Vibely

Privacy Policy — Vibely

Vibely (“Vibely”, “we”, “us”) is operated by Aryan Mehta, an individual operating as “Vibely Space” and based in New Delhi, India, who is the data controller (EU/UK GDPR), data fiduciary (India DPDP Act 2023), and business (California CCPA/CPRA) for the purposes of this policy.

This policy explains what the Vibely mobile app collects, why, who it goes to, and how you get rid of it.

Vibely is available worldwide. India, the United States, and the EU/EEA are our primary markets, and this policy carries specific supplements for each — see §14.

Contact for any privacy question, request, or complaint: spacevibely@gmail.com. Aryan Mehta personally answers these. For India he is the designated Grievance Officer under the IT Rules 2021 and the person who can answer questions about processing under the DPDP Act (§14.2); elsewhere he is the contact point for data-protection queries.

Grievances are acknowledged within 24 hours; general questions get a reply within 2 business days. Everything is resolved within the period the applicable law requires (§11).


1. What we collect

We collect only what the app needs to work. There is no advertising SDK, no analytics SDK, and no third-party tracker in the app.

1.1 Information you give us

Data When Why
Name At sign-in, from Google or Apple Shown to other users on your profile and on events you host
Email address At sign-in, from Google or Apple Identifies your account; used for service notices
Username You choose it Your public handle
Date of birth Required, when you set up your profile Proving you meet the 18+ age requirement
Gender Optional, in profile Optional profile detail

Date of birth is required — Vibely is 18+, and we check the date you give rather than simply asking you to tick a box (§8). Gender is optional; the app works without it and your profile is simply less complete.

We do not collect phone numbers.

1.2 Information created by using the app

1.3 Location

With your permission, the app reads your device’s precise location to show events near you and to set the location of an event you are hosting.

Some laws — notably California’s CPRA — classify precise geolocation as sensitive personal information. We treat it that way: it is used to provide the feature you asked for and for nothing else. See §14.3.

1.4 Device and technical data

1.5 What we do not collect


2. How we use it

We process your information to:

We do not sell your personal information, share it for cross-context behavioural advertising, use it to build advertising profiles, or use it to train machine-learning models.


Purpose Basis
Creating and running your account Performance of a contract
Showing nearby events (location) Consent — the OS permission prompt; withdrawable at any time
Push notifications Consent — the OS permission prompt; withdrawable at any time
Optional profile fields (DOB, gender) Consent — you choose whether to supply them
Moderation, safety, abuse prevention Legitimate interests, and legal obligation where applicable
Security logging and fraud prevention Legitimate interests
Responding to legal process Legal obligation

Where we rely on legitimate interests, the interest is keeping the service safe for people who meet strangers in person through it. We have weighed that against your interests and consider it proportionate because the processing is limited to what moderation and security require, and because you can object at any time (§7).

Withdrawing consent for location or notifications does not affect the lawfulness of processing before withdrawal.


4. Who we share it with

We use a small number of processors. We do not sell data to anyone.

Recipient What they receive Purpose
Google — Firebase Cloud Messaging FCM token, notification payloads Delivering push notifications
Google — Sign-In / Identity Authentication assertion Signing you in
Google — Maps SDK Map tile and interaction requests from your device Rendering the map
Google — Places API Your place-search text and a bias area, sent from our backend, not from your device Returning place suggestions when you set an event’s location
Apple — Sign in with Apple Authentication assertion Signing you in
Google — Firebase Crashlytics Crash stack traces, device and OS details Diagnosing and fixing crashes
Our hosting provider Data stored by the backend at api.vibelyspace.com Running the service

Google’s and Apple’s own privacy policies govern their handling of that data.

Other users see: your name or username, your profile details you chose to fill in, events you host, and messages you send in group chats. Your email address is never shown to other users. Treat anything you post as visible to other participants.

We may disclose information where legally required, or where necessary to investigate fraud, abuse, or threats to safety.


5. Storage, security, and retention

5.1 Security

No system is perfectly secure, and we cannot guarantee absolute security.

