Privacy Policy

• Effective Date: 2026-05-04
• Issued by: NEXEL PLATFORMS PRIVATE LIMITED, owner of the Pawgloo™ and Pawgloo-Partners brands (incorporated under the Companies Act, 2013; principal office: Plot 151, Sector 2, Kurukshetra, Haryana 136118)
• Applies To: Users of the Pawgloo Consumer Application (“Consumers”) and the Pawgloo-Partners Service Application (“Partners”).

For additional detail, see our Sensitive User Data & Financial Privacy Policy, Data Retention & Deletion Policy, and Child Safety Standards.

1. Introduction and DPDP Act compliance

Pawgloo and Pawgloo-Partners are brands owned and operated by NEXEL PLATFORMS PRIVATE LIMITED (“Company,” “we,” “us,” or “our”), which 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 data across our cloud infrastructure. By utilizing our applications, you provide explicit, informed consent for the processing of your data as defined within this policy, subject to any other lawful basis or statutory obligation that applies.

2. Data segmentation and flow architecture

We organize data according to its purpose and the registered user type to support data minimization and purpose limitation:

A. For pet parents (Consumer App users)

• Profile Data: Upon registration via OTP, your Name, Email, Phone Number, account identifiers, and associated profile information are securely stored in our primary secure database.
• Pet Data: Information regarding your pet (breed, age, vaccination status, temperament) is stored to power the matchmaking algorithm and provide essential context to Partners during bookings. Matchmaking may use pet attributes, user preferences, service requirements, availability, and geographic proximity.
• Media & Object Storage: Photographs, profile images, pet imagery, chat attachments, and other media files are transmitted to cloud object storage (secure cloud storage). References, URLs, object keys, and associated metadata may be retained within our secure database or service records.
• Geospatial Data: To connect you with geographically proximate services, we process and store your submitted or selected location. Location may be stored as a GeoJSON Point, using coordinates: [longitude, latitude], together with available labels, address information, and service-radius or matchmaking information.
• Social and Communication Data: Content submitted to Playdate or other social features, including posts, captions, reactions, comments, profile references, and media references, may be stored in our secure database and secure cloud storage. In-app chat content and related events may be processed through our communication partner.

B. For service providers (Pawgloo-Partners)

• Professional Profiles: Specialty, biography, qualifications, availability, scheduling data, service areas, pricing, and related profile information are stored in Pawgloo’s operational secure database collections and used to offer, match, and administer services.
• Verification Documents (KYC): Sensitive identity information and documents (e.g., Aadhaar, PAN, Veterinary Licenses) may be received by our backend. Submitted Aadhaar numbers, PAN information, verification results, and related KYC fields may be stored in secure database, while uploaded document images, video KYC , or associated media may be stored in secure cloud storage.
• Payout Information: Partner bank account numbers, account-holder information, IFSC codes, UPI IDs, verification responses, our payment processor beneficiary references, and related payout details may be received and stored by Pawgloo and transmitted to our payment processor for verification and payout processing.
• Service Telemetry: We record transactional and service metadata, including appointment identifiers, timestamps, participant identifiers, booking status, call identifiers, call status, and available audio/video call duration metadata, to operate consultations, resolve disputes, and support payout calculations.

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

To operate the platform efficiently, we securely transmit limited data subsets to the following infrastructure and service providers:

• our cloud infrastructure provider: Our backend infrastructure uses cloud infrastructure services for compute, APIs, logs, and cloud object storage. Profile images, pet imagery, KYC media, chat attachments, and other uploaded objects may be stored in secure cloud storage. - our secure database: our secure database is used as a primary operational database for user and Partner profiles, pet records, GeoJSON location data, bookings, service records, payment and payout metadata, KYC fields, social features, notification data, and other application records. - our communication partner: For in-app chat and audio/video consultations, we create or synchronize user identities and

  issue access tokens to our communication partner. Chat text, reactions, message events, attachment references, and communication transport are handled through our communication partner. Audio/video streams are transported through our communication partner’s calling infrastructure, and call identifiers, participants, status, timestamps, and duration or session metadata may be available to our communication partner and Pawgloo. - our notification provider: For transactional communications (e.g., booking confirmations, OTPs), your contact details, user identifiers, notification preferences, and device push tokens may be transmitted securely to our notification provider’s notification infrastructure.

