A. This Privacy Policy Part 1 ("Privacy Policy Part 1") applies to the Sadagati Network Private Limited digital Site(s)/ App(s) platforms including without limitation www.sadagatinetwork.com and other related Site(s)/ App(s), mobile applications and other online features (each a "Site(s)/ App(s)"). The Site(s)/ App(s) are offered by the Sadagati Network and its subsidiaries or affiliated companies. (collectively, "the Sadagati Network "{or "we", "us" and "our").

B. This Privacy Policy Part 1 should be read in conjunction with the Terms of Use available on the Site(s)/ / App(s). Personal Information/Data/Information (defined below) of a user(s) is collected if the user(s) registers with the Site(s)/ App(s), accesses the Site(s)/ App(s) or takes any action on the Site(s)/ App(s) or uses or accesses the Services as defined in the Terms of Use. The terms ‘Personal Information and ‘Sensitive Personal Information or Information shall have the meaning ascribed to it under the Indian Information Technology Act, 2000 read with the Information Technology.

C. Please read this Privacy Policy Part 1 carefully as your use of this Site(s)/ App(s) constitutes your consent to the processing of your Personal Information as described in the Privacy Policy Part 1. If you are younger than 18 years of age, and you wish to provide us with your Personal Information to participate in a promotion or contest, you must read this Privacy Policy Part 1 with your parent or guardian.


  • A. We use Personal Information to allow you to participate in the features on the Site(s)/ App(s), to process your registration, and to provide you with other requested content related to our content and other offerings.

  • B. We provide interactive features that engage with third-party social media Site(s)/ App(s), such as Facebook and Twitter. Any data that we obtain about your use of such features is subject to this Privacy Policy Part 1. Any data that the social media Site(s)/ App(s) gather about you is subject to your terms with them.

  • C. We may disclose your Personal Information to any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors, etc. insofar as necessary for the purposes set out in this Privacy Policy Part I. We may also disclose Personal Information when you request or agree to such sharing with business partners or other third parties, when we engage a third-party to process data on our behalf, when such sharing is required by law, or in certain other situations.

  • D. If you are under 18 years old, you must obtain the permission of your parent or guardian before participating in a contest or engaging in other activities. The only exceptions are if you simply sign up for a newsletter.

  • E. We use cookies and other technologies to track the use of our Site(s)/ App(s). We allow third parties to place such technologies on our Site(s)/ App(s) to allow them to display advertising and for other purposes.


    We may collect Personal Information/Information, including your name, email or street address, date of birth, telephone number, your preferences and interests, or other information you provide to us or grant us access to when you register for newsletters, communicate with us, or take part in interactive games,

features or competitions. The Site(s)/ App(s) may also ask you to provide other information about yourself or certain information about your preferences and interests. If we combine demographic or other information we collect about you with Personal Information about you, we will treat the combined information as personal information. Please note that information submitted to the Site(s)/ App(s) via a "contact us" or other similar function may not receive a response. We will not use the information provided to contact you for marketing purposes unrelated to your request unless you agree otherwise.


Certain Site(s)/ App(s) may attract individuals younger than 18 years old of age ("Minor" or "Minors"). On those Site(s)/ App(s), Sadagati Network may collect the e-mail address and age of Minors in order to send them newsletters and engage them in other limited activities. If you are a Minor, and you wish to provide us with your Personal Information for any other purposes, such as to participate in a promotion or contest, you must read this Privacy Policy Part 1 with your parent or guardian and must not provide your Personal Information without obtaining your parent's or guardian's prior consent and under their supervision. If we are notified or otherwise learn that a Minor has submitted Personal Information to us through any of our Site(s)/ App(s) other than under the conditions set forth above, we will delete that Minor's Personal Information. Children younger than 18 years of age may only surf the Site(s)/ App(s) and play with the features, but Sadagati Network does not knowingly collect data of users younger than 18 years of age.


