JIO BLOCKCHAIN BASED REWARDS PROGRAMME PRIVACY POLICY
  1. Introduction
    1. The Jio ad Rewards Programme, currently referred to as the Blockchain Based Reward Programme ('BBRP'), and any rebranded or successor version of the BBRP Rewards Programme (“Rewards Programme”), designed, offered and operated by Jio Platforms Limited and/or its affiliates (“Company”, “We,” “Us” and “Our”) values the trust placed in Us by You and therefore, We strive to follow the reasonable standards of care to protect privacy of the personal data shared by You or accessed by Us in connection with the Rewards Programme (“Personal Data”). We recognize Your expectations with regard to Your privacy, confidentiality and security of the Personal Data that resides with Us.
    2. This privacy policy of the Rewards Programme (this “Privacy Policy”) applies to all users and others who participate and enrol in the Rewards Programme, submit any Personal Data or whose Personal Data is processed by the Rewards Programme and/or BBRP Vault for the purposes mentioned in the Privacy Policy (hereinafter referred to as either “You” or “Your”). The Privacy Policy governs the privacy practices regarding the collection, use, processing, disclosure, transfer, retention and safeguarding of Your Personal Data by Us in connection with Your use of the Services.
    3. All capitalized terms that have not been expressly defined herein shall have the meaning ascribed to them under the Terms available here ("Terms"). This Privacy Policy and the Terms should be read in conjunction and together with the terms of use and privacy policy applicable to the relevant product that is integrated with the Rewards Programme available via the Company applications and services, which apply to you in connection with, amongst others, the collection, processing, and usage of your personal information Programme in connection with your use of that product. For the purposes of this Privacy Policy, 'Personal Data' or 'Data' or 'Personal Information' or 'Sensitive Personal Data or Information' shall have the meaning ascribed to it under applicable laws in India, including the Information Technology Act, 2000 and the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011, the Digital Personal Data Protection Act, 2023 and the rules thereunder (from the time such law and the rules thereunder are brought into force), and shall be deemed to include Personal Data of any minor under Your care to whom You have provided permission to participate and enrol in the Rewards Programme.
    4. This Privacy Policy and Terms are an electronic record in terms of the IT Act 2000 and rules thereunder, and are published in accordance with the provisions of Rule 3 (1) of the of the Information Technology (Intermediary Guidelines and Digital media Ethics Code) Rules, 2021 and Rule 4(1) of the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011, which mandates for publishing of rules and regulations, privacy policy and terms of use for the participation in the Rewards Programme. This electronic record is generated by a computer system and does not require any physical or digital signatures.
  2. Consent
    1. You expressly understand, agree and acknowledge that Our collection, retention, use, disclosure, transfer, storage and processing of Your Personal Data is for a lawful and legitimate purpose connected with your participation in the Rewards Programme. You further understand, agree and acknowledge that Your Personal Data is considered necessary for Us to provide the Services to You and for Your participating in the Rewards Programme provided by Us.
    2. By participating and enrolling in the Rewards Programme after providing Your consent to the Terms and the Privacy Policy, You have deemed to have given consent to collect, store, use, disclose, transfer and process Your Personal Data in accordance with this Privacy Policy. You hereby agree to be bound by the terms of this Privacy Policy. If You do not agree with the terms contained herein, please do not participate in the Rewards Programme or use the Services. You are providing Your Personal Data out of Your free will and explicitly.
  3. Changes to Privacy Policy and Notice
    1. Subject to applicable laws, the Company reserves the right to update and / or modify this Privacy Policy from time to time without any prior written notice to You (“Updated Privacy Policy”). The Updated Privacy Policy shall be effective immediately and shall supersede this Privacy Policy. You are encouraged to check the “Last Updated” legend at the top of this page to see when this Privacy Policy was last revised. We will use commercially reasonable efforts to notify you of any change to Our Privacy Policy. Your continued participation the Rewards Programme after the Updated Privacy Policy has been published, will imply Your acceptance to such Updated Privacy Policy. We are obligated to protect Your Personal Data in accordance with laws and regulations applicable in the territory of India. Kindly note that the Services are not authorised for use outside the territory of India.
  4. Collection of Personal Data
    1. When You participate in the Rewards Programme, the Company will collect the following categories of Personal Data (including without limitation) from You for the purposes mentioned below:
        2. a) Name
        b) Email address
        c) Phone number
    2. We may process some other information, including but not limited to, Your participation details, usage statistics and usage activity related to BBRP Vault and Tokens, that may arise from Your participation in the Rewards Programme but cannot be used to identify You, whether on its own or in combination with other information or otherwise and such information will not constitute Personal Data or Personal Information for the purposes of this Policy.
  5. Sources of Collection of Personal Data
    1. We collect information (which includes Personal Data) either directly from You through various means, including without limitation: (i) information You provide while participating in the Rewards Programme or interacting with the Company's applications and services, such as during login, or engagement with Ads; (ii) Data collected via cookies and similar technologies utilized across the Company's applications and services to enhance Your experience; and (iii) information You share voluntarily through communication channels like emails, customer care centers, or other Company services made available to You.
  6. Purpose and Use of Personal Data
    1. 6.1 We use the Personal Data mentioned above to provide, maintain, improve, analyse and personalise the following lawful and legitimate services for You:
        2. a) Enabling Rewards Programme: We will use Your Personal Data such as Your name, phone number and email address to: (i) enrol You as a participant in the Rewards Programme; (ii) enable Your BBRP Vault for tracking and managing Tokens; (ii) credit Tokens earned by You; and (iv) send notifications relating to the Services directly to Your device.

