Date of Last Revision: 1 September 2025
Selsom Technologies Private Limited (as applicable, "FreeUp," "we," "us," and/or "our") respects the privacy of our users (“user” or “you”). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our websites www.freeup.app and www.freeupapp.com, and the FreeUp mobile application (“the Application”). Please read this Privacy Policy carefully. IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY, PLEASE DO NOT ACCESS THE APPLICATION.
We reserve the right to make changes to this Privacy Policy at any time and for any reason. We will alert you about any changes by updating the “Last updated” date of this Privacy Policy. You are encouraged to periodically review this Privacy Policy to stay informed of updates. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised Privacy Policy by your continued use of the Application after the date such revised Privacy Policy is posted.
This Privacy Policy does not apply to the third-party online/mobile store from which you install the Application or make payments, including any in-game virtual items, which may also collect and use data about you. We are not responsible for any of the data collected by any such third party.
Under the Digital Personal Data Protection Act, 2023 (DPDP Act):
NOTICE & CONSENT REQUIREMENTS
Unconditional & Affirmative Consent
By signing up, registering, or using FreeUp, you provide free, specific, informed, unconditional, and unambiguous consent for processing your personal data for the specified purposes outlined herein.
Multilingual Option
In compliance with Section 5(3) of the DPDP Act, this notice and Privacy Policy are available in English and can be accessed upon request in any of the 22 languages specified in the Eighth Schedule to the Constitution of India.
Withdrawal of Consent
You reserve the right to withdraw your consent at any time through app settings or by emailing our Grievance Officer. Withdrawal will not affect the legality of processing prior to withdrawal, but may prevent us from offering services like peer-to-peer delivery or payout transfers.
COLLECTION OF YOUR INFORMATION
We may collect information about you in a variety of ways. The information we may collect via the Application depends on the content and materials you use, and includes:
Personal Data That You Provide Through Services
We collect Personal Data from you when you voluntarily provide such information, such as when you register for or use our Services. This information may include:
Derivative Data
Information our servers automatically collect when you access the Application, such as your native actions that are integral to the Application, including liking, sharing, following, commenting on or replying to a post, as well as other interactions with the Application and other users via server log files.
Financial Data
Financial information, such as data related to your payment method (e.g. valid credit card number, expiration date, UPI ID) that we may collect when you purchase, order, return, exchange, or request information about our services from the Application. We store only very limited, if any, financial information that we collect. Otherwise, all financial information is stored by our payment processor, Razorpay and Paytm, and you are encouraged to review their privacy policy and contact them directly for responses to your questions.
Facebook/Google/Apple Permissions
The Application may by default access your Facebook/Google/Apple basic account information, including your name, email, gender, current city, and profile picture URL, as well as other information that you choose to make public. We may also request access to other permissions related to your account, such as friends, checkins, and likes, and you may choose to grant or deny us access to each individual permission. For more information regarding Facebook permissions, refer to the Facebook Permissions Reference, Google Account Permissions, and Apple Account Permissions.
Geo-Location Information
We may request access or permission to and track location-based information from your mobile device, while you are using the Application, to provide location-based services. If you wish to change our access or permissions, you may do so in your device’s settings.
Mobile Device Access
We may request access or permission to certain features from your mobile device, including your mobile device’s camera, contacts, microphone, reminders, SMS, social media accounts, storage, and other features. If you wish to change our access or permissions, you may do so in your device’s settings.
Mobile Device Data
Device information such as your mobile device ID number, model, and manufacturer, version of your operating system, phone number, country, location, and any other data you choose to provide.
Push Notifications
We may request to send you push notifications regarding your account or the Application. If you wish to opt out from receiving these types of communications, you may turn them off in your device’s settings.
Third-Party Data
Information from third parties, such as personal information or network friends, if you connect your account to the third party and grant the Application permission to access this information.
Data From Contests, Giveaways, and Surveys
Personal and other information you may provide when entering contests or giveaways and/or responding to surveys.
USE OF YOUR INFORMATION
Having accurate information about you permits us to provide you with a smooth, efficient, and customized experience. Specifically, we may use information collected about you via the Application to:
DISCLOSURE OF YOUR INFORMATION
We may share information we have collected about you in certain situations. Your information may be disclosed as follows:
By Law or to Protect Rights
If we believe the release of information about you is necessary to respond to legal process, to investigate or remedy potential violations of our policies, or to protect the rights, property, and safety of others, we may share your information as permitted or required by any applicable law, rule, or regulation. This includes exchanging information with other entities for fraud protection and credit risk reduction.
Third-Party Service Providers
We may share your information with third parties that perform services for us or on our behalf, including payment processing, data analysis, email delivery, hosting services, customer service, and marketing assistance.
Marketing Communications
With your consent, or with an opportunity for you to withdraw consent, we may share your information with third parties for marketing purposes, as permitted by law.
Interactions with Other Users
If you interact with other users of the Application, those users may see your name, profile photo, and descriptions of your activity, including sending invitations to other users, chatting with other users, liking posts, following other users.
Online Postings
When you post comments, contributions or other content to the Applications, your posts may be viewed by all users and may be publicly distributed outside the Application in perpetuity. You may choose to remove any content you do not wish to be publicly visible.
Third-Party Advertisers
We may use third-party advertising companies to serve ads when you visit the Application. These companies may use information about your visits to the Application and other websites that are contained in web cookies in order to provide advertisements about goods and services of interest to you.
Affiliates
We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.
Business Partners
We may share your information with our business partners to offer you certain products, services or promotions.
