Privacy Policy for Zivazi — India

Effective Date 03-Sep-2026
1. Introduction
Suntech Software Solutions Ltd ("Zivazi", "we", "us", or "our") operates the Zivazi dating and social connection application ("App" or "Service").
We respect your privacy and are committed to handling your personal data responsibly.
This Privacy Policy explains:
This Privacy Policy applies to users who access or use Zivazi in India.
By using Zivazi, you acknowledge that you have read this Privacy Policy.
Where applicable law requires consent for a particular processing activity, we will seek that consent in the manner required by law.
2. Data Controller / Data Fiduciary
For purposes of applicable Indian data-protection law, including the Digital Personal Data Protection Act, 2023 ("DPDP Act"), Suntech Software Solutions Ltd is responsible for determining the purposes for which and the manner in which your personal data is processed in connection with Zivazi.
Zivazi is provided in India by Suntech Software Solutions Ltd, a company incorporated in the United Kingdom. Zivazi does not currently have a separate establishment or group company in India. Suntech Software Solutions Ltd is the Data Fiduciary for users in India and is responsible for compliance with applicable Indian law, including the DPDP Act and the Information Technology Act, 2000 and the rules made under it.
Where applicable law requires us to appoint or identify a Data Protection Officer, Grievance Officer or other responsible person, the relevant details will be made available through the App or website.
3. Personal Data We Collect
We collect personal data that is necessary to provide, secure and improve Zivazi.
The information we collect may include the following.
3.1 Account Information
When you create an account, we may collect:
A full name is not currently required where the App allows you to use the Service without providing one.
3.2 Profile Information
You may provide information for your dating profile, including:
Some profile information is optional.
Gender and gender preference may be required because they are used to provide matching functionality.
3.3 Age Information
Zivazi is an adults-only service. When you register, you provide your date of birth, which must indicate that you are at least 18 years old.
Age is self-declared. Zivazi does not currently require users in India to submit an identity document or a verification photograph (such as a selfie), and does not carry out identity or age verification or a criminal background check.
Age verification is not mandatory in India and is not currently enforced by Zivazi. We may introduce an identity or age-verification step in the future. If we do, we will update this Privacy Policy and provide any information required before that processing begins.
Additional information is provided in our Age Eligibility Notice.
3.4 Location Information
Zivazi uses location information to provide location-based matching and search functionality.
Depending on your device permissions and settings, we may receive geographic location information, including latitude and longitude.
We may use this information to determine your approximate location or city for matching purposes.
If you do not wish to provide device-based location information, the App may allow you to select a predefined city or location instead.
Your precise location is not intended to be publicly displayed to other users merely because location functionality is enabled.
3.5 Communications
We may process information associated with communications through Zivazi, including:
Zivazi currently provides one-to-one video calls using WebRTC technology.
Zivazi does not currently record or store the content of video calls.
3.6 User Reports and Safety Information
When a user reports another user, we may collect and process information associated with the report, including:
Reports are currently reviewed manually.
3.7 Device and Technical Information
We may automatically collect technical information such as:
3.8 Purchase Information
If you purchase premium features, the purchase is processed through the applicable app-store provider.
This may include:
We may receive information necessary to confirm and administer your purchase, such as transaction identifiers, product purchased, purchase status and entitlement information.
We do not generally receive or store the complete payment-card details processed by the applicable app store.
3.9 Advertising Information
Zivazi uses, or may in future use, Google AdMob to display advertisements in certain circumstances. Advertising may not be present in every release of the App.
AdMob and related technologies may process technical information associated with your device and use of the App.
We currently intend to use non-personalised advertising rather than using your Zivazi dating profile information to create a personalised advertising profile for our own advertising purposes.
Third-party advertising services may nevertheless process information under their own terms, technologies and applicable privacy requirements.
4. How We Use Personal Data
We may use your personal data for the following purposes.
4.1 Providing the Service
We use personal data to:
4.2 Matching
We use information such as:to provide algorithmic matching and search functionality.
The detailed logic, weighting and technical implementation of our matching algorithm are confidential and may constitute trade secrets. We therefore do not disclose the detailed operation of the matching system.
4.3 Safety and Integrity
We use account, profile, device and report-related information to:
4.4 Communications
We process communication information to enable:
4.5 Security and Fraud Prevention
We may process personal data to:
4.6 Purchases
We use purchase-related information to:
4.7 Communications and Marketing
We may send essential communications relating to your account and use of Zivazi.