        b) Facilitating Redemption of Tokens:Your Personal Data will be used to verify whether You meet the requirements for redeeming BBRP Tokens. This includes ensuring compliance with the redemption criteria, such as age eligibility, ownership of a valid Jio mobile number, Indian mobile number, or UPI-linked bank account (as the case may be), and other conditions as set forth by the Company in the Terms. We process Your Personal Data to ensure the accurate and timely execution of redemption requests. This may involve cross-checking the data provided by You, conducting additional identity verification steps, and ensuring compliance with applicable policies and legal requirements.

        c) Delivering Ads: : We use Your Personal Data to: (i) serve personalized Ads on Company applications and services, including Rich Communication Services (RCS), enabling You to earn Tokens through such engagement; and (ii) track Your engagement with Ads and ensure accurate allocation of Tokens for qualifying activities.

        d) Ensuring Security and Fraud Prevention:Your Personal Data is used to: (i) secure the BBRP Vault and Tokens against unauthorized access, misuse, or fraudulent activities; and (ii) monitor suspicious activities and enhance the security measures of the Services.

        e) Communication and Customer Support:We use Your Personal Data to: (i) notify You about updates, changes, and important information related to the Services; and (ii) respond to queries, concerns, and support requests related to Your BBRP Vault, Tokens, or the Rewards Programme.

        f) Improving Services:To provide You with a seamless experience, We may collect Personal Data to: (i) to analyse usage patterns, participation trends, and engagement metrics for improving and optimizing the Services; and (ii) develop new features, products, or services based on aggregated insights from user interactions.

        g) User Feedback Integration:We value Your feedback and use it to continuously improve our services. We may collect feedback on the Services and overall user experience. This information is used to refine our algorithms and our service offering, ensuring that the Rewards Programme meets Your needs.

        h)Device Independence:The Services are designed to be device-independent or agnostic, meaning it can function across various devices and platforms. To achieve this, we may collect and use information related to Your device type, operating system, and other technical details.

        i) Aggregated or Anonymized Data for Statistical and Analytical Purposes:We may aggregate or anonymize Your Personal Data to conduct statistical and analytical research. This data helps us understand user trends, improve our services, and develop new features.

        j) Legal Compliance and Service Integrity:: We may use the Personal Data to comply with applicable laws, enforce our agreements, and protect the rights or safety of the Services, our users, or any other person. This includes verifying user profile information with third-party providers, ensuring technical service functionality, performing troubleshooting, and preventing or detecting fraud, security breaches, or illegal activities associated with the Services, business and operations.