• our authorized payment gateway: Consumer checkout, transaction status processing, Partner beneficiary verification, payouts, and related financial services are processed through our payment processor. Pawgloo does not store full credit or debit card numbers, CVVs, or UPI PINs. Pawgloo does store or process other payment and payout information described in this policy, including Partner bank account and IFSC information. - our analytics provider: We use our analytics provider for product analytics and feature-performance measurement. Analytics events may include user or account identifiers, screen and feature interactions, timestamps, application version, device information, session properties, and selected event attributes. - our error monitoring partner: We use our error monitoring partner for application error reporting, crash diagnostics, and performance monitoring. Reports may include stack traces, request or route information, timestamps, application version, device and operating-system details, network information, user or account identifiers, and diagnostic context associated with an error.

4. Temporary caching and system state management

To maintain application performance, preserve sessions, coordinate bookings, and prevent duplicate or conflicting transactions, we use local and backend state-management mechanisms.

• Idempotency & Concurrency State: When a booking or payment operation is initiated, Pawgloo may create reservation state, idempotency records, transaction identifiers, or concurrency controls. These records contain identifiers and operational information required to prevent duplicate actions, coordinate booking availability, and reconcile payment activity.
• Device Storage (AsyncStorage): The mobile applications use AsyncStorage to retain selected state on the user’s device. Depending on the application flow, this may include authentication or session tokens, account and profile identifiers, onboarding state, preferences, selected location information, notification or device-token state, and cached application data.
• Cache Purpose: Where a cache or temporary state store is used, its purpose is to improve performance, maintain application continuity, coordinate time-sensitive operations, and reduce duplicate requests. Cache entries and local application state are not treated as exempt from this policy merely because they are temporary.

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, support the live deletion flow described below, resolve disputes, maintain security, or comply with applicable Indian law.

• Account Deletion: Where the option is available, users may initiate account deletion via the application settings. Users may also submit a verifiable deletion request to privacy@pawgloo.com. The live deletion service deletes or updates the specific our secure database records and secure cloud storage objects expressly handled by that service after applicable checks. - Current Deletion Scope and Omissions: The current deletion flow does not provide a universal deletion or anonymization orchestration across every processor and every related data store.

Data held by our communication partner, our notification provider, our payment processor, our analytics provider, our error monitoring partner, or other processors may remain subject to their own retention, deletion, security, and legal requirements. Historical booking, transaction, payout, KYC, support, audit, safety, or related records not expressly removed by the live deletion service may also remain. - Regulatory Retention: Transactional records, ledger entries, invoices, payout information, Partner KYC information, and related records may be retained where required for tax, accounting, anti-money-laundering, corporate, dispute-resolution, security, or other legal purposes. Fixed retention durations remain subject to legal review and approval as described under “Planned experience, not live.”

6. Data security and internal access controls

• Encryption in Transit: Data transmitted between your device, our backend APIs, and supported service providers is protected using TLS/SSL protocols where those services support secure transport.
• Authentication and Authorization: We use OTP-based authentication, application tokens, API authorization checks, object-access controls, and service credentials to restrict access to account data and backend operations.
• Storage and Secrets: secure cloud storage, secure database, and other service providers supply storage security and access-control capabilities. Application secrets and processor credentials are separated from normal client-side application content and are limited to services that require them.
• Payment Safeguards: our payment processor checkout keeps entry of full card numbers, CVVs, and UPI PINs within our payment processor’s payment environment. our payment processor webhook requests are validated before payment status or payout information is accepted by Pawgloo.
• Monitoring and Response: Operational logging, our error monitoring partner diagnostics, processor dashboards, and internal review may be used to identify errors, suspicious events, misuse, or unauthorized access. Sensitive values should be minimized or masked in logs where supported and appropriate.