Our servers automatically collect limited information about your Devices' connection to the internet, including your IP address, Device and/or MAC ID, etc., when you visit our Site(s)/ App(s). Your IP address is a number that lets computers attached to the internet know where to send your data -- such as the web pages you view. Your IP address, Device and/or MAC ID, etc., does not identify you personally but may be combined with your Personal Information which then may identify you personally.


We will use Personal Information collected through the Site(s)/ App(s) to: (1) allow you to participate in the features we offer on the Site(s)/ App(s); (2) provide you with information that you request or agree to receive;
(3) improve the Site(s)/ App(s) and for internal business purposes;

(4) contact you with regards to your use of the Site(s)/ App(s), and any changes to our policies; (5) tailor content, advertisements and offers we serve you; and

(6) fulfil other purposes disclosed at the time you provide your Personal Information or otherwise with your consent.


While on our Site(s)/ App(s), you may have the opportunity to opt-in to receive information and/or marketing offers from someone else or to otherwise consent to the sharing of your Personal Information with a third-party. If you agree to have your Personal Information shared,

your Personal Information will be disclosed to the third-party and the Personal Information you disclose will be subject to the Privacy Policy Part 1 and business practices of that third-party. You may also specifically request Sadagati Network, sometimes, through your use of an interactive feature, a widget or an application, that we share your Personal Information with a third-party and we will typically do so under those circumstances. In addition, if you choose to register for a promotion, such as a competition, prize draw or contest, your Personal Information may be disclosed to third parties for the purposes of administration of such promotions.


    The Site(s)/ App(s) may offer sweepstakes, contests, and other promotions (each, a "Promotion") that may require registration. If you choose to enter a Promotion, your Personal Information may be disclosed to third parties in connection with the administration of such Promotion, such as in connection with winner selection, prize fulfillment, and as required by law, such as on a winners list. By entering a Promotion, you are agreeing to the official rules that govern that Promotion, which may contain specific requirements from you, including, except where prohibited by law, allowing the sponsor and/or other parties to use your name, voice and/or likeness in advertising or marketing materials.


    We may share your Personal Information with other entities (group entities and/ or affiliates) for internal reasons, primarily for business and operational purposes. Sadagati Network or any of its assets, including the Site(s)/ App(s), may be sold, or other transactions may occur in which your Personal Information is one of the business assets of the transaction. In such a case, your Personal Information may be transferred. Hence, Sadagati Network reserves the right to disclose and transfer user information, including Personal Information in connection with a corporate merger, consolidation, restructuring, the sale of certain of Sadagati Network assets, or other corporate change including, without limitation, during the course of any due diligence process


    We may engage any third parties to perform functions on our behalf, such as hosting or operating our Site(s)/ App(s), sending e-mail communications, and data analysis. We may share Personal Information with third parties in order for them to provide content or otherwise perform services for us, and we will require such parties to maintain appropriate security to protect such data from unauthorized access or processing. It is clarified that in no event shall Sadagati Network, or any of its directors, employees, or any representatives, be held liable for use of such Personal Information by itself and the aforementioned third parties.


Certain investors may be interested in investing funds in Sadagati Network. For the purposes of securing such investment, Sadagati Network may be required to disclose data pertaining to your Personal Information or to your Usage Information. We will require such parties to maintain appropriate security to protect such data from unauthorized access or processing. It is clarified that in no event shall Sadagati Network be held liable for use of such Personal Information/ Information by itself and the aforementioned third parties.


The Site(s)/ App(s) may provide links to other Site(s)/ App(s) applications. This includes links from advertisers, sponsors and partners that may use our logo(s) as part of a co-branding agreement. Certain content on the Site(s)/ App(s) may be hosted and served by third parties, which may include third-party widgets (such as those that allow you to "like" or "share" content with third-party Site(s)/ App(s) and interactive services, or third-party "get tickets and showtimes" widgets). The use of these third-party Site(s)/ App(s) applications and any information collected, stored and transferred by them is not subject to this Privacy Policy Part 1 and is usually governed by their own terms of use and Privacy Policy Part 1. By clicking through to these third-party Site(s)/ App(s) applications, you will be governed by such third- party's Privacy Policy Part 1/ Terms of Use. We have no control over these third parties. These third parties may send their own cookies to your Device, they may independently collect data or solicit Personal Information and may or may not have their own published privacy policies. Sadagati Network is not responsible for the privacy practices or business practices of any third-party Site(s)/ App(s).

