Privacy Notice

1. What is 2 Shabd?

2 Shabd is a platform to manage your public image with verified reviews and aura. Our website, Android and iOS applications (collectively, the "Platform") provide information about us and allow individuals to sign-up and use 2 Shabd services.

The profile that 2 Shabd Users are able to create is referred to in this Privacy Notice as "User profile". User profiles are by default not accessible to the public.

We are headquartered in Pune, India. For more information about the 2 Shabd journey, please see the "About" section of our Website.

2. How does this Privacy Notice apply to me?

This Privacy Notice only applies to personal information we collect as a controller from:

• individuals, or representatives of individuals that sign up to use our 2 Shabd services - our "2 Shabd Users";
• individuals that visit and interact with User profiles ("Profile Visitors");
• individuals who respond to our surveys, marketing materials or participate in trade promotions or competitions that we may run from time to time.

This Privacy Notice applies to the processing of personal information by 2 Shabd as a controller. When we talk about 2 Shabd acting as a "controller", we mean that 2 Shabd determines the purpose and means of processing your personal information.

If you provide us with information about another person, you must provide them with a copy of this Privacy Notice and let that person know that we use their personal information in the ways set out in this Privacy Notice.

3. What personal information do we collect?

The personal information that we may collect about you broadly falls into the following categories:

• Information you provide voluntarily: When you sign up to become a 2 Shabd User, use or interact with our services, visit our Platform, respond to a survey, or contact us, we may ask you to provide information such as your name, username, email address, profile information, and communication preferences.
• Information collected automatically: When you use our Platform, certain technical information may be collected automatically from your device or browser. This may include IP address, browser type, device type, operating system, app version, referral URLs, pages viewed, timestamps, and basic usage activity.
  
  For Android and iOS app users, the app may also collect device-related information necessary for security, authentication, app functionality, and performance monitoring.
  
  One of the primary activity records we maintain is profile visit information so users can see who visited their profile under the "Visitors" section.
  
  We currently do not collect diagnostic or crash-related information. Altough, app crash data may be collected by Google Play Services automatically per Google's own privacy policy.
  
  We may undertake automated scanning of user profiles or reviews to determine whether content violates our Terms of Service or Community Standards.
• Device & App Data (Android & iOS): When you use our Android or iOS application, we may automatically collect:
  
  • Device type
  • Unique device identifiers necessary for app functionality
  • App version and session information
  • Other users' profile visit information (if you visit other profiles)
  
  • Your Reactions on a review (if you react to a review)
  
  • We do not collect location data, contacts, SMS, call logs, or other sensitive information.
  
  This data is used solely to ensure app stability, security, and to improve the user experience. We do not use this data for advertising or share it with third-party ad networks.
• Permissions and device access: The Android or iOS application may request certain permissions depending on the features you use. These permissions are only used for Platform functionality.
  
  Examples may include:
  
  • Internet access – required for communication with our servers.
  • Camera or media access (if enabled in future features) – required for uploading profile images or content.
  • Notification permission (if enabled) – required for sending activity notifications or updates.
  
  We do not request SMS, Call Log, or other high-risk permissions. We only request permissions necessary for operation of the Platform.
• Third-party services: Our Platform may rely on third-party infrastructure or service providers for hosting, security, analytics, authentication, notifications, content delivery, or app functionality.
  
  These providers may process limited technical information necessary to provide their services.
  
  The Android or iOS application may also interact with Google Play Services/Apple Services or Android/iOS system components necessary for app delivery, security, notifications, or performance.
• Children's data: Our services are not intended for children. If you are under 18, please do not use the Platform or provide personal information.
  
  If we become aware that personal information from a child under 18 has been collected, we will take reasonable steps to delete such data promptly. Parents or guardians may contact us at support@2shabd.com to request removal of a minor's data.

4. Why do we collect your personal information?

We may use your information for the following purposes:

• To provide, maintain, and improve the 2 Shabd Platform and services.
• To provide customer support and respond to requests or complaints.
• To monitor Platform usage and detect, prevent, or resolve technical issues.
• To verify identity and prevent fraud, abuse, or unauthorized access.

