1. Introduction & Scope

Miloner (“we”, “us”, “our”, “the App”) is a social connection platform that lets adult users talk to each other through voice calls, private chat and community chat. This Privacy Policy explains how we collect, use, store, share, transfer, and protect your personal information when you use the Miloner Android app and our website miloner.online. It applies to all users, including male users, female experts, visitors, and anyone who interacts with our services. We aim to comply with:

• India: Information Technology Act, 2000; IT (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011; IT (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021; Digital Personal Data Protection Act, 2023 (DPDP Act).
• European Union / UK: General Data Protection Regulation (GDPR) 2016/679 and UK GDPR.
• United States (California): California Consumer Privacy Act (CCPA) as amended by CPRA.
• Brazil: Lei Geral de Proteção de Dados (LGPD) Law No. 13,709/2018.
• Other jurisdictions: We follow internationally recognised privacy principles where no local law exists.

Please read this Policy carefully. By creating an account and using Miloner, you acknowledge that you have read and understood this Policy. Where the law requires your consent (for example, for sensitive data or personalised ads), we ask for it separately inside the App. If you do not agree with this Policy, please do not use the App, or delete your account as described in Section 11.

2. Definitions

• Personal Data: Any information relating to an identified or identifiable natural person (e.g., name, email, phone number, device ID, IP address).
• Sensitive Personal Data: Voice recordings, video recordings, government‑issued ID proofs (Aadhaar, PAN, passport, driver’s license) and financial information such as bank account / UPI details.
• Processing: Any operation performed on personal data – collection, recording, organisation, storage, adaptation, retrieval, consultation, use, disclosure, combination, restriction, erasure, or destruction.
• Data Controller / Data Fiduciary: Miloner (we decide the purposes and means of processing).
• Data Processor: A third party that processes personal data on our behalf (e.g., Agora, Google Firebase, Supabase, Cashfree, Google AdMob).
• User: Any individual who creates an account or uses the Miloner app.
• Male User: A user registered with gender “male”, who can call female experts.
• Female Expert: A user registered with gender “female” who has passed voice verification and can receive calls and earn.
• Admin Panel: Internal dashboard accessible only to authorised Miloner staff/moderators for user management, content moderation, verification approvals, and payout processing.
• Community Guidelines: Rules governing user conduct; violation may lead to warnings, suspension, or permanent ban.
• SOS / Report: Feature allowing users to report inappropriate behaviour or harassment.
• GDPR: General Data Protection Regulation (EU).
• CCPA: California Consumer Privacy Act.
• DPDP Act: Digital Personal Data Protection Act, 2023 (India).
• LGPD: Lei Geral de Proteção de Dados (Brazil).

3. Types of Information We Collect

3.1 Account & Profile Information

• Name / display name (required, shown on your profile).
• Email address or mobile phone number (required for registration and login; one of these is used as your login ID).
• Password (stored only as a secure hash by Firebase Authentication – we never see your password).
• Mobile phone number (used for login and password recovery via one‑time password (OTP) sent by SMS).
• Age confirmation (you must confirm that you are at least 18 years old).
• Gender (male/female, required because app features differ by gender).
• City (optional, entered by you; used for profile display and suggestions). We do not collect GPS / precise location.
• Profile photo (optional, shown to other users).
• Languages, interests, bio and other profile details you choose to add.

3.2 Sensitive Personal Data (explicit consent required)

• Voice recordings: A short voice sample recorded during voice verification (female experts only). Used only for admin review/approval. Deleted within 30 days after the admin decision.
• Video recordings: A short self‑introduction video recorded during higher‑tier (Gold/Diamond) verification. Used only for identity confirmation by a human admin. Deleted within 30 days after the verification decision.
• ID proof images: Aadhaar, PAN, passport, or driver’s license uploaded for Silver/Gold verification. Used only for identity confirmation. Deleted within 30 days after the verification decision. We recommend masking your Aadhaar number (showing only the last 4 digits).
• No biometric processing: We do not create facial recognition templates, voiceprints, or any other biometric identifiers. Verification is done manually by a human reviewer.