        Except as provided herein, We do not solicit any Personal Data about You. The authenticity of the Personal Data or other information or data provided by You shall not be Our responsibility, and We will not be liable for any actions, claims, costs, expenses or other liabilities that may arise as a consequence. Additionally, if You share any Personal Data or other information or data with us voluntarily (beyond what the Services require), We will not be liable for any actions, claims, costs, expenses or other liabilities that may arise as a consequence of such any unauthorized use or misuse of the same.
    2. Inferred Information through Usage and Log Data: We may track certain information about You based upon Your participation in the Rewards Programme and usage of the BBRP Vault and Tokens, however, such information cannot be used to identify You, whether in combination with other information or otherwise and such information will not constitute Personal Data or Personal Information for the purposes of this Policy. We use this information for conducting internal research on Our users’ demographics, devices, interests, and behaviour to better understand, protect and serve Our users. This information is compiled and analysed on an aggregated basis. We may also collect Your information to track users behaviour and preferences for internal analytics and research and targeting cohorts. We may also use Your information: (i) to validate and process Your request for the services offered by the Company; (ii) to improve the quality of the Services; (iii) to assist You to determine which services best meet Your needs; or (iv) to facilitate Our internal business operations, including the fulfilment of any legal and regulatory requirements; or (v) to provide You with recommendation about services You may be interested in, based on Your participation in the Rewards Programme.

      We may identify and use Your IP address to help diagnose any problems with Our server, and to administer the Services. Your IP address is also used to help identify You and to gather broad demographic information to customize Your experience in the Rewards Programme.

      We may occasionally ask You to complete optional online surveys. These surveys may ask You for Your contact information and demographic information (such as pin code, age, etc). We use this data to tailor Your experience and participation in the Rewards Programme.
  7. Cookies
    1. We may use technologies such as cookies to provide and enhance Your experience and improve the Services. A ‘cookie’ is a small piece of information stored by a web server on a web browser so it can be later read from that browser. Cookies are useful for enabling the browser to remember information or data specific to a given user. We place both permanent and temporary cookies in Your computer’s hard drive. Every time You use the Services, Our servers through cookies collect basic technical information such as Your domain name, the address of the last URL visited prior to acessing the Rewards Programme, and Your browser and operating system, etc. We may collect this information for statistical purposes or otherwise to find out how the Services are used and navigated, including the number of hits, the frequency and duration of visits, most popular session times. We may use this information to evaluate and improve the Services. The cookies do not contain any Personal Data. You can disable cookies through Your browser settings. However, disabling cookies may restrict certain features of the Rewards Programme and impact Your experience.
    2. We may combine Your Personal Data or other information collected from tracking technologies and aggregate it with information collected from other users using the Services to attempt to provide You with the Services and a better experience of the Services.
    3. For clarity, to the extent that IP addresses or similar identifiers are considered Personal Data by applicable law in the territory of India, We will treat any information linked to such identifiers as Personal Data. Similarly, to the extent that Non-Personal Information is combined with Personal Data, We will treat the combined data or information as Personal Data.
  8. Third Party Services
    1. As part of the Rewards Programme, You may interact with or access services, content, or features provided by Participating Members or other third-party entities. These third-party services may independently collect, use, share, or process information about You, including Your Personal Data, over which We have no control.
    2. For detailed information about how such Participating Members handle Your Personal Data, please review their respective privacy policies. We encourage You to exercise caution and familiarize Yourself with the privacy practices of these third parties before sharing any information or engaging with their services.
    3. The Rewards Programme may also include links to third-party websites, applications, or other content (“Third-Party Content”), which operate under separate terms of use and privacy policies. Any Personal Data or other information You provide while accessing Third-Party Content will be governed by the privacy policies of the respective operators.
    4. You agree that: (i) We are not responsible for the privacy practices, content, or security of any third-party websites, applications, or services; (ii) We do not endorse or guarantee the accuracy, relevance, or completeness of any Third-Party Content accessed through the Rewards Programme; and (iii) We will not be liable for any actions, claims, costs, expenses, or other liabilities arising out of Your interaction with or use of such Third Party Content.
    5. If You cannot locate the privacy policy of a third-party website, application, or service, We recommend contacting the respective operator directly for more information. By interacting with third-party services through the Rewards Programme, You acknowledge and agree that Your engagement is at Your own risk, and We bear no liability for any consequences thereof.
  9. Sharing of Personal Data
    1. We may disclose, share or transfer Your Personal Data to third parties (“Recipients”) under the following circumstances:
        2. a) Legal Compliance: We may disclose Your Personal Data to comply with applicable laws, regulations, or legal processes served on us, such as court orders or government demands. This ensures that we fulfil our legal obligations while protecting Your rights. In the event of any requirement by court order, government or quasi-government agency to disclose Your Personal Data, We will disclose the same as may be legally required.