We do not sell personal data. Information collected is primarily used for Platform functionality, account management, security, fraud prevention, and improving user experience.

5. Legal basis for processing personal information

We process personal information with your consent, to provide requested services, comply with legal obligations, protect Platform security, and pursue legitimate interests related to operating and improving the Platform.

6. Who may we disclose your personal information to?

We do not sell your personal information to third parties.

We may share limited information with trusted infrastructure providers or service providers strictly for purposes such as hosting, analytics, security, notifications, customer support, app functionality, or legal compliance.

We may also disclose information if required by law, legal process, regulation, or to protect the rights, security, safety, or integrity of the Platform and its users.

7. Disclosure of personal information to other countries

Your data is stored on servers located in India. We do not transfer your personal data internationally.

We take reasonable measures to ensure appropriate protection of personal information wherever it is processed.

8. Cookies and PHP Session Technologies

Our website uses essential session technologies, including PHP session-based functionality, to support sign-in, authentication, account security, and continuity between requests. These technologies help the website recognize your active session and provide features you request.

Session cookies are not intended for advertising or cross-site tracking. We currently do not use tracking, advertising, or third-party analytics cookies on the website, as described in this Notice. Certain embedded or app-based components may use equivalent technologies needed for authentication or core functionality.

Because these cookies and session technologies support core account functionality, disabling or blocking them in your browser may prevent you from signing in or using certain features. You can manage cookies through your browser settings; however, deleting or blocking essential session cookies may end your session or require you to sign in again. We recommend configuring session cookies with appropriate security settings, such as secure transmission over HTTPS and protections against script access, where supported by the website configuration.

For more information about the personal data associated with your account session, please see the sections on data collection, security, and retention in this Privacy Notice.

9. How long do we retain your personal information?

We retain personal information for as long as necessary to provide the Platform and fulfill legal, operational, security, and dispute-resolution obligations.

When you delete your account, we will take reasonable steps to delete or anonymize your information within 30 days, unless retention is required by law or for legitimate security purposes.

10. How can I delete my account and all of its data?

You can delete your account and all associated data through any of the following methods:

• In-app or on website: Go to your Account page, scroll down to the "Delete Account" section, and click the "Delete" button.

• By email: Send a deletion request to support@2shabd.com from your registered email address.

All personal data will be permanently deleted within 30 days of your request.

11. How do we secure your personal information?

We implement reasonable technical and organizational safeguards designed to protect personal information from unauthorized access, disclosure, misuse, alteration, or destruction.

Access to personal information is limited to authorized personnel and service providers who require access to operate the Platform.

While we strive to use commercially acceptable means to protect personal information, no method of transmission or storage is completely secure. We will notify affected users and applicable regulators of any data breach where legally required to do so.

Data transmitted between the app, website, and our servers is protected using industry-standard encryption technologies where applicable.

12. What are your rights in relation to personal information?

You may access, correct, update, or delete your personal information through your account settings where available.

Depending on applicable laws, you may also have rights to:

• Request deletion of your personal information.
• Restrict or object to certain processing activities.
• Withdraw consent where processing is based on consent.
• Opt out of marketing communications by clicking "unsubscribe" in any marketing email or by contacting support@2shabd.com.

Requests related to personal information may be sent to support@2shabd.com. We respond to all requests in accordance with applicable data protection laws.

13. Complaints

If you have concerns regarding our handling of personal information, you may contact us using the details provided below.

We will review complaints and respond within a reasonable timeframe. If we are unable to resolve your complaint to your satisfaction, you may contact the local privacy and data protection authorities in your jurisdiction.