3.3 Call and Communication Data

• Call logs: start/end time, duration, cost, caller ID, receiver ID, call type (free / paid).
• Voice call audio: transmitted in real time via Agora. We do not record or store call audio.
• Chat messages: private messages and community chat messages, stored in Google Firebase (Cloud Firestore / Realtime Database). Messages are encrypted in transit (TLS) and at rest by our cloud provider, and protected by access rules. Messages are not end‑to‑end encrypted; authorised admins may review them only when investigating a report, a safety issue, or a legal request.

3.4 Wallet, Payment and Payout Data

• Recharges: Recharge amount, order ID, transaction ID, payment status, date, balance before/after, applied discount. Payments are processed by our payment gateway Cashfree Payments. Your card number, CVV, UPI PIN or net‑banking password are entered on Cashfree’s secure interface and are never received or stored by Miloner.
• Withdrawals (female experts): Amount, UPI ID and/or bank account details (account holder name, account number, IFSC), status (pending/approved/rejected), processing date, transaction reference.
• Call deductions: Each minute deducted from the wallet, with timestamp.

3.5 Level and Bonus Data

• Total call minutes accumulated (rolling 30 days).
• Current level.
• Bonus amounts claimed (weekly, monthly, streak).
• Commission percentage based on level.
• Leaderboard rank.

3.6 Referral Data

• Your unique referral code.
• Users you referred (their user IDs and timestamps).
• Rewards earned (free minutes or message credits).

3.7 Reports, Blocks and SOS Data

• When you report another user: reporter ID, reported user ID, reason, timestamp, and any screenshots you attach.
• Users you have blocked.
• Outcome of the report: resolved, rejected, or escalated.

3.8 Technical and Device Data

• Device model and manufacturer.
• Operating system version.
• Device identifiers: Android ID, Firebase Installation ID, push notification (FCM) token.
• Google Advertising ID (resettable by you).
• App integrity signals from Google Play Integrity / Firebase App Check (used to block fake or modified apps and bots).
• IP address (used for security and approximate country/region – not precise location).
• Network type (Wi‑Fi / mobile data).
• App version and build number.
• Crash logs and diagnostics (via Firebase Crashlytics).
• In‑app usage events (via Firebase Analytics), such as screens viewed and features used.

3.9 Permissions Requested

We request each permission only when the related feature is used. You can withdraw any permission at any time in your device Settings → Apps → Miloner → Permissions.

We do not access your contacts, call logs, SMS, precise location, or files outside what you choose to upload.

3.10 Data from Third Parties

• Payment status and transaction references from Cashfree Payments when you recharge your wallet.
• Phone number verification result from Firebase Authentication when you use OTP.
• We do not import data from social media platforms and do not buy data from data brokers.

4. Sensitive Data & Explicit Consent (GDPR Art. 9, DPDP Act)

We treat voice recordings, video recordings, ID proofs, and bank/UPI details as sensitive personal data. Before collecting voice, video or ID proof, we show a clear in‑app notice explaining what is collected and why, and ask for your explicit consent. You may withdraw consent at any time by emailing support@miloner.com or by deleting your account; we will then delete the related verification files. Withdrawal does not affect processing that happened before withdrawal. Without this consent, you cannot become a voice‑approved female expert or obtain higher verification badges, but you can still use the other features of the App.

5. Collection Methods

• Directly from you: When you register, fill your profile, upload photos, record voice/video, send messages, make calls, recharge your wallet, request withdrawals, or submit reports.
• Automatically: Through our servers and the SDKs listed in Section 9 when you use the App – device information, IP address, call duration, usage events, crash logs.
• From third parties: Payment status from Cashfree; OTP verification result from Firebase Authentication.