Sadagati Network may also display its content/ widgets on third-party Site(s)/ App(s) /Application(s). Please note that in such an eventuality, your use of the third-party Site(s)/ App(s)/ Application(s) shall continue to be governed by the third-party's Privacy Policy Part 1/ Terms of Use. We have no control over these third parties. These third parties may send their own cookies to your Device, they may independently collect data or solicit Personal Information and may or may not have their own published Privacy Policies. Sadagati Network is not responsible for the privacy practices or business practices of any third-party Site(s)/ App(s).


We may transfer and disclose information, including your Personal Information, Usage Information and Device Identifier (including IP address, Device and/or MAC ID, etc), to third parties: to comply with a legal obligation; when we believe in good faith that the law requires it; at the request of governmental authorities conducting an investigation; to verify or enforce the Site(s)/ App(s)'s Terms of Use or other applicable policies; to respond to an emergency; or otherwise to protect the rights, property, safety, or security of third parties, visitors to this Site(s)/ App(s) or the public. Pursuant to valid requests by law enforcement agencies, we may also use Device Identifiers to identify users, and may do so in cooperation with copyright owners, internet service providers, wireless service providers or law enforcement agencies, at our discretion. Such disclosures may be carried out without notice to you.


Our Site(s)/ App(s) may offer message boards, chat rooms, alternative reality games, multiplayer games and other public areas (collectively, "Community Forums") where you can engage in social networking, interact with others, as well as have the opportunity to submit photographs, writings, music, video, audio recordings, computer graphics, pictures, data, questions, comments, suggestions or other content, including Personal Information (collectively, "User Submissions"). To participate in certain Community Forums, you may be asked to select a username, screen name or member name and password. Furthermore, any such User Submissions that you publish on our Site(s)/ App(s) or submit for publication on our Site(s)/ App(s) may be available, via the internet, around the world, and we cannot prevent the use or misuse of such information by others.


User Submission(s) may be used or shared with any third parties. Information you choose to post or make available in the Community Forums may be viewed, collected and used by others and we shall have no control over the manner and mode of such use. If you choose to voluntarily disclose User Submissions, the protections of this Privacy Policy Part I will not cover such disclosure of information. Think carefully before you post and use caution before disclosing any Personal Information.

Also, functionality on the Site(s)/ App(s) may permit interactions between the Site(s)/ App(s) and a third- party Site(s)/ App(s) or service, such as enabling you to "like" a product on our Site(s)/ App(s) or "share" content to other Site(s)/ App(s) or services. If you choose to "like" or "share" content on the Site(s)/ App(s) or to otherwise post information from or via the Site(s)/ App(s) to a third-party's Site(s)/ App(s), service, feature or application, etc. that information will become public and the third-party may have access to information about you and your use of our Site(s)/ App(s).

User Submissions may be published online or offline in any media or format (currently existing or hereafter developed). We may also publish your name, voice, likeness and other Personal Information with your User Submissions, and Sadagati Network may use the content, or any portion of the content, for advertising, marketing, publicity, promotional or any other activities. For full terms and conditions regarding User Submissions you submit to the Site(s)/ App(s), please refer to our Terms of Use.


Sadagati Network may receive information about you from third parties. For example, if you are on another Site(s)/ App(s) and you opt-in to receive information from Sadagati Network that Site(s)/ App(s) will forward to us your email address and other information about you so that we may contact you as requested. You may also choose to participate in a third-party application or feature on our Site(s)/ App(s) (such as logging in through Facebook Connect or otherwise linking the Site(s)/ App(s) with another Site(s)/ App(s) or interactive service) or on a third-party Site(s)/ App(s) or service (such as one of our Facebook applications or a similar application or feature on a third-party Site(s)/ App(s) or service) through which you allow us to collect (or the third-party to share) information about you, including Personal Information. When you choose to participate, you may be opting to link your activity on our Site(s)/ App(s) with that third-party Site(s)/ App(s) or service, which may then collect information about your visits to our Site(s)/ App(s) and may publish that activity as you request to your "profile" or similar feature with that third-party (such as if you choose to share content you find on one of our Site(s)/ App(s) with your "connections" on the third-party's Site(s)/ App(s) or service). The information we collect is subject to this Privacy Policy Part 1.