        b) Protection of Rights and Enforcement: We may share Personal Data to protect and defend our rights or enforce our agreements, including investigating potential violations of our Terms. This disclosure helps us maintain the integrity and security of the Services.

        c) Security and Public Safety: : If necessary, we may disclose Personal Data to protect the security and safety of our users, members of the public, or other important public interests. Such disclosures will only be made when legally permissible, and in good faith that they are required to safeguard individuals or prevent harm.

        d) Statistical and Analytical Purposes: We may share anonymized or aggregated Personal Data with Recipients for statistical and analytical purposes in order to enhance the performance of Reward Programme's algorithm, improve user experience, and develop new features.

        e) Merger and Acquisition: In the event the Services are or the Company is merged with, or acquired by, another company or its business or the Services or Company is transferred/sold, or in case of re-organization or re-structuring of Our business, We and Our affiliates may disclose or transfer Your Personal Data, wholly or in part, to another business entity, and You consent to such disclosure or transfer.
        You authorize Us to disclose, share or transfer such Personal Data to the Recipients. We may disclose, share and/or transfer such information to Recipients for the purpose stated in paragraph - 6 above including to provide You with enrol You as a participant in the Rewards Programme or any other activity conducted by Us, to provide the Services, to comply with Our legal obligations, to enforce Our Terms, or to prevent, detect, mitigate, and investigate fraudulent or illegal activities.
        You hereby provide Your express and explicit consent to Us for sharing Your Personal Data with the aforesaid Recipients for the legitimate business activities and for the purpose stated in paragraph 6 above.
  10. Retention of Personal Data
    1. Subject to applicable laws, the Personal Data so collected shall be retained only for a limited duration necessary to fulfil the purposes outlined herein and will be erased / deleted when we receive a request for erasure / deletion of Your Personal Data or withdrawal of consent for Your Personal Data, in accordance with the process set out in this Policy. In such instances, We may retain the Personal Data only where a longer retention period is required or permitted by law for fulfilling the purposes defined above. Once the purpose is achieved, all Personal Data will be deleted in a safe and secure mode.
  11. Non-Personal Information
    1. Non-Personal Data or Non-Personal Information (“NPI”) shall mean any data that does not personally identify You and may include unique system or hardware identifiers, system or application software, and peripherals.
    2. Any NPI, when clubbed with Personal Data to personally identify an individual shall be treated as Personal Data.
    3. The following is the manner in which We collect, use, share and retain NPI.
        4. a)Collection: You agree that We may collect diagnostic, technical, usage related information, for the usage purposes described below.

