QURKLE SOCIAL PRIVATE LIMITED

2nd Floor, Plot No.4 Minarch Tower, Sector-44 Gurgaon Haryana India 122003

Date of incorporation: 27.03.2025.

Unlisted company

INTRODUCTION

Qurkle Social Pvt. Limited (“Qurkle”, “we”, “our”, “us”) respects your privacy and is committed to protecting your personal data. This Privacy Policy outlines how we collect, use, disclose, transfer, and protect information gathered through our mobile application (the “App”) and associated services (“Services”), which include AI-based matchmaking chat and offline/in-app events.

By accessing or using our Services, including profile creation, AI chat, event participation, ticketing, or subscriptions, you accept the practices outlined in this Policy. If you do not agree with any part of it, do not use our Services.

SCOPE

This Policy applies to all Users, regardless of location, and covers current operations including India-based data storage, as well as future expansions. It applies to all information collected through the App, email, SMS, phone, social media integrations, or offline event interactions.

DEFINITIONS

1. “Personal Data” refers to data that identifies you, such as your name, contact details, DOB, location, photos, selfies, and AI chat logs.

2. “Sensitive Personal Data or Information (SPDI)” includes biometrics (e.g., selfies), precise location (GPS), and voice recordings.

3. “User” means any registered individual using the App or Services.

INFORMATION WE COLLECT

Directly from You

During account creation, you provide Personal Data including name, age, height, email, Instagram handle, workplace, home and work location, and a selfie for validation. Additional data may include chat messages, voice notes, RSVP preferences, event feedback, and profile bios.

Automatically from Your Device

We collect Device Metadata (model, OS), IP address, timestamps, session logs, and crash reports. GPS-based location data is captured only when the App is in use. SDKs (Firebase, CleverTap, Google Analytics) also gather anonymous usage data to help improve UX and App performance.

AI Interaction Logs

All dialogues between you and Qurkle’s AI assistant are securely stored. While your identity is not directly exposed, chat transcripts may later be anonymized and used to train self-hosted AI models or improve matchmaking algorithms.

PURPOSES FOR WHICH WE USE YOUR DATA

Matchmaking & Chat

We use your data primarily to facilitate AI-powered matchmaking and chat services that are central to Qurkle’s platform. Your personal information, including profile attributes, stated preferences, and behavioral signals, helps us recommend potential matches with greater relevance and nuance. These data points also inform how our

AI chat models interact with you, adapting tone and prompt complexity in real time to improve your experience. All such usage is strictly limited to social discovery and does not extend to profiling for employment, insurance, or credit scoring purposes.

Event Management

For event-related services, your data enables us to manage ticketing, verify your presence, arrange logistics, and send communications relevant to each event you RSVP for or attend. We may use your preferences and activity patterns to suggest curated events, assign seating clusters or networking groups, and optimize crowd control at physical venues. Event registration data, attendance records, and cancellation logs are also maintained to enforce refund rules and detect repeat no

show behaviour.

Account Verification & Security

Your data is essential for account verification, security, and platform integrity. We use your real-time selfie, verified mobile number, device information, and IP logs to confirm identity and prevent the creation of fake or duplicate profiles. These measures help maintain a safe environment for all users. Monitoring tools also allow us to detect misuse of the chat feature, spamming, rapid-fire interactions, or location spoofing. Where necessary, this information enables us to restrict or suspend access to users engaged in abusive, unlawful, or otherwise prohibited behaviour.

Improving the App

We continuously analyze app usage data to improve the Qurkle platform. This includes understanding how you navigate features, the time you spend engaging with matches or events, the types of profiles you interact with, and your responsiveness in chat. Such insights allow us to refine our user interface, deliver more timely and meaningful notifications, fix bugs, and test new features. All improvements are guided by user behavior but executed in a privacy-conscious and an aggregated manner.

Legal & Safety Compliance

In certain cases, we are legally obligated to use and retain your data. We may need to investigate potential violations of Qurkle’s Terms of Use, assist regulatory agencies, respond to complaints or court orders, or meet tax and audit requirements. For example, we may retain your data in connection with a grievance submitted through our redressal process, or use it to assess the conduct of users who attend age

restricted events. We are committed to complying with all applicable Indian laws, including the Information Technology Act, 2000 and the Digital Personal Data Protection Act, 2023, in the use, storage, and potential disclosure of your data for legal or safety purposes.

DATA SHARING AND THIRD-PARTY DISCLOSURES

We do not sell your personal data. However, your data may be disclosed under specific, limited circumstances as well as in accordance with law to ensure the functionality and security of our Services:

With Service Providers: Your data may be shared with vendors who help us operate and manage the app, including cloud infrastructure providers (e.g., AWS, MongoDB Cloud), analytics services (e.g., Firebase, CleverTap), crash-reporting tools, and mobile SDK providers. These providers process your data only on our behalf and under binding agreements.

