1. Introduction
This Privacy Policy explains how Hustle Ventures ("we", "us", "our"), operating Photos.Chat, collects, uses, processes, and protects information when you use our AI-powered style transformation service through WhatsApp.
Company: Hustle Ventures
Product/Service: Photos.Chat - AI-powered style transformation service
2. Information We Collect
2.1 Information You Provide
| Data Type | What We Collect | Purpose | Retention |
|---|---|---|---|
| WhatsApp Phone Number | Your WhatsApp number | Service communication, account identification | Until account deletion |
| Portrait Photos | Images you send for transformation | AI style transformation processing | 10 minutes maximum |
| Payment Information | Transaction data (via Razorpay) | Payment processing and order confirmation | Handled by Razorpay (not stored by us) |
| Usage Data | Points balance, transformation count | Service delivery and account management | Until account deletion |
2.2 Information We Do NOT Collect
- ❌ No Personally Identifiable Information (PII) beyond WhatsApp number
- ❌ No name, email, address, or demographic data
- ❌ No browsing history or device information
- ❌ No location data or GPS coordinates
- ❌ No tracking cookies or web analytics
3. How We Use Your Information
We use collected information solely for:
- Processing your photo transformations using AI models
- Delivering transformed images back to you via WhatsApp
- Managing your points balance and transaction history
- Providing customer support when requested
- Improving our service quality and AI model performance
4. Image Storage and Deletion
4.1 Image Processing Timeline
- Upload (0 min): You send a photo via WhatsApp
- Processing (2-5 min): AI transforms your image
- Delivery (5-7 min): Transformed image sent back to you
- Deletion (10 min): All copies automatically deleted
4.2 No Long-Term Storage
We do NOT:
- Store images in permanent databases
- Create backups of your photos
- Archive transformed images
- Use images for training AI models (without explicit consent)
5. Third-Party Services
Your images are processed by the following third-party AI services:
5.1 Replicate AI
- Used for AI style transformation processing
- Images processed per Replicate's terms of service
- Privacy Policy: replicate.com/privacy
5.2 Google Gemini AI
- Used for image analysis and content moderation
- Images processed per Google's AI guidelines
- Privacy Policy: policies.google.com/privacy
5.3 Razorpay (Payment Processing)
- Handles all payment transactions securely via UPI, cards, and wallets
- We do NOT store payment card details - all payment data is handled exclusively by Razorpay
- UPI Payments: No processing fees (0% fee) - recommended payment method
- Card/Wallet Payments: Standard payment gateway fee applies (~2% convenience fee)
- Payment Links: Payment links expire after 10 minutes for security
- Data Shared with Razorpay: Phone number, order amount, session ID (for transaction verification)
- Privacy Policy: razorpay.com/privacy
5.4 WhatsApp Business API (Meta)
- Used for messaging and communication
- Subject to WhatsApp's privacy policy
- Catalog Orders: When you select products from our catalog, Meta receives your order details (product IDs, quantities, phone number)
- Meta AI Integration: As of 2025, WhatsApp uses catalog interaction data for Meta AI training and improvement
- Cross-Platform Data Sharing: Meta may share your WhatsApp interaction data with other Meta companies (Facebook, Instagram)
- No End-to-End Encryption for Catalog Orders: Catalog order data is NOT end-to-end encrypted (unlike regular WhatsApp messages)
- Privacy Policy: whatsapp.com/legal/privacy-policy
5.5 WhatsApp Catalog Data Tracking (Meta)
When you browse or order from our WhatsApp Catalog, Meta (WhatsApp's parent company) receives and processes your order information, including product selections, quantities, and pricing. This data is used by Meta for analytics, business insights, and may be shared across Meta's family of companies (Facebook, Instagram, etc.).
What Meta Receives When You Use Our Catalog:
- Your WhatsApp phone number
- Product IDs you view and select
- Order quantities and timestamps
- Interaction patterns (how you browse our catalog)
- Transaction metadata (but NOT payment card details)
What Meta Does With This Data:
- Business analytics and insights
- Improving WhatsApp Business features
- Training Meta AI systems (as of 2025)
- Potential ad targeting across Meta platforms (subject to Meta's policies)
Your Control: By using our WhatsApp Catalog, you consent to Meta's processing of this data per their WhatsApp Privacy Policy and Business Data Processing Terms.
5.6 WhatsApp Business API Pricing Transparency
We use WhatsApp Business API to communicate with you. As of July 1, 2025, WhatsApp charges businesses per message sent. These costs are:
| Message Type | When It's Sent | Cost to Us | Cost to You |
|---|---|---|---|
| Your Messages to Us | When you send photos or text | Free | Free |
| Our Replies (within 24 hours) | Confirmation, style selections | Free | Free |
| Marketing Messages | Catalog displays, promotions | ~₹0.60 per message | Free |
Transparency Commitment: These WhatsApp API costs are included in our service pricing. You are NEVER charged extra for WhatsApp messages.
