Privacy Policy

1. Introduction

ShotWot Labs Private Limited ("ShotWot," "we," "us," or "our") is committed to protecting your privacy and personal data in accordance with the Digital Personal Data Protection Act, 2023 (DPDPA), the Information Technology Act, 2000, the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, and all applicable global data protection laws including the General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA), to the extent applicable.

This Privacy Policy applies to all users of the ShotWot platform, which includes:

• Our website accessible at www.shotwot.com

• Our mobile application available on Android and iOS ("the App")

• All related services, features, tools, and content offered through the above

By creating an account, accessing, or using the ShotWot platform in any manner, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy. If you do not agree, please discontinue use of our platform immediately.

For any questions, please contact us at: hello@shotwot.com

2. Definitions

3. Who This Policy Applies To

This Privacy Policy applies to:

• General Users who visit or browse the Platform

• Contributors and Artists who register to upload and license their content

• Buyers who purchase or license content

• Mobile App Users who use the ShotWot Android or iOS application

4. Information We Collect

4.1 Information You Provide Directly

For all users (website and app):

• Full name, username, and profile information

• Email address and phone number

• Country of residence and billing address

• Password (stored in encrypted form only)

For Contributors and Artists (additional):

• Government-issued ID or KYC documents for identity verification and tax compliance

• Bank account details, UPI ID, or other payout information

• Portfolio and content metadata submitted during upload

• Model release and property release documents, including the personal data of third parties named therein

• Tax information including PAN, GST number, or equivalent international tax identification

For Buyers (additional):

• Payment card details, UPI, net banking, or other payment information processed through our secure payment partners

• Billing address and invoicing details

• VAT or GST registration number where applicable

4.2 Information Collected Automatically

When you access our website or use our mobile application, we automatically collect:

• Device Information: Device type, model, operating system version, unique device identifiers, and mobile network information

• App Usage Data: Features accessed, screens viewed, time spent, in-app actions, crash reports, and performance logs

• Log Data: IP address, browser type, referring URLs, pages viewed, and date and time of access

• Location Data: General location derived from IP address; precise GPS location only if you grant permission on the mobile app (used for content metadata)

• Transaction Data: Purchase history, download history, and licensing records

• Communications: Any messages, support requests, or feedback submitted to us

4.3 Information From Third Parties

We may receive information about you from:

• Social login providers (Google, Apple) if you use them to sign in

• Payment processors confirming transaction completion

• Analytics partners helping us understand platform usage

4.4 Cookies and Tracking Technologies

We use cookies, pixels, and similar technologies on our website and app. These include:

You may control cookie preferences through our cookie consent banner on the website. For the mobile app, you can manage tracking permissions through your device settings (iOS: Settings > Privacy > Tracking; Android: Settings > Privacy). Note that disabling essential cookies or identifiers may affect platform functionality.

5. Legal Basis for Processing

We process your personal data only where we have a lawful basis to do so:

Where we rely on consent, you may withdraw it at any time without affecting the lawfulness of processing before withdrawal.

6. How We Use Your Information

We use the information we collect for the following purposes:

Account and Service Management:

• Creating and managing your ShotWot account on the website and mobile app

• Processing contributor content submissions and buyer purchases

• Managing payouts and financial transactions for contributors

• Providing customer support and responding to your queries

Platform Operations:

• Content moderation and quality review of uploaded media

• Automated tagging, categorisation, and search indexing of content using AI tools

• Detecting and preventing fraud, abuse, and unauthorised access

• Enforcing our Terms of Service, Contributor Agreement, and licensing terms

Communications:

• Sending transactional emails and app notifications (upload status, payment updates, license alerts)

• Sending marketing communications where you have consented; you may opt out at any time

Improvement and Analytics:

• Understanding how users interact with our website and app

• Conducting statistical research and product development

• Testing new features and improving existing ones

Legal Compliance:

• Meeting obligations under Indian tax law, financial regulations, and data protection law

• Responding to lawful requests from government or law enforcement authorities

Disclosure Regarding AI Processing:
Our platform uses automated systems and artificial intelligence for content tagging, search ranking, quality assessment, and fraud detection. These automated processes do not make legally significant decisions about you without human oversight. You have the right to request human review of any automated decision that materially affects you.