For Event Execution: When you RSVP or purchase tickets to events, your basic profile data (e.g., name, check-in status, dietary preference) may be shared with trusted venue partners, logistics coordinators, and event hosts strictly for operational purposes.

Legal obligations :

Qurkle may disclose your personal data when required to do so by (e.g., court order, government directive), we may disclose your data to law enforcement or regulators.

We may also share data to enforce our Terms of Use or protect the safety of any individual including but not limited to law enforcement agencies, regulatory bodies, tax authorities, and judicial forums. Disclosure may also occur in connection with an investigation of a breach of law, misuse of Services, or safety threat to users of the app or the public in general.

Corporate Transactions and Transfers:

In the event of a proposed or actual merger, acquisition, restructuring, reorganization, financing, or sale of Qurkle or its assets, your personal data may be transferred to a successor entity or acquiring party as part of a diligence process or post-transaction integration. In such cases, Qurkle will ensure that the recipient entity is subject to obligations that offer substantially equivalent levels of data protection.

User Consent: In scenarios where data sharing is not otherwise covered under the above categories, we will seek your explicit consent before sharing your data with any external party.

YOUR DATA RIGHTS

We respect your rights under Indian law (including DPDP Act) and global privacy frameworks (like GDPR). You are entitled to the following:

Right to Access: You may request access to the personal data we hold about you, including your profile details, chat transcripts, and event history.

Right to Correction: If any data is inaccurate or outdated, you may request correction. Some fields may be editable directly via your profile settings.

Right to Deletion: You may request the deletion of your personal data. Upon successful verification, we will delete your data within 60 days unless legal obligations require us to retain it (e.g., refund logs, complaint records).

Right to Portability: Where applicable, you may request an export of your data in a machine-readable format.

Right to Object/Restrict Processing: In certain circumstances, you may object to or request restriction of specific uses of your data.

All such requests may be directed to our Grievance Officer. We acknowledge grievances within 7 business days and resolve them within 30 days, as per the IT Rules, 2021.

DATA RETENTION PRACTICES

We retain your personal data only for as long as necessary to fulfill the purposes outlined in this policy, or as required by law:

Active Accounts: While your account remains active, we retain all profile, chat, and event data for functionality.

Inactive Accounts: After 12 consecutive months of inactivity (i.e., no matches, chats, or event participation), your account may be flagged for deletion.

Post-Deletion Retention: Once your account is deleted, we delete or anonymize your personal data within 60 days, subject to any legal hold.

Anonymized Data: Aggregated, non-identifiable data may be retained for analytics and product development.

SECURITY OF YOUR PERSONAL DATA

We implement commercially reasonable and industry-standard technical and organizational safeguards to ensure the confidentiality, integrity, and availability of your personal data. All personal information collected through the Qurkle platform is encrypted in transit using HTTPS and is exchanged through secure APIs. Your data is stored on protected cloud servers located within India and maintained by compliant service providers such as AWS and MongoDB Cloud.

Access to personal data is tightly controlled using role-based permissions and authentication protocols, ensuring that only authorized personnel can retrieve or process your data based on operational necessity. To maintain system security, we implement real-time monitoring, conduct regular vulnerability assessments, and perform scheduled audits of our infrastructure and codebase.

While Qurkle is committed to taking adequate measures to safeguard your information, no platform can be guaranteed to be completely free from unauthorized intrusion, cyberattack, or technical malfunction. By continuing to use our Services, you acknowledge and accept that there are inherent risks associated with online data transmission and storage and agree not to hold Qurkle liable for any data breach or loss arising despite our good faith security efforts, except in cases of gross negligence or willful misconduct.

CHILDREN’S DATA

Qurkle does not knowingly collect data from individuals under 18 years of age. If we become aware of such collection, the data will be promptly deleted. Parents or guardians may contact us to report such incidents.

GOVERNING LAW AND JURISDICTION

This Privacy Policy shall be governed in accordance with the laws of India. Any disputes arising from this Policy shall be subject to the exclusive jurisdiction of the courts in Faridabad, Haryana.

GRIEVANCE REDRESSAL & CONTACT DETAILS

If you have concerns, requests, or complaints regarding your data or privacy practices:

Grievance Officer: Shubham Muthreja

Email: admin@qurkle.com

Email: support@qurkle.com

Address: Qurkle Social Pvt. Limited, 2nd Floor, Plot No. 4, Minarch Tower, Sector 44, Gurgaon, Haryana – 122003, India.

We acknowledge all complaints within 7 business days and respond with a resolution within 30 days.