        b)Usage: The NPI is gathered periodically to provide and improve the Services therein to facilitate the provision of software updates, product support and other services to You (if any) and verify compliance with the terms of this Policy.

        c)Sharing: To enable the Services and any third party developers to improve their software, hardware and services designed for use with, or for, the Rewards Programme, We may also provide any such partner or third party developer with a subset of diagnostic information that is relevant to that partner's or developer's software, hardware and/or services, as long as the diagnostic information is in a form that does not personally identify You.

        d)Retention: The NPI so collected shall be retained only for a limited duration necessary to fulfil the purposes outlined herein unless a longer retention period is required or permitted by law and only for the purposes defined above. Once the purpose is achieved, all NPI may be deleted, however, in a safe and secure mode.

  12. Location Services
    1. The Rewards Programme, its licensees and agents, may access, collect and analyse Your usage of the Services and other information related to Your location on a regular basis through various technologies. This location data collection is intended to enhance the performance of the Services, improve the design, functionality, and content of the Services, and to offer personalized features. Please note that the collection of geo-location information requires the location settings to be enabled on Your device. The Rewards Programme may request that You enable these settings; however, granting permission for location data collection is optional and not mandatory. You have the choice to decline this permission, though certain features may be limited as a result.
    2. Except in cases where any specific services requested by You require or involve personal identification, We collect location data anonymously and in a form that does not personally identify You. By participating in the Rewards Programme, You agree and consent to transmission, collection, maintenance, processing and use of Your location data and queries to provide and improve such services.
  13. Your Rights
    1. We strive hard to keep Our records updated and accurate with Your latest Personal Data, including any other information that We may have about You. You shall be responsible to ensure that the Personal Data You provide from time to time is and shall be correct, complete, and up to date and You have all the rights, permissions and consents to provide such Personal Data. You will be required to inform Us by contacting Us in the manner provided under this Privacy Policy, whenever there is a change in the Personal Data possessed by Us in relation to you, like change in name, phone number, email address, etc.
    2. Your exercise of the rights mentioned herein will be subject to applicable law and conditions stipulated therein.
        3. a)Right to access Personal Data: Where We have relied on your consent to process your Personal Data, or where you have voluntarily provided your Personal Data for a specified purpose, you have the right to obtain information from Us as follows:
          (i) Summary of Personal Data and processing activities: You have the right to receive a summary of Your Personal Data that is being processed by Us, along with details regarding the processing activities undertaken by Us, in relation to your Personal Data.
          (ii) Identities of other entities: You have the right to know the identities of other entities with whom Your Personal Data has been shared by Us. This includes a description of the Personal Data shared with these entities.

        b)Right to correct, complete and update personal data:Where We have relied on your consent to process Your Personal Data, or where you have voluntarily provided your Personal Data for a specified purpose, you have the right to correct, complete, and update your Personal Data. This includes the right to:
          (i) Correct any inaccurate or misleading Personal Data.
          (ii) Complete your incomplete Personal Data.
          (iii) Update your Personal Data.