Offer Wall
The Application may display a third-party-hosted “offer wall.” Such an offer wall allows third-party advertisers to offer virtual currency, gifts, or other items to users in return for acceptance and completion of an advertisement offer. Such an offer wall may appear in the Application and be displayed to you based on certain data, such as your geographic area or demographic information. When you click on an offer wall, you will leave the Application. A unique identifier, such as your user ID, will be shared with the offer wall provider in order to prevent fraud and properly credit your account.
Social Media Contacts
If you connect to the Application through a social network, your contacts on the social network will see your name, profile photo, and descriptions of your activity.
Other Third Parties
We share personal data only with trusted third-party Data Processors under strict contractual safeguards ensuring compliance with the DPDP Act:
Sale or Bankruptcy
If we reorganize or sell all or a portion of our assets, undergo a merger, or are acquired by another entity, we may transfer your information to the successor entity. If we go out of business or enter bankruptcy, your information would be an asset transferred or acquired by a third party. You acknowledge that such transfers may occur and that the transferee may decline honor commitments we made in this Privacy Policy.
We are not responsible for the actions of third parties with whom you share personal or sensitive data, and we have no authority to manage or control third-party solicitations. If you no longer wish to receive correspondence, emails or other communications from third parties, you are responsible for contacting the third party directly.
TRACKING TECHNOLOGIES
Cookies and Web Beacons
We may use cookies, web beacons, tracking pixels, and other tracking technologies on the Application to help customize the Application and improve your experience. When you access the Application, your personal information is not collected through the use of tracking technology. Most browsers are set to accept cookies by default. You can remove or reject cookies, but be aware that such action could affect the availability and functionality of the Application. You may not decline web beacons. However, they can be rendered ineffective by declining all cookies or by modifying your web browser’s settings to notify you each time a cookie is tendered, permitting you to accept or decline cookies on an individual basis.
Internet-Based Advertising
Additionally, we may use third-party software to serve ads on the Application, implement email marketing campaigns, and manage other interactive marketing initiatives. This third-party software may use cookies or similar tracking technology to help manage and optimize your online experience with us. For more information about opting-out of interest-based ads, visit the Network Advertising Initiative Opt-Out Tool or Digital Advertising Alliance Opt-Out Tool.
Website Analytics
We may also partner with selected third-party vendors, such as Adobe Analytics, Google Analytics, Clicktale, Clevertap, Cloudfare, Crazy Egg, Heap Analytics, Inspectlet, Kissmetrics, Mixpanel and others, to allow tracking technologies and remarketing services on the Application through the use of first party cookies and third-party cookies, to, among other things, analyze and track users’ use of the Application, determine the popularity of certain content, and better understand online activity. By accessing the Application, you consent to the collection and use of your information by these third-party vendors. You are encouraged to review their privacy policy and contact them directly for responses to your questions. We do not transfer personal information to these third-party vendors. However, if you do not want any information to be collected and used by tracking technologies, you can install and/or update your settings for one of the following:
Digital Advertising Alliance Opt-Out Tool
Google Analytics Opt-Out Plugin
Network Advertising Initiative Opt-Out Tool
You should be aware that getting a new computer, installing a new browser, upgrading an existing browser, or erasing or otherwise altering your browser’s cookies files may also clear certain opt-out cookies, plug-ins, or settings.
THIRD-PARTY WEBSITES
The Application may contain links to third-party websites and applications of interest, including advertisements and external services, that are not affiliated with us. Once you have used these links to leave the Application, any information you provide to these third parties is not covered by this Privacy Policy, and we cannot guarantee the safety and privacy of your information. Before visiting and providing any information to any third-party websites, you should inform yourself of the privacy policies and practices (if any) of the third party responsible for that website, and should take those steps necessary to, in your discretion, protect the privacy of your information. We are not responsible for the content or privacy and security practices and policies of any third parties, including other sites, services or applications that may be linked to or from the Application.
SECURITY OF YOUR INFORMATION
We implement technical, organizational, and physical safeguards—including SSL encryption, access controls, and regular vulnerability assessments—to prevent unauthorized access, alteration, or data breaches. While we have taken reasonable steps to secure the personal information you provide to us, please be aware that despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse. Any information disclosed online is vulnerable to interception and misuse by unauthorized parties. Therefore, we cannot guarantee complete security if you provide personal information.
PERSONAL DATA OF CHILDREN
FreeUp is intended for users who are 18 years of age or older. We strictly refrain from conducting behavioral tracking, targeted advertising, or processing children's personal data in any manner likely to cause harm to a minor. We do not knowingly solicit information from or market to a minor. If you become aware of any data we have collected from children, please contact us using the contact information provided below.
CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems [and our mobile applications] include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.
DATA RETENTION & ERASURE POLICY
Personal data is retained only for as long as necessary to fulfill the purposes for which it was collected or to satisfy statutory legal, accounting, and tax reporting obligations under Indian law.
Account Information
You may at any time review or change the information in your account or terminate your account by:
Upon your request to terminate your account or withdrawal of consent, your data will be permanently erased or anonymized from our active databases within 30 days, unless legal obligations necessitate extended retention. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with legal requirements.
Emails and Communications
If you no longer wish to receive correspondence, emails, or other communications from us, you may opt-out by:
If you no longer wish to receive correspondence, emails, or other communications from third parties, you are responsible for contacting the third party directly.
CHANGES TO THIS PRIVACY POLICY
FreeUp may amend this Privacy Policy from time to time. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is used. If we make changes in the way we use personal information, we will notify you by posting an announcement on our site or sending you an email. Users are bound by any change to the Privacy Policy when he or she uses or otherwise accesses the Application after such changes have been first posted.
CONTACT US
If you have queries relating to the processing/usage of information provided by you or regarding this Privacy Policy, you may email the Grievance Redressal/Data Protection Officer (DPO) at privacy@freeupapp.com.