adda365

Draft v0.1 — under legal review; not yet in force. Published for transparency while counsel settles the text.

Adda 365 — Privacy Policy

DRAFT v0.2 · 30 August 2026 · For counsel review — not yet in force. v0.2 incorporates the international annex: multi-market scope, per-regime legal bases and rights, transfers, and representatives. Drafted as the itemized, standalone, plain-language notice the DPDP Rules, 2025 require. Every claim below is mapped to what the system actually does; engineering references appear in italics and would be removed from the published version or kept — counsel's call (we recommend keeping them: verifiable claims are the brand).

Data Fiduciary / Controller: [Company name], [address] ("we"). Grievance Officer / DPO: [Name], [email] (appoint before launch; a DPO becomes mandatory on SDF designation in India and is prudent for EU/UK launches). EU representative (Art. 27): [appoint at EU launch]. UK representative: [appoint at UK launch].

1. The short version

We collect the minimum needed to run a verified, safe dating service for adults in India. We never see your Aadhaar number or date of birth. Your messages are encrypted at rest and are never sold, mined for advertising, or shared with advertisers — there are no third-party advertising or tracking SDKs in the app. Wellness activity is walled off from matching. You can see, correct, export the substance of, and erase your data.

2. What we collect, why, and for how long

Consent is requested per purpose at the point it first arises; each item below is a separate line in the consent record (DPDP §6, Rules 2025 notice requirements).

#DataPurposeRetention
1Phone number — stored only as a keyed one-way hash + last 4 digits (HMAC; the number itself is never stored)Account identity, login OTPsLife of account
2Age check result — a single yes/no "over 18" from DigiLocker (date of birth and document contents are discarded in the handler and never persisted or logged)Legal 18+ gateLife of account
3Liveness selfieAnti-impersonation checkUntil check passes + [30] days, then deleted
4Student proof (college email or ID image)Optional campus verificationID images: deleted at the moment of review decision — only the verdict remains
5Profile (name, department, bio, interests, prompts, photos) and the optional questionnaire (lifestyle, tastes, what you're looking for; validated against a fixed catalog — no free-form keys). Faith and politics are optional, sensitive, off by default, shown only if you fill them, clearable any time, and processed under explicit matching consentYour public profile and better match reasonsLife of account; each answer individually clearable
6Quiz answers, importance weights, this-or-that votesMatching (see §4)Life of account
7Messages and voice notesDelivering your conversationsUntil you delete them/your account; encrypted at rest (AES-256-GCM), with cryptographic integrity records (§6)
8Wellness activity — questions asked, circles joinedWellness features onlyPseudonymised under a separate identity; structurally severed from matching (a one-way database bridge the application role cannot reverse)
9Device identifiers, IP logsSecurity, fraud, CERT-In obligationsIP logs [180 days / 1 year — see counsel memo], then automatically purged
10Payment events for ticketsOrder fulfilment, refundsStatutory accounting periods. Card/UPI details never touch our systems — the RBI-regulated aggregator holds them
11Push tokensNotifications you enableUntil you log out, disable, or the token dies
12Intake/coach conversation textAI-assisted onboarding and coachingProcessed by our AI processor (§7); coach context is drawn from your recent messages at request time
13Consent recordsProof of your consents (DPDP Rules)7 years

We collect no location beyond your chosen campus/city, no contacts upload, no background tracking.

3. Legal basis — by your market

Withdrawing consent is as easy as giving it (Settings → Privacy) and stops the related processing prospectively; some features stop working when their data stops flowing.

4. Matching — what the algorithm sees

Matching uses your quiz answers, declared preferences, campus pool, and in-app interactions (likes, replies, game completions). It never uses wellness data (§2.8), message content, or verification documents. We show you reasons for a suggestion, never a score, and we cap how often any profile is shown to keep exposure fair. No fully automated decision produces legal or similarly significant effects; enforcement always involves a human.

5. Who receives data

We sell nothing and run no advertising. Processors, each under contract, receiving only what their function needs:

Government and courts: we disclose only against valid legal process, under our published evidence procedure, and we log every production.

6. Security — what we actually do

TLS 1.3 everywhere; message bodies AES-256-GCM encrypted at rest with keys held only on production systems; phone numbers hashed; per-conversation tamper-evident hash chains anchored daily to an independent timestamping authority (so history can be proven unaltered — and any tampering, including by us, is mathematically detectable); append-only audit logs; staff access role-restricted with second-factor authentication and every action audited; no identity documents at rest. Breach response: we will notify affected users and the Data Protection Board within 72 hours of confirming a notifiable breach (DPDP Rules, 2025).

7. Your rights (DPDP §§11–14)

8. Children

None. The Service is 18+, verified, before any social feature works.

9. Scope, markets, and international transfers

We offer the Service in the markets listed in the Terms' Schedule A. Today that is India (DPDP Act governs). At each international launch the corresponding regime applies in full to that market's users: GDPR (EU/EEA), UK GDPR + Data Protection Act 2018 (UK), and applicable state privacy laws (US).

Transfers. Your data is processed in [India / the hosting region in Schedule A] and by the processors in §5. For EU/UK users, transfers out of the EEA/UK rest on Standard Contractual Clauses (with the UK IDTA/addendum) plus transfer impact assessments; India currently has no adequacy decision. A data-processing agreement is in place with every processor, and our hosting providers are additionally bound by the data-protection law of their own jurisdictions.

10. Changes

Material changes are notified in-app before they take effect. Every version is archived with its date, and your consent record shows which version you accepted.