6. Legal Bases for Processing (GDPR Art. 6, DPDP Act)

7. How We Use Your Information

• ✅ Create and manage your account and log you in securely.
• ✅ Enable real‑time voice calls between users.
• ✅ Provide community chat and private messaging.
• ✅ Process wallet recharges, deduct call costs, and calculate expert earnings.
• ✅ Handle withdrawal requests and pay out earnings to female experts.
• ✅ Review female expert voice samples to maintain quality and safety.
• ✅ Verify identity through video and ID proofs to issue trust badges (Silver, Gold, Diamond).
• ✅ Detect and block fake profiles, bots, spam, modified apps, and fraudulent activity.
• ✅ Review reported calls/chats for violations of our Terms (by human moderators).
• ✅ Send push notifications for incoming calls, new messages, level‑up bonuses, withdrawal status, and policy updates.
• ✅ Display advertisements (banner, interstitial, rewarded) – mainly to male users.
• ✅ Analyse usage patterns to improve performance and features.
• ✅ Fix bugs and crashes using crash logs.
• ✅ Develop new features using aggregated, anonymised data.
• ✅ Respond to law enforcement requests, court orders, or legal obligations.
• ✅ Enforce our Terms and Conditions and Community Guidelines.
• ✅ Investigate and resolve user reports (SOS).
• ✅ Calculate expert levels, bonuses, and leaderboard rankings.
• ✅ Manage referral programs and credit rewards.
• ✅ Prevent ban evasion by checking device identifiers.
• ✅ Provide customer support.

We do not use your data for any purpose that is incompatible with the purposes listed above without informing you and, where required, asking for your consent.

8. Local Storage, SDKs & Tracking (Mobile)

The Miloner app does not use traditional web cookies. However, we use:

• Local storage (SharedPreferences / app cache): Stores your login session, app settings, notification preferences, and cached images on your device. No third‑party access.
• Firebase Analytics: Uses the Firebase Installation ID and, where permitted, the advertising ID to measure in‑app events (screen views, feature use, call completions, level ups).
• Firebase Crashlytics: Collects crash reports and device state at the time of the crash.
• Firebase App Check / Play Integrity: Checks that requests come from the genuine Miloner app on a genuine device.
• Google AdMob SDK: Collects advertising ID, IP address, device type and ad interactions to serve and measure ads. You can reset your advertising ID or opt out of personalised ads (see Section 16).

We do not sell your data or share it with data brokers.

9. Data Sharing & Third‑Party Processors

We share personal data only with the service providers below, only to the extent needed to run the App, and under contracts that require them to protect your data.

Other disclosures: Your public profile (name, photo, city, gender, level, verification badge) is visible to other users. We may also disclose information (a) if required by law, court order, or a lawful government request; (b) to protect the rights, safety, or property of Miloner, our users, or the public, including fraud prevention; or (c) to a successor entity in a merger, acquisition, or sale of assets, in which case this Policy will continue to apply to your data. We do not sell your personal data.

10. International Data Transfers

We store our main databases in cloud regions we select for our backend (Google Firebase/Google Cloud and Supabase). Some of our service providers (such as Agora, Google AdMob, Firebase Analytics and Crashlytics) may process data on servers located outside India, including in the United States, Europe, and Singapore. Whenever data is transferred outside your country, we rely on safeguards required by applicable law – for users in the European Economic Area (EEA) and the United Kingdom, this includes the Standard Contractual Clauses (SCCs) adopted by the European Commission that our providers offer. Transfers from India are made in accordance with the DPDP Act and any restrictions notified by the Government of India. You may request more information by emailing support@miloner.com.

11. Data Retention and Account Deletion

11.1 How to delete your account – inside the App

1. Open Miloner and go to Settings → Delete Account.
2. Confirm by tapping Delete.
3. Your account is immediately deactivated and hidden from other users.
4. Your personal data is permanently deleted within 30 days.

11.2 How to delete your account – without the App

If you have uninstalled the App or cannot log in, send an email to support@miloner.com with the subject “Account Deletion Request” from the email address, or mentioning the phone number, registered with your account. We may ask you to confirm ownership of the account. We will complete the deletion within 30 days and confirm by email.

11.3 What is deleted and what is kept

• Deleted: Profile, photos, voice/video samples, ID proofs, chats, call history, referral data, device tokens, and bank/UPI details.
• Kept for a limited time: Wallet and payout transaction records (up to 8 years, required by tax law), records linked to an open investigation or legal claim (until resolved), and device identifiers of banned accounts (up to 3 years, to prevent ban evasion).
• You can also request deletion of some data (for example, only your verification files or profile photo) without deleting your account by emailing us.
• Any unused wallet balance is governed by our Terms and Conditions. Female experts should withdraw eligible earnings before requesting deletion.

