Privacy Policy

OVERVIEW

We are an over-the-top ("OTT") platform where the users are offered access to audio-visual media and entertainment content in the form of full-length feature films, non-feature film videos, television serials, short films, documentary films, promotional videos, music videos and various other media and entertainment related contents ("Content"). The Content is made available through internet streaming with an option of downloading (wherever available) and is accessible through our application Ultra Play and website www.ultraplay.in and all its variants.

COLLECTION AND USE OF INFORMATION

‘Personal Information’, ‘Information’ and ‘Sensitive Personal Data or Information’ shall have the meaning ascribed to it under the Information Technology Act, 2000 and Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011.

1. GENERIC INFORMATION / FINANCIAL INFORMATION

a) We collect your Personal Information or Information when you use or browse the Service and at the time of your registration with Service and you share such information with us through email or by posting on the Service or by interacting with our customer care in surveys or service, or by participating marketing promotions or by any other means made available to you by us.

b) We collect information with respect to your name, mobile number, email, address, IP address, zip code, age, gender, occupation etc. Based on your purchase of the subscription package, our payment gateway partners collect information with respect to your credit/debit card details or other bank account details, payment method. This information is stored by our payment gateway partners.

c) In order to access some features of the Service, you will have to create an account. You shall never use another's account without prior permission. When creating your account, you must provide accurate and complete information. You are solely responsible for the activity that occurs on your account, and also shall be solely responsible for keeping your account's password secure.

2. DEMOGRAPHIC INFORMATION

a) We may track certain information about you based upon your behavior while using the Service. We use this information for conducting internal research on our users' demographics, interests, and behavior to better understand, protect and serve our users.

b) We may also collect your Information to track user behavior and preferences for internal analytics and research. We may also use your information to evaluate your interest for various genres of content, services, offers; to perform analytics, conduct customer research; to provide you a personalized service and experience; and to research and analyze our audience.

c) If you choose to post messages on our message boards, chat rooms or other message areas or leave feedback, we will collect that information you provide to us.

d) If you send us personal correspondence, such as emails or letters, or if other users or third parties send us correspondence about your activities or postings, we may collect and store such information.

e) We identify and use your IP address to help diagnose problems with our server. Your IP address is also used to help identify you and to gather broad demographic information.

f) We will occasionally ask you to complete optional online surveys. These surveys may ask you for contact information and demographic information. We use this data to tailor your experience, providing you with content that we think you might be interested in.

3. COMMUNICATION DATA INFORMATION

We may use the information collected about You for the purpose of communicating with You through various methods, including but not limited to email, push notifications, phone calls, text messaging, and WhatsApp messages. These communications may include:

• Updates regarding new Content(s) uploaded on Lumos.
• Information about new features or enhancements to the platform.
• Marketing and promotional announcements.
• Consumer surveys to improve our services.
• Notifications related to Your Membership Plan, including confirmation, expiry, and renewal details.
• Delivery of services requested by You and processing of transactions.

4. AUTOMATIC INFORMATION COLLECTION

We may use a variety of technologies that automatically or passively collect information about how the Service is accessed and used ("Usage Information"). Usage Information may consist of your browser type, operating system, the page served, the time spent on the Service, and the preceding page views.

We also automatically collect your IP address or other unique identifier for the computer, mobile device, set top boxes, smart TVs, and other streaming devices you use to access the Service. Automatically collected information also includes your activity on the Service such as title selections, shows and series you have watched, search queries, and details of your interactions with our customer service.

5. COOKIES INFORMATION

When you use the Service, our servers may collect information indirectly and automatically about your activities on the Service by way of cookies. "Cookies" are small text files that help store user preferences and activity. This helps us to learn more about your interests, and provide you with essential features and services including:

• Keeping track of the list of content watched or added in your list on your account.
• Conducting research and diagnostics to improve the content, products, and services.
• Preventing fraudulent activity.
• Improving security.

