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INTRODUCTION

This Privacy Policy governs the collection, use, storage, and protection of personal information by NELEN ("we," "us," "our," or "Company"), a service operated by The Bhimavaram Community Network, India. This policy applies to all users ("you," "your," or "User") accessing or using our website, mobile applications, IPTV services, and related digital platforms (collectively, the "Services").

By accessing or using NELEN Services, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy. If you do not agree with any provision of this policy, please discontinue use of our Services immediately.

1. INFORMATION COLLECTION

We collect and process personal information to deliver, maintain, and improve our Services in accordance with applicable data protection laws, including the Information Technology Act, 2000 and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011.

1.1 Personal Identification Information

We collect the following personal information during account registration and service usage:

• Full name
• Email address
• Mobile telephone number
• Residential address (if applicable)
• Date of birth (for age verification purposes)
• Account credentials and authentication information

1.2 Financial and Transaction Information

For subscription management and payment processing:

• Transaction identification numbers
• Payment status and transaction history
• Subscription plan details and validity periods
• Billing information and invoices

1.3 Technical and Usage Data

We automatically collect certain technical information to ensure service quality, security, and optimal performance:

• Device identifiers (IMEI, MAC address, device ID) and hardware information
• Operating system type and version
• Application version and configuration settings
• Internet Protocol (IP) address and geolocation data
• Network information and connection quality metrics
• Service usage patterns, viewing preferences, and interaction data
• Login timestamps and session information
• Browser type, version, and language preferences
• Diagnostic and error reporting data

2. PURPOSE OF DATA PROCESSING

Your personal information is processed for the following legitimate business purposes:

Account Management

• Creating, maintaining, and securing user accounts
• Authenticating user identity and preventing unauthorized access
• Managing subscription plans, renewals, and modifications

Service Delivery

• Activating and provisioning IPTV services
• Ensuring content delivery and streaming quality
• Personalizing user experience based on preferences
• Technical support and troubleshooting

Communication

• Sending transactional notifications regarding account and subscription status
• Providing customer support and responding to inquiries
• Delivering important service updates and policy changes
• Notifying users of technical maintenance or service interruptions
• Sending promotional offers and marketing communications (with user consent)

Security and Compliance

• Detecting and preventing fraud, misuse, and unauthorized access
• Investigating security incidents and policy violations
• Complying with legal obligations and regulatory requirements
• Maintaining audit trails as required by law

Service Improvement

• Analyzing usage patterns to enhance platform functionality
• Conducting research and development for service optimization
• Evaluating and improving streaming quality and network performance
• Developing new features and services based on user feedback

We do not use your personal information for purposes incompatible with those disclosed in this Privacy Policy without obtaining your explicit consent.

3. DATA SHARING AND DISCLOSURE

We maintain strict confidentiality of your personal information. We do not sell, rent, lease, or trade your personal data to third parties for their marketing purposes.

Personal information may be disclosed only in the following circumstances:

3.1 Service Providers and Business Partners

We may share limited information with carefully selected third-party service providers who assist in:

• Payment processing and transaction verification
• IPTV content delivery network operations
• Cloud infrastructure and data hosting services
• Customer relationship management systems
• Technical support and maintenance services
• Analytics and performance monitoring tools

All such third parties are contractually obligated to maintain confidentiality and use your information solely for providing services to NELEN. We conduct due diligence to ensure service providers implement appropriate security measures.

3.2 Legal and Regulatory Compliance

We may disclose personal information when required by law or in good faith belief that such action is necessary to:

• Comply with legal obligations, court orders, or judicial proceedings
• Respond to lawful requests from government authorities, law enforcement agencies, or regulatory bodies
• Enforce our Terms of Service and protect our legal rights
• Investigate potential violations of our policies
• Protect the safety, security, and integrity of our Services and users
• Comply with regulations issued by the Telecom Regulatory Authority of India (TRAI) and other applicable authorities

3.3 Business Transfers

In the event of a merger, acquisition, reorganization, or sale of assets, your personal information may be transferred to the successor entity, subject to the same privacy protections outlined in this policy. We will provide notice before your information is transferred and becomes subject to a different privacy policy.

4. DATA RETENTION

We retain personal information only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

• Active Accounts: Information is retained throughout the duration of your active subscription and account status
• Inactive Accounts: Following account closure or subscription termination, we may retain certain information for a reasonable period to:
  • Complete pending transactions and resolve disputes
  • Comply with legal, tax, accounting, and regulatory obligations
  • Prevent fraud and enforce our agreements
  • Maintain business records as required by law

Retention periods are determined based on the nature of the information, applicable legal requirements, and legitimate business needs. Typically, financial records are retained for seven years in accordance with accounting standards, while other personal data may be deleted within 30 days of account closure unless legally required otherwise.

5. DATA SECURITY

We implement commercially reasonable technical, administrative, and physical security measures designed to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include:

• Secure Socket Layer (SSL)/Transport Layer Security (TLS) encryption for data transmission
• Industry-standard encryption for data at rest
• Multi-factor authentication and access controls
• Regular security assessments and vulnerability testing
• Employee training on data protection and confidentiality
• Network security monitoring and intrusion detection systems
• Secure data centers with physical access controls
• Regular data backups with secure off-site storage

6. COOKIES AND SIMILAR TECHNOLOGIES

NELEN uses cookies, web beacons, pixel tags, and similar tracking technologies to enhance user experience and analyze platform performance.