However, the information collected and stored by the third-party remains subject to the third-party's privacy practices, including whether the third-party continues to share information with us or with other third parties, the types of information shared, and your choices with regard to what is visible to others on that third-party's Site(s)/ App(s) or service. The third-party may allow you to remove the application or feature, in which case we will no longer collect information about you through the application or feature, but we may retain the information previously collected. In addition, we may receive information about you if other users of a third-party Site(s)/ App(s) or service give us access to their profiles and you are one of their "connections" or information about you is otherwise accessible through your "connections" web page, profile page, or similar page on a social networking or other third-party Site(s)/ App(s) or interactive service.

We may also supplement the information we collect about you through the Site(s)/ App(s) with outside records from third parties in order to enhance our ability to serve you, to tailor our content to you and to

offer you opportunities to purchase products or services that we believe may be of interest to you. We may combine the information we receive from these third parties with information we collect through the Site(s)/ App(s). In those cases, we will apply this Privacy Policy Part 1 to any Personal Information received, unless we have disclosed otherwise.


Sadagati Network licenses technology to serve advertisements on its own Site(s)/ App(s) and within its videos and other content as that content is served across the internet. In addition, Sadagati Network may use third-party network advertisers to serve advertisements and third-party analytics service providers to evaluate and provide us with information about the use of the Site(s)/ App(s) and viewing of our content. We do not share Personal Information with these third parties, but ad network providers, the advertisers, the sponsors, and/or analytics service providers may set and embedded scripts on your Device and they may otherwise collect or have access to information about you, including Usage Information. With regard to advertisements, we and our network advertisers may target advertisements for products and services in which you might be interested based on your visits to both the Site(s)/ App(s) and other Site(s)/ App(s).


We incorporate commercially reasonable safeguards to help protect and secure your Personal Information. However, no electronic data transmissions or storage of information can be guaranteed to be 100% secure. You acknowledge that we cannot ensure or warrant the security of any information you transmit to us, and you use the Site(s)/ App(s) and provide us with your information at your own risk.

You may also contact us in case you have any questions / suggestions about the Privacy Policy Part 1 using the contact information mentioned above.


We cooperate with mandated government and law enforcement agencies or to any third parties by an order under law for the time being in force to enforce and comply with the law. We will also disclose any information including Personal Information or Information about you to government and law enforcement agencies or private parties without your permission as we, in our sole discretion, believe necessary or appropriate to respond to valid claims and legal process, to protect the property and rights of Site(s)/ App(s) or a third-party, to protect the safety of the public or any person, or to prevent or stop any illegal, unethical or legally actionable activity. Site(s)/ App(s) may also provide your Personal Information including Sensitive Personal Information or Information to various authorities upon any demand or request from them.


We reserve the right to change the terms of this Privacy Policy Part 1 at any time, without notice, by prominently posting notice of the amendment on this Site(s)/ App(s). To the extent permitted by applicable law, such changes will be applicable from the time they are posted. Sadagati Network will use your Personal Information in a manner consistent with the Privacy Policy Part 1 in effect at the time you submitted the information.


We may use your Personal Information or Information for the aforementioned purposes of the services/Site(s)/ App(s). You have full control regarding which emails you want to receive. If you decide at any time that you no longer wish to receive such communications from us, please follow the instructions to unsubscribe, as provided in any of the communications.

Please note that once we receive your request, it may take an additional period of time for your opt-out to become effective.


Identity theft and the practice currently known as "phishing" are of great concern to us. Safeguarding information to help protect you from identity theft is a top priority. We do not and will not, at any time, request your credit card information or national identification numbers in a non-secure or unsolicited email or telephone communication.