7. Model Releases and Property Releases

As part of our content licensing operations, Contributors may submit model releases and property releases containing personal data of third parties (including names, contact details, and signatures of individuals depicted in content). ShotWot will:

• Store these documents securely and use them solely to validate the licensing rights of submitted content

• Not use third-party personal data in releases for marketing or any unrelated purpose

• Retain releases for as long as the associated content is live on the platform and for [FILL: e.g., 5 years] thereafter to manage any licensing disputes

• Require Contributors to confirm that they obtained proper consent from all individuals depicted in their content before submission

8. Sharing of Information

We do not sell your personal data. We may share your information in the following limited circumstances:

Service Providers:
We engage trusted third-party vendors to operate our platform, including:

• Cloud infrastructure providers (e.g., Google Cloud and Firebase)

• Payment processors (e.g., Razorpay, Stripe, or equivalent)

• Analytics platforms (e.g., Google Analytics, Firebase Analytics)

• Customer support tools

• Email and push notification services

All service providers are bound by data processing agreements and are prohibited from using your data for their own purposes.

Business Transfers:
In the event of a merger, acquisition, restructuring, or sale of all or part of ShotWot's business, your personal data may be transferred to the successor entity. We will notify you before your data is transferred and becomes subject to a different privacy policy.

Legal Requirements:
We may disclose your data to government authorities, law enforcement, or regulatory bodies where required by applicable law, court order, or to protect the rights, property, or safety of ShotWot, its users, or the public.

With Your Consent:
We may share your data in any other manner with your explicit prior consent.

9. International Data Transfers

ShotWot is headquartered in India. Your personal data may be transferred to and processed in countries outside India, including but not limited to the United States, in connection with the cloud and technology services we use.

When we transfer data internationally, we ensure adequate protection through:

• Standard Contractual Clauses (SCCs) approved by relevant data protection authorities

• Data Processing Agreements with all receiving third parties

• Transfer only to countries that provide an adequate level of data protection

You may contact us at hello@shotwot.com to obtain information about the safeguards we have put in place for international transfers.

10. Children's Privacy

The ShotWot platform and mobile application are strictly intended for users who are 18 years of age or older.

• We do not knowingly collect personal data from individuals under the age of 18

• Users below 18 may only use the platform with verifiable consent from a parent or lawful guardian

• If we become aware that we have inadvertently collected data from a minor without appropriate consent, we will delete it promptly

• Parents or guardians who believe their child's data has been collected may contact us at hello@shotwot.com to request deletion

This requirement applies to both the website and the mobile application on Android and iOS.

11. Data Retention

We retain your personal data only for as long as necessary for the purposes described in this policy and to comply with our legal obligations:

When data is no longer required, we securely delete or anonymise it.

12. Data Security

We implement industry-standard technical and organisational security measures to protect your personal data, including:

• Encryption of data in transit (TLS/HTTPS) and at rest

• Secure and encrypted storage of passwords

• Role-based access controls ensuring only authorised personnel access personal data

• Regular security audits and vulnerability assessments

• Secure payment processing through PCI-DSS compliant payment partners (we do not store full card details on our servers)

• Mobile app security measures including certificate pinning and secure local storage

Despite these measures, no method of transmission over the internet or mobile network is 100% secure. We cannot guarantee absolute security of your data, but we will notify you promptly in the event of a breach that affects your personal data.