We may also send promotional communications, such as information about new features, improvements, activity or opportunities to return to the Service, where permitted by applicable law and subject to applicable choices or consent requirements.
You may be able to control certain communications through the App or by using the unsubscribe mechanism provided in the communication.
5. Purposes, Personal Data and Legal Grounds
Under the DPDP Act, we process personal data on the basis of your consent, or on the basis of certain legitimate uses permitted by the Act, or as otherwise required or permitted by law. The DPDP Act does not provide a general "performance of a contract" ground; where processing is necessary to provide a feature you have asked for, we rely on the consent you give when you register or when you choose to use that feature.
The following sets out, for each purpose, the main categories of personal data used and the legal ground we rely on.
Consent requests are presented in clear and understandable language and identify the relevant personal data and the purpose of processing. The DPDP Act requires consent to be free, specific, informed, unconditional and unambiguous, given by a clear affirmative action, and to be capable of withdrawal with comparable ease.
You can withdraw consent as described in Section 17 (Withdrawal of Consent), and you can raise a grievance or complain to the Data Protection Board of India as described in Section 18 (Grievance Redressal).
6. Your Profile and Information Visible to Other Users
Zivazi is a dating application and certain profile information is intended to be visible to other users.
Depending on your profile and privacy settings, other users may be able to see information such as:
Your gender is displayed as either Male or Female.
Your gender preference — the gender you wish to be matched with — is used for matching. It is not shown on your public profile.
You should consider carefully what information you choose to include in your profile.
7. Granular Access Controls
Zivazi provides users with granular controls over access to certain resources.
These resources currently include:
A user may configure a resource as:
7.1 Anyone
Where a resource is set to Anyone, eligible users may access that resource according to the functionality of the App.
7.2 Connected Only
Where a resource is set to Connected Only, another user must first establish a connection with the profile owner.
The profile owner can accept or reject a connection request.
The profile owner can subsequently change the connection or access settings.
7.3 Controlled Access
Controlled Access is currently available only to women.
This feature is intended as an additional safety and privacy measure, particularly for users who want greater control over who can access their private interactions.
A woman may require individual users to request access to particular resources.
For example, she may approve:
Individual permissions can subsequently be changed or revoked.
8. Sharing Personal Data
We may disclose or make personal data available in the following circumstances.
8.1 Other Users
Information that you choose to make available through your profile or access settings may be visible to other users.
The amount of information available to another user depends on:
8.2 Service Providers
We use third-party service providers to operate Zivazi.
These may include providers for:
Our current infrastructure includes Amazon Web Services (AWS), including S3 storage and CloudFront content delivery, and, where advertising is enabled, Google AdMob for advertising.
We require service providers to process personal data in accordance with applicable contractual and legal requirements.
8.3 App Stores
Apple and Google process information associated with purchases made through their respective app stores.
Their own privacy policies and terms may also apply.
8.4 Legal and Regulatory Requirements
We may disclose personal data where reasonably necessary to:
8.5 Business Transfers
If Zivazi or substantially all of its assets are involved in a merger, acquisition, restructuring, financing, sale or similar transaction, personal data may be transferred as part of that transaction, subject to applicable law.
9. International Data Transfers
Zivazi is operated by a UK company and may use infrastructure and service providers located in countries outside India.
Your personal data may therefore be processed or stored outside India.
For example, Zivazi currently uses AWS infrastructure and other third-party services that may involve international processing.
Where applicable Indian law imposes requirements concerning international transfers or access to personal data, we will comply with those requirements.
We will take appropriate steps to protect personal data when it is processed by our service providers.
10. Data Retention
We retain personal data only for as long as reasonably necessary for the purposes described in this Privacy Policy, subject to applicable legal requirements.
10.1 Account Information
We generally retain account information while your account remains active.
If you delete your account, your account may initially be marked as deleted or deactivated while deletion processes are carried out.
10.2 Reports and Safety Information
Information relating to user reports may be retained for as long as reasonably necessary to:
10.3 Deleted Accounts
Deletion of an account does not necessarily mean that every copy of information is immediately removed from every backup, security system, legal record or other system.
Where information must be retained for a lawful purpose, we may retain it for the period reasonably necessary for that purpose.
We will not retain personal data indefinitely without a lawful reason.
11. Security
We use appropriate technical and organisational measures designed to protect personal data against unauthorised access, loss, misuse, alteration or disclosure.
