Enforcement Date: 25th April 2025

1. INTRODUCTION

Welcome to the VLNCY Privacy Policy ("Policy"). This Policy elucidates the methodologies governing the collection, storage, safeguarding, and dissemination of your personal information and delineates the parties with whom such information is shared. It is expected and assumed that you shall continuously keep yourself informed of the contents of this Policy, in conjunction with our End User License Agreement (“EULA”)/Terms and Conditions of Use.

During your engagement with the VLNCY mobile application, inclusive of its desktop version (collectively referred to as the "App"), our websites and microsites, such as vlncy.org/vlncy.co.in/vlncy.com/vlncy.in/vlncy.net, or any other site/URL offered by Us (“Website(s)”), or your utilisation of our digital products and services, including but not limited to competitions and surveys, collectively referred to as "Sites" or “Platform”, we undertake the collection of certain information pertaining to you. Furthermore, you may opt to use the App and/or Sites to disseminate information to other users, encompassing your friends and contacts on the App ("Other Users").

The App and Sites are administered by "VLNCY", which is owned and operated by Strangequark India Private Limited, (hereinafter referred to as "we" or "us" or “the Company”), who will be the data controller(s)/data fiduciary(ies) responsible for the collection and processing of personal information through the VLNCY App and Sites.

We have duly designated a Data Protection Officer ("DPO") as mandated by the Digital Personal Data Protection Act of 2023 ("DPDPA”), who may be reached via email at DPO@VLNCY.com or through postal correspondence addressed to the following location: A-904, Salarpuria Silverwoods, Vartur Road, Nagavara Palya, Bangalore 560093.

2. COLLECTION OF INFORMATION

2.1. REGISTRATION INFORMATION

Upon downloading the VLNCY application and subsequent creation of an account ("Account"), Users shall be subject to the collection of specific information, henceforth referred to as "Registration Information":

You specifically assert and affirm that to the extent that VLNCY requires from you the disclosure of any personal information, being any information that may come under the purview of the DPDPA and any associated Rules, belonging to any third-party/person, you have taken/acquired the explicit and lawful consent of such persons to share such information with VLNCY.

Upon successful registration, Users retain the privilege to review and modify this aforementioned information at any time by simply logging into the VLNCY App/Site/Platform, with the exception of the date of birth and location data. Notably, the location information, if consented by the user to be accessed by VLNCY via device settings, are automatically updated based on the device's location. Users are entrusted with the responsibility to ensure the accuracy and currency of their account details. Any alterations in contact information, particularly the phone number, should be promptly updated within the User's account.

The information procured during registration is instrumental in refining the functionalities of the App/Site/Platform and validating the User base, with the express intent to create an environment free from automated entities ("Robots"/“Bots”). It is pertinent to acknowledge that certain components of the Registration Information, such as sexual preference, name, and username, may be accessible to other Users who visit an individual's profile page within the VLNCY application.

2.2. PROFILE INFORMATION

It is strongly advised and expected that due diligence and thoughtful consideration shall be exercised by Users, as well as all members of VLNCY, when divulging personal details on their public profiles post-registration. We explicitly discourage the inclusion of sensitive information that might be susceptible to misuse or abuse, including, but not limited to, email addresses, URLs, instant messaging details, phone numbers, full names or addresses, credit card information, national identity numbers, driver's licence particulars, and/or other akin personal information or confidential data on any User's profile.

Users are expressly cautioned that when sharing information about themselves or engaging in communication with other Users via the messaging function within the VLNCY application, the degree of personal information disclosed is undertaken at the User's own risk. Therefore, Users are entirely responsible for the information they choose to share through these means, acknowledging the potential risks associated with such disclosures within the VLNCY Platform.

2.3. PROFILE VERIFICATION INFORMATION

In pursuit of ensuring safety, security, and optimal user experience, VLNCY mandates User Account verification, involving the requisition/use of a User’s phone number and, in specific scenarios, an Aadhaar or other biometric verification process. The principal objectives are twofold: to substantiate the legitimacy of Users and to preclude the establishment of counterfeit VLNCY Accounts potentially engaging in illicit activities that could compromise the integrity of the VLNCY network and its Users. These verification measures are specifically deployed to forestall fraudulent behaviour.