The Terms of Use (as provided on the Site(s)/ App(s)), and any other documents, instructions, etc. included on the Site(s)/ App(s) shall be read in conjunction with and shall be an integral part of these Privacy Policy Part 1.



Sadagati Network has endeavored to align its Privacy Policy in line with the newly enacted General Data Protection Regulation (Regulation (EU) 2016/679) (the "GDPR"), made effective from May 25, 2018. Below are the key provisions of the GDPR for Your information and understanding.


As mentioned in Clause 1 of the Privacy Policy, We would collect Information (as defined in the Privacy Policy Part 1) from You when You set up your account with the Site(s)/App(s). The Information would include but not be limited to your full name, email address, mobile number, location and date of birth. Upon You accessing/using the Site(s)/App(s) as a registered user, we would also collect certain additional information related to You such as demographic, geographic information (such as gender, zip code, age, etc.), information about your preferences and interests to build a better user friendly experience and/or product to continually endeavor to provide better features, access and audio visual content to our end users.


a. One of the prime purposes of uploading the Privacy Policy Part 2 on our Site(s)/App(s) is to inform You of who we are and what business we carry on for which we collect the Information. We collect and use Your Information to better provide You with the required services. We would therefore use Your Information in order to:

  • (i) respond diligently to queries or requests submitted by You;

  • (ii) process financial transactions or applications submitted by You;

  • (iii) administer or otherwise carry out our obligations in relation to any agreement you have with us;

  • (iv) resolve problems/complaints with any goods or services supplied to You;

  • (v) create products or services that may meet your needs and requirements.
    Please refer to Annexure 1 to this Privacy Policy Part 2 to understand how Your Information would be

    processed and the purpose for processing Your Information.

    b. We process Information to pursue our legitimate interest to run, maintain and develop our services in order to meet needs/requirements of our end users/viewers/subscribers. At times while consuming the services, you may be requested to grant Your consent for the processing/usage of Your Information. In this event, you may withdraw Your consent at any time post which we shall refrain from using Your Information in any manner whatsoever.

    c. To optimize our Services, we may wish to use Your Information for marketing our services whereby we send you emails, messages relating to our services and/or our Site(s)/App(s). As We respect your privacy, we will only use Your Information for the purpose of marketing our services when you are aware about the same and if required, we will request your consent prior to using Your Information for such marketing purposes.

    d. Except as set out in this Privacy Policy, We will not disclose any personally identifiable information (if any available with us in the Information) without Your permission to third party(ies) unless we are legally entitled or required to do so (for example, if required to do so by legal process or statutory requirements or regulatory policies or court orders or for the purposes of prevention of fraud or other crime) or if we believe that such disclosure is necessary to protect and/or defend our rights, property or personal safety and those of our users/viewers/subscribers or other individuals.

    e. Please be assured that we will not use Your Information for any of the purposes if You have indicated that you do not wish us to use Your Information in any certain manner/way when submitting the Information or at any later stage.


We use third party service providers for rendering support services, such as Email/ SMS service providers for marketing, for conducting analytics purposes and for software development purposes. We use these third-party services solely to obtain, process or store Your Information for the purposes described in this policy. We may further share your Information to track your usage of the services provided by us on Site(s)/App(s), however the same is not shared with any third party(ies) who are unauthorized to receive such Information.

Sadagati Network and/or its partners/third party firms and/or third party service providers may use

Your Information

  1. (i) to study how You use the Site(s)/ App(s) so we can make improvements and provide you with better customer experiences

  2. (ii) to record information about the pages You visit in the of the Site(s)/App(s), the duration of time You spend on the pages of the Site(s)/ App(s), how You arrived at the Site(s)/ App(s) and the content you clicked on when You visit the Sites(s)/App(s),

  3. (iii) to provide targeted content recommendations to You based on Your interests; (iii) for the purpose of A/B testing,

  4. (iv) marketing communications to comply with legal obligations as per jurisdiction and

  5. (v) to conduct various internal audits and analytics to understand customer behavior and their interaction with features of the platform. We also use your account information to deliver

    content based on subscription pack, country, location and age.