5.2 How long we keep things

Category Retention
Profile — name, username, email, date of birth, gender Life of your account. Overwritten when you delete it — see §5.3.
Events you hosted, bookings, attendance Cancelled and hidden when you delete your account. The records remain linked to the anonymised account id, not to you.
Group chat messages Messages in a group you created are erased outright. Messages you sent in someone else’s group stay, so the conversation still makes sense to the people in it — but the sender resolves to “Deleted user”, not to you. Copies already delivered to other people’s devices are outside our control either way.
Friends, friend requests, block list Removed when you delete your account.
FCM push token Deleted outright when you sign out, uninstall, or delete your account.
Precise location used for a nearby-events search Not retained. Used for the request and discarded.
Location you attach to an event you host Life of that event. Cancelled with your account, and no longer linked to you.
Server request logs (IP, timestamps) Up to 12 months.
Crash reports (Crashlytics) 90 days — Google’s default retention for crash data.
Reports you filed about other users Kept while needed for safety enforcement. Once your account is gone they no longer identify you as reporter.
Reports filed against you Kept as an abuse record. Free text and the copy of the reported content are stripped 90 days after the report is settled.
Sign-in identifier (which provider you used, that provider’s ID for you, and the email address on it) 12 months after you close your account, then erased outright — unless the account was banned, in which case it is kept for as long as the ban stands. This is the one identifying field that survives deletion — see §5.3.
Moderation and ban records The minimum needed to enforce a ban and prevent re-registration: the sign-in identifier above, plus the fact of the ban and its reason.
Records we are legally required to keep The legally required period, and nothing longer.

When a retention period ends, or when you withdraw consent and we have no other basis to keep processing, the data is deleted or irreversibly anonymised.

5.3 What “deleting your account” actually does

We are specific about this because “we delete everything” is usually not true, and we would rather tell you exactly where the line is.

Your account is not simply hidden. When you delete it — or if we remove it — your profile is overwritten in our database: name, username, email address, date of birth, and gender. Those copies are not recoverable, by us or by anyone else.

What remains is an anonymous account number with no personal data attached to it. We keep it because other people’s records point at it: a booking on someone else’s event, a message in a group still in use, a report someone filed about conduct. Removing the number outright would corrupt or destroy those other people’s data. Under the GDPR and the DPDP Act this satisfies your right to erasure — the requirement is that the data stop being attributable to an identifiable person, which it does.

One identifying record deliberately survives, and we want to be straight about it. Our sign-in system separately keeps the identifier you logged in with — which provider (Google or Apple), that provider’s ID for you, and the email address on it. Everything else attached to it, including the security tokens for your Google or Apple session, is erased.

We keep it for one purpose: enforcing bans. If we could not, then deleting your account before we acted on a report would erase the record of it, and the same person could sign straight back up with the same email. That would make deletion a way to shed a ban, at the expense of the people the ban protects. It is not used to contact you, to profile you, or for anything else, and it plays no part in a normal deletion — if you are never banned, it is only ever matched against and never acted on.

It does not last forever. If you were never banned, it is erased outright 12 months after you close your account — the point by which the risk of someone deleting their account to dodge a pending report has passed. Only a banned account’s identifier is kept beyond that, and only for as long as the ban stands.

Our legal basis is legitimate interests (GDPR Art. 6(1)(f)) in keeping the service safe; under India’s DPDP Act we rely on §8(7), which allows retention where it is needed to enforce legal rights. The 12-month limit is how we keep that proportionate, as GDPR Art. 5(1)(e) storage limitation requires. You can object at spacevibely@gmail.com and we will weigh your objection against the safety interest and tell you the outcome.

Signing in again with the same Google or Apple account, if you were never banned, simply gives you a new, empty account — the identifier is reused, but nothing from your old account comes back with it.

Two further consequences worth stating plainly:

Deletion reaches our live systems immediately. Encrypted backups are overwritten on their normal rotation.


6. Reporting, blocking, and moderation

Vibely carries user-generated content, so it has active moderation.

Reports include the reported content and your identity as the reporter. We do not disclose your identity to the person you reported, but we may need to act on the report in ways that make the subject aware something was reported.

No solely automated decisions. Content removals, suspensions, and bans are decided by a person reviewing the report — there is no automated scoring, profiling, or algorithmic banning. You are therefore not subject to a decision based solely on automated processing that produces legal or similarly significant effects (GDPR Art. 22). If your account is actioned you are told why, and you can appeal to spacevibely@gmail.com.


7. Your rights and choices

You can, at any time:

We respond to rights requests within the period required by applicable law — see §11 — and we do not charge for them or treat you differently for making one. We may need to verify your identity first, and we may decline a request that is manifestly unfounded or excessive, telling you why.


8. Children

Vibely is not directed at children and is intended for users aged 18 and over. This is enforced rather than merely declared: you must give a date of birth to finish setting up a profile, and our servers reject any date under 18 — on account creation and on every later profile edit — so the check cannot be bypassed by altering the app.

We do not knowingly collect personal information from anyone under that age, we do not profile or behaviourally advertise to anyone, and we do not process children’s data at all. If you believe a child has created an account, contact spacevibely@gmail.com and we will remove it.


9. International transfers

Our infrastructure and our processors (Google, Apple) may process data outside your country.

You can ask us for details of the safeguards that apply to a particular transfer.