        c) Right to seek erasure / deletion of personal data: Where We have relied on your consent to process Your Personal Data, or where you have voluntarily provided Your Personal Data for a specified purpose, You have the right to request for the erasure / deletion of Your Personal Data, unless retention of such Personal Data is required for the specified purpose for which it was collected and processed, or for compliance with any law for the time being in force.
        d) Right to withdraw consent: Where We have relied on your consent to process Your Personal Data, You have the right to withdraw Your consent at any time through an option provided within the Rewards Programme]. Please note that withdrawal of Your consent will not be retrospective in nature and shall be applicable prospectively. You may note that the withdrawal of consent or deletion of certain Personal Data may lead to cancellation of Your participation in the Rewards Programme and certain features of the associated services can be restricted and may also lead to complete cessation of Your usage of the Services. Additionally, within a predefined duration as specified by the applicable laws, any Personal Data related to You will be removed from our records.
        e) Right to nominate an individual for exercising rights: You have the right to nominate any other person to exercise the rights mentioned from (a) to (d) above in case of your death or incapacity / inability to exercise the rights mentioned above due to unsoundness of mind or infirmity of body.
        Unless a specific mechanism for exercising a certain right has been mentioned above, for exercising your rights under this Policy, you may email Us at JioSphere.support@jio.com.
    3. We will respond to your request(s) within the timeframes and in the manner specified under applicable law.
    4. If You choose to amend or disable the spam categories, the Personal Data made available by You will be updated or disabled at Our systems and the older Personal Data will thereafter not be available in Our systems. You acknowledge and agree that We may keep and process Your Personal Data related to such request in order to be able to honour the request in accordance with applicable law.
    5. You can limit or opt-out of the collection and use of Your Personal Data for ad targeting by third parties via Your device settings.
    6. You acknowledge and agree that You may receive certain notifications relating to the Services on Your device or on Your registered contact for the purposes mentioned above. You agree that any communication so received by You from Us will not amount to spam, unsolicited communication or a violation of Your registration on the national do not call (DND) registry. At any given point of time, if You decide to not receive notification, You may turn off such notifications through the settings tab in the BBRP Vault.
  14. Security, Transfer and Compliance with Laws
    1. We strive to protect Your Personal Data against unauthorized disclosure, misuse, unlawful use, modification, loss or destruction. We take all reasonable measures and precautions, per standard industry practises, to keep Your Personal Data confidential. We ensure compliance with all applicable laws.
    2. We use reasonable administrative, technical, physical and managerial measures to safeguard Your Personal Data against loss, theft and unauthorized access, use and modification as per law. Unfortunately, no measures can be guaranteed to provide 100% security. Accordingly, We cannot guarantee the security of Your Personal Data. By continuing to participate in the Rewards Programme You are aware of such risk.
    3. We are committed to protecting Your Personal Data and ensuring that it is handled securely. We use reasonable administrative, technical, physical and managerial measures to not transfer, process, or store Your Personal Data outside the territory of India. All data collected by Us is stored and processed within India to maintain the highest standards of data protection in accordance with local laws.
    4. We do not engage in cross-border data transfers, ensuring that Your Personal Data remains within the jurisdiction and legal framework of India.
    5. Notwithstanding anything contained in this Privacy Policy or elsewhere, We shall not be held responsible for any loss, damage or misuse of your Personal Data, if such loss, damage or misuse is attributable to a Force Majeure Event. A “Force Majeure Event” shall mean any event that is beyond Our reasonable control 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, unauthorised access to computer data and storage device, computer crashes, breach of security and encryption, etc.
  15. Children's Personal Data
    1. The Rewards Programme is meant for adults. We do not knowingly collect Personal Data from children under 18 without permission from a parent or guardian. If You are a parent or a legal guardian and Your child under 18 has given Us Personal Data without Your permission, You can email us here JioSphere.support@jio.com. You can also write to us at the address listed below.
  16. Queries and Complaints
    1. We are committed to protect Your Personal Data collected and processed by Us and look forward to Your continued support for the same. In case of any feedback, grievances, queries or concern regarding the processing and protection of Your Personal Data, or any privacy-related feedback or concerns, You may contact: JioSphere.support@jio.com

      2. Address: Office - 101, Saffron, Nr. Centre Point, Panchwati 5 Rasta, Ambawadi, Ahmedabad - 380006, Gujarat, India

      Communication Address: Reliance Corporate Park, MIDC Industrial Area, Ghansoli, Navi Mumbai, Maharashtra 400701
  17. Right of Appeal
    1. If You are aggrieved with Our decisions as part of the grievance redressal process available to you under this Privacy Policy, You have the right to lodge an appeal with the relevant supervisory authority.