If you have any concerns or complaints regarding the use of the Site(s)/Apps(s), please contact us

at sadagatintework@gmail.com.

The following is a comprehensive list of what /Information we collect, how we use it:


Purpose of processing

Registration Data and Log-in Data. Your name, email, mobile phone number, password, date of birth, gender, and IP address.

Legal Basis (EU): Contract

  • To set up and log-in to a user account on Sadagati Network;

  • To notify you about changes to Sadagati Network;

  • To facilitate communication;

  • To provide you with user support;

  • To enforce our terms, conditions, and policies;

  • To communicate with you;

  • To provide personalised help and instructions;

  • To better understand how you access and use Sadagati


  • To develop new and improve existing features;

  • To provide language and location customisation;

  • To protect any rights, property or safety of ours, our affiliate companies, or other users of Sadagati Network; and

  • To administer Sadagati Network and for internal operations, including troubleshooting, data analysis, testing, research, security, fraud-detection, account management, and survey purposes.

User Profile Search
Data. Record of search inquiries.
Legal Basis (EU): Contract

To provide quick access to previous searches.

Additional Account Security. Kids mode PIN (an optional security feature for you), Managed Devices, Email address, Facebook Connect Token.
Legal Basis (EU): Contract

To verify your identity account security.

Log File Information See definition above.
Legal Basis
(EU): Legitimate Interests

To better understand how you access and use Sadagati Network;
To administer Sadagati Network;
For internal operations, including troubleshooting, data analysis, testing, research, security, fraud-detection, and account management.

Android Device Permissions. Your on- device contact list, SMS, Location, Telephone Legal Basis (EU): Contract

To process payment for subscription via various payment gateways, wallets, mobile carrier billing, etc;

Transaction/ Financial information
Legal Basis (EU): We process this data in accordance with our obligations under applicable law.

As per Indian law and jurisdiction, Sadagati Network is required to store information regarding any payment transaction attempted on the platform. Account ID (Customer ID)- created when a user registers on the app
Order ID (generated when a user initiates a transaction)

Location (Location from which the transaction was done) Package selected
Duration of Package (Quarterly, Half-yearly, Yearly) Payment gateway through which transaction has been done Email Id of the user

Date of transaction
Type of transaction (Success/ Failure) Invoice issued to subscriber

Customer Support Information. Any information that you provide to our customer

• To investigate your support issue.

support team.
Legal Basis (EU): Contract

Device Data. Media stored on your device.
Legal Basis (EU): Contract

• To facilitate the usage of the download feature of Sadagati Network.

Surveys. If you choose to participate in a survey, we may request certain Personal Information from you. We may use a third- party service provider to conduct these surveys and this will be notified to you prior to you completing the survey.

Legal Basis (EU): Consent

  • To better understand how you access and use Sadagati Network;

  • To provide personalised help and instructions;

  • To develop new and improve existing services;

  • To improve Sadagati Network and respond to customer

    requests and preferences.

Contest Information. Any information that you provide to us in submitting an entry to a contest offered on Sadagati Network.

Legal Basis (EU): Contract

  • To facilitate your participation in the contest;

  • To award prizes, if applicable.

Anonymized and Aggregated Data. We anonymize and aggregate certain Information to improve our services

  • Analysis of what features or actions are taken within the app in order to improve app experience

  • Fraud detection and account safety analysis

  • User demographic analysis on items such as region, phone

    model, operating system platform, system language, and Sadagati Network version in order to better understand how our users are using Sadagati Network

  • Web and account traffic statistics of what content and services are used when users access third-party services on the Sadagati Network Open Platform as a method for informing third-party service providers basic analysis of how their service is being used by Sadagati Network users

Information. Please note that where a payment is processed by a third- party payment service provider, we do not collect or store any Personal Information,

  • To facilitate your purchases within Sadagati Network; and

  • For financial reconciliation

  • To investigate fraud

  • To comply with Indian tax laws

  • To provide support and troubleshooting

though we may receive summary information about transactions.