7. User rights and grievance redressal

Under the DPDP Act, 2023, subject to applicable conditions and exemptions, you possess the right to:

• Access: Request a summary of your personal data being processed, the processing activities performed, and available information concerning the processors with whom that data has been shared.
• Correction: Rectify inaccurate or incomplete profile information directly within the application or request completion, updating, or correction of personal data.
• Nomination: Nominate an individual to exercise your rights in the event of death or incapacity in accordance with applicable law.
• Erasure: Request erasure of personal data that is no longer necessary for its stated purpose, subject to statutory retention, legal claims, safety obligations, processor limitations, and the scope of the live deletion flow.
• Withdrawal of Consent: Withdraw consent for consent-based processing by using available account controls or contacting us. Withdrawal does not invalidate processing lawfully performed before withdrawal and may prevent us from continuing to provide features that require the affected data.
• Grievance Redressal: If you have concerns regarding our data practices, please contact our designated privacy contact at privacy@pawgloo.com. For matters specifically concerning child safety and CSAE, please refer to our Child Safety Standards or contact our Safety Officer at safety@pawgloo.com. We are committed to resolving grievances promptly in accordance with applicable statutory timelines.

Sensitive user data & financial privacy policy

This section details the handling of sensitive personal data and financial information. A separately linked version is available in the Sensitive User Data & Financial Privacy Policy.

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

This policy governs the collection, storage, transmission, tokenization, 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.

Under the SPDI Rules, SPDI includes passwords; financial information such as bank-account, credit-card, debit-card, and other payment-instrument details; physical, physiological, and mental-health conditions; sexual orientation; medical records and history; biometric information; information relating to those categories provided for receiving a service; and information received for processing, stored, or processed under a lawful contract or otherwise.

Within the context of the Pawgloo ecosystem, sensitive personal data and related identifiers specifically encompass:

• Financial Account Instruments: Full Credit/Debit Card Numbers, Card Verification Values (CVV), Expiry Dates, Bank Account Numbers, and associated IFSC Codes.
• Payment Identifiers: Unified Payments Interface (UPI) IDs (Virtual Payment Addresses / VPAs) and payment or payout references.
• Government-Issued Identifiers (KYC): Unique identification documents and related fields, including Aadhaar, Permanent Account Numbers (PAN), and statutory Veterinary/Professional Licenses.
• Authentication and Verification Data: OTP-related records, access tokens, KYC verification results, video KYC , signatures, and other information used to authenticate an account or verify a Partner.

2. Payment-data storage boundaries

Pawgloo excludes specific payment secrets from its proprietary operational storage. We explicitly do not store full credit or debit card numbers, CVVs, or UPI PINs on our proprietary secure cloud infrastructure servers, secure databases, or cloud storage environments.

This exclusion is not a broad zero-knowledge or financial-data air-gap claim. Pawgloo’s backend receives and stores other financial and KYC information required for platform operations, including Partner bank account numbers, account-holder details, IFSC codes, UPI IDs where submitted, beneficiary references, Aadhaar and PAN details, payment and payout identifiers, order status, settlement information, and verification responses.

To support security and compliance with the Payment Card Industry Data Security Standard (PCI-DSS) and applicable regulations issued by the Reserve Bank of India (RBI), we use a segmented payment flow:

• Consumer Checkout Transmission: When a Consumer initiates a payment (Pay-in), full card details, CVVs, and UPI PINs are entered within the our authorized payment gateway SDK or checkout environment and are not provided to Pawgloo’s backend.
• Partner Payout Transmission: When a Partner provisions financial details for earnings (Pay-out), Pawgloo’s backend receives the submitted bank account, IFSC, UPI, and account-holder fields, stores applicable operational records, and transmits the required information to our payment processor.
• Secure Conduits: Data is transmitted via encrypted API connections using TLS to our RBI-authorized Payment Aggregator and verification provider, our authorized payment gateway India Pvt. Ltd.

