Privacy Policy

1. Introduction

Gulel Entertainment ("we", "us", "our") operates Gulel OTT at thegulel.com and the Gulel apps for iOS and Android. This Privacy Policy explains how we collect, use, and protect your personal information when you use our Service. We comply with applicable data protection laws including the EU General Data Protection Regulation (GDPR) and India's Digital Personal Data Protection Act 2023 (DPDP Act).

2. Data We Collect

• Account data: Phone number or email used during sign-up.
• Usage data: Episodes watched, watch progress, search queries.
• Transaction data: Coin purchases, payment method type (not card details — handled by Stripe/Razorpay).
• Device data: Browser type, OS, device identifiers, IP address.
• Analytics data: Page views and interactions via Google Analytics 4 and Facebook Pixel (where consented).

3. How We Use Your Data

• To provide, personalise, and improve the Service.
• To process payments and manage your coin balance.
• To send service-related notifications (OTP, receipts).
• To analyse usage trends and improve content recommendations.
• To detect and prevent fraud and abuse.
• To comply with legal obligations.

4. Legal Basis (GDPR)

For users in the EU/EEA, we process personal data under the following legal bases:
• Contract performance — to provide the Service you signed up for.
• Legitimate interests — fraud prevention, security, analytics.
• Consent — marketing cookies and advertising pixels where required.
• Legal obligation — where required by applicable law.

5. Data Sharing

We do not sell your personal data. We share data only with:

• Payment processors (Stripe, Razorpay) — for transaction processing, including the UPI Autopay, card or netbanking mandates used to renew VIP subscriptions.
• Apple (App Store In-App Purchase), Google (Google Play Billing) and RevenueCat — for purchases made in the mobile apps.
• Google AdMob — to serve rewarded ads in the mobile apps (see section 6).
• Analytics providers (Google Analytics, Meta) — under their respective data processing agreements.
• Infrastructure providers (Vercel, Supabase) — for hosting and database services.
• Law enforcement — where required by law or valid legal process.

6. Mobile apps (iOS & Android)

When you use the Gulel apps for iOS and Android, the following also applies:

• Sign-in:you can sign in with your phone number (one-time SMS code, via Supabase), with Google, or with Sign in with Apple. We receive your name, email address and/or phone number from the method you choose. If you use Sign in with Apple and choose to hide your email, we only receive Apple's private relay address.
• Rewarded ads:in the Android app (and on the website, where offered) you can choose to watch an ad to earn coins; the iOS app currently shows no ads. These ads are served by Google (AdMob / Ad Manager), which may use your device's advertising identifier (AAID on Android), cookies, IP address and device information to show, measure and limit ads. Where the law requires it, we ask for your consent first using Google's User Messaging Platform (UMP); if you decline, only non-personalised ads are shown. If we offer ads on iOS in the future, we will ask for permission through Apple's App Tracking Transparency (ATT) prompt before using the advertising identifier (IDFA). Where available, you can change your ad privacy choices from the app's Get Coins screen (“Ad privacy settings”); you can also reset or limit the advertising identifier in your device settings.
• Ad reward verification: when you finish a rewarded ad, Google sends a server-side verification callback to our servers that includes your Gulel user ID, so we can credit your coins securely and prevent abuse.
• In-app purchases: coins and VIP subscriptions bought in the apps are paid through Apple In-App Purchase or Google Play Billing. Purchases are processed by RevenueCat, which receives your Gulel user ID and the purchase details (not your card details) so we can grant what you bought. Store subscriptions are managed and cancelled in your App Store or Google Play account.
• Account deletion:you can delete your account in the app (Account > Delete account). See thegulel.com/delete-account for details.

7. Data Retention

We retain your account data for as long as your account is active. Watch history and preferences are retained for up to 2 years of inactivity. You can delete your account and associated data at any time — see how to delete your account. After deletion we keep only a one-way hash of your phone number and email address, used solely to prevent repeated sign-up bonus abuse.

8. Your Rights

Depending on your jurisdiction, you may have the right to:

• Access the personal data we hold about you.
• Correct inaccurate or incomplete data.
• Request erasure of your data ("right to be forgotten").
• Object to or restrict certain processing activities.
• Data portability (receive your data in a machine-readable format).
• Withdraw consent where processing is based on consent.

To exercise these rights, email us at hello@thegulel.com. We will respond within 30 days.

9. Cookies

We use cookies and similar technologies for authentication, analytics, and advertising. You can control cookie settings through your browser. Disabling certain cookies may affect Service functionality.

10. YouTube API Services

We use YouTube API Services to publish and manage videos on our own YouTube channels and to read those channels' analytics. Only our team uses this integration; it does not access, collect or store data about you or your YouTube account. When you watch or interact with our videos on YouTube, the YouTube Terms of Service and the Google Privacy Policy apply. You can review or revoke apps connected to your Google Account at myaccount.google.com/permissions.

11. Children's Privacy

Gulel OTT is not directed to children under 13. We do not knowingly collect personal data from children. If you believe we have collected data from a child, please contact us immediately.

12. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be communicated via the app or email. Continued use of the Service after the effective date constitutes acceptance of the updated policy.

13. Contact and Grievance Officer

For privacy enquiries or to exercise your rights, contact us at hello@thegulel.com. Complaints about how we handle your personal data can also be sent to our Grievance Officer, who will resolve them within one month:

Designation

Grievance Officer

Email

hello@thegulel.com

See Grievance Redressal for how complaints are handled.