14. Android and iOS App — Additional Disclosures

For users accessing 2 Shabd via our Android or iOS application, the following additional disclosures apply:

• Ads: Our app does not contain any third-party advertisements, ad SDKs, banner ads, interstitial ads, or native ads.
• Permissions: We do not request SMS, Call Log, location, contacts, or other high-risk permissions. Only permissions essential to core app functionality are requested.
• Target audience: The app is intended for users aged 18 and above. It is not directed at children.
• Data safety: All data handling described in this Privacy Notice applies equally to the Android and iOS apps. We do not sell user data or share it with advertising partners.
• Google Play Services (only for Android app): The app may interact with Google Play Services for delivery, security, and performance. Google's own privacy policy governs data collected by Google Play Services.
• Account deletion: Users can permanently delete their account and all associated data via the Account page in-app or by emailing support@2shabd.com.

15. 2 Shabd Safety Standards

2 Shabd has zero tolerance for child sexual abuse, exploitation, or any form of child sexual abuse material (CSAM). Users are prohibited from uploading, sharing, promoting, or engaging in any content or behavior involving:

• Child sexual abuse material (CSAM)
• Sexual exploitation of minors
• Grooming or predatory behavior
• Human trafficking or abusive exploitation
• Any illegal sexual content involving minors

We reserve the right to remove content, suspend accounts, and report unlawful activity to appropriate authorities where required by law.

Users may report content or accounts that violate these standards by contacting support@2shabd.com.

2 Shabd is intended for users aged 18 and above.

16. Compliance with the Digital Personal Data Protection (DPDP) Act, 2023

2 Shabd processes personal data in accordance with applicable provisions of the Digital Personal Data Protection Act, 2023 ("DPDP Act"), and applicable rules. This section specifically applies to reviews and observations voluntarily submitted by you for your own Behavioral Competency Report (BCR) or for the BCR of another user.

16.1 Personal Data We Collect

In connection with semester group activities and behavioral assessments, we may collect and process the following personal data, as applicable:

• Identity and account information, including your name, college roll or identification number, email address, and semester or course details.
• Written reviews and behavioral observations submitted by you, your assigned peers, or your supervisor during group activities, including descriptions of observed actions and behavior.
• Activity evidence, including photographs, video links, project reports, and other supporting materials submitted to verify group activity completion.
• Behavioral competency assessment data, including standardized ratings across predefined behavioral competencies assessed through the applicable review process.

16.2 Purpose of Processing

We process the above personal data for the following specific purposes:

• To prepare your confidential Behavioral Competency Report (BCR) for the relevant semester using reviews and observations submitted for your assessment.
• To verify group activity completion through submitted evidence and supervisor verification.
• To enable authorized psychologists to review and interpret written observations and map them to standardized behavioral competency levels.

Reviews are intended to record observable behavior rather than merely confirm task completion. You should submit reviews honestly, responsibly, and only for the stated assessment purposes.

16.3 Confidentiality and Control Over Your BCR

Your BCR is intended for your personal access and remains confidential within your 2 Shabd account, subject to applicable law and this Privacy Notice. We do not sell your personal data or use it for targeted advertising. We do not share your BCR with your college, parents, or external recruiters without your explicit authorization for the relevant disclosure, except where disclosure is required or permitted by applicable law.

Sharing your BCR for placements, interviews, or other purposes is voluntary. Where available, you may choose to generate a report-sharing link or withhold your report from prospective recruiters.

16.4 Your Rights Under the DPDP Act, 2023

Subject to applicable law, you may exercise the rights available to you as a Data Principal, including:

• Right to Access Information: Request information about the personal data processed by us and access the information available to you under applicable law.
• Right to Correction and Erasure: Request correction or completion of inaccurate or incomplete personal data and erasure of personal data where applicable, subject to legal retention requirements and other lawful grounds for continued processing.
• Control Over Your BCR: Where the relevant features are available, you may manage which eligible reviews are included in your BCR.
• Right to Grievance Redressal: Raise a privacy-related concern or grievance with our designated Grievance Officer using the contact details provided below.