During the verification process utilising Aadhaar or other biometric methods, the submitted data undergoes comprehensive scrutiny and/or scanning. Such procedures may encompass the utilisation of biometric identification technologies to validate the provided information against the User's profile, thereby ensuring the asserted identity of the User. It is of critical importance to note that the information obtained through these verification procedures is not integrated into the User's profile. VLNCY retains this information for future verification and record-keeping purposes until such data is no longer necessary for these intended purposes, or for a period of three years from the User's last interaction with VLNCY, contingent upon whichever transpires first. Subsequent to the designated retention period, commercially reasonable measures are diligently undertaken to effectuate the permanent and secure deletion of this information from VLNCY's systems.

2.4. PURCHASES INFORMATION

If you choose to avail yourself of our Services, VLNCY will utilise a Third-Party Payment Gateway to handle your payment transactions. The Company will not retain any payment information, as it will be securely processed and managed by the designated Third-Party service. VLNCY emphasises that it will not hold any payment data for any purpose, including but not limited to the purpose(s) of fraud prevention, audit, and/or taxation requirements.

The Third-Party Payment Gateway employs automated decision-making mechanisms to prevent potentially fraudulent transactions, forming an integral part of its comprehensive anti-fraud protocols. Throughout this process, the payment transactions are thoroughly examined to identify behavioural patterns indicative of possible breaches of our pre-established Terms and Conditions of Use. If a transaction meets specific criteria signalling a potential breach and is deemed likely to be fraudulent, the transaction may be automatically blocked. In such cases, affected Users will be notified that their transaction cannot be processed and will retain the option to contest the decision by reaching out to VLNCY.

It is crucial to highlight that VLNCY's account blockage procedures are not applicable to payment transactions as the responsibility for payment information lies solely with the Third-Party Payment Gateway. This ensures that the potential blocking of accounts across various VLNCY Group platforms and applications, in line with our stringent anti-spam and anti-fraud procedures, is distinct from payment-related matters handled by the Third-Party service.

2.5. GEOLOCATION INFORMATION

In the event that you have provided VLNCY with access to your geographical location through your device settings, your utilisation of the mobile device will result in the collection of information concerning, but not necessarily limited to, WiFi access points, alongside longitude and latitude data. VLNCY may retain your device's coordinates to facilitate the provision of specific features. This collected information aids in the identification of your precise physical location, subsequently utilised to customize the application and streamline your interaction with other Users. This includes presenting general geographical details to Users viewing your profile and displaying profiles of other Users in close proximity to you.

In the event that you have granted VLNCY access to your location, yet opt to disable this function, you retain the option to do so by following the prescribed steps:

1. a. For iPhone users: Access the "settings" tab, navigate to "privacy," select "location services," and proceed to adjust settings for VLNCY.
2. b. For Android users: Access the "settings" section, choose "location," select "VLNCY," navigate to "permissions," and subsequently manage the location settings.

2.6. DEVICE AND PHOTOS INFORMATION

In the course of utilising the Application, it is imperative to elucidate that VLNCY does not provide Users with the option to upload profile pictures. Consequently, the Application abstains from accessing or storing any photographic content contributed by Users for profile presentation. Notably, VLNCY exclusively retains photographs when Users capture in-app images during their interactive sessions. Importantly, these in-app photographs are transient, dissipating within a duration not exceeding 30 seconds subsequent to viewing. They are purged from the system within 72 hours of viewing.

Furthermore, VLNCY has implemented robust mechanisms to deter the capture of unauthorised screenshots, affirming the paramount importance attributed to the right to privacy.

It is expressly stated that VLNCY, by default, does not have access to or store any User-uploaded profile pictures. The sole circumstance wherein VLNCY may access in-app photographs is contingent upon the lodgement of a complaint against a User for contravention of the stipulated Terms and Conditions. Such grievances must be lodged within a timeframe of 48 hours from the initial viewing of the photograph to instigate any requisite remedial measures.

It is incumbent upon Users to comprehend that the accrual of data associated with photographs, as previously outlined, is incongruous in the absence of User-provided profile images.

