PRIVACY POLICY
PRIVACY POLICY
Voice Soul, is an AI-enabled voice, image and language assistance platform that enables its users to record, upload, translate, process and receive audio, image-based, contextual and language-related outputs through artificial intelligence and third-party processing systems (collectively referred to as the ‘Services’), and is owned and operated by Sohofi Global Technologies, a partnership firm based in India, with its registered office at Flat No. 203, 23/1, J R Makwoods Apartments, Old Mangammanapalya Road, Popular Colony, Mangammanapalya, Bengaluru, Bengaluru Urban, Karnataka, 560068 (hereinafter referred to as the “SOHOFI”, “Company”, “we”, “us”, “our”, or “ourselves”).This Privacy Policy (“Policy”) explains how we collect, use, disclose, store, retain, protect, and otherwise process personal data and other information when you use or visit the Voice Soul mobile application, website, web application, APIs, interfaces, software, tools, content and related services (hereafter referred to as the “Platform”).
Please read this Privacy Policy carefully, before accessing or using our Platform, to understand our policies and practices regarding your Information/Data and how we will treat it. This Policy is provided for transparency and information purposes. It is not, by itself, a consent instrument. Reading, accessing, acknowledging this Policy, or registering on or using the Platform does not, by itself, constitute your Consent to the processing of your Personal Data for any purpose. Where consent is the applicable legal basis under the Digital Personal Data Protection Act, 2023 (“DPDP Act”) and applicable rules thereunder, we will separately obtain your free, specific, informed and unambiguous consent, through a dedicated, itemized consent notice presented at the relevant point of use, before processing your Personal Data for the relevant purpose. If you accept this Policy on behalf of another person, company or other legal entity, you represent and warrant that you have full authority to bind such person, company, or legal entity to this Policy.
This Privacy Policy (“Policy”) explains how we collect, use, disclose, retain and protect your personal Information/Data when you use the Voice Soul mobile application, website, web application, APIs, interfaces, software, tools, content and related services (the “Platform”). This Policy has been drafted not merely to explain what Information/Data we process, but also why we process it, the safeguards we apply to protect it, and the rights and choices available to you under Applicable Laws. For AI Processing features, Input Data is intended to be processed on a one-time, transient basis to generate the requested AI Output and is then deleted, de-identified or retained only in limited form as described in this Policy.
This Policy is provided electronically and should be read with the Terms and Conditions, consent notices, cookie notices, feature-specific notices and in-app disclosures. Nothing in this Policy limits any mandatory rights available to you under Applicable Laws.
In this Policy, “you” / “your” / “yourself” means the person using the Platform and/or the person on whose behalf you are acting. We process Personal Data, Sensitive Personal Data or Information, third-party information and other Information/Data only for the relevant features and purposes described in this Policy and in accordance with Applicable Laws.
This Policy describes our current data protection policies and practices and may be amended/updated from time to time. Any changes to this Policy will become effective upon posting of the revised Policy on the Platform or upon such other date as may be notified by us. We suggest that you regularly check this Policy to apprise yourself of any updates.
1. CONSENT
This Policy is a privacy notice provided to you in accordance with the Digital Personal Data Protection Act, 2023 and the Digital Personal Data Protection Rules, 2025 (as may be amended from time to time). It describes our data practices so that you an informed decision before providing consent. Where a feature can be used without personal data, we will not make consent for that data a condition of access to unrelated services. This Policy, by itself, does not constitute your consent to the processing of your Personal Information/Data. By accessing or using the Platform, you acknowledge that you have read and understood this Policy and, where consent is the applicable legal basis under the DPDP Act, we will present you with a separate, itemised consent notice at the relevant point of use before collecting or processing your Personal Information/Data. That consent notice will specify the personal data to be collected, the specific purpose for which it is collected, our use of your Personal Information/Data and the manner in which you may exercise your rights and withdraw consent,as prescribed by the DPDP Rules. If you do not agree with the terms of this Policy or the applicable consent notice, please do not use the relevant feature or Service. This Policy should be read together with the Terms and Conditions and other applicable notices. It does not, by itself, constitute consent to the processing of Personal Data.
“Consent” under this Policy means a free, specific, informed, unconditional and unambiguous indication of your wishes by a clear affirmative action, signifying agreement to the processing of Personal Information/Data for a specified purpose, as defined under Section 2(za) read with Section 6 of the Digital Personal Data Protection Act, 2023. Where consent is the lawful basis for processing, we will present you with a consent notice that: (a) itemizes each category of personal data proposed to be processed; (b) specifies each purpose for which it is processed; (c) explains the manner in which you may withdraw consent and exercise your rights under the DPDP Act; and (d) where processing is to be carried out by a Data Processor or third-party service provider on our behalf, identifies the categories of such processors. Consent will not be bundled with acceptance of terms and conditions, and you will not be required to consent to processing that is beyond what is necessary for the Service you are using. Consent obtained through this Policy, app permissions or terms acceptance alone does not satisfy the itemised-notice requirement where the DPDP Act requires a specific, itemised consent notice; where required, we will separately obtain such consent through in-app prompts, consent notice.
Where the Platform transmits your personal data to a third-party AI service as part of providing the core AI Processing functions described in this Policy, such transmission forms an integral part of the Service you have requested. Before you use a feature that involves transmission of your personal data to a third-party AI service for the first time, the Platform will, to the extent technically practicable and before such transmission commences: (a) inform you of the nature of the data to be sent; (b) identify the category of third-party service provider that will receive it; (c) specify the purpose of such transmission; and (d) obtain your free, specific, informed, unconditional and unambiguous consent by way of a separate, itemized consent notice, particularly where the processing involves Sensitive Personal Data or Information. Your Input Data will be sent to third-party AI service providers in the categories described in this AI Processing, Model Operations and Outputs Section, solely to provide the relevant features to you and only after such consent has been obtained. Creating an account or using the Platform generally does not, by itself, constitute your consent to such transmission. You may withdraw your consent or decline to use AI Processing features at any time by using the controls described in the User Rights and Choices Section of this Policy; such withdrawal will not affect the lawfulness of processing carried out before withdrawal but may limit or prevent your continued use of the relevant feature.
You may withdraw your consent at any point in time, in the manner described in this Policy. Withdrawal of consent will not affect processing already undertaken before withdrawal and may limit or prevent your use of the relevant Service, feature, Coin-related functionality, Offer Wall activity or Third-Party Service. We may continue processing where required or permitted under Applicable Laws, including for legal compliance, fraud prevention, security, record-keeping, dispute resolution and legal claims.
2. APPLICABILITY
This Privacy Policy applies to Information/Data we collect through the Platform and Services, including account creation, app usage, voice-to-voice translation and the Image to Your Voice / Visual Story Converser (image-based question-and-answer), image-to-voice functionality, contextual image assistance, language mapping, location-based language configuration, customer support, Coins, Premium Membership Plans, advertisements, Offer Wall activities, Third-Party Services and related functionality. Our Privacy Policy applies to all Users, Visitors and others who access our Platform.
This Privacy Policy does not apply to the privacy practices of independent third-party applications, app stores, payment gateways, AI vendors, cloud providers, analytics providers, advertising partners, Offer Wall providers, survey providers, game providers, external websites, linked content or other Third-Party Services that collect or process Information/Data for their own purposes. If you have any questions about the specific settings and privacy practices of such third parties, please review their privacy notices, policies and terms.
Where we engage any third-party AI vendors, cloud infrastructure providers, analytics service providers, or customer support platforms to process Personal Data exclusively on its behalf and strictly in accordance with our documented instructions, such entities shall operate as Data Processors within the meaning of the DPDP Act. We retain ultimate regulatory accountabilities for all Personal Data processing activities carried out by such contracted Data Processors on our behalf. All contracted Data Processors are bound by enforceable Data Processing Agreements (“DPAs”) requiring them to: (i) implement appropriate technical and organisational security measures; (ii) maintain strict confidentiality; (iii) process Personal Data solely for specific authorised purposes; and (iv) afford Data Principals protection no less stringent than under this Policy and as prescribed by the DPDP Act, 2023 and the related rules thereto. If you submit, upload, record or process Content, including any person’s voice, image, likeness, biometric information, personal information, confidential information, sensitive information, prompts, files, messages, image links or other materials through the Platform, you are responsible for ensuring that you have all rights, consents, notices, permissions and lawful grounds required under Applicable Laws and the Terms and Conditions.
