This Privacy Policy explains how the GramPhoto Android app ("the App") handles your information. The App is developed and published by KumawatPulse Technologies ("we", "us", "our"). [Registered legal entity name and address to be confirmed by counsel.]

By using the App, you agree to the practices described here. We never sell your personal information or your photos. Regional addenda below cover users in the EU/UK and India specifically.

1. Who we are

For data-protection purposes, KumawatPulse Technologies acts as the Data Controller (under the EU GDPR) and the Data Fiduciary (under India's DPDP Act, 2023) for information processed through the App. Contact for all privacy matters: gramphotos@kumawat.co.in. Our Grievance Officer for India is [NAME, designation and contact — to be appointed before publishing].

2. What data we collect

3. How and why we use it

We do not use your photos for advertising, profiling, or any purpose outside this list.

4. Legal bases (GDPR)

Where the GDPR applies: backup, sync, and sharing rest on your consent (given by granting permissions and tapping backup/share) and on performance of the service you requested; advertising rests on consent where required; support and security rest on our legitimate interests. You may withdraw consent at any time (Section 10).

5. Third parties and processors

6. International data transfers

Telegram operates globally distributed infrastructure, so backed-up content leaves your country when you back up or share. We have no EU establishment; Europeans can use the App incidentally via Google Play. Transfers occur through our processors' global infrastructure under their published terms; counsel should confirm transfer safeguards before publishing.

7. Data retention and deletion

Your library is retained while your account is active so sync keeps working. You may stop using the App at any time and request deletion of data we hold by emailing gramphotos@kumawat.co.in; the App can also clear its on-device data (bot token, destination, preferences, upload logs). Copies already transmitted to Telegram are subject to Telegram's retention and deletion. Support emails are kept only as long as needed to resolve your request. [Exact retention periods to be confirmed.]

8. Security measures

Photos and videos are encrypted in transit during upload. No method of transmission or storage is 100% secure, and absolute security cannot be guaranteed. Keep your account credentials and bot token safe, and never share your bot token publicly.

9. Children's privacy

The App is rated 3+ on Google Play and is a general-audience tool; it is not directed at children, and we do not knowingly collect personal information from children under 13. Because India law defines a child as anyone under 18, users in India under 18 may use the App only with verifiable parental consent, and we do not use behavioral tracking or targeted advertising directed at children. If you believe a child has provided personal information, contact us and we will take steps to remove it.

10. Your rights

Depending on where you live, you may have rights including access, correction, deletion, portability, objection, and withdrawal of consent. The addenda below detail them. To exercise any right, email gramphotos@kumawat.co.in — we respond within 30 days.

11. Cookies and ad identifiers

This website sets no cookies and runs no trackers (which is why there is no consent banner). Ad identifiers in the free app come from Google AdMob; manage them in Android Settings → Privacy → Ads, or remove ads by upgrading to Premium once available. Details: Cookie Policy.

12. GDPR addendum (EEA, UK, Switzerland)

Controller: KumawatPulse Technologies (contact above). We have no EU establishment, so no EU Representative is appointed; Europeans use the App incidentally via Google Play. Legal bases are listed in Section 4. Your rights: access, rectification, erasure ("right to be forgotten"), restriction, portability, objection, the right not to be subject to solely automated decision-making, and the right to withdraw consent at any time (withdrawal does not affect prior lawful processing). Complaints: you may complain to your local Data Protection Authority. Retention and transfers: see Sections 6–7. Exercise any right by email; we respond within 30 days.

13. India DPDP Act, 2023 addendum

Data Fiduciary: KumawatPulse Technologies. Personal Data and purposes: exactly the categories and itemized purposes in Sections 2–3 — nothing is collected or used beyond them. Consent is free, specific, informed, unconditional, and unambiguous, given when you grant permissions and configure backup; you may withdraw it as easily by clearing app data, revoking permissions, or emailing us. Data Principal rights: access a summary of your data and processing, correction, erasure, grievance redressal, and nomination of another individual to exercise your rights in case of death or incapacity. Grievance Officer: [NAME, designation, contact — to be appointed before publishing]; write to gramphotos@kumawat.co.in in the meantime. Retention and erasure: data is erased once its purpose is served (see Section 7), unless the law requires retention. Children: under-18 users need verifiable parental consent; no behavioral tracking or targeted ads directed at children. Cross-border transfers: content resides on Telegram's global infrastructure; we will comply with any transfer restrictions the Indian government notifies. Breach notification: we will notify the Data Protection Board of India and affected users as the Act's rules require.

14. Changes to this policy

We may update this Privacy Policy from time to time. Material changes will be posted on this page with a new "Last updated" date. Continued use after changes take effect means you accept them. Also see our Terms & Conditions and Cookie Policy.

15. Contact us

Questions or suggestions about this policy: gramphotos@kumawat.co.in. For grievance redressal in India, see the Grievance Officer details in Section 13.