Privacy Policy

• Effective Date: 2026-05-04
• Applies To: Users of the Pawgloo-Partners Service Application (“Partners” or “Service Providers”).

The Bottom Line Up Front (BLUF): At Pawgloo™, we take your privacy seriously. We are compliant with the Digital Personal Data Protection (DPDP) Act, 2023. This policy explains what data we collect (professional profile, KYC, location), how we store it securely using enterprise-grade cloud providers, and your rights regarding your data, including details on sensitive data handling and retention.

1. Introduction and DPDP Act compliance

NEXEL PLATFORMS PRIVATE LIMITED, which operates the Pawgloo platform (“Company,” “we,” “us,” or “our”), acts as a Data Fiduciary under the Digital Personal Data Protection (DPDP) Act, 2023. This policy comprehensively outlines the methodology by which we collect, store, process, and securely transfer your personal and professional data across our cloud infrastructure. By utilizing the Pawgloo-Partners application, you provide explicit, informed consent for the processing of your data as defined within this policy.

This notice is supplemented, and not replaced, by the detailed Account deletion flow and the additional information in the Sensitive user data & financial privacy policy and Data retention & deletion policy sections below.

2. Data collection and flow architecture

We operate a segmented data architecture intended to support data minimization and purpose limitation. Data is routed and stored according to its operational purpose:

• Professional Profiles: Your specialty, biography, contact details, profile media, and scheduling data are stored in a dedicated service-provider database to connect you with pet parents.
• Verification Documents (KYC): Sensitive identity information, including Aadhaar and PAN information, is collected for identity verification, tax, fraud-prevention, and regulatory purposes. Raw Aadhaar data is stored in our KYC records and may be reused when initiating or completing our payment processor video KYC.
• Professional Licences: Veterinary and other professional licence files are uploaded to private cloud object storage. References or URLs for those files are stored with your Partner profile in the vetProfile service.
• Financial and Payout Information: Full bank account numbers, associated IFSC codes, and submitted UPI IDs or Virtual Payment Addresses (VPAs) are persisted in backend standing-bank records to support verification, beneficiary creation, and payouts.
• Service Telemetry: We record transactional metadata, including appointment timestamps and the duration of audio/video calls, to ensure auditable, accurate payout calculations.
• Geospatial Data: To connect you with geographically proximate service requests, we process your device’s location. This data is utilized dynamically for matching and tracking active bookings, such as dog walks, and is handled according to the applicable operational and retention requirements described in this policy.

3. Third-party data processors (sub-processors)

To operate the platform efficiently, we securely transmit limited data subsets to the following categories of enterprise-grade infrastructure partners:

• Cloud Hosting & Infrastructure Providers: Our primary backend databases and object storage are hosted using third-party cloud infrastructure providers. The location and processing of data are governed by our service arrangements and applicable legal requirements.
• Real-Time Communication Platforms: For in-app chat and video consultations, we pass account information, content, and temporary access tokens to our communication providers as necessary to provide those services. Those providers process data under their applicable terms, retention practices, and contractual obligations.
• Notification & Messaging Services: For transactional communications, such as booking confirmations and OTPs, your contact details and device tokens are transmitted securely to our notification infrastructure partners.
• Regulated Payment Aggregators: Financial transactions, beneficiary verification, and payouts are processed with regulated payment partners. Full bank account numbers, IFSC codes, and submitted UPI VPAs are also persisted by Pawgloo in backend standing-bank records for these operations. We do not ask you to provide your UPI PIN.
• Identity Verification Providers: Aadhaar, PAN, profile, and related verification information may be transmitted to identity verification providers. Raw Aadhaar information stored by Pawgloo may be retrieved and reused for our payment processor video KYC.

For more information about consent for processor disclosures, see Third-party compliance and explicit consent.

4. Temporary caching and system state management

To maintain application performance and prevent concurrent booking conflicts, we employ an in-memory caching layer.

• Idempotency & Concurrency Locks: When a booking is initiated or modified, a temporary reservation lock is generated in the cache. This lock contains minimal identifier data and is released or expires as part of transient booking state management.
• Non-Persistence: Our caching infrastructure is utilized for transient state management rather than as the authoritative persistent archive for personally identifiable information (PII). The exact cache expiration schedule remains subject to operational validation and legal approval.

5. Data retention and deletion (the right to be forgotten)

We retain your personal data only for as long as necessary to fulfill the purposes outlined in this policy or as required by applicable Indian law.

• Account Deletion: Partners may request account deletion via the application settings. Upon verification and completion of the closure workflow, Pawgloo deletes Partner profile and authentication data, locally held standing-bank records, associated media in cloud object storage, and applicable Stream communication account data. Historical bookings are anonymized. KYC records are marked deleted and retained, while the wallet is closed and wallet and ledger records are retained.
• Regulatory Retention: Transactional records, ledger entries, closed wallet information, tax records, and marked-deleted Partner KYC records may be retained in a restricted state for the duration required by applicable Indian financial, taxation, anti-money-laundering, dispute, and audit obligations. The fixed duration for these categories remains pending legal confirmation.

Detailed category outcomes and legal-hold exceptions are set out in the Data retention & deletion policy and supplemented by the Account deletion flow.

6. Data security and internal access controls

• Encryption in Transit: Data transmitted between your device and our backend APIs is secured using modern TLS/SSL protocols.
• Storage Safeguards: We apply technical and organizational safeguards to databases, object storage, processor integrations, and operational systems based on the sensitivity and purpose of the data involved.
• Access Controls: Access to Partner data is limited according to operational need, service responsibilities, and applicable confidentiality and security requirements.
• Monitoring and Response: We maintain operational monitoring and incident-response processes intended to identify, investigate, contain, and report security events as required by applicable law.

7. User rights and grievance redressal

Under the DPDP Act, 2023, you possess the right to:

• Access & Nominate: Request a summary of your personal data and nominate an individual to exercise your rights in the event of incapacity.
• Correction: Rectify inaccurate or incomplete profile information directly within the application or request correction of data that cannot be edited in the application.
• Deletion: Request erasure of personal data that is no longer necessary, subject to statutory retention duties, unresolved transactions, legal holds, and the exceptions described in the Data retention & deletion policy.
• Grievance Redressal: If you have concerns regarding our data practices, please contact our designated Data Protection Officer (DPO) at privacy@pawgloo.com. We are committed to resolving grievances promptly in accordance with statutory timelines.

Sensitive user data & financial privacy policy

This section details the handling of sensitive personal data and financial information.

1. Scope of sensitive personal data or information (SPDI)

This policy strictly governs the collection, transmission, storage, and processing of “Sensitive Personal Data or Information” (SPDI), as defined under the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, read alongside the Digital Personal Data Protection (DPDP) Act, 2023.

Within the context of the Pawgloo-Partners ecosystem, SPDI specifically encompasses:

• Financial Account Instruments: Bank Account Numbers and associated IFSC Codes.
• Payment Identifiers: Unified Payments Interface (UPI) IDs (Virtual Payment Addresses / VPAs).
• Government-Issued Identifiers (KYC): Unique identification documents, including Aadhaar, Permanent Account Numbers (PAN), and statutory Veterinary/Professional Licenses.

2. Current storage and processing architecture

Pawgloo currently persists full bank account numbers, associated IFSC codes, and submitted UPI IDs or VPAs in backend standing-bank records. This information is used to support bank verification, beneficiary creation, payout routing, fraud prevention, reconciliation, and account servicing.

Financial and identity information is also transmitted through secure API connections to regulated Payment Aggregator and Identity Verification partners when required to perform payout or KYC operations. Pawgloo does not request a Partner’s UPI PIN.

Raw Aadhaar information is stored in Pawgloo KYC records. That raw information may be retrieved and reused when initiating or completing our payment processor video KYC. Veterinary and other professional licence files are uploaded to cloud object storage, and the corresponding file URLs or references are stored in the Partner’s vetProfile record.

3. Partner application: pay-outs and statutory KYC

To facilitate the lawful disbursement of professional earnings and comply with the Prevention of Money Laundering Act (PMLA), 2002, Pawgloo is required to verify the Partner’s identity and banking credentials as applicable to the service.

A. Beneficiary creation & mandatory verification When a Partner inputs their Bank Account or UPI ID, our Partner-backend stores the submitted credentials and transmits the required SPDI to our Payment Aggregator to instantiate or verify a “Beneficiary” profile. We utilize secure identity verification suites to execute verification methods that may include a Penny Drop verification, such as remitting a nominal ₹1. The payment partner returns the verified bank name status, which our algorithms compare against the Partner’s registered profile to substantiate ownership and mitigate financial fraud.

B. Post-verification data retention Following verification, Pawgloo continues to retain full bank account numbers, IFSC codes, and submitted UPI VPAs in backend standing-bank records until the records are removed through the applicable account-closure workflow or another valid deletion process. We may also retain operational routing information, including:

• A system-generated beneficiary reference issued by our payment aggregator.
• The binary verification status (verified / failed).
• Masked display strings (e.g., last 4 digits of the account number, partial IFSC) for your recognition within the app dashboard.

C. Archival of government identifiers and licences Government-issued identifiers, including Aadhaar and PAN, may be stored in Pawgloo KYC records for identity verification, Section 194-O TDS compliance, fraud prevention, tax reporting, and dispute resolution. Raw Aadhaar information may be reused for our payment processor video KYC. Veterinary and professional licence files are stored in cloud object storage, while their URLs or references are stored with the Partner’s vetProfile.

4. Third-party compliance and explicit consent

Because our Payment Aggregator and Identity Verification partners execute sensitive financial processing, settlement, beneficiary verification, and identity validation on behalf of Pawgloo, their operations are governed by their independent security, privacy, and regulatory obligations.

• Explicit Consent: By submitting payout credentials, identity information, or verification documents through the Pawgloo-Partners application, you hereby acknowledge and provide explicit, affirmative consent for the storage and secure transmission of your SPDI to our regulated payment and identity verification partners for the purposes described in this policy.
• Review of Partner Protocols: Users are strongly advised to review the official security architecture and privacy practices of our regulated payment aggregators and identity verification providers as linked during the onboarding or verification process.
• Withdrawal and Deletion Requests: Withdrawal of consent or an account deletion request does not require Pawgloo or a processor to erase records that must be retained under applicable law, for an unresolved transaction, or under a valid legal or trust hold.

5. Security incident response protocol (CERT-In mandate)

Pawgloo maintains incident-response processes and operational logs appropriate to the systems and data involved. In the event of a cybersecurity incident, unauthorized access, or personal data breach, Pawgloo follows applicable investigation, containment, notification, and reporting obligations.

• CERT-In Reporting Mandate: For cybersecurity incidents reportable under the directions issued pursuant to subsection (6) of section 70B of the Information Technology Act, 2000, we will report the incident to the Indian Computer Emergency Response Team (CERT-In) within six (6) hours of noticing the incident or being brought to notice about it.
• Data Breach Notifications: We will notify affected Data Principals and the applicable regulatory authority or Data Protection Board when and in the manner required by the DPDP Act, 2023, its rules, or other applicable law.

6. Planned experience, not live

The controls and durations in this subsection describe a planned experience or a proposal pending legal approval. They are not representations of Pawgloo’s current storage architecture or current fixed retention periods.

A. Planned masked or tokenized-only financial storage Pawgloo plans to evaluate an architecture under which raw account numbers and IFSC codes are removed after successful verification and only non-sensitive operational routing identifiers are retained:

• A system-generated, encrypted beneficiary reference issued by our payment aggregator.
• The binary verification status (verified / failed).
• Masked display strings (e.g., last 4 digits of the account number, partial IFSC) strictly for your recognition within the app dashboard.

B. Planned post-verification data scrubbing Upon the successful confirmation of verification, Pawgloo intends to evaluate an automated routine to immediately and permanently scrub the raw account number and IFSC code from its memory caches and persistent standing-bank records. This automatic scrubbing process is not live, and full bank account numbers, IFSC codes, and submitted UPI VPAs are currently persisted as described above.

C. Planned isolated compliance vault Pawgloo plans to evaluate an isolated, access-restricted storage environment for government-issued identifiers required for statutory KYC and Section 194-O TDS compliance. The proposed design would use advanced encryption protocols and access controls limited to designated compliance personnel for statutory auditing, tax reporting, and dispute resolution. This isolated one-officer vault model is not the current architecture.

D. Retention periods pending legal approval The following schedules remain proposals pending confirmation by legal counsel and are not current fixed retention commitments:

• Financial ledgers, transaction records, payout batches, and invoices retained for a minimum of eight (8) years.
• Partner KYC and tax deduction records retained for eight (8) years following account termination.
• Customer support and grievance communications retained for two (2) years.
• Transient cache data permanently flushed within 10 minutes to 7 days, depending on the cache key and operational purpose.

The detailed Account deletion flow currently leaves the KYC retention duration open. Current category status is described in the Data retention & deletion policy.

Data retention & deletion policy

This section outlines Pawgloo’s data lifecycle management practices, including retention schedules and the right to data erasure.

1. Purpose and statutory alignment

This policy articulates the data lifecycle management practices of NEXEL PLATFORMS PRIVATE LIMITED. It defines the durations or current legal-review status for which varying categories of personal and operational data are retained, our deletion processes, and the mechanisms through which users may exercise their right to data erasure (the “Right to be Forgotten”) pursuant to the Digital Personal Data Protection (DPDP) Act, 2023.

This section supplements the main Privacy Policy and the detailed Account deletion flow. Those detailed materials do not replace the disclosures, rights, processor information, or contact details in this notice.

2. Dynamic data retention schedules

We adhere to the principle of data minimization. Data is retained strictly for the duration necessary to fulfill its operational purpose or to comply with statutory mandates:

• Active Account Data: Profile information, professional dossiers, contact information, authentication data, and scheduling preferences are retained in our primary databases for the continuous duration of your active account status.
• Financial Credentials: Full bank account numbers, IFSC codes, and submitted UPI VPAs are retained in backend standing-bank records while needed for verification, beneficiary management, payout operations, and account servicing.
• KYC Data: Aadhaar, PAN, verification results, and related KYC records are retained while required for verification and compliance. Raw Aadhaar may be reused for our payment processor video KYC.
• Professional Licence Files: Licence files are retained in cloud object storage while required for the active Partner profile, with their URLs or references stored in vetProfile.
• Media and Object Storage: Profile pictures and uploaded chat attachments are retained while the account is active.
• Service Telemetry and Location: Booking timestamps, call-duration metadata, and service-related location data are retained according to the operational purpose of the associated booking or service record.
• Ephemeral State Data (In-Memory Cache): Transient operational data is retained only for cache and lock-management purposes. The exact expiration schedule remains pending operational validation and legal approval.
• Customer Support & Grievance Logs: Communications directed to our support or Trust & Safety teams are retained as needed to resolve the matter and satisfy applicable legal obligations. A fixed two-year schedule remains pending legal approval.

3. Mandatory legal retention (the immutable ledger)

To comply with applicable Indian financial and taxation frameworks, Pawgloo may be legally required to retain data integral to financial reconciliation even after account closure.

• Financial Ledgers & Transactional Invoices: Data recorded within our accounting architecture, including transaction records, ledger entries, closed wallet records, invoices, and payout batches, is retained for the period required by applicable tax, financial, audit, and dispute-resolution obligations. A fixed eight-year period remains pending legal confirmation.
• Booking Anonymization: Upon the successful execution of an account deletion request, the user’s profile is deleted and historical booking records are anonymized. Financial metadata linked to historical bookings, automated payouts, and TDS deductions may remain preserved where required for reconciliation or legal compliance.
• Partner KYC Archival: Identity verification records, including Aadhaar/PAN information and corresponding tax deduction histories, are marked deleted but retained after account termination when required for compliance. The applicable KYC duration remains open pending legal confirmation and is not currently represented as a fixed eight-year period.

4. Data erasure protocol (the right to be forgotten)

Subject to the exceptions outlined in Section 5, users possess the statutory right to request the permanent erasure of their personal data.

A. Initiation of the erasure request:

1. Navigate to the Settings interface within the Pawgloo-Partners application.
2. Access Account Security > Delete Account.
3. Alternatively, a formal, verifiable data erasure mandate may be transmitted via email to privacy@pawgloo.com.

B. The erasure execution lifecycle: Upon the authentication of a deletion request, and contingent upon the absence of pending financial settlements:

• Account Closure: The account is deactivated, authentications are revoked, Partner profile data is deleted, and the Partner is delisted from applicable search indexing and partner directories.
• Database and Standing-Bank Deletion: Profile, authentication, and locally held standing-bank records, including persisted bank account, IFSC, and UPI VPA information, are deleted through the closure workflow.
• Object Storage and Communication Deletion: Associated managed secure cloud storage objects, including profile and licence files, and applicable Stream user and related communication account data are deleted through the closure workflow.
• Booking Anonymization: Historical booking records are anonymized to remove or replace the closing Partner’s direct identifying association while preserving records required for operational integrity.
• KYC Preservation: KYC records are marked deleted and retained for the applicable legal or compliance period, which remains pending legal confirmation.
• Wallet and Ledger Preservation: The wallet is closed, while wallet, transaction, and ledger records are retained where required for reconciliation, tax, audit, legal, or dispute purposes.

For implementation details, see the Account deletion flow. That detailed page supplements and does not replace this Privacy Policy.

5. Legal & trust holds (exceptions to erasure)

Pawgloo explicitly reserves the right to deny, suspend, or delay a data erasure request under the following circumstances:

• Active Litigation or Disputes: The existence of an unresolved dispute, active insurance claim, or pending litigation involving the account.
• Financial Delinquency: The account owes an outstanding refund or financial penalty to the platform or a counterparty.
• Trust & Safety Violations: If the account has been permanently suspended for severe breaches of the Terms of Service (e.g., violating the Anti-Circumvention Policy).