3. DEFINITIONS
a) “Applicable Laws” shall mean and include all applicable laws, statutes, ordinances, rules, regulations, notifications, orders, judgments, governmental directions, guidelines and requirements having the force of law in India, including the Digital Personal Data Protection Act, 2023 and the rules, notifications and directions issued thereunder; the Information Technology Act, 2000 and rules framed thereunder, including the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011; the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021, to the extent applicable; the Indian Contract Act, 1872; the Consumer Protection Act, 2019; applicable payment and consumer-protection laws; and any applicable directions of Indian governmental, regulatory, cyber-security, law-enforcement or judicial authorities. Where a provision of Applicable Laws is not yet in force or becomes enforceable in phases, we will comply with that provision from the date on which it applies to the Company or to the relevant processing activity.
b) “Personal Data” or “Personal Information” means any data about an individual who is identifiable by or in relation to such data, including digital personal data processed through the Platform. References to “Personal Data” shall be construed accordingly. Information that is lawfully made or caused to be made publicly available by the Data Principal or by a person under a legal obligation to make such information publicly available may be treated in accordance with Applicable Laws. Aggregated, anonymized or de-identified information that cannot reasonably identify an individual is not treated as Personal Information/Data for purposes of this Policy.
c) “Sensitive Personal Data” or “Sensitive Personal Information” or “SPDI” shall have the meaning assigned to it under the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, to the extent those Rules remain applicable and have not been superseded, amended or repealed by or pursuant to the Digital Personal Data Protection Act, 2023. As of the date of this Policy, the Central Government has not formally repealed or replaced the IT (SPDI) Rules 2011 in their entirety, and they may continue to apply to the extent consistent with the DPDP Act. The Platform does not generally process SPDI. Passwords and financial information you provide are treated as SPDI where applicable. Voice recordings, images and other Content processed by the Platform for transcription, translation or contextual description are not, by themselves, SPDI or biometric information, and would only fall within SPDI if used for biometric identification or authentication, or if their content otherwise reveals a category of SPDI recognized under the IT (SPDI) Rules, 2011 or other protected categories under Applicable Laws. Under the DPDP Act, all digital personal data about an identifiable individual is “Personal Data” and the Act does not separately designate a category of sensitive personal data, though the Central Government may notify additional obligations for certain categories of personal data or Data Fiduciaries under the DPDP Act.
d) “Data Principal” means the individual to whom Personal Data relates and includes, where applicable, a parent or lawful guardian acting on behalf of a child or a person with disability under Applicable Laws.
e) “Data Fiduciary” means the person who determines the purpose and means of processing Personal Data. SOHOFI acts as the Data Fiduciary for Personal Data processed for the purposes described in this Policy, except where a Third-Party Service independently determines its own purposes and means.
f) “Data Processor” means any person who processes Personal Data on behalf of a Data Fiduciary, and may include service providers, vendors, contractors and other processors engaged by us.
g) “Processing” means any wholly or partly automated operation performed on Personal Data, including collection, recording, organization, structuring, storage, adaptation, retrieval, use, disclosure, transmission, alignment, combination, indexing, sharing, restriction, erasure or destruction.
h) “Content” means audio, voice recordings, speech, images, image links, prompts, text, metadata, feedback, files, messages, names, likenesses, usage instructions and other material submitted, uploaded, recorded, transmitted or made available by or on behalf of a User.
i) “AI Outputs” means translations, audio responses, transcriptions, descriptions, contextual responses, language-related outputs, image-related outputs, prompts, text, voice outputs or other outputs generated, translated, enhanced, summarized, classified or assisted by artificial intelligence, machine-learning models, translation engines, speech engines, computer-vision systems or related third-party APIs.
j) “AI Processing” means the processing of Content, Personal Data, device information, technical data, prompts, voice recordings, images, metadata and other inputs by or through artificial intelligence systems, machine-learning models, translation engines, speech-processing systems, text-to-speech systems, speech-to-text systems, computer-vision systems, safety classifiers, content-moderation tools, model orchestration tools and related Third-Party Services.
k) “Input Data” means prompts, audio, voice recordings, images, image links, text, instructions, metadata, files, feedback and other information submitted, uploaded, recorded, transmitted or otherwise provided to the Platform for processing by a Service or AI system.
l) “Model Improvement Data” means data used to monitor, test, evaluate, debug, improve or enhance the quality, reliability, safety, latency, usability or performance of the Platform, Services, AI Outputs, speech-processing systems, translation engines, computer-vision systems or related safety systems. Model Improvement Data may include aggregated, anonymized, or de-identified data, and may include Personal Data only where permitted under this Policy, a consent notice, feature-specific notice or Applicable Laws.
m) “Human Review” means review by authorized personnel, contractors or service providers for limited purposes such as troubleshooting, support, quality review, safety review, abuse investigation, legal compliance, grievance handling, security incident response, fraud prevention or improvement of the Platform, subject to confidentiality and access controls.
n) “Coins”, “Offer Wall”, “Premium Membership Plan”, “Third-Party Services”, “User” and “Visitor” shall have the meanings assigned to them in the Terms and Conditions.
4. INFORMATION WE COLLECT
We collect only such Personal Data as is necessary for the purposes for which consent is sought or for the legitimate use for which it is to be processed, consistent with our obligations under Section 6(1) of the Digital Personal Data Protection Act, 2023. We will not collect personal data beyond what is described in this Policy, the applicable consent notice, Terms and Conditions, or feature-specific notices, and we will not use Personal Data for any purpose other than the purpose specified in the consent notice or for a legitimate use under Section 7 of the DPDP Act. Depending on your use of the Platform, we may collect the following categories of Information/Data:
a) Information You Provide to Us
i) Account Information: Information about you that you provide to us when creating, maintaining or using an account, including name, username, account ID, profile information, email address, mobile number, language preferences, location/country selection, authentication-related information and any other information provided by you.
ii) Content and AI Processing Information: Voice recordings and speech you provide for translation or conversation; photos or images you capture or upload for the Image to Your Voice / Visual Story Converser; the text of any follow-up questions you ask; and the AI-generated translations, transcriptions and answers (AI Outputs) we return to you. Your voice recordings and images are not stored, they are processed in real time and deleted immediately after the relevant AI Output is generated.
iii) Communication Information: If you communicate with us, such as by email, in-app support, phone, grievance channels or other means, we may collect your contact information, communication content and related records.
iv) Payment, Subscription, Coins and Offer Wall Information: Premium Membership Plan selection, subscription status, invoice identifiers, transaction references, app-store or payment-provider confirmations, refund status, Coin balance, Coin allocations, usage deductions, reward history, Offer Wall completion status, anti-fraud checks, eligibility criteria, attribution identifiers, third-party verification status and related records.
v) Any Other Information: Any other additional Information/Data you voluntarily provide in connection with the Platform or Services, such as customer support communications, feedback, or survey responses, which shall be collected and used solely for the purposes described in this Policy.
b) Information We Collect Through Automated Means
When you use the Platform or Services, we may collect device identifiers, advertising identifiers where permitted, app instance identifiers, IP address, operating system, browser type, app version, device model, network information, crash logs, diagnostics, access times, pages or screens viewed, features used, session length, usage patterns, cookies, SDK data, analytics data, attribution information, app permission status and similar technical logs, which we collect and use for the purposes described in this Policy, including operating and securing the Platform, diagnosing and fixing technical issues, improving features and performance, and understanding usage patterns. The Platform may request access to device permissions such as microphone, camera, photo library, file access, storage, location and notifications. You may enable, disable or modify such permissions through your device settings or Platform settings. If you disable a permission, the relevant feature may not function or may function only in a limited manner.
law.
c) Information We Collect from Other Sources
We may receive Information/Data from app stores, payment providers, Advertising Partners, Offer Wall providers, survey providers, game providers, AI vendors, cloud providers, analytics providers, fraud-prevention providers, support tools and other Third-Party Services integrated with or accessible through the Platform, in each case for the purposes described in this Policy and the Terms and Conditions.