2.7. LINKS

During the course of engagement with VLNCY, including third-party services, we reserve the right to monitor and track the nature of your interactions with hyperlinks available on the Platform. Such monitoring may involve the redirection of clicks or other means for tracking purposes. Subsequently, we may collate and disseminate aggregated statistical data regarding the frequency of link clicks, including the specific count of clicks on individual links.

2.8. VLNCY SUCCESS STORIES, SURVEYS, AND OTHER CONTRIBUTIONS

Periodically, in pursuit of research objectives, we conduct surveys and may extend communication to ascertain your interest in participation. Furthermore, we may reach out to inquire if you would be amenable to providing feedback, testimonials, or partaking in promotional endeavours, exemplified by scenarios such as notifying us of finding a match on the Application/Site/Platform, whereupon we may seek your willingness to feature in VLNCY's promotional activities.

It is vital to acknowledge that these surveys and marketing initiatives are discretionary in nature, and comprehensive details will be furnished at the time of engagement. Should you prefer not to be contacted for survey participation or marketing campaigns, we encourage you to contact our Customer Support Team through our Feedback Page to express your preferences.

2.9. CUSTOMER SUPPORT COMMUNICATION PROTOCOL

Upon contacting our Customer Support Team through our designated Feedback Page, your email address will be received, and there is a possibility of tracking your IP address, alongside the information transmitted, all in the pursuit of addressing and resolving your query. Our records encompass the entirety of our correspondence with you, inclusive of any grievances lodged by or against you by other Users, persisting for a duration of six years post the removal of your Account, subject to any applicable enactments/rules.

PROTOCOL ON COOKIES AND COMPARABLE TECHNOLOGIES

In the course of your interaction with our Sites/Platform or utilisation of our App, automatic acquisition of your personal data may occur through the utilisation of cookies or analogous technologies. Cookies, i.e. small files positioned on your device or browser, serve the purpose of facilitating the recognition and recollection of User information.

For detailed insights into cookies, including their functionalities, applications, and the array of choices available to you, we recommend consulting our comprehensive Cookie Policy for further information.

3. USE OF YOUR INFORMATION

3.1. REASONS FOR UTILISATION

The utilisation of your information by VLNCY is comprehensive and multifaceted, devised to serve the dual purpose of enhancing User experiences and fortifying protection against adverse encounters. In this pursuit, we employ your Registration Information and correlated information/data for the following objectives/activities:

1. A. Service Provision
   
   
   1. a. Account Administration: This involves the establishment, organization, and ongoing management of User Accounts to enable seamless interaction within the VLNCY Platform.
      
      
   2. b. Customer Support: We dedicate resources to provide prompt and effective customer support, catering to User queries and concerns, ensuring a smooth and satisfying experience.
      
      
   3. c. Information Dissemination: Regular communication of updates, new features, and essential information regarding the VLNCY Application/Platform for User awareness and engagement
      
      
   4. d. Personalization: Tailoring the content and interface of the VLNCY App/Sites/Platform to align with individual User preferences, enriching the overall User experience.
      
      
2. B. Facilitation of User Connectivity
   
   
   1. a. Service Offerings and Matching: Offering a spectrum of services and functionalities, including the sophisticated task of matching Users based on compatibility parameters for enhanced connections. VLNCY has developed matching algorithms, inclusive of the Helen Fisher Temperament Test [1], to predict the compatibility between its Users. The matching algorithms use the data submitted for the completion of the Helen-Fisher Temperament Test.
      
      [1] For more information on the Helen-Fisher Test please click on [add third party independent website link]
      
      
   2. b. Profile Sharing: Facilitating the exchange of User profiles, fostering interactions and connections between Users within the VLNCY ecosystem
      
      
3. C. Promotion and Marketing Operations
   
   
   1. a. Promotional Communications: Disseminating information about available promotions, offers, and goods/services via direct marketing or alternative communication means, contingent upon User consent and providing convenient opt-out mechanisms.
      