3. Consumer application: Pay-ins and tokenization

A. Transaction flow & card-on-file (CoF) compliance When a user books a service slot (e.g., Tele-vet consultation, Dog Walking), Pawgloo’s backend is responsible for generating a unique order identifier (order_id) and calculating the transaction payload. The user is then handed over to the our authorized payment gateway SDK or hosted checkout environment to input payment credentials. Pursuant to RBI’s Card-on-File tokenization guidelines, Pawgloo does not save full card details; users may opt to tokenize their cards through our payment processor for future use.

B. Data minimization and webhook visibility Pawgloo’s backend receives signed webhook and API data from our payment processor confirming the status of the transaction (e.g., SUCCESS or FAILED). Depending on our payment processor’s response, this may include the order ID, payment ID, amount, currency, payment-method category or masked metadata, bank reference, transaction timestamp, error details, and settlement status. Pawgloo validates applicable webhook signatures. At no juncture does Pawgloo obtain visibility into the user’s full raw card number, CVV, or UPI PIN.

C. Virtual ledger security In-app wallet balances, promotional credits, payment references, and refund logs are maintained through internal transaction and ledger records. These records may use operational identifiers such as order_id, gateway references, booking references, and idempotency_keys to audit and reconcile financial activity. These records remain linked to the applicable user, Partner, booking, or account where required for service delivery, support, fraud prevention, taxation, and accounting.

4. Partner application: Pay-outs and statutory KYC

To facilitate the lawful disbursement of professional earnings and comply with applicable financial, taxation, and identity-verification requirements, Pawgloo verifies the Partner’s identity and banking credentials.

A. Beneficiary creation & mandatory verification When a Partner inputs their Bank Account, IFSC code, account-holder details, or UPI ID, our Partner backend receives the information, stores applicable payout records in secure database, and transmits the required data to our authorized payment gateway to instantiate or update a “Beneficiary” profile. We may utilize our payment processor’s verification services to execute a Penny Drop or other account-verification flow. our payment processor may return nameAtBank, account-status, bank-reference, or verification results, which our systems compare against the Partner’s registered profile to substantiate ownership and mitigate financial fraud.

B. Post-verification data storage The live Partner payout flow may retain the submitted account number, IFSC code, account-holder information, UPI ID, verification response, and related our payment processor identifiers in Pawgloo’s operational our secure database records after verification. Applicable application interfaces may display masked strings, while the underlying backend record may contain raw values required by the current implementation.

We also retain operational routing and verification information, including:

• A system-generated beneficiary reference issued by our payment aggregator.
• The verification status (verified / failed) and available verification response.
• Masked display strings (e.g., last 4 digits of the account number, partial IFSC) for the Partner’s recognition within the app dashboard.
• Raw bank account, IFSC, account-holder, or UPI fields where retained by the live payout implementation.

C. Storage of government identifiers Government-issued identifiers (Aadhaar/PAN) required for Partner KYC, payout administration, and Section 194-O TDS compliance may be received and stored by Pawgloo. Submitted Aadhaar numbers, PAN information, extracted or entered KYC fields, verification status, and related records may be stored in secure database. Uploaded Aadhaar/PAN images, video KYC , or related media may be stored in secure cloud storage. Access is limited to authorized operational, verification, compliance, support, engineering, or legal purposes according to business need and applicable law.

5. Third-party compliance and explicit consent

Because our authorized payment gateway executes consumer checkout, sensitive payment processing, settlement, beneficiary verification, and identity-validation services on behalf of Pawgloo, their operations are governed by independent security and regulatory protocols.

• Explicit Consent: By executing a financial transaction or submitting payout credentials through the Pawgloo or Pawgloo-Partners applications, you hereby acknowledge and provide explicit, affirmative consent for the secure transmission of applicable personal data and SPDI to our authorized payment gateway India Pvt. Ltd.
• Processor Processing: our payment processor processes data according to its own legal obligations, service terms, retention requirements, fraud controls, and privacy practices. Withdrawal or account deletion at Pawgloo does not automatically erase data that our payment processor must retain independently.
• Review of Partner Protocols: Users are strongly advised to review the official security architecture and privacy practices of our regulated payment aggregator: our payment processor Privacy Policy.

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

Although Pawgloo excludes full card numbers, CVVs, and UPI PINs from its operational storage, we retain other personal, KYC, payment, payout, routing, and transaction data. We maintain operational logs of API requests and system activity, with sensitive payloads minimized, masked, or obfuscated where supported and appropriate. In the event of a cybersecurity incident, unauthorized access, or personal-data breach, Pawgloo applies the following response protocol:

• Containment and Assessment: We will investigate the event, take reasonable steps to contain it, preserve relevant logs, assess the affected systems and data categories, and coordinate with relevant processors.
• Reporting Mandate: For cybersecurity incidents reportable under the applicable CERT-In directions, 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 the incident, in accordance with directions issued under subsection (6) of section 70B of the Information Technology Act, 2000.
• Data-Breach Notifications: We will notify affected users, the Data Protection Board of India, or other authorities when and within the period required by applicable law, rules, directions, or binding regulatory instructions.
• Processor Coordination: Where an incident affects secure cloud infrastructure, secure database, our communication partner, our notification provider, our payment processor, our analytics provider, our error monitoring partner, or another processor, we may exchange incident details and identifiers with that processor to investigate, contain, remediate, and comply with legal duties.

Data retention & deletion policy

This section outlines Pawgloo’s data lifecycle management practices, including current category-based retention, deletion limitations, and the right to data erasure. A separately linked version is available in the Data Retention & Deletion Policy.

1. Purpose and statutory alignment

This policy articulates the data lifecycle management practices of NEXEL PLATFORMS PRIVATE LIMITED (operator of Pawgloo). It describes the categories of personal and operational data retained, the purposes governing their lifecycle, the scope of current deletion mechanisms, and the mechanisms through which users may exercise their right to data erasure pursuant to the Digital Personal Data Protection (DPDP) Act, 2023.

2. Dynamic data retention schedules

We adhere to the principle of data minimization. Data is retained for the duration necessary to fulfill its operational purpose, support security and dispute resolution, or comply with statutory mandates in the Republic of India:

• Active Account Data: Profile information, pet dossiers, and algorithmic matchmaking preferences are retained in our primary databases for the continuous duration of your active account status to provide uninterrupted service functionality. - Location and Matchmaking Data: Submitted or selected GeoJSON location, address information, service areas, and matchmaking fields are retained while required to provide nearby-service discovery, service matching, booking administration, profile functionality, safety, and dispute resolution. - Media and Object Storage (secure cloud storage): Profile pictures, pet imagery, social content, KYC media, and uploaded chat attachments are retained while required for the applicable account, profile, communication, verification, booking, safety, legal, or

  support purpose. Deleting or replacing an in-app reference does not necessarily establish immediate deletion of every associated secure cloud storage object. - Chat and Call Data: our communication partner chat content, message events, attachment references, user records, call identifiers, participant information, status, timestamps, and duration metadata are retained according to Pawgloo’s operational needs and our communication partner’s applicable service configuration and retention practices. - Device and Notification Data: Authentication or session state held in AsyncStorage remains on the device until removed by the application, logout flow, account flow, operating system, or user action.

