Privacy Policy


BAK digital media Inc (“we”/ “our” /“us”) is a limited liability company & is subsidiary of Red tortoise digital media Private Limited registered under companies act 2013 and having its office at 360 1st main jakkasandara koramangala Bangalore 560034

We understands that when our customers (“you”/“your”/“User”) access our website and mobile application “Flintzy Mobile” (“Platform”) and/or utilise “Platform Service” (hereinafter defined), they instil certain trust in us. We aspire to keep the trust intact. So, we have designed this Privacy Policy (“Policy”) to help you understand what data we collect, why we collect data, how we collect and what rights do you have with respect to your data.


  1. Consent” shall mean acceptance of terms contained in this Policy provided by you freely, without any undue influence or coercion.
  2. Data” shall mean the information concerning you which is subjected to processing as per this Policy.
  3. Platform Services shall mean service of channeling up the viewership of content provided by you.
  4. Process/Processing shall mean operation or set of operation which is performed on the personal Data such as collecting, recording, organising, structuring, storing, transmitting or otherwise dealing in any other manner with the Data.


  1. We may Process certain personally identifiable Data such as your name, age, gender, contact information, logged in user name on the device, internet protocol (IP) address, and such other information that you have provided to us while accessing the Platform/Platform Service.
  2. We may Process certain Data about your activity on the Platform such as the product that you search for, content you upload, the services you purchase, the pages that you visit, how you respond to offers, the links that you click, the number of times you access the page and any other such browsing information.
  3. The financial transaction such as payment of fees, undertaken by you on the Platform takes place through a third party gateway and service providers. All such financial Data passes on to such third party gateways and service providers and we do not undertake Processing of such Data in any manner. However, we may Process information pertaining to invoices, bills, receipt of payment and so on, as a part of accounting information and legal mandate.
  4. We may Process certain Data about the device through which you access the Platform such as device type and setting, mobile network information, phone number, application version number and browser type and setting. Further, depending upon your device and account setting, we may Process certain locational information such as address where you upload the content, internet protocol (IP) address and the location at which you access the Platform/ Platform Service.
  5. We may Process Data that you provide us when you interact with us such as while seeking clarification, raising any query, posting review and/or filing any grievance.
  6. We may even Process certain non – personalised Data in the form of aggregated personal Data such as statistics on the pattern of usage, views and opinion on the product or any part of the Platform Service.
  7. We may Process certain Data that will assist us in profiling so as to evaluate, analyse and/or predict your behaviour, personal preferences, interests, reliability and behaviour.
  8. We may Process certain Data about the links, clicks, pages or sites visited by you or any other Data that shall help us determine your usage, behaviour and/or interest.
  9. If you access our Platform/Platform Service through any third party website, link, advertisement, then we may collect Data about such website, link or advertisement which will help us understand your taste, habits or preferences. We may even collect Data which you have permitted to be kept open for public access at such a website, link or advertisement.
  10. We may even any Process Data in compliance with any legal mandate imposed upon us. Subject to the law applicable to you, we may Process Data in accordance with the data impact assessment report.


The Data we Process helps us:

  1. understand and predict your requirement and thereby help us to provide you with a better user interface experience by customising the Platform Service and personalising the content on the Platform Service.
  2. understand the issues with the Platform and/or Platform Service and thereby troubleshooting the issues, tracking outages and so on.
  3. analysing the usage trends and preferences, so as to improve the Platform/Platform Services and to develop new product, feature or functionality.
  4. communicate to you about the particulars of your account, thereby helping us to protect and manage the account created by you at the Platform.
  5. render you with relevant advertisement, content and thereby enhance your user experience.
  6. understand the market demand and preference.
  7. comply with any legislative, regulatory, administrative, or judicial or quasi - judicial mandate, to detect and prevent any illegal activities.

In addition to the above, we share Data to effectively provide Platform Services or respond to your customer support request.


  1. When you open an account with us, you are required to furnish certain personal Data. We may Process all or any such Data provided by you at the time of opening an account with us. We may collect Data when you access, utilise or interact with the Platform and/or Platform Service.
  2. When you interact with us through any of your social media account, we may collect Data about you through that particular social media account. The exact nature of the Data that we Process through such a social media account depends on your social media account privacy setting.
  3. We may Process Data through cookies, web beacons, log files, and other such tracking technology.
  4. We may Process Data from third party service providers, advertising partners, through any of Our subsidiaries, partner, associates or affiliates.


  1. We may utilise cookies and other tracking technologies (collectively referred to as “Cookie”) to Process Data. Cookies are small pieces of text sent to your browser by the Platform.
  2. In particular, We may use the following Cookie:-
    1. Strictly necessary cookie: The presence of these cookies is very essential for proper functioning of certain features and functionality on the Platform/Platform Service. These cookies, amongst other things, help us to prevent fraudulent activity.
    2. Performance cookie and analytics technology: We may use these cookies to analyse the performance of certain features of the Platform/Platform Service. For instance, the functionality which is most popular amongst the users. Such cookies help Us improve the content and thereby enhance the quality of Platform Service.
    3. Process cookie: We may use a process cookie to help us understand what you expect, such as navigating around the Platform or accessing secure areas of the Platform.
    4. Web beacons and parameter tracking: Web beacons help us track the number of users who visit Platform through advertisements placed by us on third party websites. Such cookies help us understand the effectiveness of an advertisement campaign.
    5. Log files: We may collect Data through log files. The Data collected through log files may include internet protocol (IP) address, browser type, internet service provider (ISP) name, number of clicks and so on.
    6. Targeting and advertising cookie: The targeting and advertising cookie helps us deliver to you pertinent and relevant advertisement. Such targeting and advertising cookie are usually placed by advertising networks. The functioning of such cookies is beyond the scope of this Policy.
    7. Third party cookie: When you access Platform and/or utilise Platform Service, you may receive a certain third party cookie onto your device. Such third party cookies are placed by third parties. The presence and/or functioning of such cookies are not covered by this Policy.
    8. Google analytics cookie: Google analytics cookie may analyse how you may use the Platform/ Platform Service. Google may deal with such Data in a manner that they deem appropriate and in accordance with their privacy policy. Any Data collected by Google through Google analytics cookie is not covered by this Policy and we recommend you to read and understand Google's privacy policy to completely understand your rights in this regard.
  3. Your Consent to this Policy unequivocally renders Us with the right to Process Data through cookies.
  4. You have an option to opt – out of the cookie service by undertaking appropriate changes to the setting. In the event You exercise such an option, you may notice certain shortcomings in the Platform/Platform Service. You agree that we cannot be held responsible, in any manner, for such shortcomings.