COOKIE POLICY

a) REQUIREMENT OF COOKIE POLICY — It is mandatory to have a cookie policy for the Service. Laws such as the ePrivacy Directive and the General Data Protection Regulation (GDPR) require us to detail our use of cookies to users, including what cookies the site uses, why they use those cookies, who provides the cookies, and how users can set their cookie preferences.

b) REJECTION AND DELETION OF COOKIE — You can choose to reject or block all or specific types of cookies set by virtue of your visit to our website by changing your browser settings. Please note that most browsers automatically accept cookies. Therefore, if you do not wish cookies to be used, you may need to actively delete or block the cookies.

c) AVOID INVASION OF PRIVACY — We have set out compliances and ways to evade the invasion of privacy. The Service through cookies will have transparent policies and will make clear options to people about how their personal information is stored, used or transmitted. Cookies are small data files stored on your hard drive through our websites. We always suggest our individual users to delete them after they complete browsing to protect their privacy.

6. WEB BEACONS

"Web Beacons" (also known as image tags, pixel tags, clear GIFs or web bugs) are small pieces of code used to collect advertising data, such as counting page views, promotion views or advertising responses. Web beacons or similar technologies may be used to count visitors to the Service, to monitor how users navigate the Service, to count how many sent emails were actually opened or to determine whether content sent was actually viewed.

7. EMBEDDED SCRIPTS

An embedded script is a programming code that is designed to collect information about your interactions with the Service, such as the links you click on. The code is temporarily downloaded onto your device from our server or a third-party service provider, is active only while you are connected to the Service, and is deactivated or deleted thereafter.

8. LOG FILE INFORMATION

When you use the Service, our servers automatically record certain information that your web browser sends whenever you visit any website. These server logs may include information such as your web request, Internet Protocol ("IP") address, browser type, browser language, referring/exit pages and URLs, platform type, number of clicks, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, the date and time of your request, and one or more cookies that may uniquely identify your browser.

9. INFORMATION FROM PARTNERS

We collect information from other companies with whom you have a relationship ("Partners"). These Partners might include your TV or internet service provider, or other streaming media device providers who make our service available on their device; mobile phone carriers or other companies who provide services to you and collect payment for the Service for distribution to us or provide pre-paid promotions for the Service.

10. INFORMATION COLLECTION FROM OTHER SOURCES

We may also obtain information from other sources including service providers that help us determine a location based on your IP address; security service providers who provide us information to secure our systems; payment service providers; online and offline data providers; and publicly available sources such as publicly available posts on social media platforms.

11. DISCLOSURE OF PERSONAL INFORMATION WITH THIRD PARTIES

a) We may disclose Personal Information to affiliates and group companies. We may disclose such information to third parties in order to provide you access to the Service, to comply with our legal obligations, to enforce our Terms of Use, to facilitate our marketing and advertising activities, or to prevent, detect, mitigate, and investigate fraudulent or illegal activities related to the Service.

b) We will always take your consent at the time of sharing your Personal Information with third parties for their marketing and advertising purposes. In the event of any requirement by court order, government or quasi-government agency to disclose your Personal Information, we will disclose information as may be legally required.

c) We do not share your personally identifiable information (such as name or email address) with other, third-party companies for their commercial or marketing use without your consent.

d) We do share non-personally identifiable information (such as anonymous user usage data, referring/exit pages and URLs, platform types, number of clicks, etc.) with interested third-parties for commercial and marketing use.

12. ACCESS TO ACCOUNT AND PROFILE

a) For your convenience and ease you can use the "Remember me" function when you log in to the Service. This function uses technology that enables us to provide direct account access without requiring re-entry of any password.

b) In the event you share or allow others to have access to your account, they will be able to see the Content you have watched, ratings and your account information.

c) Profiles allow users to have a distinct, personalized experience of our Service, built around the Content of interest to them, as well as separate watch histories. Please note that profiles are available to everyone who uses your account.

13. THIRD PARTY SITES

a) The Service may provide links to various third-party websites that may collect your Personal Information. Use of your information collected by such third-party website will be governed by the privacy policy in such third-party website. We have no control on the operation of such third-party websites.

b) We allow other companies, called third party ad servers or ad networks, to serve advertisements within the Service. These third-party ad servers or ad networks use technology to send, directly to your browser, the advertisements and links that appear on our website.

14. ACCESS TO INFORMATION

Only authorized employees, service providers, agents and contractors (who have agreed to keep information secure and confidential) may have access to information collected/received from you. All emails and newsletters from the Service allow you to opt out of further mails. Extremely sensitive information like your credit card details etc. are transacted upon secure sites of approved payment gateways which are digitally under encryption.