Our security measures may include:
We maintain a documented information-security programme and apply organisational and technical safeguards that are proportionate to the personal data we hold, consistent with the security requirements of applicable Indian law.
No internet-based system can be guaranteed to be completely secure.
If a personal-data breach occurs, we will notify the Data Protection Board of India and each affected Data Principal in the form and manner required by the DPDP Act and its rules. This obligation is not subject to a harm or risk threshold. We will also take reasonable steps to identify the cause, contain the breach and prevent recurrence.
12. Children's Privacy
Zivazi is strictly intended for adults aged 18 and over. To register, you must provide a date of birth indicating that you are at least 18 years old.
Under the DPDP Act, a person under the age of 18 is a child. Zivazi is not directed at children. We do not knowingly collect or process the personal data of anyone under 18, and we do not direct advertising, tracking or behavioural monitoring at children.
We do not knowingly permit individuals under 18 to use the Service.
If we become aware that a user is under 18, we will stop processing their personal data for the Service, and will restrict or terminate the account and delete the associated personal data, except where limited retention is required or permitted by applicable law.
13. Cookies and Similar Technologies
Because Zivazi is primarily an application, certain technologies may operate through the App rather than traditional browser cookies.
We may use technologies such as:
These technologies may be used to:
Further information is provided in our Cookie, Analytics and Advertising Notice.
14. Advertising
Zivazi uses, or may in future use, Google AdMob.
We currently intend to display non-personalised advertisements rather than use your dating profile information to personally target advertisements ourselves.
However, advertising providers may collect or process technical information from the device or App in accordance with their own technology and policies.
Advertising arrangements may change in the future.
If we materially change how personal data is used for advertising, we will update this Privacy Policy and obtain consent where required by applicable law.
15. Your Privacy Rights
Subject to applicable law, you may have rights relating to your personal data.
These may include rights to:
The scope and availability of particular rights may depend on the DPDP Act, applicable rules and other applicable law.
The DPDP Act provides Data Principals with rights including access to information about personal data, correction and erasure, grievance redressal and nomination, subject to the statutory framework.
16. How to Exercise Your Rights
To make a privacy request, contact:
When making a request, please provide enough information for us to identify your account and understand your request.
For security reasons, we may need to verify your identity before processing certain requests.
We will respond within the timeframe required by applicable law.
Where a request cannot be fulfilled, we will explain the reason where legally required or appropriate.
17. Withdrawal of Consent
Most of the personal data we process is processed on the basis of your consent. You can withdraw consent as follows:
To withdraw consent, contact support@zivazi.com. Further detail is in our Data Protection Rights & Privacy Request Procedure.
Withdrawal does not affect the lawfulness of processing carried out before withdrawal. We will give effect to a withdrawal within a reasonable time and stop the relevant processing unless we are required or permitted by law to continue.
18. Grievance Redressal
If you have a privacy complaint or concern, you should first contact:
We will review and respond to grievances in accordance with applicable law.
Where Indian law requires Zivazi to designate and publish the details of a Grievance Officer or other responsible person, those details will be provided through the App and/or website.
If you remain dissatisfied after using our internal grievance process, you may have the right to complain to the Data Protection Board of India, or to approach another applicable regulatory or statutory authority, subject to applicable law.
19. User Safety and Privacy
Dating services involve interactions between individuals who may initially be strangers.
You should therefore take reasonable precautions when sharing personal information.
We recommend that users:
Zivazi's access-control features are intended to give users additional control over access to certain resources, but they cannot prevent another person from independently copying information that they can legitimately view.
20. Video Calls and Recording
Zivazi currently provides one-to-one video calls using WebRTC.
Zivazi does not currently record video-call content.
However, Zivazi cannot guarantee that another participant will not:
Users must respect the privacy and rights of other participants and must not record, reproduce or distribute private interactions without appropriate consent or where otherwise prohibited by applicable law.
21. Changes to This Privacy Policy
We may update this Privacy Policy from time to time.
When we make material changes, we may notify users through:
The "Effective Date" at the beginning of this Privacy Policy will be updated when a new version becomes effective.
We encourage you to review the Privacy Policy periodically.
22. Third-Party Services
Zivazi relies on third-party services to provide parts of the Service.
These may include:
Third-party services may process information according to their own terms and privacy policies.
We recommend that you review the relevant third-party privacy policies where appropriate.
23. Contact Us
For privacy questions, requests or concerns, contact:
24. Effective Date
This Privacy Policy is effective from: