Privacy Policy

This Privacy Policy explains how THE ANU'S NETWORK PRIVATE LIMITED (“ Celaeno ”) collects, uses, stores, shares and protects personal information when you use the Celaeno Platform. It applies to registered Users, prospective Users, Influencers, visitors and individuals who communicate with the Company in connection with the Platform.

Celaeno will process personal information for identified purposes and in accordance with applicable data-protection law. Information will not be collected merely because it might be useful in the future.

2.1. Definitions. In this Privacy Policy, unless the context requires otherwise:

• “Account” means the registered profile created by a User or Influencer to access the Platform.
• “Applicable Law” means all laws, rules, regulations, orders and binding directions of any competent court, regulator or governmental authority in force in India from time to time, including the Information Technology Act, 2000, the Digital Personal Data Protection Act, 2023 (the “DPDP Act”), and the rules made under them, each as amended or re-enacted.
• “Aadhaar-Related Information” means any information relating to an individual’s Aadhaar number, Aadhaar card or Aadhaar-based verification, to the extent its collection or use is permitted under the Aadhaar (Targeted Delivery of Financial and Other Subsidies, Benefits and Services) Act, 2016 and Applicable Law.
• “Celaeno”, “Company” means THE ANU’S NETWORK PRIVATE LIMITED, a company incorporated under the laws of India, having its registered office at H.32, Janhit Awas Yojna, Modern Railway City Road, Chhaprola (Chhapraula), Gautam Budh Nagar, Uttar Pradesh – 201009, and its successors and permitted assigns.
• “Consent” means a free, specific, informed, unconditional and unambiguous indication of a person’s agreement to the processing of their Personal Information for a stated purpose, given through a clear affirmative action, in accordance with Applicable Law.
• “Content” means any photograph, biography, message, profile detail, complaint, report or other material that a User or Influencer provides or submits through the Platform.
• “Cookie Policy” means the Celaeno Cookie and Tracking Technologies Policy.
• “Data Principal”, “you” or “your” means the individual to whom Personal Information relates, including a registered User, prospective User, Influencer, visitor or any other individual who communicates with the Company in connection with the Platform.
• “Financial Eligibility Evidence” means any employment-related document, income-related document or other evidence submitted to satisfy a financial eligibility requirement for a particular service or account category.
• “Grievance Channel” means the grievance email address or in-app mechanism notified by the Company on the Platform for receiving requests and complaints under this Policy.
• “Influencer” means an individual engaged by or participating with Celaeno to provide interaction services to Users, wherever located.
• “Personal Information” means any information about an individual who is identified or identifiable by or in relation to that information, and includes “personal data” as defined under the DPDP Act.
• “Personal Information Breach” means any unauthorised processing, or any accidental disclosure, acquisition, sharing, use, alteration, destruction or loss of access to Personal Information, that compromises its confidentiality, integrity or availability.
• “Platform” means the Celaeno website, mobile application, communication features, paid services and related offerings.
• “Policy” means this Privacy Policy, as updated from time to time.
• “Processing” means any operation performed on Personal Information, including collection, recording, storage, use, sharing, disclosure, transfer, restriction, erasure and destruction, and “process” has a corresponding meaning.
• “Security Incident” means any actual or reasonably suspected event that compromises the security of the Platform or of Personal Information within Celaeno’s control, including a Personal Information Breach.
• “Service Provider” means any third party engaged by or on behalf of Celaeno to support the Platform, including hosting and cloud infrastructure providers, identity and eligibility verification providers, payment processors, app-store providers, customer-support and security service providers, professional advisers and auditors.
• “Sensitive Verification Data” means identity documents, Financial Eligibility Evidence and Aadhaar-Related Information.
• “Terms of Use” means the Celaeno Terms of Use, as updated from time to time.
• “User” means any individual who registers for, accesses or uses the Platform, other than as an Influencer, and includes a prospective User where the context so requires.
• “Verification” means any check carried out by or for Celaeno to confirm a person’s age, identity or financial eligibility for a particular service or account category, including through a Service Provider.

Depending on the features used and the verification process applicable to an account, Celaeno may collect account and identity information, including name, date of birth, contact number, email address, profile details and identity verification status. It may also collect photographs, biographies, preferences, messages, complaints and other content that Users choose to provide.

Where financial eligibility is required, Celaeno may process an appropriate employment-related document, income-related document or other evidence accepted for the relevant eligibility check. The Company will seek to minimise the information collected and avoid retaining complete financial documents where a verification result is sufficient. Aadhaar-related information, where lawfully used, will be limited to what is necessary for the relevant verification process.

Technical information may include IP addresses, device identifiers, operating system, application version, log data, crash reports and security signals. Approximate or precise location information may be processed where the relevant feature requires it and an appropriate permission or lawful basis exists. Transaction information may include purchases, subscription status, transaction references, refunds and payment-provider responses. Full card or banking credentials may be handled directly by the payment provider rather than stored by Celaeno.

The Company may also process support requests, safety reports, moderation records and relevant communications to investigate abuse, maintain security, resolve disputes and comply with legal obligations. Usage information may be processed to understand how features are used, diagnose technical issues and improve the Platform.

The information collected may be used to create and manage accounts, verify eligibility, provide communication and discovery features, process payments, prevent fraud, investigate complaints, maintain security, communicate service updates, comply with law, establish or defend legal claims and conduct permitted analytics. Where consent is the applicable legal basis, it will be obtained in an appropriate form and will not be treated as unlimited permission for unrelated uses.

Financial eligibility checks are intended to establish eligibility for a specified service or account category. They are not credit assessments and do not guarantee wealth, good character, financial reliability or safety. Where practicable, verification will be conducted through a restricted process that returns a result such as “verified”, “not verified” or “additional information required”.

Celaeno will not use financial eligibility documents for targeted advertising, sell them or disclose their contents to other Users. Access will be restricted to authorised personnel and service providers who require the information for the disclosed purpose. When the verification purpose has been completed, the underlying document will be deleted or de-identified.

Aadhaar-related verification will be undertaken only through a lawful process, with the required consent and safeguards. Users should not send identity documents through ordinary chat or general customer-support channels.

Location sharing will be feature-specific. Users will be informed whether a feature uses approximate or precise location and whether the information is visible to other Users. Celaeno will not make a User's precise real-time location publicly visible by default. Access to a device's contacts will not automatically authorise the Company to message those contacts or disclose the User's participation on the Platform.

Private communications may be processed to provide the service, maintain technical security and investigate reported misconduct, subject to applicable law and the Platform's actual technical design.

Users should assume that a recipient may screenshot, copy or disclose information shared with them. This does not authorise the recipient to misuse it, but Celaeno cannot guarantee the confidentiality of information voluntarily disclosed directly to another person. Access to messages by Company personnel will be limited to the purposes permitted by the Platform's design, the relevant disclosures and applicable law.

Celaeno may share limited personal information with hosting and cloud infrastructure providers, identity and eligibility verification providers, payment processors, app-store providers, customer-support and security service providers, professional advisers and auditors where reasonably necessary. Information may also be disclosed to courts, regulators, law-enforcement agencies or other competent authorities where required or lawfully permitted.

A successor entity may receive relevant information in connection with a merger, restructuring, acquisition or transfer of business, subject to applicable law and appropriate safeguards. Service providers must be subject to appropriate contractual and security controls. The Company does not sell identity documents or financial eligibility documents to advertisers and will not disclose personal information to another User merely because that User requests it.

Celaeno may use service providers or engage Influencers in countries outside India, including the Philippines and Vietnam. International access to or transfer of personal information will be managed in accordance with applicable Indian law.

Celaeno will implement reasonable and appropriate technical and organisational safeguards proportionate to the information processed and the risks involved. These may include access controls, secure transmission, authentication, logging, restricted administrative access, vendor assessment and incident-response procedures.

No online system can be guaranteed completely secure. If a security incident occurs, Celaeno will assess and respond to it in accordance with applicable legal requirements, including any required notification to affected individuals or competent authorities.

Personal information will be retained only for as long as reasonably necessary for the disclosed purpose, applicable legal requirements, security, dispute resolution and lawful recordkeeping. Identity documents, financial eligibility evidence, ordinary messages, payment records, safety complaints and security logs may have different retention periods.

Deleting an account will initiate the applicable account-deletion process. Limited information may remain where necessary or legally required, including information subject to a valid preservation request or relevant legal claim.

Subject to applicable law and the provisions in force at the relevant time, Users may request correction or updating, deletion through the grievance redressal mechanism. Requests may be submitted to grievance@celaeno.in . Celaeno may take proportionate steps to verify the requester's identity before acting.

The use of cookies, software development kits, analytics and similar technologies is described in the Cookie and Tracking Technologies Policy. Where consent is required, the relevant technology will be deployed in accordance with the applicable consent mechanism.

Celaeno may update this Policy to reflect changes in its services, data practices or applicable law. Material changes will be communicated through an appropriate channel, and renewed consent will be obtained where required. The updated Policy will state its effective date.

For assistance with privacy-related queries, account concerns, or questions about the handling of personal information, Users may contact Celaeno at privacy@celaeno.in.