      
   2. b. Third-Party Collaboration: Collaboration with third-party entities for marketing and advertising purposes pertaining to the success stories of VLNCY shall be conducted in strict adherence to privacy and consent principles. It is imperative to clarify that VLNCY, as an ad-free Platform, does not engage in serving advertisements within the App or on its associated websites/Sites. VLNCY may however explore collaborative ventures with external entities for the explicit purpose of showcasing success stories. These collaborative marketing initiatives will involve highlighting success stories, particularly those instances where Users have found meaningful relationships through the VLNCY dating App/Platform. It is emphasised that such collaborations will only be undertaken subsequent to obtaining explicit consent from all involved parties, including former Users who are the subjects of the success stories. This commitment to explicit consent aligns with VLNCY's dedication to User privacy and ethical advertising practices. Users can rest assured that any collaborative efforts for marketing and advertising will be conducted with the utmost respect for privacy and only after receiving clear and informed consent from the relevant individuals.
      
      
   3. c. Engagement of Service Providers: Involvement of third-party service providers, including, but not limited to, payment processors and cloud-storage entities to ensure smooth operational functionalities.
      
      
4. D. Platform Enhancement and Algorithm Development
   
   
   1. a. Research and Analytics: Carrying out extensive research and analytics to comprehend and analyse User behavior and interaction with the VLNCY App/Sites/Platform.
      
      
   2. b. Technological Advancements: Experimentation with new technologies and processes aimed at fortifying and advancing the functionalities and User experience within the VLNCY ecosystem.
      
      
   3. c. Feature and Service Development: Engaged in the continual development of new features and services to expand and enrich the VLNCY Platform.
      
      
   4. d. Service Quality Improvement: Conducting reviews of interactions with customer care teams, aiming to enhance the overall quality of service rendered to Users.
      
      
5. E. Legal Compliance and Protection
   
   
   1. a. Dispute Resolution: Addressing and resolving disputes and issues while upholding the stipulated Terms & Conditions to maintain a fair and conducive environment for all Users.
      
      
   2. b. Fraud Investigation and Legal Enforcement: Diligently investigating fraudulent activities, protecting legal rights, and enforcing the specified Terms & Conditions to sustain the integrity of the VLNCY Platform.
      
      
   3. c. User and Third-Party Protection: Efforts directed towards safeguarding Users and third parties from potential harm or adversities that may arise within the VLNCY ecosystem.
      
      
   4. d. Legal Mandate Compliance: Adherence to legal mandates, including responding to subpoenas, or summons, or analogous legal processes, within the stipulated legal frameworks.
      
      

To lawfully process the information as elucidated in this Privacy Policy, our actions are grounded upon a comprehensive spectrum of legal bases, each meticulously tailored to different facets of our services and obligations:

1. 1. Service Provision: At the heart of our operation lies the provision of services, forged upon a contractual agreement between our Users and us. This foundation necessitates the handling of User information for managing accounts, profiles, and connections. By making User profiles visible to others, suggesting potential connections, and delivering services, we honor our commitments within the agreed-upon terms.
   
   
2. 2. Compliance with Applicable Laws and Regulations: Adherence to pertinent laws and regulations dictates the manner in which we handle User information. Essential data retention for accounting, taxation, and legal obligations/requirements is rigorously observed. This encompasses the retention of traffic data and transaction-related information, ensuring compliance with lawful requests/directions from any Court, Tribunal, or Forum, or from any Authority, under the law in force. Additionally, the maintenance of records encompassing User consents and preferences for specific features or data processing aligns with these statutory obligations.
   
   
3. 3. Legitimate Interests: Central to our practices is the processing of information aligned with our legitimate interests. This involves a continuous evaluation of User behavior within our services to perpetually enhance and refine our offerings. Recommendations for pertinent offers, internal service promotions, safety measures for our Users, and data processing to uphold our rights, assist law enforcement, and bolster our defenses/stand in legal proceedings are all encompassed within this sphere.
   
   
4. 4. Consent: In cases where Users provide information classified as "special" or "sensitive" under certain jurisdictions, such as data related to sexual orientation/preference, religious belief, race, etc., the sharing of this information is considered as explicit consent to its processing in accordance with the tenets outlined in this Privacy Policy. Furthermore, specific requests for data collection, such as precise geolocation or sensitive content within User profiles, may necessitate explicit User consent. Withdrawal of consent can be effectuated by adjusting User settings (e.g., geolocation preferences) or deleting sensitive content from User profiles. Such consent withdrawal is feasible at any point by initiating contact using the provided details in this Privacy Policy.

