1. Information We Collect

1.1 Information You Provide Directly

When you register or use the Application, we collect the following information:

• Full legal name, Mobile phone number, Email address (optional, provided at your discretion) and Date of birth
• KYC documents: Aadhaar Card photograph, PAN Card photograph, Driving License photograph
• Bank account details: account number, IFSC code, and account holder name
• Booking requests and associated notes you submit when requesting Benefits from Company Partners

1.2 Information Collected Automatically

When you use the Application, we may automatically collect:

• Device information, including device model, operating system version, and unique device identifiers
• App usage data, including screens visited, features used, and session duration
• Push notification token for delivering notifications to your device
• Network and connectivity information

1.3 Information from Third Parties

We do not currently receive personal information about you from third-party sources. OTP verification services may process your phone number solely for the purpose of identity verification.

2. How We Use Your Information

We use the personal information we collect for the following purposes:

• To verify your identity and process your registration on the Application.
• To activate your paid membership following confirmation of payment.
• To manage and display your position within the referral network (binary tree).
• To calculate, record, and display referral income in your Wallet.
• To process and manage Withdrawal Requests upon KYC approval.
• To facilitate booking of Benefits with Company Partners by sharing your name, phone number, and booking notes with the relevant Company Partner.
• To send you push notifications regarding Wallet activity, booking updates, new Benefits, and Withdrawal Request status.
• To allow you to share the Application with others.
• To respond to your support queries and grievances.
• To maintain the security and integrity of the Application.
• To comply with applicable legal obligations.

3. Legal Basis for Processing

We process your personal information on the following bases:

• Contractual necessity: Processing is required to fulfil our obligations to you under these Terms and to provide the services you have registered for.
• Legitimate interests: Processing is necessary for the security and proper functioning of the Application, fraud prevention, and communication with you.
• Legal obligation: Processing may be required to comply with applicable Indian laws and regulations.
• Consent: Where you have provided consent for specific processing activities (such as optional information you choose to share), which you may withdraw at any time.

4. How We Share Your Information

4.1 With Company Partners

When you submit a booking request for a Benefit, we share the following information with the relevant Company Partner:

• Your full name
• Your mobile phone number
• Any additional note you have included in the booking request

This sharing is limited to what is necessary for the Company Partner to process and fulfil your booking request. Company Partners are not authorised to use this information for any other purpose.

4.2 With the Owner

The Platform Owner (administrator) has access to all User information for the purposes of account management, KYC verification, payment confirmation, Withdrawal Request processing, and support.

4.3 Service Providers

We may share your information with third-party service providers who assist us in operating the Application, including cloud hosting providers and communication or OTP verification services. These service providers are permitted to use your information only as necessary to provide services to us and are required to maintain appropriate security measures.

4.4 Legal Compliance

We may disclose your personal information if required to do so by applicable law, court order, or at the request of a competent government or regulatory authority in India. We may also disclose information where we believe disclosure is necessary to protect our rights, the safety of Users, or to prevent fraud or illegal activity.

4.5 No Sale of Data

We do not sell, rent, or trade your personal information to any third party for commercial purposes.

5. KYC and Financial Information

KYC documents (Aadhaar, PAN, Driving License) and bank account details are particularly sensitive. We treat this information with the highest level of care:

• KYC documents are used solely for verifying your identity and eligibility for withdrawals.
• Bank details are used solely for processing approved Withdrawal Requests.
• This information is stored securely and is accessible only to authorised personnel of the Owner.
• We do not share KYC or banking information with Company Partners or any third parties except as required by law.

6. Data Retention

We retain your personal information for as long as your account is active or as necessary to provide you with services. Upon account deletion:

• Your profile and network data will be removed from the active Application.
• Transaction records and KYC documents may be retained for a period required to comply with applicable legal and regulatory obligations.
• Wallet balance and pending Withdrawal Requests will be forfeited and records retained for audit purposes.

We may retain anonymised or aggregated data that cannot identify you personally for analytical purposes without time limitation.

7. Account DeletionData Security

We implement appropriate technical and organisational security measures to protect your personal information against unauthorised access, disclosure, alteration, or destruction. However, no method of transmission over the internet or electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your information, we cannot guarantee its absolute security.

You are responsible for maintaining the confidentiality of your account credentials. Please do not share your OTP, login details, or account access with any third party.

8. Push Notifications

The Application sends push notifications to your device for events such as:

• New booking requests (for Company Partners)
• Booking request status updates (for Users)
• Wallet credits
• Withdrawal Request status updates
• New Benefits posted by Company Partners

You may disable push notifications through your device settings. Please note that disabling notifications may affect your awareness of important account activity.

9. Children's Privacy

The Application is intended for use by individuals who are 18 years of age or older. We do not knowingly collect personal information from anyone under the age of 18. If we become aware that we have inadvertently collected information from a person under 18, we will take steps to delete such information promptly. If you believe a minor has registered on the platform, please contact us immediately.

10. Your Rights

Subject to applicable Indian law, you have the following rights in relation to your personal information:

• Access: You may request access to the personal information we hold about you.
• Correction: You may request correction of inaccurate or incomplete personal information.
• Deletion: You may request deletion of your account and personal information, subject to legal retention obligations.
• Withdrawal of Consent: Where processing is based on your consent, you may withdraw that consent at any time, though this will not affect the lawfulness of processing prior to withdrawal.

To exercise any of these rights, please contact us at the details provided in Section 12 below.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or for other reasons. The updated version will be made available within the Application with the revised effective date. Your continued use of the Application after any changes constitutes your acceptance of the updated Privacy Policy. We encourage you to review this Policy periodically.

12. Governing Law

This Privacy Policy is governed by the laws of India. Any disputes arising in relation to this Policy shall be subject to the exclusive jurisdiction of the courts located in Maharashtra, India.

13. Contact Us

If you have any questions, concerns, or grievances regarding this Privacy Policy or our data practices, please contact us at:

Email: dharmaspa1977@gmail.com

Phone: +91 9892062001