5. HOW WE USE YOUR INFORMATION
Under the Digital Personal Data Protection Act, 2023, we must process Personal Data only on a lawful basis, being either: (i) your consent, obtained through a separate, itemized consent notice presented before the relevant processing commences; (ii) legitimate uses recognized under Section 7 of the DPDP Act, including processing necessary for compliance with any law or order of a court or tribunal, for the State or its instrumentalities for performance of a function authorized by law, for purposes related to employment or safeguarding of Data Principals, and for purposes of preventing or responding to a medical or public health emergency; or (iii) any other lawful basis notified or recognized under the DPDP Act or DPDP Rules from time to time. The specific lawful basis applicable to each purpose is indicated below, and where consent is required we will present you with the required itemized notice before processing commences:
Sr. No.
Purpose
DPDP Basis
a
To create, authenticate, maintain, secure and administer your account and provide account-related support.
Consent (Sections 5-6)
b
To provide and maintain the Services, including voice-to-voice translation, the Image to Your Voice / Visual Story Converser (image-based question-and-answer) image-to-voice functionality, contextual image assistance, language mapping, location-based language configuration, voice-to-voice translation, image-to-voice functionality, contextual image assistance, language mapping, location-based language configuration, customer support and related functionality.
Consent (Sections 5-6), obtained before the relevant functionality is activated
c
To process content, prompts, voice recordings, images, metadata and other inputs through AI, translation, speech, computer-vision and related third-party systems to generate AI Outputs.
Consent (Sections 5-6), via separate itemised notice before first use of the relevant AI feature
d
To allocate, deduct, verify and administer Coins, Usage Charges, Premium Membership Plans, subscriptions, Offer Wall rewards, refunds, disputes and account balances.
Consent (Sections 5-6)
e
To display, measure, attribute and manage advertisements, rewarded advertisements, Offer Wall tasks, surveys, games, promotions and other monetization features, subject to your choices and Applicable Laws.
Consent (Sections 5-6); separate consent obtained for targeted advertising or profiling where used.
f
To detect, prevent, investigate and respond to fraud, abuse, spam, impersonation, payment fraud, Offer Wall manipulation, security incidents and other prohibited conduct.
Consent (Sections 5-6)
g
To improve, maintain, test, monitor, debug and develop the Platform, Services, safety systems, language quality, translation accuracy, performance and user experience.
Consent (Sections 5-6)
h
To communicate with you about account activity, service updates, security alerts, support, policy changes, subscriptions, rewards, offers, marketing communications and administrative matters.
Consent (Sections 5-6)
i
To comply with Applicable Laws, court orders, governmental directions, regulatory requirements, cyber-security obligations, audit, taxation, accounting, record-keeping and law-enforcement requests.
Compliance with legal obligations (Section 7 (d)) and Compliance with judgement, decrees or order (Section 7 (e))
j
To enforce the Terms and Conditions, this Policy and other applicable terms, and to establish, exercise or defend legal claims.
Consent (Sections 5-6) and under Section 17(1)(a), processing necessary for enforcing a legal right or claim is exempt from the Chapter-II consent/notice obligations
k
To create aggregated, anonymized or de-identified analytics, statistics and service-improvement insights that do not reasonably identify an individual.
Consent (Sections 5-6) for the underlying processing of personal data used to generate the aggregated/anonymised output. Once data is genuinely anonymised such that an individual can no longer be identified, the resulting output falls outside the Act’s definition of “Personal Data”.
Unless expressly disclosed in a consent notice, feature-specific notice or applicable setting, we do not use your voice recordings, images, prompts or Content containing Personal Information/Data to train third-party public foundation models. We may use aggregated, anonymized, de-identified or non-personal information to improve, test and monitor the Platform, Services and safety systems, provided that such information does not reasonably identify an individual.
6. COOKIE CONSENT POLICY
We use cookies and similar tracking technologies on our website to enable core site functionality, remember your preferences, improve website performance, and, where applicable, support analytics and marketing. We will use non-essential cookies only after obtaining consent, and we will provide a cookie preference tool to withdraw or modify consent at any time. Where any such cookies or technologies involve the processing of personal data, we will implement consent controls consistent with applicable law.
When you first visit our website, you will be shown a Cookie Consent Banner and a clear Notice describing our use of cookies and similar technologies. The banner will allow you to accept all cookies, decline non-essential cookies, or customize your preferences by category. Essential cookies that are strictly necessary for the operation, security, and basic functionality of the website may be enabled by default, while performance, analytics, and marketing cookies will be activated only after obtaining your affirmative consent.
You may review, modify, or withdraw your cookie preferences at any time through the cookie settings or preferences dashboard made available on the website. Withdrawal of consent will apply prospectively and will not affect the lawfulness of processing carried out before withdrawal, although some features or personalized experiences may no longer be available after non-essential cookies are disabled.
We maintain records of cookie consent grants, changes, and withdrawals for audit, compliance, and operational purposes, and we may update this notice if our cookie practices, service providers, or processing purposes change materially. Any such update will be accompanied by a revised notice and, where required, renewed consent.
7. DISCLAIMER
WHERE THE PLATFORM PROVIDES VOICE, IMAGE OR LANGUAGE ASSISTANCE FOR ACCESSIBILITY, CONVENIENCE, TRANSLATION OR CONTEXTUAL UNDERSTANDING, SUCH ASSISTANCE IS PROVIDED AS AN AUTOMATED AID AND NOT AS A GUARANTEED DESCRIPTION OF THE ENVIRONMENT, DOCUMENT, SIGN, OBJECT, PERSON, PLACE, RISK OR CONTEXT. USERS REMAIN RESPONSIBLE FOR EXERCISING INDEPENDENT JUDGMENT AND OBTAINING HUMAN ASSISTANCE WHERE CIRCUMSTANCES REQUIRE ACCURACY OR SAFETY.
THE PLATFORM IS NOT A SUBSTITUTE FOR PROFESSIONAL TRANSLATORS, INTERPRETERS, LAWYERS, DOCTORS, FINANCIAL ADVISERS, EMERGENCY SERVICES, GOVERNMENT AUTHORITIES, ACCESSIBILITY PROFESSIONALS OR OTHER QUALIFIED PROFESSIONALS. YOU MUST NOT RELY ON THE PLATFORM OR AI OUTPUTS FOR MEDICAL, LEGAL, FINANCIAL, TAX, INVESTMENT, EMERGENCY, GOVERNMENTAL, IMMIGRATION, LAW-ENFORCEMENT, SAFETY-CRITICAL, LIFE-CRITICAL, REGULATED PROFESSIONAL, HIGH-RISK OR OTHER DECISIONS WHERE INACCURATE TRANSLATION, DESCRIPTION, CONTEXTUAL ANSWER OR AUDIO OUTPUT COULD CAUSE HARM, LOSS, LIABILITY OR LEGAL CONSEQUENCE.
AI OUTPUTS MAY CONTAIN ERRORS, MISTRANSLATIONS, OMISSIONS, HALLUCINATIONS, INCORRECT IMAGE INTERPRETATIONS, MISSED NUANCE, DIALECT MISMATCH, TONE MISMATCH, CONTEXTUAL ERRORS, OFFENSIVE OR UNSAFE STATEMENTS, INAPPROPRIATE DESCRIPTIONS, INCORRECT OBJECT RECOGNITION, INCORRECT TEXT RECOGNITION, OR FAILURE TO IDENTIFY RISKS, SENSITIVE CONTENT OR MEANING. YOU SHOULD INDEPENDENTLY VERIFY ANY AI OUTPUT BEFORE RELYING ON IT, PARTICULARLY WHERE THE MATTER IS IMPORTANT, URGENT, REGULATED, SAFETY-SENSITIVE, FINANCIAL, LEGAL, MEDICAL, GOVERNMENTAL, IMMIGRATION-RELATED, EMPLOYMENT-RELATED, EDUCATIONAL, EMERGENCY-RELATED, LIFE-CRITICAL OR OTHERWISE CONSEQUENTIAL.