Types of Cookies Used:

• Essential Cookies: Required for basic website functionality, authentication, and security. These cannot be disabled.
• Performance Cookies: Collect anonymous information about how users interact with our Services to improve performance.
• Functionality Cookies: Remember user preferences and settings for enhanced experience.

Purpose of Cookies:

• Maintaining user sessions and authentication status
• Remembering user preferences and settings
• Analyzing usage patterns and traffic statistics
• Optimizing platform functionality and performance
• Personalizing content recommendations

User Control: You may configure your browser or device settings to refuse cookies or alert you when cookies are being sent. However, disabling cookies may limit your ability to access certain features of our Services. For more information about specific cookies used, please contact us at the address provided below.

7. USER RIGHTS

Subject to applicable law, including the Information Technology Act, 2000 and related rules, you have the following rights regarding your personal information:

• Right to Access: Request confirmation of whether we process your personal data and obtain a copy of such information
• Right to Rectification: Request correction of inaccurate or incomplete personal information
• Right to Erasure: Request deletion of your personal information, subject to legal retention obligations and legitimate business needs
• Right to Restrict Processing: Request limitation of processing activities under certain circumstances
• Right to Data Portability: Request transfer of your data to another service provider in a structured, commonly used format (where technically feasible)
• Right to Object: Object to processing of your personal information for specific purposes
• Right to Withdraw Consent: Withdraw previously provided consent for data processing (where consent is the legal basis for processing)

To exercise any of these rights, please submit a written request to: contact@nelen.in

We will respond to your request within a reasonable timeframe (typically within 30 days) as required by applicable law. We may require identity verification before processing requests to protect against unauthorized disclosure. If we deny a request, we will provide an explanation for the denial.

8. THIRD-PARTY SERVICES AND CONTENT

NELEN provides access to third-party Over-The-Top (OTT) platforms, IPTV content providers, and external websites. Please note:

• Third-party platforms operate independently and maintain their own privacy policies
• NELEN is not responsible for the privacy practices, content, or data collection activities of third parties
• Links to external websites do not constitute endorsement or responsibility for their content or practices
• We encourage users to review the privacy policies of any third-party services before providing personal information

Your interactions with third-party platforms are governed by their respective terms and privacy policies. We do not control and are not liable for the privacy practices of these third parties.

9. CHILDREN'S PRIVACY

NELEN Services are intended exclusively for individuals aged 18 years or older. We do not knowingly collect, use, or solicit personal information from children under the age of 18.

If you believe we have inadvertently collected information from a minor, please contact us immediately at contact@nelen.in, and we will take prompt action to delete such information from our systems.

Parents and guardians are responsible for monitoring and supervising their children's internet usage. We recommend implementing parental controls and actively reviewing children's online activities.

10. INTERNATIONAL DATA TRANSFERS

Your personal information is primarily processed and stored within India. If information is transferred to other jurisdictions for service delivery or operational purposes, we ensure appropriate safeguards are in place to protect your data in accordance with applicable data protection laws.

Such safeguards may include standard contractual clauses, adequacy decisions by regulatory authorities, or other legally recognized transfer mechanisms. We ensure that recipient jurisdictions provide an adequate level of data protection as required under Indian law.

11. POLICY AMENDMENTS

We reserve the right to modify, update, or replace this Privacy Policy at any time to reflect:

• Changes in applicable laws and regulations
• Enhancements to our Services or business practices
• Technological developments or security improvements
• Operational or organizational changes

Notice of Changes:

Material changes to this Privacy Policy will be communicated through:

• Email notification to registered users
• Prominent notice on our website and applications
• Updated "Last Updated" date at the top of this document

Acceptance: Your continued use of NELEN Services following the posting of changes constitutes acceptance of the revised Privacy Policy. If you do not agree to the updated terms, you must discontinue use of our Services. We encourage you to review this policy periodically to stay informed about how we protect your information.

12. DATA BREACH NOTIFICATION

In the event of a data security breach that may compromise your personal information, we will:

• Notify affected users within 72 hours of becoming aware of the breach
• Inform relevant regulatory authorities as required by law
• Provide details about the nature and scope of the breach
• Advise on steps users can take to protect themselves
• Implement remedial measures to prevent future occurrences

13. GRIEVANCE REDRESSAL

In accordance with the Information Technology Act, 2000 and applicable rules, NELEN has appointed a Grievance Officer to address user concerns regarding privacy and data protection.

Users may contact the Grievance Officer for any complaints, concerns, or queries regarding this Privacy Policy or our data practices.

14. GOVERNING LAW AND JURISDICTION

This Privacy Policy is governed by and construed in accordance with the laws of India, including but not limited to the Information Technology Act, 2000, and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011.

Any disputes arising from or relating to this Privacy Policy shall be subject to the exclusive jurisdiction of the courts located in Bhimavaram, Andhra Pradesh, India.

15. CONTACT INFORMATION

For questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

16. ACKNOWLEDGMENT AND CONSENT

By using NELEN Services, you acknowledge that:

• You have read and understood this Privacy Policy in its entirety
• You consent to the collection, use, and disclosure of your personal information as described herein
• You are at least 18 years of age or have obtained parental/guardian consent to use our Services
• You understand your rights and our obligations regarding personal data protection
• You agree to comply with all applicable laws and regulations while using our Services

This Privacy Policy represents the complete agreement between NELEN and users regarding the collection and use of personal information through our Services. This policy supersedes all prior agreements, understandings, and communications regarding privacy matters.