10. Data breaches

If a personal data breach occurs we will investigate it, take steps to contain it, and:


11. Response times

Regime We respond within
EU/UK GDPR 1 month, extendable by 2 further months for complex requests (we will tell you)
India — IT Rules 2021 grievances Acknowledged in 24 hours, resolved in 15 days (§14.2)
India DPDP Promptly, and in any case within the period prescribed under the Act
California CCPA/CPRA 45 days, extendable once by a further 45 days
Other US states 45 days, extendable as that state’s law allows
Everywhere else 30 days

The 24-hour acknowledgement is the shortest clock we are held to, so in practice it is the one we work to for any grievance, wherever you are.


12. Changes

We will update this policy when the app changes. Material changes will be notified in the app or by email before they take effect, and the “Last updated” date above will change. Continuing to use Vibely after an update means you accept the revised policy.


13. Contact

Aryan Mehta New Delhi, India spacevibely@gmail.com

A postal address is available on request.


14. Regional supplements

The policy above applies to everyone. These sections add what specific regimes require.

14.1 EEA and United Kingdom

14.2 India — DPDP Act 2023 and the IT Rules 2021

Two regimes apply to us in India, and this section covers both: the Digital Personal Data Protection Act, 2023 (how we handle your data) and the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021 (our duties as a platform that hosts what users post).

Grievance Officer

Required by Rule 3(2) of the IT Rules 2021, and the same person handles DPDP grievances:

   
Name Aryan Mehta
Designation Grievance Officer, Vibely
Email spacevibely@gmail.com
Address New Delhi, India — full postal address on request

Write with “Grievance” in the subject line. We will acknowledge your complaint within 24 hours and resolve it within 15 days of receipt, as Rule 3(2)(a) requires. If a complaint concerns content you want removed, tell us what it is and where to find it.

This channel is for grievances specifically — anything about your personal data, content you believe breaches our Terms or the law, or a decision we have taken about your account. General support questions go to the same address and get a reply within 2 business days.

DPDP roles

14.3 United States

California (CCPA / CPRA)

We have not sold or shared personal information for cross-context behavioural advertising in the preceding 12 months, and we do not do so now. We have never sold the personal information of anyone, including minors under 16. Because we do not sell or share, there is no “Do Not Sell or Share My Personal Information” opt-out to operate — but if that ever changes, we will add one and tell you before it takes effect.

Categories collected in the preceding 12 months, in the statute’s own terms:

CCPA category Collected? What Source Purpose Disclosed to
A — Identifiers Yes Name, email, username, account ID, IP address, FCM token You; Google/Apple sign-in; your device Account, notifications, security Processors in §4
B — Cal. Civ. Code §1798.80(e) records Yes Name, email You Account Processors in §4
C — Protected classifications Yes, optional Age (from date of birth), gender You Age eligibility; optional profile detail Processors in §4
D — Commercial information No
E — Biometric information No
F — Internet or network activity Limited Server request logs Your device Security, abuse prevention Hosting provider
G — Geolocation data Yes Precise location while the app is open; the location you attach to an event Your device, with permission Nearby events; hosting Processors in §4
H — Audio, visual, or similar No
I — Professional or employment No
J — Education information No
K — Inferences / profiles No
L — Sensitive personal information Yes Precise geolocation only Your device, with permission Providing the nearby-events and hosting features Processors in §4

We use sensitive personal information only to perform the service you asked for. We do not use or disclose it to infer characteristics about you, so the right to limit its use under §1798.121 is not engaged — but you can still switch location off in system settings at any time, which stops the collection entirely.

Your California rights: to know and access, to delete, to correct, to opt out of sale or sharing (not applicable — see above), to limit use of sensitive PI (not engaged — see above), and to non-discrimination for exercising any of them. We do not offer financial incentives. Exercise any of these at spacevibely@gmail.com; we respond within 45 days (§11). An authorised agent may act for you with written permission, and we will verify both.

Retention is set out in §5.2 rather than as a single period, because it differs by category.

Shine the Light (Cal. Civ. Code §1798.83): we do not disclose personal information to third parties for their own direct marketing purposes.

Other US states

Residents of Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, and other states with comprehensive privacy laws have broadly equivalent rights — access, correction, deletion, portability, and opting out of targeted advertising, sale, and profiling with legal or similarly significant effects. We do not conduct targeted advertising, sell personal data, or profile anyone, so those opt-outs have nothing to apply to; the access, correction, deletion, and portability rights work exactly as described in §7.

If we refuse a request, you may appeal by replying to our decision with “Appeal” in the subject line. We will respond to the appeal within 45 days with a written explanation, and if we still refuse we will tell you how to contact your state Attorney General.