12. Security Measures

• 🔐 Encryption in transit: TLS (HTTPS) for all data between your device and our servers.
• 🔐 Encryption at rest: Data stored in Google Cloud/Firebase and Supabase is encrypted at rest by those providers (AES‑256).
• 🔐 Secure authentication: Firebase Authentication with hashed passwords and SMS OTP verification.
• 🔐 Access control: Database and storage security rules ensure users can access only their own private data; only authorised admins can access the Admin Panel.
• 🔐 Server‑side protection: Sensitive operations such as wallet updates and payouts run only on our secure backend, not on your device.
• 🔐 App integrity: Firebase App Check / Play Integrity blocks requests from modified apps and bots.
• 🔐 Data minimisation: We collect only what is necessary and delete verification files after review.
• 🔐 Regular reviews: We update dependencies and review our security rules regularly.
• 🔐 Code protection: Production app code is minified and obfuscated.
• 🔐 Incident response: We have a documented procedure for handling data breaches.
• 🔐 Admin logging: Admin actions are logged.
• 🔐 Advertising ID separation: The advertising ID is not combined with your name, email or phone number.

Despite these measures, no method of transmission over the Internet or electronic storage is 100% secure. Please keep your password private and contact us immediately if you suspect unauthorised access to your account.

13. Your Rights (GDPR, CCPA, DPDP, LGPD)

• Right to Access (GDPR Art. 15 / DPDP s.11): Request a summary or copy of the personal data we hold about you.
• Right to Rectification (Art. 16 / DPDP s.12): Correct inaccurate information via your profile or by contacting us.
• Right to Erasure (Art. 17 / DPDP s.12): Delete your account from Settings or by email (see Section 11), except where retention is required by law.
• Right to Restrict Processing (Art. 18): Ask us to limit how we use your data in certain cases.
• Right to Data Portability (Art. 20): Request a machine‑readable copy (JSON/CSV) of your data.
• Right to Object (Art. 21): Object to processing based on legitimate interests (e.g., analytics).
• Right to Withdraw Consent: Withdraw consent at any time (e.g., for verification data or personalised ads), without affecting earlier processing.
• Right to Nominate (DPDP s.14): Indian users may nominate another person to exercise their rights in the event of death or incapacity.
• Right to Grievance Redressal / Complaint: Contact our Grievance Officer (Section 18), and/or file a complaint with your local Data Protection Authority (in India, the Data Protection Board of India).
• Right to Non‑Discrimination (CCPA): We will not discriminate against you for exercising your rights.

To exercise your rights, email support@miloner.com with “Privacy Request” in the subject line. We may verify your identity before acting on the request. We respond within 30 days (or sooner if required by local law).

14. Age Restriction – Adults Only (18+)

Miloner is strictly for users who are 18 years of age or older. The App is not directed at children, and we do not knowingly collect personal data from anyone under 18. Users must confirm they are 18+ during registration. If we learn that a user is under 18, we will immediately suspend the account and delete the associated personal data (except where we must keep limited data to meet legal obligations or protect child safety). If you are a parent or guardian and believe a person under 18 is using Miloner, please contact us at support@miloner.com.

We have zero tolerance for child sexual abuse and exploitation (CSAE). Any such content or behaviour results in an immediate permanent ban and will be reported to the relevant authorities, including the National Center for Missing & Exploited Children (NCMEC) and Indian law enforcement where applicable.

15. Third‑Party Links & Services

The App may contain links to external websites or services (e.g., the payment gateway, support pages, social media). When you open such links, you leave the Miloner app. We are not responsible for the privacy practices of those third parties, and we encourage you to read their privacy policies before providing any data.

16. Advertising & Your Choices (Google AdMob)

We use Google AdMob to show banner, interstitial, and rewarded ads (mainly to male users). AdMob may collect your advertising ID, IP address, and device information to show and measure ads. Your choices:

• Reset advertising ID: Settings → Google → Ads → Reset advertising ID (path may vary by device).
• Delete advertising ID / opt out of personalised ads: Settings → Google → Ads → Delete advertising ID. You will still see ads, but they will not be personalised.
• EEA/UK users: Where required by law, we ask for your consent before showing personalised ads, and you can change your choice at any time.
• Rewarded ads: Shown only when you tap “Watch ad”.