THE NATURE OF AI PROCESSING MEANS THAT AI OUTPUTS ARE GENERATED ALGORITHMICALLY AND MAY NOT BE DETERMINISTIC. THE SAME OR SIMILAR INPUT DATA MAY PRODUCE DIFFERENT OUTPUTS AT DIFFERENT TIMES DUE TO CHANGES IN MODELS, THIRD-PARTY SYSTEMS, LANGUAGE SETTINGS, PROMPTS, SYSTEM INSTRUCTIONS, SAFETY FILTERS, LATENCY, NETWORK CONDITIONS, REGIONAL AVAILABILITY, DEVICE SETTINGS OR PRODUCT CONFIGURATION. WE DO NOT REPRESENT THAT AI OUTPUTS WILL BE UNIQUE, EXCLUSIVE, COMPLETE, ACCURATE, LAWFUL, NON-INFRINGING, UNBIASED, NON-OFFENSIVE, SUITABLE FOR A PARTICULAR PURPOSE OR FREE FROM ERROR.
AI PROCESSING MAY OCCUR IN MULTIPLE STEPS. FOR EXAMPLE, A VOICE INPUT MAY BE RECORDED OR UPLOADED, CONVERTED INTO A MACHINE-PROCESSABLE FORMAT, TRANSCRIBED, TRANSLATED, EVALUATED FOR SAFETY OR ABUSE SIGNALS, CONVERTED INTO A TRANSLATED OR DESCRIPTIVE AUDIO RESPONSE, ASSOCIATED WITH METADATA SUCH AS LANGUAGE PAIR, DURATION, DEVICE STATE AND SESSION IDENTIFIER, AND LOGGED TO MAINTAIN SERVICE INTEGRITY. SIMILARLY, AN IMAGE INPUT MAY BE CAPTURED OR UPLOADED, ANALYZED FOR TEXT, OBJECTS, CONTEXTUAL FEATURES OR USER QUESTIONS, PROCESSED THROUGH COMPUTER-VISION OR LANGUAGE SYSTEMS, AND CONVERTED INTO A DESCRIPTIVE, TRANSLATED OR VOICE-BASED RESPONSE.
8. AI PROCESSING, MODEL OPERATIONS AND OUTPUTS
The Platform is an AI-enabled service and necessarily involves AI Processing. When you use voice-to-voice translation, the Image to Your Voice / Visual Story Converser (image-based question-and-answer) image-to-voice functionality, contextual image assistance, language mapping, location-based language configuration or related functionality, your Input Data may be processed by a combination of Company systems and Third-Party Services. These may include speech-to-text systems, text-to-speech systems, translation and multimodal AI models (which interpret both voice and images), content-moderation and safety-filtering systems, and cloud infrastructure and other processing systems required to provide the Service.
When you speak into Voice Soul, or take a photo for the Image to Your Voice / Visual Story Converser, that audio or image is held in temporary memory on our servers, or those of our AI providers, just long enough to generate your translation, transcription or answer. It is not written to permanent storage, and it is dropped immediately after we deliver the response to you; the only exception being that, within an active conversation, we keep it briefly so you can ask follow-up questions about that same recording or photo, after which it is dropped too. We do not use your voice recordings or images to train AI models, and there is no setting, on our side or yours, that keeps them for that purpose.
When your Input Data is transmitted to a third-party AI service for processing, the data sent may include: (a) voice recordings, audio clips or speech submitted by you; (b) images or image links submitted by you; (c) text prompts, instructions or queries submitted by you; (d) transcripts or converted representations of the above; (e) session metadata such as language selected, feature used, region identifier and timestamp; and (f) such other technical or contextual data as is strictly necessary for the specific AI function you have invoked to operate, limited to the minimum data required for that function. We do not transmit account credentials, payment information or unnecessary personal identifiers to third-party AI services for AI Processing purposes.
Since raw voice recordings and images are deleted immediately after your AI Output is generated, as described above, we do not use them to build test prompts, benchmark datasets or evaluation sets. Any quality, safety or abuse-prevention metrics we maintain (for example, error rates, latency, or the number of safety-filter triggers) are aggregated technical statistics and do not include your underlying voice recordings, images or transcripts.
Feedback, corrections, ratings, suggested translations, quality comments, support tickets and similar inputs provided by you may be used to evaluate, debug, improve and develop the Platform, Services and AI Outputs. You should not include Personal Data, SPDI, confidential information or third-party information in feedback unless strictly necessary to resolve the issue. We recommend redacting or omitting such information where possible, as feedback may be retained, reviewed by personnel or service providers, and used to evaluate and improve the Platform, Services and AI Outputs.
Where we use Personal Data for model improvement, evaluation or quality review, we will do so only where permitted by Applicable Laws, this Policy, a consent notice, a feature-specific notice, user settings, contractual necessity, legitimate operational necessity recognized under Applicable Laws, or another lawful basis. We may also restrict model improvement processing for certain categories of Content, such as children’s data, SPDI, payment-related data, account credentials, support grievances or content subject to legal restrictions.
We may use aggregated, anonymized, de-identified or non-personal information to improve, test and monitor the Platform, Services, AI Outputs, safety systems, performance, language quality, feature availability, routing logic, abuse-prevention systems and user experience. We will use measures to make re-identification of an individual from such information unlikely, taking into account the means available to any person to reverse the anonymization or de-identification process.
Unless expressly disclosed in a consent notice, feature-specific notice or applicable setting, we do not use your voice recordings, images, prompts or other Content containing Personal Data to train third-party public foundation models. Where third-party AI vendors, translation providers, speech providers or computer-vision providers process Input Data, we use contractual restrictions or technical controls that limit their use of such Input Data to providing and supporting the relevant services, subject to the terms available from those providers and Applicable Laws.
The categories of third-party service providers that may receive your Input Data for AI Processing purposes include: (i) large language model (LLM) / foundation model providers that generate text, language or contextual responses; (ii) speech-to-text and text-to-speech engine providers that convert voice recordings to text and text to audio output; (iii) machine translation providers that translate content between languages; (iv) computer-vision and image-analysis providers that interpret images and generate image-related outputs; and (v) cloud infrastructure providers whose compute or storage resources host or route Input Data during processing. We do not share your Input Data with these providers for their own marketing, profiling or model-training purposes beyond what is described in this Policy. Where we are permitted to identify a specific provider by name, details will be published on the Platform or notified to you in a feature-specific notice.[K&K_HA1]
9. MODEL IMPROVEMENT, TRAINING AND EVALUATION
We distinguish between processing needed to provide the Service and processing for model improvement, evaluation or training. Service delivery processing includes receiving Input Data, routing it to appropriate Company systems or Third-Party Services, generating AI Outputs, maintaining session state, applying safety filters, performing abuse checks, calculating Coin deductions and resolving technical errors. Model improvement processing may include quality measurement, debugging, latency evaluation, safety testing, translation-quality review, speech-recognition assessment, image-processing assessment, prompt and response evaluation, and development of improved workflows or safety controls.
Where a feature offers you the choice to allow your Content to be used to improve or train models we release, whether independently or with partners, you may enable or disable that choice at any time in your account privacy settings, and we will honor your selection prospectively. Enabling this setting does not constitute a general authorization for us to share your Content with unrelated third parties for their own purposes; it authorizes use of your Content for model improvement, training and evaluation as described in this Section, subject to the service-provider and disclosure practices described elsewhere in this Policy.