15. PROMOTIONAL AND MARKETING ACTIVITIES

a) We will send communications to you at regular intervals to notify you of various offers, new content, exclusive deals, etc.

b) By accessing our Service, you expressly consent to receiving such communications from us at regular intervals. However, if you do not wish to receive any communications from us, you may request to opt-out by sending an email to support@lumos.com with the subject as "Unsubscribe".

c) We may communicate to you from time to time as and when there are offers, new content, exclusive deals, or new series that may be available and may be of interest to you to subscribe.

16. SECURITY AND COMPLIANCE WITH LAWS

We strive to protect your Personal Information against unauthorized disclosure, misuse, unlawful use, modification, loss or destruction. We take all reasonable measures and precautions, as per standard industry practices, to keep your Personal Information confidential.

We ensure compliance with all applicable laws including but not limited to Information Technology Act, 2000 (as amended) and Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011. We will only retain your data for as long as we need it to fulfill our purposes, including any legal or regulatory compliances or requirements.

17. AMENDMENT

We reserve the right, at our sole discretion, to modify the terms of this Policy from time to time in order to ensure compliance with applicable laws. The Updated Terms shall be effective immediately and shall supersede these the terms of this Policy. By continuing to use the Service after the Updated Terms have been published, you affirm your agreement to the Updated Terms.

18. CONSENT

By using the Service and/or by providing your information, you fully understand and directly and expressly consent to the transfer, processing, collection, storage and use of the information you disclose on the Service in accordance with this Policy, including but not limited to your consent for sharing your information as per this Policy.

19. OUR COMMITMENT TO DATA SECURITY

Company is committed to protecting the security of information provided/received from you. Company uses a variety of security enabled technologies and procedures for protection of information from unauthorized access, use, or disclosure. Company maintains data accuracy, and ensures correct use of information.

We also monitor the use of the Service, and we use all information including the Personal Information, in order to identify fraudulent activities and transactions; seek prosecution for any potential threats or misuse to the Service, ensure compliance with the applicable Terms Of Use and this Policy.

20. FORCE MAJEURE

Notwithstanding anything contained in this Policy or elsewhere, Company/Service shall not be held responsible for any loss, damage or misuse of information, if such loss, damage or misuse is attributable to a Force Majeure Event. A "Force Majeure Event" shall mean any event that is beyond the reasonable control of the Company and shall include, without limitation, sabotage, fire, flood, explosion, acts of God, civil commotion, strikes or industrial action of any kind, riots, insurrection, war, acts of government, computer hacking, unauthorized access to computer data and storage device, computer crashes, breach of security and encryption, etc.

21. OUR COMMITMENT TO CHILDREN'S PRIVACY

Protecting the privacy of young children is especially important. We do not knowingly collect or maintain personally identifiable information on the Service from persons below 18 years of age, and no part of the Service is directed to persons below the age of 18 years. If you are under 18 years of age, then please do not use or access the Service at any time or in any manner.

22. YOUR CHOICE

You may choose to decline to submit Personal Information through the Service, in which case we may not be able to provide certain services to you. You may update or correct your Personal Information and email preferences at any time by visiting your account profile page on the Service.

Please contact support@lumos.com with any questions or comments about this Policy, your personal information, your consent, or your opt-in or opt-out choices.

23. PROHIBITED USES

You may use the Service only for lawful purposes. You may not use the Service:

• In any way that breaches any applicable local, national or international law or regulation.
• In any way that is unlawful or fraudulent, or has any unlawful or fraudulent purpose or effect.
• For the purpose of harming or attempting to harm any other person including minors in any way.
• To transmit, or procure the sending of, any unsolicited or unauthorized advertising or promotional material (spam).
• To knowingly transmit any data or upload any material that contains viruses, Trojan horses, worms, or any other harmful programs.

24. GOVERNING LAWS AND JURISDICTION

This Policy shall be governed and construed by the laws of India and Courts of Mumbai, India shall have exclusive jurisdiction for any disputes/interpretation arising under this Policy.

25. GRIEVANCE REDRESSAL

In accordance with Information Technology Act, 2000 and rules made thereunder, if you notice any discrepancies in the information provided or have any grievance against the Service/Company, You may contact our Grievance Officer at:

Email: grievance@lumos.com

Monday to Friday except Public Holidays (10:00 AM to 6:00 PM)

Please do not share any private information at the above stated email ID.