Privacy Policy

1. What is this Privacy Policy?

This Privacy Policy explains how Gum (“we”, “us”, or “our”), owned and operated by Disco Theory Private Limited, collects, uses, stores, discloses, and protects your personal information when you use the Gum mobile application and related services (collectively, the “Platform”).

This Policy forms part of our Terms and Conditions of Use. We encourage you to read both documents carefully. Our correspondence address is: legal@passthatgum.com

2. Information We Collect

2.1 Information You Provide

• When you register or create an account: name, email address, phone number, date of birth, username, password, and profile details.
• Profile and User Content: photographs, event logs, artist cards, reviews, messages, interests, preferences, and other content you upload or share.
• Information provided when contacting support, participating in surveys, promotions, competitions, or using in-app communication features.

2.2 Information Collected Automatically

When you use the Platform, we automatically collect:

• Technical and device information: Internet Protocol (IP) address, device ID, device type and model, operating system, browser type and version (if applicable), app version, time zone setting, and unique device identifiers.
• Usage and activity data: full clickstream data (including Uniform Resource Locators (URLs) visited within the app), page response times, download errors, session duration, features accessed, scrolls, clicks, taps, and other interaction metrics.
• Location data: precise or approximate GPS-based location, collected only with your explicit permission. This enables features such as discovering nearby events, syncing with attendees at the same venue, and proximity-based matching. You can enable or disable location services through your device settings at any time.
• Cookies and similar tracking technologies: We use cookies, tracking pixels, local shared objects (also known as flash cookies), and other automated mechanisms to remember your preferences, analyse usage, personalise your experience, and improve functionality. Gum uses cookies and similar technologies to operate, maintain user sessions, remember preferences, improve functionality, and better understand how users interact with Gum. These technologies may collect limited technical information such as device type, browser information, IP address, and usage patterns. Gum does not use cookies to sell user data, or for third-party advertising purposes. Users may control or disable cookies through their browser settings; however, doing so may affect certain features of Gum.

2.3 Information from Third Parties

• If you sign in using Google, Apple, Facebook, or other social media accounts, we may receive basic profile information (such as name, email, profile picture, and public details) subject to your privacy settings on those platforms.
• Data from Third Parties including event organisers, or other service providers, where lawfully shared with us.

3. How We Use Your Information

We use the collected information to:

• Create, verify, and manage your account and provide access to the Platform.
• Enable core features including event discovery, location-based services, friend syncing, artist/event card logging, and community engagement.
• Personalise content, recommendations, and your overall experience.
• Process transactions (if any) and send confirmations.
• Send important service notifications, updates, and (only with your consent) marketing or promotional messages via push notifications, email, or SMS.
• Analyse usage, troubleshoot issues, conduct research, statistical analysis, and improve the Platform’s performance and security.
• Detect and prevent fraud, misuse, or violations of our Terms.
• Comply with legal obligations and respond to lawful requests from authorities.

4. Location Services

Location data is essential for many features of Gum. We collect it through your device’s GPS, location services, and related technologies only with your consent. Disabling location permissions will limit or disable features such as memory logging, event discovery and proximity matching.

5. Sharing Your Information

We do not sell your personal information. We may share it as follows:

• With trusted service providers and processors (e.g., cloud hosting, analytics, payment gateways, customer support) under strict confidentiality and data processing agreements.
• With event organisers, venue partners, or other users where necessary for the features you use (on an anonymized basis) (e.g., sharing profile details at an event).
• On an aggregated or anonymised basis with advertisers, analytics providers, or partners for insights and optimisation.
• With affiliates, pursuant to any form of corporate restructuring
• When required by law, to protect rights, safety, or property, or to enforce our Terms.

6. Children

Gum is intended for users aged 18 and above. We do not knowingly collect personal information from children under 18. If we become aware that we have collected such data, we will delete it promptly.

7. Data Security

We implement reasonable technical and organisational safeguards to protect your information, including encryption (such as SSL/TLS for data in transit), secure servers, access controls, and regular security reviews. However, no method of transmission over the internet or electronic storage is 100% secure. You are responsible for keeping your account password and login credentials confidential.

8. Data Retention

We retain your personal information only for as long as necessary to fulfil the purposes outlined in this Policy, comply with legal obligations, resolve disputes, and enforce our agreements. When you delete your account, we will delete or anonymise your data as per our retention practices.

9. Your Rights and Choices

You may:

• Access, review, update, or correct your information through the app settings.
• Delete your account and associated data.
• Opt out of marketing communications and push notifications via app settings or by contacting us.
• Withdraw consent for certain processing activities (which may affect your ability to use parts of the Platform).

For other data rights requests, contact us at the details below.

10. International Transfers

Your data may be transferred to, stored, and processed outside India (including in jurisdictions that may not offer the same level of protection). We ensure appropriate safeguards are in place as required under applicable data protection laws.

11. Changes to this Policy

We may update this Privacy Policy from time to time. Material changes will be notified through the app or email. Your continued use of Gum after such changes constitutes acceptance of the revised Policy.

12. Grievance Officer

In accordance with Digital Personal Data Protection Act, 2023, our Grievance Officer is: Rakshith Reddy Katpally, Disco Theory Private Limited, legal@passthatgum.com.

You may contact the Grievance Officer with any complaint about how we handle your personal data. We aim to acknowledge complaints within two working days and respond within 30 days.

13. Contact Us

If you have any questions, complaints, or concerns about this Privacy Policy or our data practices, please contact us at: legal@passthatgum.com

We aim to respond to all enquiries within 30 days.