13. Data Breach Notification

In the event of a personal data breach that is likely to result in risk to your rights and freedoms, ShotWot will:

• Notify the Data Protection Board of India (and other relevant regulatory authorities where required) without undue delay, and in any event within 72 hours of becoming aware of the breach, to the extent required by applicable law

• Notify affected users promptly with information about the nature of the breach, the data involved, likely consequences, and steps we are taking

• Maintain an internal register of all data breaches, regardless of whether notification is required

14. Your Rights

As a user of the ShotWot platform, you have the following rights regarding your personal data:

Right to Access: You can request a copy of the personal data we hold about you.

Right to Rectification: You can request correction of inaccurate or incomplete personal data.

Right to Erasure (Right to be Forgotten): You can request deletion of your personal data where it is no longer necessary for the purpose it was collected, or where you withdraw consent.

Right to Withdraw Consent: Where processing is based on consent, you may withdraw it at any time via your account settings or by contacting us.

Right to Data Portability: You may request your personal data in a structured, commonly used, machine-readable format.

Right to Object: You may object to processing based on legitimate interests, including direct marketing.

Right to Restrict Processing: You may request that we limit the use of your data in certain circumstances.

Right to Human Review: You may request human review of any automated decision that significantly affects you.

For EU/EEA Users (GDPR): You have the right to lodge a complaint with your local supervisory authority.

For California Users (CCPA): You have the right to know what personal data is collected, the right to delete, and the right to opt out of sale (we do not sell your data).

To exercise any of these rights, please submit a written request to hello@shotwot.com. We will respond within 30 days of receiving your request. We may need to verify your identity before processing your request.

15. Marketing Communications

We will only send you marketing and promotional communications with your explicit consent. You can opt out at any time by:

• Clicking the "Unsubscribe" link in any marketing email

• Updating your notification preferences in the ShotWot mobile app settings

• Contacting us at hello@shotwot.com

Opting out of marketing communications will not affect your receipt of transactional messages related to your account or orders.

16. Third-Party Links and Services

Our website and mobile application may contain links to third-party websites or integrate with third-party services (such as social login via Google or Apple). This Privacy Policy does not apply to those third-party services. We encourage you to review the privacy policies of any third-party services you access through our platform.

17. Briefs Tab Content Disclaimer

The content published under the Briefs tab on the ShotWot application is provided solely for reference and informational purposes. ShotWot does not hold any copyright over the images or illustrations used as references in the Briefs section. If you have any complaints or concerns regarding published content, please contact our grievance team at hello@shotwot.com.

18. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we make material changes, we will:

• Update the "Last Updated" date at the top of this page

• Notify you via email and a prominent in-app notification on the ShotWot mobile application

• Where required by law, seek your renewed consent before the new terms take effect

Your continued use of the platform after the notification period constitutes acceptance of the updated policy. If you do not agree to the revised terms, you may close your account at any time by contacting us.

19. Grievance Officer

In accordance with the Information Technology Act, 2000, the IT (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021, and the Digital Personal Data Protection Act, 2023, ShotWot has appointed a Grievance Officer to address any complaints or concerns regarding the processing of your personal data.

Grievance Officer Details:

Name: Shubham Goyal
Designation: Data Protection Officer
Organisation: ShotWot Labs Private Limited
Address: G24, Hinjewadi Phase 1, Pune – 411057, Maharashtra, India
Email: hello@shotwot.com
Phone: +91 7000350005

We will acknowledge your complaint within 48 hours and resolve it within 30 days of receipt.

20. Contact Us

For any questions, concerns, or requests related to this Privacy Policy or how we handle your personal data, please reach out to us:

ShotWot Labs Private Limited
G 24, Hinjewadi Phase 1,
Pune – 411057, Maharashtra, India

Email: hello@shotwot.com
Website: www.shotwot.com

21. Complaints to Regulatory Authorities

If you believe your privacy rights have been violated and we have not resolved your complaint satisfactorily, you have the right to lodge a complaint with:

• India: Data Protection Board of India (once fully operational under DPDPA 2023)

• European Union: Your local Data Protection Authority (for EU/EEA residents)

• United Kingdom: The Information Commissioner's Office (ICO)

• United States (California): California Attorney General's Office

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