Version: 0.1 (draft for advocate review)
In short
- Our Grievance Officer can be reached at hi@prive.buzz (name and phone to be published).
- We acknowledge every complaint within 24 hours and resolve it within 15 days.
- Complaints about non-consensual intimate imagery are acted on within 24 hours. Other requests to remove unlawful Content are resolved within 72 hours.
- Not satisfied? You can appeal to the Government's Grievance Appellate Committee within 30 days, or approach the Data Protection Board or a Consumer Commission.
- Government agencies and courts can use the same contact. Lawful orders are handled within the legal timelines (36 hours for removal, 72 hours for information).
1. Who we are
Privé is operated by POLYMATH COGNITIVE, a partnership firm constituted under the Indian Partnership Act, 1932. Its registered office is at S-300-H, Scheme 4-S, Macheda, Jaipur, Rajasthan, India. Sanstha Aadhaar Number (Rajasthan): 8005220006002779.
This Policy is published under:
- Rule 3(2) of the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021 (the "IT Rules");
- Rule 4 of the Consumer Protection (E-Commerce) Rules, 2020;
- the Digital Personal Data Protection Act, 2023.
Defined terms are as in the Terms of Service.
2. Grievance Officer
| Name | To be published |
| Designation | Grievance Officer |
| hi@prive.buzz | |
| Phone | to be published |
| Address | POLYMATH COGNITIVE, S-300-H, Scheme 4-S, Macheda, Jaipur, Rajasthan, India |
| Hours | To be published |
The Grievance Officer is also our contact for data-protection grievances under the DPDP Act, and our designated child-safety contact.
General enquiries, and grievances, can also be sent to hi@prive.buzz, which is passed to the Grievance Officer.
3. What you can complain about
You can complain about any of these:
- Content or conduct that breaks our Terms, the Community Guidelines or the law;
- non-consensual intimate imagery;
- impersonation;
- copyright (see also the Copyright and Takedown Policy);
- payments, Coins and refunds;
- Creator payouts;
- moderation decisions about you, including suspension and removal;
- personal data and privacy requests;
- account deletion;
- child safety;
- anything else about Privé.
4. How to complain
Email the Grievance Officer, or write to the address above. Please include:
- your name and the email on your Privé account, if you have one;
- what happened, with dates;
- links, handles, or screenshots of the location of the Content. Never send copies of intimate imagery or child sexual abuse material;
- for payments, your Razorpay payment ID;
- what outcome you want.
You may complain on behalf of someone else if you are authorised to, or, for intimate imagery, if you are the person shown or someone acting for them.
5. Timelines
| Step | Timeline |
|---|---|
| Acknowledge your complaint, with a reference number | Within 24 hours |
| Resolve your complaint, with reasons | Within 15 days |
| A request to remove Content in the categories of Rule 3(1)(b) of the IT Rules (except where the request is clearly frivolous or abusive) | Resolved within 72 hours |
| Content showing a person's private area, nudity, a sexual act, or impersonation in morphed images (Rule 3(2)(b)), complained of by that person or on their behalf | Removed or disabled within 24 hours |
| Consumer complaints (E-Commerce Rules) | Acknowledged within 48 hours, resolved within 1 month |
5.1 If we need more information, we will ask, and the clock pauses until we receive it.
5.2 Notice of action. When we act on Content you posted, we tell you, where the IT Rules require it and where it is safe. You can respond or appeal by writing to the Grievance Officer.
5.3 False complaints. Malicious or knowingly false complaints may lead to action against the complainant's account.
6. Escalation and appeal
If you are not satisfied with the Grievance Officer's decision, or you receive no decision within the timelines above:
- Grievance Appellate Committee (GAC). Under Rule 3A of the IT Rules, you may appeal within 30 days of receiving our decision, online through the GAC portal (gac.gov.in). We will comply with the GAC's orders.
- Data Protection Board of India. For personal-data grievances, after using our process.
- Consumer Commissions. Under the Consumer Protection Act, 2019, including through the National Consumer Helpline (1915, or consumerhelpline.gov.in).
- Courts at Jaipur, Rajasthan, as set out in the Terms of Service.
7. Government agencies and courts
7.1 Where to send. Orders and requests from courts and authorised government agencies should be sent to the Grievance Officer at the email above, or to hi@prive.buzz.
7.2 How we respond.
- Orders to remove or disable Content (Rule 3(1)(d)): within 36 hours.
- Requests for information or assistance for verification of identity, or for the prevention, detection, investigation or prosecution of offences (Rule 3(1)(j)): within 72 hours of a lawful written order.
- Cyber-security incidents: reported to CERT-In within 6 hours where CERT-In's directions apply.
- Preservation of removed Content and related records: for at least 180 days, or longer when required (Rule 3(1)(g)).
7.3 Status. Privé is not currently a "significant social media intermediary". If it becomes one, it will appoint a Chief Compliance Officer, a Nodal Contact Person and a Resident Grievance Officer, as Rule 4 requires.