Location-related processing may include approximate location derived from IP address, device settings, selected region, language settings, app-store region or network information, and precise location only where enabled by you and required by a feature. Location information may be used to configure language sets, regional experiences, feature availability, fraud-prevention controls, compliance settings, advertising attribution, Offer Wall eligibility and security measures.
You should not submit personal details, identity documents, payment information, passwords, health information, children’s information, precise location information, confidential business information, legal documents, medical documents or other sensitive content unless strictly necessary for the specific Service and unless you have the right and consent or another lawful ground recognised under Applicable Laws to do so; for example, an identity document is necessary only where a feature expressly requires identity verification, not for general translation or chat features. The Platform is not intended to be used as a repository for highly sensitive records unless a feature expressly states otherwise.
You must not record, upload, process or submit another person’s voice, image, likeness, biometric information, confidential information, personal information or sensitive information unless you have all notices, consents, permissions and lawful grounds required under Applicable Laws and the Terms and Conditions. Where permitted, you are responsible for obtaining all necessary notices, consents, and permissions before doing so. This restriction applies to recordings of conversations, images of individuals, images of documents, images containing personal details, workplace recordings, classroom recordings, medical, legal or financial information, and any Content where another person has a privacy or confidentiality interest.
Classification of Voice and Image-related Data
The Platform helps you read, translate and understand documents and text in various languages, depending on your subscription plan (free or premium), and processes your voice and images to generate translations, transcriptions, descriptions and contextual answers, and to run safety and fraud-prevention checks, not to identify you. The Platform does not have the ability to analyse, interpret, describe or comment on facial features, scenery or other visual characteristics depicted in an image, and will not respond to requests seeking such analysis. The Platform does not currently include any feature that uses voice or facial characteristics to verify your identity or isolate individual behavioral metrics, and the Platform does not perform any facial recognition, facial analysis or extraction of facial characteristics from images. If such a feature is introduced in future, we will obtain your separate, explicit consent before enabling it.
10. VOICE, IMAGE AND LOCATION-RELATED PROCESSING
The Services may process voice recordings, speech, accents, dialect, language patterns, background audio, images, faces, objects, text within images, places, signs, documents, metadata and location-related settings. Such information may identify you or another person and may reveal sensitive context. Depending on the nature of the Content and the purpose of processing, certain information may constitute SPDI, including biometric information, or may otherwise require heightened care under Applicable Laws.
We may implement safety filters, content moderation rules, rate limits, usage limits, routing controls, feature restrictions, geo-configuration, child-safety controls, sensitive-content filters and other safeguards. These controls may also be used to comply with Applicable Laws and prevent misuse. These controls may prevent, modify, delay, refuse or limit processing of certain Content or generation of certain AI Outputs, including where necessary to comply with Applicable Laws, protect users, protect third-party rights, reduce misuse or maintain integrity of the Platform.
Where an automated process materially affects your account, access, Coins, rewards, subscription status or rights under Applicable Laws, you may contact us through the grievance mechanism described in this Policy. We will provide a grievance route for review of such decisions, subject to applicable law and technical feasibility. We may review relevant logs, device information, offer-completion records, support communications, payment metadata, Content metadata and other records necessary to resolve the issue, subject to Applicable Laws and the Terms and Conditions.
The Platform may use automated systems to detect abuse, fraud, malware, unlawful content, prohibited conduct, spam, manipulation of Coins, Offer Wall abuse, repeated failed payments, suspicious device behavior, account compromise, policy violations, unsafe prompts, harmful outputs or attempts to circumvent technical measures. Such automated systems may affect availability of features, routing of requests, generation or suppression of outputs, suspension of rewards, investigation of accounts, security challenges or enforcement actions.
Most AI Outputs are generated through automated processing. However, authorized personnel, contractors, vendors or service providers may conduct Human Review for limited purposes such as customer support, troubleshooting, quality assurance, abuse investigation, safety review, model evaluation, fraud prevention, security incident response, legal compliance, grievance handling, enforcement of the Terms and Conditions or responding to lawful requests. Human Review is limited to feedback, support tickets or other Content you separately choose to submit, and to session metadata, safety-filter logs and technical records, rather than to the underlying voice recording or image itself.
11. HOW WE SHARE AND DISCLOSE YOUR INFORMATION[K&K_HA2]
We may share Information/Data in the following ways:
a) Affiliates and group companies: We may share Information/Data with our affiliates and group companies to operate, administer, support, secure and improve the Platform and Services, subject to contractual obligations requiring such affiliates and group companies to process the Information/Data only for the purposes described in this Policy and to maintain equivalent security and confidentiality safeguards.
b) Service providers and Data Processors: We may provide access to or share Information/Data with hosting providers, cloud providers, AI vendors, translation providers, speech-engine providers, computer-vision providers, analytics providers, security vendors, customer-support tools, email/SMS providers, payment support vendors, fraud-prevention vendors, auditors, professional advisers and other processors engaged to provide services on our behalf, in each case under a valid contract requiring such processors to act only on our instructions and to process Information/Data solely for the purposes described in this Policy.
c) App stores, payment providers and subscription partners: We may share Information/Data to process subscriptions, verify payments, issue refunds, resolve disputes, administer Premium Membership Plans and comply with payment-related requirements.
d) Advertising Partners and Offer Wall providers: We may share Information/Data to display, measure, attribute and verify advertisements, rewarded advertisements, surveys, games, installs, offers, eligibility, anti-fraud checks and Coin credits. Such partners may also process certain information as independent data fiduciaries/controllers under their own policies. Where required by law, we will obtain separate consent for advertising-related profiling or tracking.
e) Third-Party Services selected or used by you: We may share Information/Data where you choose to access, connect, interact with or complete activities through a Third-Party Service linked to or integrated with the Platform.
f) Protection of our rights and interests: We may disclose Information/Data to prevent fraud or abuse, protect the security and integrity of the Platform, enforce the Terms and Conditions, protect rights and safety, or respond to misuse of the Services.
g) Business transfers: We may disclose or transfer Information/Data in connection with a merger, acquisition, investment, financing, restructuring, sale of assets, insolvency, reorganization or transfer of all or part of our business, subject to appropriate confidentiality and legal safeguards.
h) Legal purposes: We may disclose Information/Data where required or permitted by Applicable Laws, court order, governmental direction, legal process, investigation, cyber-security reporting obligation or to protect rights, property, safety, security or the public interest.
i) Any other person with your consent: We may share Information/Data with a specified recipient where you expressly instruct or authorize us to do so.
We do not disclose Personal Data for unrelated monetary consideration. Where a Third-Party Service processes information for advertising, attribution, rewards or monetization, such processing will be governed by this Policy, the relevant third-party policy, your choices and Applicable Laws.
We will seek to ensure that vendor changes do not materially reduce the protection of Personal Data under this Policy. Where a change materially affects processing of Personal Data or requires notice or consent under Applicable Laws, we will provide notice or obtain consent as required.
We may change, add, remove, replace or reconfigure AI vendors, models, cloud providers, speech engines, translation engines, computer-vision tools, analytics providers, safety systems or other processing tools from time to time to improve functionality, safety, latency, availability, cost, language coverage, quality, reliability or legal compliance. Such changes may affect output quality, available features, regional availability, latency, retention, data flows and the categories of processors involved.
Where a provider acts as our Data Processor or service provider, we seek to impose appropriate obligations relating to confidentiality, purpose limitation, security, access controls, retention, incident notification, assistance with rights requests, deletion or return of data, and restrictions on unauthorized use of Input Data. Where a provider acts independently, its own terms and privacy policy may apply, and you should review such terms where the provider is identified or where you interact directly with that Third-Party Service.
With respect to third-party AI service providers that receive your personal data for AI Processing purposes, we require, through contractual measures, that such providers afford a standard of protection at least equivalent to that set out in this Policy and required under Applicable Laws, including restrictions on using your Input Data for purposes other than providing the relevant service to us, obligations of confidentiality, appropriate security measures, and data-deletion or return obligations upon termination of the engagement. Where a provider operates under its own privacy framework that is independently certified or recognized as equivalent or higher, we may rely on that framework to satisfy this standard. We will take reasonable steps to assess and address any material shortfalls that come to our attention.