6. Data Security
We implement industry-standard security measures:
- 🔒 Encrypted data transmission (HTTPS/TLS)
- 🔒 Secure serverless architecture on Vercel
- 🔒 Automatic image deletion after processing
- 🔒 No permanent storage of sensitive data
- 🔒 Regular security audits and updates
7. Your Rights and Choices
7.1 Access and Deletion
You have the right to:
- Request deletion of your account and data
- Know what data we hold about you (limited to phone number and usage stats)
- Opt out of marketing communications (if applicable)
7.2 Data Portability
Since we do not store PII or images, there is minimal data to export. You can request your points balance and transaction history.
7.3 Right to Object
You can object to the processing of your images by ceasing to use our service.
8. Marketing and Promotional Use
9. Children's Privacy
Our service is available to users aged 13 and above. We do not knowingly collect information from children under 13. If you believe a child under 13 has used our service, please contact us immediately.
10. Data Retention
| Data Type | Retention Period | Reason |
|---|---|---|
| Photos (original & transformed) | 10 minutes | Processing only |
| WhatsApp phone number | Until account deletion | Account identification |
| Points balance | Until account deletion | Service delivery |
| Transaction records | 7 years (legal requirement) | Tax and accounting compliance |
11. International Data Transfers
Your data may be processed by third-party services located outside India (Replicate AI, Google Gemini). These services comply with international data protection standards.
12. Cookies and Tracking
We do NOT use cookies or tracking technologies. Our service is entirely WhatsApp-based, with no web tracking.
13. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. Changes will be posted with a new "Last Updated" date. Continued use of our service after changes constitutes acceptance of the updated policy.
14. DPDPA 2023 Compliance (India)
14.1 Data Fiduciary Statement
Hustle Ventures (operating Photos.Chat) acts as a Data Fiduciary under DPDPA 2023 for the following personal data:
- WhatsApp phone number (identifier)
- Portrait photos (temporary processing only - deleted within 10 minutes)
- Transaction records (payment history, points balance)
14.2 Legal Basis for Processing
We process your personal data under the following lawful grounds:
- Consent: You provide explicit consent when you use our WhatsApp service
- Contract Performance: Processing is necessary to deliver our AI transformation service
- Legal Obligation: Transaction record retention for tax compliance (7 years)
14.3 Your Rights Under DPDPA 2023
As a Data Principal (user), you have the following rights:
| Right | What It Means | How to Exercise |
|---|---|---|
| Right to Access | Know what personal data we hold about you | Message us on WhatsApp: +91 99005 31341 |
| Right to Correction | Request correction of inaccurate data | Message us with corrected information |
| Right to Erasure | Request deletion of your account and data | Send "DELETE MY ACCOUNT" via WhatsApp |
| Right to Grievance Redressal | Raise complaints about data handling | Contact our Data Protection Officer (details below) |
| Right to Nominate | Nominate someone to manage your data in case of death/incapacity | Email support@photos.chat with nominee details |
14.4 Data Protection Contact
For DPDPA 2023 related queries, grievances, or to exercise your data rights:
- Email: support@photos.chat
- WhatsApp: +91 99005 31341
- Response Time: We will respond to your request within 7 working days
Note: Photos.Chat is a bootstrapped startup. All data protection queries are handled directly by our founding team.
14.5 Cross-Border Data Transfers
Your personal data may be transferred outside India to the following locations:
- United States: Replicate AI (AI processing), Meta/WhatsApp (messaging)
- Global Cloud Infrastructure: Vercel (serverless hosting)
All cross-border transfers comply with DPDPA 2023 safeguards and are governed by standard contractual clauses approved by international data protection authorities.
14.6 Data Breach Notification
In the event of a data breach affecting your personal data:
- We will notify the Data Protection Board of India within 72 hours
- We will notify affected users via WhatsApp message within 7 days
- Notification will include: nature of breach, data affected, remedial actions taken
14.7 Consent Withdrawal
You can withdraw your consent for data processing at any time by:
- Sending "STOP" or "WITHDRAW CONSENT" via WhatsApp
- Requesting account deletion (this will terminate service access)
Note: Withdrawing consent may prevent us from providing our service. Transaction records will still be retained for 7 years as required by law.
15. Legal Compliance
We comply with applicable data protection laws, including:
- Digital Personal Data Protection Act (DPDPA), 2023 - India's comprehensive data protection law
- India's Information Technology Act, 2000
- Information Technology (Reasonable Security Practices) Rules, 2011
- WhatsApp Business API Terms of Service
- Meta Business Terms and Data Processing Terms
- Payment gateway regulations (Razorpay compliance with RBI guidelines)
16. Contact Us
For questions about this Privacy Policy or to exercise your rights, contact us:
- WhatsApp: +91 99005 31341
- Email: support@photos.chat
- Support Hours: 9:00 AM - 10:00 AM IST (Daily)