We do not request ads targeted on sensitive categories (such as health, religion, or sexual orientation). Learn more at How Google uses information from apps that use its services.

17. Data Breach Notification

If a personal data breach occurs, we will notify affected users and the relevant authorities as required by applicable law – including the Data Protection Board of India and CERT‑In (India), and the supervisory authority within 72 hours where GDPR applies. Notification will be sent to your registered email address and/or via an in‑app alert, and will describe the nature of the breach, likely consequences, and measures taken.

18. Grievance Officer (India – IT Rules 2021 & DPDP Act)

In accordance with the Information Technology Act, 2000, the IT (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021, and the Digital Personal Data Protection Act, 2023, the details of our Grievance Officer are:

• Name: Abhishek Kumar
• Email: grievance@miloner.com
• Address: Miloner, Hariwatika Chowk, Bettiah, West Champaran, Bihar – 845438, India
• Response time: Acknowledgment within 24 hours; resolution within 15 days of receipt. Complaints about content that exposes private areas of a person, nudity, or impersonation are acted on within 24 hours.

19. Specific Provisions for Indian Users (DPDP Act, IT Rules)

• Notice & Consent: This Policy serves as notice under the DPDP Act. We obtain your consent at registration, and separate explicit consent for sensitive data (voice, video, ID).
• Purpose limitation: Data is used only for the purposes stated in this Policy.
• Data retention: Financial records are kept as required by tax laws; other data is deleted on account deletion as described in Section 11.
• Data storage: We store data with reputable cloud providers and transfer it outside India only as permitted under the DPDP Act (see Section 10).
• Grievance redressal: Grievance Officer details are given in Section 18. If you are not satisfied, you may approach the Data Protection Board of India.
• Rights: Access, correction, erasure, grievance redressal, and nomination (Section 13).
• No profiling with legal effects: We make no fully automated decisions with legal or similarly significant effects.

20. California Residents (CCPA/CPRA)

• Right to Know: Request the categories and specific pieces of personal information we collected, the sources, the business purposes, and the categories of third parties with whom we share it.
• Right to Delete: Request deletion of personal information (subject to legal exceptions).
• Right to Opt‑Out of Sale/Sharing: We do not sell personal information. To opt out of personalised (cross‑context behavioural) advertising, delete or reset your advertising ID as described in Section 16.
• Right to Correct: Correct inaccurate information.
• Right to Limit Use of Sensitive Personal Information: We use sensitive data only for verification, payouts, and security.
• Right to Non‑Discrimination: We will not discriminate against you for exercising your rights.

To make a CCPA request, email support@miloner.com with “CCPA Request” in the subject. We will verify your identity before responding. Authorised agents may act on your behalf with written permission.

21. Brazilian Residents (LGPD)

Under the LGPD you have the rights listed in Section 13, plus:

• Confirmation that processing exists.
• Access to data.
• Correction of incomplete, inaccurate, or outdated data.
• Anonymisation, blocking, or deletion of unnecessary or excessive data.
• Data portability.
• Deletion of personal data processed with your consent.
• Information about public and private entities with which we have shared data.
• Information about the possibility of not giving consent and the consequences of refusal.
• Revocation of consent.

To exercise LGPD rights, email support@miloner.com.

22. Community & Content Moderation (Admin Panel)

Miloner works to keep a safe and respectful environment. Our Admin Panel is an internal tool used only by authorised moderators and administrators. Its capabilities include:

• Viewing user profiles, including verification status, wallet balance, call history, and reports.
• Reading community chat, and reading private messages only when investigating a specific report, safety issue, or legal request.
• Reviewing voice verification samples, video recordings, and ID proofs.
• Approving or rejecting verification requests.
• Managing withdrawal requests and processing payouts.
• Issuing warnings, temporary suspensions, or permanent bans.
• Deleting offensive messages, profile photos, or verification files.
• Freezing wallets during investigations.
• Blocking device identifiers to prevent ban evasion.
• Exporting user data to respond to legal requests or user data requests.
• Reviewing SOS reports and taking action.

Admin access is restricted to authorised personnel, and admin actions are logged.