3.2. DISCLOSURE OF INFORMATION

1. a. Recipient Parties: In our overarching pursuit to facilitate meaningful connections, the distribution of Users' information comprises an intricate ecosystem involving various entities. Principally, Users' information is disseminated among fellow Users. Simultaneously, it is shared with service providers, operational partners, affiliates, and, where necessary, any other legal entities. For an elucidation regarding the orchestrated sharing of User information, the following segment elaborates on these intricate interrelations.
   
   
   1. i) Sharing with Other Users: User information is voluntarily revealed to other Users, chiefly within the public domain of the service, constituting the fundamental avenue for information exchange. Users are advised to exercise prudence and discretion when disclosing their information, emphasising the importance of content alignment with their comfort levels in public exposure. Users reserve the autonomy to restrict audience access to specific segments of their profiles or particular content, modulating visibility according to their chosen settings. Moreover, in circumstances wherein reports/complaints are filed against a User, such as, but not limited to, complaints relating to potential breaches of the Terms & Conditions of Use, the Platform retains the prerogative to notify the reporting entity about any actions taken in response to such reports/complaints.
      
      
   2. ii) Sharing with Service Providers and Partners: Integral to the operational architecture, various service providers are engaged to support diverse facets of the service including, but not limited to, data hosting, maintenance, analytical insights, customer support, marketing strategies, advertising initiatives, payment processing, and security measures. Collaborations extend to partners facilitating service distribution and promotional activities. Notably, the Platform may share limited User information with advertising vendors in a hashed, non-human readable format. Prior to engaging in any partnerships or vendor relationships, the Platform ensures a meticulous vetting process, imposing stringent obligations concerning confidentiality and compliance.
      
      
   3. iii) Sharing with Affiliates: The exchange of information with affiliated entities is meticulously regulated within a defined scope, serving specific legitimate purposes such as bolstering platform security, conducting corporate audits, performing analyses, and preparing consolidated reports, in adherence to relevant laws and regulations. Your data may also be shared with other VLNCY affiliated companies to block accounts and suspected fraudulent payment transactions as part of our anti-spam/anti-fraud procedures.
      
      
   4. iv) Corporate Transactions: In scenarios concerning corporate transitions, including but not limited to mergers, acquisitions, divestitures, restructurings, reorganizations, dissolutions, bankruptcies, and/or any other alterations in ownership or control, User information may be subject to partial or complete transfer upon the execution/culmination of such transaction.
      
      
2. b. Legal Requirements: Disclosure of information is affected when reasonably necessary to adhere to legal processes such as court orders, subpoenas/summons, search warrants, government/law enforcement investigations, or any order/direction from any competent authority. Furthermore, information may be utilised for crime prevention or detection, subject to pertinent laws, and is wielded to ensure the safety of individuals or to protect the legal rights of the platform, users, business partners, or other involved stakeholders.
   
   
3. c. Consent-Based or Requested Disclosure: Requests for User consent regarding the sharing of information with third parties are meticulously managed, elucidating the precise purpose of such information exchange. Non-personal and personal information presented in hashed, non-human readable forms are utilised and exchanged in accordance with the aforementioned circumstances.
   
   
4. d. Moderators: VLNCY also uses automated systems and a team of moderators to monitor and review accounts and messages for any content that breaches our Terms and Conditions. If any Account or message or any exchange/communication meets certain criteria that demonstrate that the Terms and Conditions of Use have been breached, the relevant account will be subject to warning and the User’s access will be restricted, following which it may be blocked. Aggrieved Users may contact the moderators to review the decision.
   
   

3.2.1. Circumstances where Data may be Disclosed

VLNCY employs stringent protocols for the disclosure of Registration Information and personal data. Exceptions to this policy are made only in the specific situations outlined below:

1. a. Service Providers: We may engage reputable third-party entities to perform critical functions and offer services on our behalf. Your Registration Information or personal data might be shared with these third parties, solely to facilitate these functions and service provisions. For further details, refer to the section below.
   
   
2. b. Moderators: To monitor activity on the App/Platform and approve content.
   
   
3. c. Law and Harm: As we mentioned in the Terms & Conditions, we think it is very important that all Users behave whilst using the App/Platform. We will cooperate with all third parties to enforce their intellectual property or other rights. We will cooperate with lawfully made law enforcement requests, or any orders or directions from any competent authority,  for information from within or outside your country of residence where we are required to by law. This may include, but is not limited to, where there is an investigation into alleged criminal behavior, or to protect the vital interests of a person. We may preserve or disclose any of your information, including your Registration Information, if we believe in good faith that it is necessary to comply with any law or regulation, or when we believe in good faith that disclosure is necessary in order:
   
   
   1. to comply with a binding direction/court order, or any order or direction from any competent authority, or any lawful request;
   2. to protect the safety of any person(s);
   3. to address fraud, security or technical issues, including but not limited to through anti-spam providers to protect the service/Platform from criminal activity; or
   4. to protect our rights or property, or those of third parties.
      
      VLNCY reserves the right to exercise or waive all rights and reliefs available to it under law in these circumstances.
4. d. Business Transfers: In situations where a VLNCY Group entity or its affiliates undergo a business transition, change of ownership, such as a merger, acquisition, re-organization, or asset sale, or in cases of insolvency or administration, your personal data may be disclosed, to the extent permissible under law.
   
   
5. e. Marketing Services Providers: To aid in our marketing and advertising endeavors on third-party platforms and applications, and to gauge the efficacy of our advertising campaigns.
   
   
6. f. Anti-Spam and Anti-Fraud: Your data may be shared among other VLNCY Group companies to detect and prevent fraudulent activities, including but not limited to blocking accounts and suspected fraudulent payment transactions in line with our anti-spam and anti-fraud measures.

3.2.2. Additional Information About Disclosures

As outlined above, your Registration Information or personal data may be shared with Third-Party Vendors/Venues, with the purpose of facilitating critical functions and services related to the use of the App/Sites. A list of such Third-Party Vendors/Venues may be accessed by You at any time by reviewing this Privacy Policy. This list is subject to changes/amendments/additions/reductions. By utilising our Services you agree for your Registration Information or personal data to be shared with such Third-Party Vendors/Venues, subject to this Privacy Policy.
Your Data may be shared with the following service providers, operational partners, affiliates, and, where necessary, any other legal entities, for the purposes of providing seamless services to You, subject to the terms of the present Privacy Policy:

• . Signzy
• . Airtel
• . textlocal
• . Google Maps
• . Google Play Store
• . Apple App Store

4. USERS' PRIVACY RIGHTS AND CHOICES

The privacy and associated/related laws applicable in India afford you certain rights regarding your digital personal data processed by an organization. At VLNCY, these rights are acknowledged, and we aim to facilitate the exercise of these rights in compliance with the pertinent regulations. The rights granted to you under the Indian privacy and associated/related laws are outlined below:

1. a. Right to Information: You possess the right to be informed about what digital personal data is being processed by an organisation and the rationale behind such processing. VLNCY provides this requisite information in this Privacy Policy to ensure your awareness of the processing procedures undertaken.
   
   
2. b. Right of Access: You retain the right to request and obtain a copy of your digital personal data held by VLNCY.
   
   
3. c. Right of Rectification: In circumstances where the digital personal data retained is deemed inaccurate or incomplete, you hold the right to request its rectification or correction.
   
   
4. d. Right to Erasure: Subject to the terms of this Privacy Policy, and the applicable law in force, you possess the right to request the deletion of your digital personal data. However, VLNCY retains the authority to maintain digital personal data integral to ongoing proceedings or claims against you, or otherwise permissible to be retained under the law in force.
   
   
5. e. Right to Restrict Processing: Subject to the terms of this Privacy Policy, and the applicable law in force, you reserve the right to request a halt in the processing of your digital personal data while ensuring its retention.
   
   
6. f. Right to Data Portability: You may request a copy of specific digital personal data in a machine-readable format for portability to another service provider.
   
   
7. g. Right to Object: Under certain circumstances, especially where digital personal data is processed based on legitimate interests or for marketing purposes, you retain the right to object to such processing.
   