Important Note on Peer Reviews: If you delete a review that you submitted for another user, it will be removed from that user's peer-review profile, where applicable. However, if the review has already been incorporated into that user's BCR, the review or the assessment derived from it may remain in the BCR, subject to applicable law and our retention obligations. Deleting a submitted review does not automatically require the deletion or revision of a report that has already been generated.

16.5 Data Storage and Authorized Access

We implement appropriate technical and organizational safeguards to protect personal data against unauthorized access, disclosure, alteration, or loss. Personal data, observations, and uploaded activity evidence are stored on cloud infrastructure located in India, as applicable to our service arrangements.

Authorized psychologists may access relevant reviews through a secured dashboard for assessment purposes. Access is restricted through appropriate security controls, including restrictions on downloading or exporting review data, where implemented.

Activity evidence is used for verification purposes and will be deleted upon a valid request or account deletion, as applicable, subject to technical limitations and any retention required or permitted by applicable law.

16.6 Grievances and Contact

If you have questions about the processing of your personal data, wish to exercise your rights, or wish to raise a grievance under the DPDP Act, 2023, you may contact our designated Grievance Officer using the following details:

• Grievance Officer: Vivek Kumar
• Email: vivek@2shabd.com
• Grievance Handling: We aim to acknowledge queries within 24 hours and resolve grievances within 7 business days, subject to the nature and complexity of the matter.

If your grievance remains unresolved, you may approach the Data Protection Board of India or other competent authority, as applicable under the DPDP Act and the rules in force.

17. Behavioral Competency Reports (BCRs) and Review Visibility

2 Shabd processes reviews and observations submitted for a Behavioral Competency Report (BCR) to support the assessment of observed behaviors and competencies. Reviews submitted for BCR consideration may be examined by an authorized psychologist, who determines whether the observations are suitable for interpretation and inclusion. The review limits, reviewer eligibility, and submission requirements are described in our Terms of Use and Review Writing Guidelines.

17.1 Visibility of Approved Reviews

If a review submitted for BCR consideration is approved and incorporated into the assessment process, the original review may be displayed on home pages of users belonging to the relevant user's college, regardless of the visibility setting originally assigned to that review. When someone visits the user's profile directly, the review's assigned profile visibility setting continues to apply, subject to the Platform's functionality.

This limited home-page visibility exception is intended to encourage accountable, evidence-based observations and discourage collusion, reciprocal review arrangements, and the halo effect. Please do not submit a review for BCR consideration if you are unwilling for the approved source review to be displayed to users within the relevant college community under this rule. This exception applies to the source review; it does not make the interpreted BCR publicly available.

17.2 Confidentiality of the BCR

The interpreted observations and competency assessments compiled into a BCR are intended to remain confidential and available to the report subject through their account, subject to applicable law and the terms of this Privacy Notice. Displaying an approved source review on college users' home pages does not, by itself, grant those users access to the BCR. Sharing a BCR remains subject to the applicable authorization and privacy requirements described in this Notice.

17.3 Review Deletion and Derived Assessments

If you request deletion of a review you submitted for another user, we will handle the request in accordance with applicable law, our retention obligations, and the operation of the service. Removing a source review from a profile does not necessarily mean that an assessment or report already derived from that review will automatically be deleted or recalculated. Where applicable, you may contact us to exercise your data rights or raise a grievance as described in this Privacy Notice.

For practical information about the observation format and the supervisor role, see the Review Writing Guidelines and Supervisor Policy.

18. Changes to This Privacy Notice

We may update this Privacy Notice from time to time in response to legal, technical, or operational changes.

Your continued use of the Platform after updates become effective constitutes acceptance of the revised Privacy Notice.

The "Last Updated" date at the top indicates when this Notice was last revised.

19. Contact

If you have questions about this Privacy Notice or our privacy practices, please contact us:

• By email: support@2shabd.com
• By visiting: 2shabd.com/contact
• By post at Jaglen Platforms Private Limited, 204, Sapphire Chambers, First Floor, Suite #1075, Baner Gaon, Pune, Maharashtra, India, 411045.

2 Shabd

Jaglen Platforms Private Limited