  1. We may permit third parties to place their content and serve you advertisement. We do not have any control over the content and/or advertisement served by such third parties. We encourage you to learn about the Privacy Policy of such third parties prior to placing any reliance upon it.
  2. We disclaim any responsibility for your reliance upon the content and/or advertisement placed by third parties on the Platform.


  1. The Data that we Process may be disclosed to our employees, officers, agents, directors, agent, consultants or affiliates to serve you with the Platform Services effectively and efficiently.
  2. We may disclose Data to third party advertisement service providers or other entities for their digital media marketing purpose such as e-commerce marketing, search engine optimization, content marketing, email direct marketing and so on.
  3. We may disclose Data to third party service providers that assist in providing Platform Service or any part of such service and so on.
  4. We may disclose Data where such disclosure is warranted by a legal mandate or to protect the safety of a person, to address fraud or resolve a technical or security issue.
  5. We may disclose Data to third party service providers who provide Processing service to us or to the third parties that Process personal Data for the purpose described in this Policy.
  6. We may disclose Data to a potential or prospective investor in connection with any proposed or actual purchase, merger or acquisition of our business.


We may transfer the Data to a country other than the country in which you reside or whose laws you may be subjected.

When we transfer the Data to such third countries, it is important for you to understand that the Data may be subjected to the data protection law of that country. However, while transferring the Data we assure you that we extend appropriate safeguards to the Data in accordance with the standard laid down by us in this Policy.


We are committed to protecting your Data from any breach or unauthorized access. We have placed adequate security measures to protect Your Data from unauthorised access. Pursuant to our commitment, we employ industry accepted technology while Processing the Data. We use encryption to keep the Data secured while in transit and have also employed a firewall and appropriate intrusion detection system. We regularly review the Processing process, to prevent unauthorised access to the Data. Despite having placed adequate security measures, due to rapid development of technology we cannot absolutely elevate risk to the Data. So, we cannot be held responsible or liable for any breach or unauthorised access of the Data.


  1. Although we have endeavoured to place adequate security measures to the Data, there are certain precautionary measures that can be exercised by you to further protect the Data. We advise you to access your account with us in a safe and secured environment and refrain from accessing your account on a public network.
  2. We advise you to refrain from disclosing any of your account credentials like user id, password, OTP and so on with any third party.
  3. We advise you to refrain from doing any act that makes your device susceptible to spyware, viruses, key logging and so on. If you suspect or strongly form an opinion that your device is susceptible to any such spyware, viruses, key logging and so on, then we advise you to refrain from accessing your account with us through such a device.
  4. If despite exercising all precautionary measures, you suspect any unauthorised access to your account then you are obligated to immediately notify us, so that we can take appropriate measures to safeguard your account.


The Data may be retained for such a period of time as is essential to fulfil the purpose for which Data is collected as per the Policy. Upon fulfilment of such purpose, we may either delete the Data, run it through a pseudonymisation process or otherwise deal with the Data in a manner that we think is appropriate and beneficial to your interest.


Subject to the law applicable to you, you shall have

  1. a right to withdraw the Consent granted by you with respect to Processing the Data;
  2. a right to obtain particulars regarding the Data that we Process;
  3. a right to rectify any inaccurate Data or provide supplementary Data concerning you;
  4. a right to have the Data concerning you to be erased;
  5. a right to restrict the Processing of the Data;
  6. a right to obtain notification regarding erasure or restriction on the Processing of the Data;
  7. a right to porting of the Data;
  8. a right to object to the Processing of the Data;
  9. a right not to be subjected to a decision solely based on automated Process; or
  10. a right to file a complaint with designated data protection authority about the infringement of Your right.


  1. To be governed by this Policy, You are required to provide Consent by performing such act as is specified in this Platform.
  2. When you provide Consent, we do not know whether the same is a valid Consent. In this regard, we may require you to perform such an act or provide such information as shall enable us to evaluate the validity of Your Consent.
  3. If you are a minor or suffer from any legal disability to provide Consent, it is essential that a person holding parental responsibility over you provide Consent on your behalf.


In addition to this Policy, we also advise you to read through and understand the Term and Conditions governing the access and/or utilisation of Platform and Platform Service.


We reserve a right to change, modify, amend or alter the terms of this Policy. We notify you of any such changes, modification, amendment or alteration to this Policy by publishing the changed, modified, amended or altered Policy on the Platform.


All the communication in the form request, clarification, doubts, disputes, difference, grievances, redressal or reporting of any undesirable activity must be directed to and at:
Karun Sondhi