations: Neko Club is not responsible for fluctuations in view counts, engagement metrics, or algorithmic changes on third-party platforms. Payouts are calculated based on the data available to us at the time of verification, and we cannot guarantee specific view counts or earnings.
• Payout Disputes: If you believe there is a discrepancy in your payout calculation, you may raise a dispute by contacting our support team within 15 days of the payout date. We will review the relevant submission data and platform metrics and provide a resolution within 30 days. Our determination, based on the data available from the platform APIs at the time of verification, shall be considered final.
• Payout Processing: Payments are processed through third-party payment service providers via UPI transfers. We are not liable for delays or failures caused by banking systems, payment processors, or incorrect payment details provided by the creator.

13. Content Ownership

All short-form content (clips, reels, edits) created by you as part of brand campaigns remains your intellectual property. By submitting content through Neko Club, you grant us a limited, non-exclusive licence to display, track, and verify the content solely for the purposes of campaign management and payout calculation.

This licence does not transfer ownership of your content to Neko Club, Aeos Ventures Pvt Ltd, or any brand partner. You retain the right to use, modify, or remove your content from your own social media accounts at any time, subject to any specific campaign terms you have agreed to.

14. Service Availability

We are committed to providing a reliable and consistent experience on Neko Club. While we cannot guarantee completely uninterrupted or error-free operation of the app, we will make every reasonable effort to minimise disruptions and maintain service quality.

Where possible, we will provide prior notice to users before:

• Scheduled maintenance or system upgrades
• Significant modifications, suspensions, or discontinuation of any feature or service

However, there may be circumstances beyond our control—such as emergency maintenance, third-party service disruptions (e.g., API outages, payment system failures), or unforeseen technical issues—where advance notice may not be possible.

15. Children's Privacy

Neko Club is not intended for individuals under the age of 18. We do not knowingly collect personal data from children. If you believe we have inadvertently collected data from a minor without verifiable parental consent, please contact us immediately and we will promptly delete such data.

16. Grievance Officer

In accordance with the DPDPA, we have appointed a Grievance Officer to address your concerns regarding data processing:

Grievance Officer
Aeos Ventures Pvt Ltd
Email: amal@aeoscompany.com

We will acknowledge your grievance within 48 hours and aim to resolve it within 30 days.

17. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of material changes through in-app notifications or via email. Continued use of the app after changes are posted constitutes acceptance of the revised policy. We encourage you to review this policy periodically.

18. Governing Law & Jurisdiction

This Privacy Policy is governed by and construed in accordance with the laws of India. Any disputes arising out of or in connection with this policy shall be subject to the exclusive jurisdiction of the courts in Bengaluru, Karnataka, India.

19. Contact Us

For any questions, concerns, or requests regarding this Privacy Policy or our data practices:

Aeos Ventures Pvt Ltd
Bengaluru, Karnataka, India
Email: amal@aeoscompany.com