The Company may use AI vendors, translation providers, speech-processing providers, computer-vision providers, cloud infrastructure providers, analytics providers, safety-tool providers, moderation vendors, monitoring tools and other service providers to operate the Platform. These providers may process Input Data, Content, metadata, device data, logs, AI Outputs or other Information/Data on our behalf or as independent providers, depending on their role and contractual terms.
12. HOW DO WE RETAIN YOUR INFORMATION
We retain Information/Data only for as long as reasonably necessary for the purposes for which it was collected or processed, unless a longer retention period is required or permitted by Applicable Laws, contractual obligations, tax/accounting requirements, regulatory requirements, fraud prevention, security, dispute resolution, enforcement of the Terms and Conditions or establishment, exercise or defense of legal claims.
Account, profile and contact information is generally retained while your account remains active and for a reasonable period thereafter as required for legal, security, fraud-prevention, accounting or dispute-resolution purposes. Coin, subscription, payment metadata, Offer Wall and transaction records may be retained as required for accounting, tax, audit, anti-fraud, chargeback, refund, verification and legal purposes.
Your voice recordings and images are processed in real time solely to generate the requested translation, transcription or contextual response, and are deleted immediately once that AI Output has been generated and delivered to you. The only exception is that, within an active, ongoing conversation, a voice recording or image may be retained for the limited duration needed to support your follow-up questions about it; it is deleted at the end of that conversation. We do not retain your voice recordings or images for safety, debugging, fraud-prevention or model-training purposes. Text-based AI Outputs (such as a translation or answer) are likewise not retained as permanent history unless you save them, a feature provides for retention, or you submit them to us for support or feedback.
Raw voice recordings, images and prompts are not retained beyond the active conversation, as described above. Separately, session metadata, safety logs, abuse-prevention logs, Coin consumption records, model-routing records, quality metrics and error logs, none of which include your underlying voice recordings or images, may be retained for longer periods where necessary for security, fraud prevention, service integrity, accounting, legal compliance or dispute resolution, as set out below.
Without limiting the foregoing, we retain the following categories of Information/Data for the periods indicated below, or until the purpose for which the data was collected is no longer being served, whichever is later, subject to any longer period required by Applicable Laws:
(a) Account, profile and contact information: for the duration your account remains active, and for three (3) years following account closure or last login, for legal, security, fraud-prevention and dispute-resolution purposes;
(b) Coin, subscription, payment metadata, Offer Wall and transaction records: for eight (8) years from the date of the relevant transaction, as required for accounting, tax, audit and anti-fraud purposes;
(c) Voice recordings, images, prompts, transcripts and session Content not saved by you: deleted immediately after the relevant AI Output is generated and delivered to you; retained only for the duration of an active conversation to support follow-up questions, and deleted at the end of that conversation. Not retained for safety, debugging, fraud-prevention or any other purpose;
(d) Metadata, safety logs, abuse-prevention logs, model-routing records and error logs: for twelve (12) months] from creation, for security, fraud-prevention and service-integrity purposes; and
(e) Support tickets, feedback and grievance records: for three (3) years from resolution, for quality-assurance and legal-compliance purposes.
We will update the periods above as our practices evolve and will notify you of any material change in accordance with the Update to the Privacy Policy Section of this document. De-identification or anonymization may not be reversible, and once information has been anonymized or aggregated it may not be possible to associate it with your account or respond to access, correction or erasure requests in relation to that anonymized or aggregated information.
Deletion of account information or Content may not immediately delete all backup copies, logs, legal records, security records, payment records, Offer Wall verification records or data retained by Third-Party Services, but we will apply deletion, de-identification, anonymization or retention controls in accordance with Applicable Laws and our retention practices. Such residual copies will be deleted or overwritten within thirty (30) days in accordance with our backup and retention cycles, except to the extent a longer period is required for legal, security, payment or dispute-resolution records as described above.
Where the Digital Personal Data Protection Rules, 2025 require erasure of personal data upon a specified period of user inactivity (for example, under Schedule III for certain classes of data fiduciary, including online gaming and social media intermediaries meeting the prescribed user thresholds), we will erase your personal data upon the lapse of the prescribed inactivity period, unless retention is required for compliance with law or for the discharge of a legal obligation. Before doing so, we will notify you at least forty-eight hours (48) in advance, in the manner prescribed under the DPDP Rules, so that you may log in or otherwise use the Platform if you wish to prevent such erasure.
When the purpose for which Personal Data was collected is no longer being served and retention is no longer necessary for any legal, safety, fraud-prevention, security, accounting or dispute-resolution purpose, we will delete, de-identify, anonymize or aggregate Information/Data in accordance with our obligations under Section 8(7) of the Digital Personal Data Protection Act, 2023. Section 8(7) requires a Data Fiduciary to erase personal data upon the Data Principal withdrawing consent (to the extent the data is not required for a legitimate use under Section 7) or upon the Data Principal no longer being reasonably expected to use the service for which the data was collected. We will conduct periodic reviews of retained personal data to identify data that should be erased in the ordinary course. De-identification or anonymisation, where applied, will be carried out using techniques designed to prevent identification of the Data Principal, consistent with Applicable Laws and our internal retention practices; once anonymised, the resulting information will not be treated as Personal Data for the purposes of the DPDP Act.
13. HOW WE PROTECT YOUR INFORMATION
We implement reasonable security practices and procedures and appropriate technical and organizational measures designed to protect Information/Data from unauthorized access, disclosure, alteration, destruction, loss, misuse and accidental damage. These measures may include access controls, authentication, encryption or similar safeguards where appropriate, logging, vulnerability management, vendor controls, incident-response processes, employee or contractor confidentiality obligations and periodic review of security practices.
No method of transmission, storage or processing is completely secure. You are responsible for maintaining the confidentiality of your account credentials, securing your device and promptly notifying us of any unauthorized access, suspected compromise or misuse of your account.
Where a Personal Data breach triggers a reporting obligation under Applicable Laws, we will take steps required under Section 8(6) of the Digital Personal Data Protection Act, 2023which shall include intimating the Data Protection Board of India (“DPBI”/“Board”) without delay upon becoming aware of the breach, and submitting a detailed report to the DPBI within seventy-two (72) hours of becoming aware of the breach (or such longer period as the DPBI may allow on a written request), in the form and manner prescribed by the DPDP Rules. We will also intimate affected Data Principals without delay, in a concise, clear and plain manner, through their registered user account or other registered mode of communication, as prescribed under the DPDP Rules. Separately, where a cybersecurity incident triggers reporting obligations under the CERT-In Directions (Directions under Section 70B of the Information Technology Act, 2000), we will report to the Indian Computer Emergency Response Team (CERT-In) within six (6) hours of becoming aware of such incident, by submitting the incident details via email to cert-in@cert-in.org.in or through CERT-In’s online incident reporting portal, in the incident reporting form format prescribed by CERT-In, including particulars such as the time and nature of the incident, systems and networks affected, and a point of contact for further coordination. We may also notify law-enforcement authorities or other competent authorities, as required by Applicable Laws. Any breach notification to you will include, to the extent practicable and permitted by law, a description of the nature of the breach, the categories of data affected, the likely consequences, and the measures taken or proposed to address the breach.
AI-related security measures may include prompt-abuse monitoring, rate limiting, anomaly detection, access logging, segregation of production and testing environments, vendor-access controls, evaluation of model and API endpoints, restrictions on employee access to raw Content, controls on export of logs, and review of incidents involving unintended disclosure, prompt injection, model misuse, excessive data exposure or unauthorized access to Content or AI Outputs.
You should not attempt prompt injection, model extraction, data extraction, scraping, automated abuse, circumvention of safety filters, unauthorized access to AI systems or any other activity intended to expose system prompts, hidden instructions, non-public model configurations, other users’ data, vendor credentials, security controls or confidential platform information.