23. Admin Panel Powers – Block, Suspend, Ban

• Warning: A formal notification sent to the user in‑app or by email. Repeated warnings may lead to suspension.
• Temporary Suspension: Account locked for a defined period (e.g., 7, 15, or 30 days). During suspension, the user cannot make calls, send messages, recharge, or withdraw.
• Permanent Ban (Account Termination): Account permanently disabled; data is then handled as described in Section 11. Reasons include severe harassment, hate speech, threats, explicit content, impersonation, fraud, child safety violations, or repeated violations.
• Content Removal: Specific messages, profile photos, or verification files can be removed without banning the user.
• Wallet Freeze: Temporarily prevents transactions or withdrawals pending investigation.
• Device Block: In severe cases (e.g., ban evasion), we may block a device identifier to prevent re‑registration.

24. Reporting, Blocking & Appeals

You can block any user at any time; blocked users can no longer call or message you. You can manage blocked users in Settings → Blocked Users.

To report a user, use the in‑app report option (available on user profiles, chats, and call screens) and provide:

• A reason (harassment, spam, explicit content, fake profile, underage user, etc.).
• Optional screenshot attachments.

Reports are usually reviewed by an admin within 24–48 hours. The admin may review the related chat logs, call history, and attached evidence. Outcomes:

• Resolved: Action taken (warning, suspension, ban).
• Rejected: No violation found.
• Escalated: Requires senior admin review.

Appeals: If your account receives a warning, suspension, or ban, you can appeal by emailing grievance@miloner.com with “Appeal – [Your User ID]” in the subject line, along with any additional context or evidence. A senior administrator will review the appeal and reply within 7 days. Appeals may result in reinstatement, a reduced penalty, or confirmation of the original action with reasons.

25. Grounds for Suspension or Permanent Ban

• Harassment / Bullying: Repeated offensive, threatening, or abusive language in calls or chats.
• Hate speech: Attacking or demeaning people based on race, religion, caste, gender, sexual orientation, disability, etc.
• Sexually explicit content: Sharing nudity or sexually explicit material, or soliciting sexual acts or sexual services.
• Child safety: Any content or behaviour that sexualises or endangers minors (immediate permanent ban and report to authorities).
• Impersonation: Pretending to be another person (including celebrities, other users, or Miloner staff).
• Fraud / Scam: Deceiving users for financial gain (e.g., fake recharge pages, phishing, asking users to pay outside the App).
• Spam / Automated activity: Bulk unsolicited messages, bots, or automated interactions.
• Ban evasion: Creating a new account after being banned.
• Illegal activity: Promoting or engaging in illegal acts (e.g., drug sales, violence).
• Fake profile: Fake photos, false identity, or fraudulent verification documents.
• Abusing the reporting system: Submitting false or malicious reports.
• Payment fraud: Chargebacks without valid reason, stolen cards, or manipulating the wallet system.
• Age violation: Registering under 18 years or misrepresenting age.
• Doxxing: Sharing another user’s personal information (address, phone number, etc.) without consent.
• Unauthorised access: Attempting to hack, reverse‑engineer, or bypass security measures.

We will give a reason for any action and an opportunity to appeal, except where immediate action is required for safety (such as child safety threats or legal orders).

26. No Automated Decision‑Making

We do not use fully automated decision‑making that produces legal or similarly significant effects on you. Moderation actions and verification approvals are made by human admins. Automated tools (such as spam filters and app integrity checks) may flag or temporarily block suspicious activity for review, but final decisions on bans and verification are made by humans.

27. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in our practices, legal requirements, or the App. When we make material changes, we will:

• Show an in‑app notice when you next open the App.
• Where appropriate, send an email to your registered email address.
• Update the “Last updated” date at the top of this page.

Where the law requires, we will ask for your consent again. If you do not agree with the updated Policy, you may stop using the App and delete your account.

28. Contact Us

• Support, privacy & account deletion requests: support@miloner.com
• Grievance Officer (India) & appeals: grievance@miloner.com
• Website: https://miloner.online
• Postal address: Miloner, Hariwatika Chowk, Bettiah, West Champaran, Bihar – 845438, India
• In‑app: Settings → Help

We aim to respond to all requests within 30 days. Urgent matters (e.g., safety issues, data breaches) are acknowledged within 24–48 hours.