   
8. h. Rights Related to Automated Decision-Making and Profiling: In scenarios where processing conducted through automated means yields significant decisions for the individual, you have the right to ensure human intervention in the decision-making process.

It is crucial to note that the specific applicability of these rights may undergo variations due to Acts of Parliament/ Legislature, including but not limited to rules, regulations, guidelines etc. of any competent governing/regularity authority, and/or decisions of a Court of Law or other competent authority. Hence, it is advised and expected for you to stay abreast of the rights conferred by these authorities or any developments in the law.

To exercise any of the rights mentioned above, please visit our Feedback Page or contact our Data Protection Officer at DPO@VLNCY.com, Phone: 6364002850. Alternatively, you can reach out to us via post at the following address: A-904, Salarpuria Silverwoods, Vartur Road, Nagavara Palya, Bangalore 560093.

For security purposes and the safeguarding of our Users, we may need to request specific information to verify your identity before addressing the aforementioned requests. If you have any concerns regarding how we have handled your request or processed your personal data, your initial point of contact should be the details provided above.

5. ROLE OF THE DATA PROTECTION OFFICER

The Data Protection Officer (“DPO”) at VLNCY assumes several crucial responsibilities to ensure stringent adherence to data protection regulations and the protection of Users' rights and information:

1. 1. Compliance Oversight: The DPO rigorously monitors and ensures VLNCY's adherence to the spectrum of data protection rights, obligations, and responsibilities. This includes taking reasonable steps towards raising awareness among all stakeholders about these standards to guarantee comprehensive compliance.
   
   
2. 2. Provision of Expertise and Guidance: Offering expert advice, training, and pertinent recommendations is a pivotal role of the DPO. The officer extends this support to VLNCY and its workforce, aiding in the meticulous interpretation and application of data protection rules to maintain the highest standards of protection and privacy.
   
   
3. 3. Record Keeping and Transparency: The DPO maintains comprehensive records encompassing all data processing activities executed by VLNCY. These records contain explicit details regarding the purpose of each activity. These records are available upon request, ensuring transparency and compliance with data protection norms.
   
   
4. 4. Conducting Audits: Regular audits are conducted by the DPO to validate compliance and pre-emptively address any potential issues that may compromise data protection standards. These audits aim to proactively identify and rectify any discrepancies or vulnerabilities to ensure an unassailable standard of protection.
   
   
5. 5. User Interface and Education: Direct interaction with Users is a fundamental aspect of the DPO's role. This interface involves informing Users about how their data is utilised within the VLNCY ecosystem. The DPO takes reasonable steps and efforts to educate Users about their rights, particularly their entitlement to have their personal data erased if necessary. Moreover, the DPO familiarises Users with the measures implemented by VLNCY to safeguard their digital personal data/information.

This multifaceted role of the Data Protection Officer forms a vital part of VLNCY's commitment to ensuring data protection, user privacy, and compliance with regulatory standards, fostering a secure and trustworthy environment for all users.

6. DATA RETENTION AND DELETION

6.1. Retention of Personal Information

VLNCY retains your digital personal data/information only for the duration required by the legal bases outlined in Section 3 and within the confines of applicable law in force. Further insights on our data retention policy regarding biometric information can be found in the "Profile Verification Information (Including Biometric Information)" section detailed above.

Upon the deletion of your Account, we ensure that it is no longer visible within the App/Platform. A window of up to 28 days exists within which accidental deletion may allow for the restoration of your Account. Post the 28-day period, the initiation of a deletion process for your digital data personal data/information within our systems begins, barring situations where retention is necessary, such as:

1. a. Obligated/directed under the purview of applicable law in force, such as retention of certain personal data pertaining to in-App purchases for accounting and tax purposes.
   
   
2. b. Necessitated to substantiate compliance with applicable law in force that entails maintaining account information and a history of behavior leading to an Account block. Such data is retained for evidential purposes regarding potential queries or legal claims associated with the Account block.
   
   
3. c. Presence of unresolved issues, claims, or disputes necessitating information retention until resolution.
   
   
4. d. Necessary due to our legitimate business interests, including but not limited to fraud prevention and augmenting user safety and security. For instance, retaining information to prevent a previously banned User exhibiting unsafe behaviour or engaging in security incidents from opening another/a new Account.