14. THIRD-PARTY LINKS AND FEATURES
The Platform may include Third-Party Services, advertisements, rewarded advertisements, Offer Wall tasks, surveys, games, links, SDKs or integrations. These may be provided by Advertising Partners, Offer Wall providers, app stores, payment providers, AI vendors, analytics providers or other third parties.
When you interact with a Third-Party Service, the third party may collect information directly from you or your device, including device identifiers, IP address, advertising identifier, interaction data, reward eligibility, offer completion status and other information needed to provide the third-party functionality. Their privacy policy and terms will govern their independent processing.
We may receive confirmation, attribution, verification, anti-fraud and reward-status information from Third-Party Services so that we can credit Coins, verify eligibility, prevent manipulation and resolve disputes. Completion of Offer Wall activities does not guarantee Coin credit unless all applicable completion conditions, third-party verification requirements and anti-fraud checks are satisfied.
The Platform may use cloud infrastructure, AI vendors, analytics providers, support tools, payment partners, Advertising Partners and other Third-Party Services located in India or outside India. Accordingly, Personal Data may be transferred to, stored in or processed in jurisdictions outside India for the purposes described in this Policy. Any cross-border transfer will be subject to applicable restrictions and notifications issued under law.
We will undertake such transfers in accordance with Applicable Laws, including the Digital Personal Data Protection Act, 2023. Under Section 16 of the DPDP Act, 2023, the Central Government may restrict the transfer of personal data to certain countries or territories, may notify or conditions applicable to such transfers. We will only transfer Personal Data outside India to countries or territories that have not been restricted under any such notification issued from time to time. As of the date of this Policy, the Central Government has not yet issued a notification restricting transfers to any specific country; we will update this Policy and implement necessary controls promptly upon any such notification being issued. A comply with any country-specific transfer restrictions or directions issued under Applicable Laws.
Where Personal Data is transferred outside India, we will do so under a contract with the recipient (such as our cloud, AI, analytics or other service providers) that binds the recipient to confidentiality obligations, purpose and use restrictions, security safeguards and data-deletion or return obligations upon termination of the engagement, consistent with the equivalency standard described elsewhere in this Policy. We use industry-standard encryption to protect Personal Data both in transit (for example, via TLS 1.3 or a PFS-validated equivalent) [K&K_HA3] and at rest (for example, using AES-256 encryption at the storage or database layer) [K&K_HA4] when it is transferred to or processed by such recipients outside India.
Where Personal Data is transferred outside India to a Data Processor or third-party service provider, we will ensure that the transfer is subject to contractual measures designed to maintain a standard of protection for your personal data that is consistent with the protections applicable under this Policy and the DPDP Act, as may be supplemented by directions of applicable regulators.
Where a feature permits you to save, download, export, share or reuse AI Outputs, you are responsible for reviewing those AI Outputs and ensuring that any Personal Data, confidential information, third-party content or sensitive information contained in them is handled lawfully and appropriately. If you request deletion or erasure of Personal Data used for AI Processing, we will assess the request under Applicable Laws. Deletion may not affect AI Outputs already delivered to you or shared by you, information retained for legal or security purposes, aggregated or anonymized information, backups awaiting deletion in the ordinary course, or information retained by independent Third-Party Services under their own policies.
If you believe an AI Output contains Personal Data about you that is inaccurate, inappropriate or should not have been generated or retained, you may contact us through the grievance redressal mechanism. We may require information sufficient to identify the relevant account, session, output, date, feature or Content, and may be unable to locate or act on a request where the relevant Content was transient, not retained, anonymized, de-identified, deleted or processed by an independent Third-Party Service.
Subject to technical availability and Applicable Laws, you may use Platform or device controls to limit certain AI Processing, including by disabling microphone, camera, photo, location, notification or advertising permissions; deleting or not saving certain Content; avoiding submission of sensitive prompts; opting out of non-essential marketing communications; or using account settings made available by us.
15. USER RIGHTS AND CHOICES
Subject to Applicable Laws, verification of identity and applicable limitations, you have the following rights as a Data Principal under the Digital Personal Data Protection Act, 2023:
a) Right to obtain a summary of Personal Data being processed and the processing activities undertaken by us, and to obtain identities of all Data Fiduciaries and Data Processors with whom your Personal Data has been shared, together with a description of the Personal Data shared: Section 11(1)(a), DPDP Act.
b) Right to request that SOHOFI correct inaccurate or misleading Personal Data, complete incomplete data, and update out-of-date data. Where SOHOFI has shared the relevant Personal Data with a Data Processor or other Data Fiduciary prior to your request, SOHOFI will, where reasonably practicable, inform such Data Processor or Data Fiduciary of your request: Section 12(1) and 12(2), DPDP Act.
c) Right to erasure of Personal Data that is no longer necessary for the purpose for which it was processed, subject to our legal retention obligations: Section 12(3b), DPDP Act.
d) Right to withdraw consent at any time, where processing is based on consent. The withdrawal of consent shall be as easy as the giving of such consent. Withdrawal will not affect the lawfulness of processing already undertaken before withdrawal and may limit or prevent use of the relevant Service: Section 6(4), DPDP Act.
e) Right to grievance redressal: You may register a complaint with us regarding any act or omission by us or our Data Processors that is in contravention of the provisions of the DPDP Act, and we must respond within the timelines prescribed under the DPDP Rules: Section 13, DPDP Act.
f) Right to nominate: You may nominate another individual to exercise your rights under the DPDP Act in the event of your death or incapacity, in the manner prescribed under the DPDP Rules: Section 14, DPDP Act.
g) Right to approach the Data Protection Board of India: If you are not satisfied with our response to your grievance, you may approach the Data Protection Board of India as established under Section 18 of the DPDP Act.
h) Right to manage your data preferences and withdraw consent at any time. You can: (a) opt-out of marketing emails or newsletters via your account settings or unsubscribe links; (b) adjust push notifications and device permissions (e.g., location, camera, microphone) through your device or in-app settings; and (c) limit advertising identifiers for interest-based ads. Essential transactional communications, security alerts, and legally required notices are necessary for account operation and cannot be opted out of.
You may submit a request by contacting the Grievance Officer / Data Protection Contact listed in the Contact Section of this Policy. We may require information reasonably necessary to verify your identity, account ownership and authority to act. We may decline or limit a request where permitted under Applicable Laws, including where compliance would adversely affect the rights of others, compromise security or fraud-prevention measures, conflict with legal obligations, affect legal claims, require disclosure of confidential information or concern data that has been anonymized or cannot reasonably be linked to you.
Where Consent Managers registered or recognised under the DPDP Act and DPDP Rules are technically available and applicable to a processing activity, you may use such Consent Manager to manage, review, grant, or withdraw consent. SOHOFI will give effect to consent instructions received through a registered Consent Manager in the same manner as direct instructions from you.
16. SENSITIVE PERSONAL INFORMATION AND CHILDREN’S PRIVACY
Sensitive Personal Data or Information (“SPDI”) has the meaning given to that term in the Definitions Section of this Policy. The Platform does not generally process SPDI. Voice recordings, images and documents processed by the Platform for transcription, translation or contextual description are not, by themselves, SPDI or biometric information; they would only fall within SPDI if used for biometric identification or authentication, or if their content otherwise reveals a category of SPDI (such as health or financial information). As the Platform cannot detect or classify such data within your Content, whether to include SPDI is a choice you make when submitting Content, and any such data is processed solely to deliver the requested output, subject to the safeguards described below.
We do not operate a dedicated consent or authorisation mechanism for SPDI. As the Platform cannot detect or classify such data within your Content, it is your responsibility not to upload or submit SPDI unless it is incidental, and necessary for the output you have requested. Any such Content is subject to the general security and confidentiality measures described in this Policy, and is not used for model training on third-party public foundation models or shared with Advertising Partners or Offer Wall providers for advertising or profiling purposes. Where you enable a setting permitting our support personnel to access your account to investigate an issue you have reported, such access will be temporary, limited to the purpose of troubleshooting, logged, and time-bound, and you may disable this setting at any time.
The Platform is intended for individuals who are legally competent to contract under Applicable Laws, including the Indian Contract Act, 1872, and who are at least eighteen (18) years of age or the age of majority in their jurisdiction, whichever is higher, unless a specific Service expressly permits otherwise in compliance with Applicable Laws.
Under Section 2(f) of the Digital Personal Data Protection Act, 2023, a “child” means a person who has not completed eighteen (18) years of age (or such other age as the Central Government may notify). In accordance with Section 9, before processing the Personal Data of a child, we are required to obtain verifiable consent from the parent or lawful guardian of the child, in the manner specified under the DPDP Rules. We will implement age-verification and parental-consent measures as required by applicable law and technically feasible for the feature in question.
We will not process the Personal Data of a child in a manner that is likely to cause any detrimental effect on the well-being of the child. We will not undertake tracking or behavioural monitoring of children or targeted advertising directed at children, as prohibited under Section 9(3) of the DPDP Act.
If we become aware that Personal Data of a child has been collected without the required verifiable parental or guardian consent, we will promptly delete or restrict such Personal Data, subject to any overriding legal obligation to retain it for safety, fraud-prevention or compliance purposes, and will notify the parent or guardian where practicable.
17. EXERCISING RIGHTS
You can exercise privacy rights described in this Policy by submitting a request sohofi@sohofi-global.com. Where available, you may also use an in-account control to request deletion of your shared data directly; such deletion requests may take up to thirty (30) days to complete, cannot be undone once processed, and do not delete or close your account. You may also contact the Grievance Officer / Data Protection Contact listed in the Contact Section of this Policy. For security purposes, we may request additional information from you to verify your identity when you request to exercise rights related to your Personal Data. If we cannot verify your identity, we may not be able to honor your request.
We will acknowledge complaints within the timeline required by Applicable Laws and aim to resolve them within the timelines prescribed under the Digital Personal Data Protection Rules, 2025. Where the DPDP Rules prescribe a specific timeline for responding to requests to exercise rights (such as access, correction, erasure and nomination), we will comply with that timeline. To the extent the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 continue to apply, grievances will also be addressed within the period prescribed thereunder. Our Grievance Officer is appointed in accordance with the requirements of Applicable Laws and is authorised to address grievances relating to processing of your Personal Data.
If you are not satisfied with the resolution of your grievance by the Grievance Officer, you have the right under Section 18 of the Digital Personal Data Protection Act, 2023 to approach the Data Protection Board of India. You may also approach any other competent authority, court or forum available under Applicable Laws, subject to the procedures and timelines prescribed by law. The Data Protection Board of India may be contacted in the manner published on the official website of the Ministry of Electronics and Information Technology (MeitY) from time to time.
18. USER RESPONSIBILITIES
You are responsible for ensuring that Personal Data you provide is accurate, complete and up to date. You must not impersonate another person, submit false or misleading information, suppress material information, raise false or frivolous grievances or complaints, or use the Platform for unlawful surveillance, unauthorized recordings, biometric misuse, illegal data collection, harassment, stalking, doxxing, identity theft, infringement of privacy or publicity rights, or any other prohibited activity under the Terms and Conditions or Applicable Laws.
If you submit, upload, record or process Personal Data relating to another individual, including voice, image, likeness, biometric information, confidential information or sensitive information, you represent that you have provided all notices and obtained all consents, authorizations and legal grounds required under Applicable Laws and the Terms and Conditions.
You agree that your use of the Platform, Content, AI Outputs, Coins, Offer Wall, advertisements and Third-Party Services shall remain subject to the Terms and Conditions, including provisions relating to user undertakings, prohibited conduct, disclaimers, limitation of liability and indemnification, to the maximum extent permitted under Applicable Laws.
19. PROHIBITED AI AND DATA USES
If we believe that Content, AI Outputs, account behavior Offer Wall activity, payment activity or use of the Platform creates legal, security, safety, privacy, reputational, operational or commercial risk, we may restrict processing, refuse to generate outputs, suspend features, withhold rewards, preserve records, report unlawful activity, cooperate with lawful authorities or take other action permitted under the Terms and Conditions and Applicable Laws.
You must not submit Content that includes malware, unlawful instructions, exploit code, phishing content, hate speech, child sexual abuse material, sexually explicit unlawful content, terrorist content, content inciting violence, threats, blackmail, extortion, Personal Data obtained unlawfully, confidential information without authority, or information that you are prohibited from processing under contract, fiduciary duty, employment obligation, law or court order.
You must not use the Platform to create or distribute deepfakes, misleading synthetic media, unlawful impersonations, deceptive audio, fraudulent translations, forged transcripts, misleading descriptions, fabricated evidence, unlawful surveillance material, non-consensual intimate content, exploitative content, infringing content or content intended to mislead courts, regulators, law-enforcement authorities, employers, educational institutions, financial institutions, medical professionals or other persons.
You must not use the Platform or AI Outputs to identify, profile, track, monitor, surveil, target, harass, deceive, defame, impersonate, manipulate or discriminate against any person in violation of Applicable Laws or third-party rights. You must not use the Platform to infer or attempt to infer sensitive attributes, biometric identity, health condition, caste, religion, sexual orientation, financial status, political views, employment status, location, vulnerability or other sensitive characteristics of another person except where expressly lawful and authorized.
20. UPDATE TO THE PRIVACY POLICY
The most current version of this Privacy Policy document will govern our use of your Information/Data and can be found on our Platform (see “Privacy Policy” section). We reserve the right to update this Privacy Policy, at any time. Where an update materially changes the purposes for which Personal Data is processed, the categories of Personal Data collected, the categories of third parties with whom Personal Data is shared, the data retention periods, or your rights and choices, we will make an updated copy of such Privacy Policy available to you and notify you in the manner prescribed under the DPDP Rules before the change takes effect. Where the change affects processing for which your consent was the basis, we will present a fresh consent notice and obtain your renewed consent before processing your Personal Data in that new or changed manner. Changes that do not materially affect your rights or the processing of your Personal Data may be communicated by posting the updated Policy on the Platform. We advise you to review the Privacy Policy at regular intervals. If you do not accept a material change, you may withdraw consent and discontinue use of the affected feature or Service, as described in the Consent Section of this Policy.
21. CONTACT
For any questions, requests or reasonable inquiry related to the protection of your Information/Data at SOHOFI or regarding this Policy in general, you can contact SOHOFI’s Grievance Officer / Data Protection Contact:
Addressed To,
Name / Designation: Sohofi / Data Protection Contact]
Company: Sohofi Global Technologies
Platform: Voice Soul
Address: Flat No. 203, 23/1, J R Makwoods Apartments, Old Mangammanapalya Road,
Popular Colony, Mangammanapalya, Bengaluru, Bengaluru Urban, Karnataka, 560068
E-mail: dpo@sohofi-global.com
Please keep in mind that email communication is not always secure. Therefore, please do not include any Personal Data or Sensitive Personal Data or Information in your emails to us.
We will do our best to address your request in time and free of charge, except where it would require a disproportionate effort or where a fee or limitation is permitted under Applicable Laws. In certain cases, we may ask you to verify your identity before we can act on your request. If you are unsatisfied with the reply received, you may then refer your complaint to the Data Protection Board of India or any other competent regulator, court or forum available under Applicable Laws.
22. GOVERNING LAW AND JURISDICTION
This Policy, and any dispute, claim, controversy or proceeding arising out of or relating to this Policy, the Platform, Services, Coins, subscriptions, AI Outputs, advertisements, Third-Party Services or any relationship between you and the Company, shall be governed by and construed in accordance with the laws of India, without regard to conflict-of-law principles.
Subject to any non-waivable statutory remedy, consumer forum remedy or regulatory remedy available under Applicable Laws, disputes relating to this Policy shall be subject to the jurisdiction provisions set out in the Terms and Conditions, including the exclusive jurisdiction of the courts and tribunals at Bangalore, Karnataka, India.