Push tokens and notification records are retained while needed to deliver notifications, maintain account functionality, or process delivery events. - Analytics and Diagnostics: our analytics provider analytics and our error monitoring partner diagnostics are retained according to configured processor settings, operational needs, security requirements, and the processors’ applicable policies. The live account deletion flow does not currently guarantee deletion of all historical processor events. - Ephemeral State Data: Operational state such as active call tokens, booking holds, and idempotency records is retained according to the needs and configuration of the applicable service. No universal

fixed cache deletion period is represented as live. - Customer Support & Grievance Logs: Communications directed to our support, privacy, or Trust & Safety teams are retained for as long as reasonably necessary to investigate the request, provide support, resolve disputes, maintain security and auditability, or satisfy applicable legal obligations. - Financial and KYC Data: Transaction records, ledger entries, invoices, payment references, payout batches, Partner bank details, Aadhaar/PAN fields, KYC media, and verification histories may be retained for operational, taxation, accounting, anti-money-laundering, fraud-prevention, audit, dispute-resolution, and legal purposes.

3. Mandatory legal retention

To comply with applicable Indian financial, taxation, corporate, and anti-money-laundering frameworks, including the Income Tax Act, 1961, the Companies Act, 2013, the Central Goods and Services Tax (CGST) Act, 2017, and the Prevention of Money Laundering Act (PMLA), 2002, Pawgloo may be legally prohibited from expunging data integral to financial reconciliation, statutory reporting, audits, investigations, or legal claims.

• Financial Ledgers & Transactional Invoices: Data recorded within our transaction and accounting architecture, including transaction records, ledger entries, invoices, gateway references, and payout batches, may be retained for the period required under applicable law and approved internal schedules.
• Historical Account Linkage: Following an account deletion request, financial metadata linked to historical bookings, automated payouts, TDS deductions, refunds, disputes, and payment-gateway transaction references may remain preserved where required for legal, accounting, security, or audit purposes.
• Partner KYC Retention: For Service Partners, identity verification records, Aadhaar/PAN information, verification , bank-account details, and corresponding tax-deduction histories may be retained where required for statutory, fraud-prevention, audit, dispute-resolution, or legal purposes.
• Pending Duration Approval: Any fixed eight-year or other category-specific retention period remains subject to legal review and approval and is not represented as a final live retention commitment unless separately confirmed.

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

Subject to the exceptions outlined in Section 5, users may request erasure of their personal data.

A. Initiation of the erasure request:

1. Navigate to the Settings interface within the Pawgloo or Pawgloo-Partners application where the deletion option is available.
2. Access Account Security > Delete Account, or the equivalent account-deletion interface presented by the application.
3. Alternatively, a formal, verifiable data erasure mandate may be transmitted via email to privacy@pawgloo.com from the user’s registered email address or with other information sufficient to verify the account.

B. The current erasure execution lifecycle: Upon authentication of a deletion request and completion of applicable eligibility checks:

• Account Action: The live deletion flow performs the account deactivation, deletion, or status changes implemented for the applicable user type and revokes or invalidates supported account access.
• Database and secure cloud storage Action: The deletion service removes or updates only the our secure database records and secure cloud storage object references expressly enumerated by the current implementation. It does not guarantee removal of every related record, derived record, backup, log, media variant, or object that is not identified by that service.
• Processor Omissions: The live flow does not currently orchestrate complete deletion from our communication partner, our notification provider, our payment processor, our analytics provider, our error monitoring partner, or every other processor. Requests concerning processor-held data may require additional handling and remain subject to legal or technical limitations.
• Preserved Records: Booking, transaction, payout, ledger, KYC, tax, support, safety, audit, dispute, and legal records may remain where they are outside the live deletion scope or where retention is necessary or required.

5. Legal & trust holds (Exceptions to erasure)

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

• Active Litigation or Disputes: The existence of an unresolved dispute, active insurance claim, safety investigation, regulatory inquiry, or pending litigation involving the account (e.g., a reported canine injury or property damage incident).
• Financial Delinquency: The account exhibits a negative wallet balance, an active booking or pending settlement, or the user owes an outstanding refund or financial penalty to the platform or a counterparty.
• Legal and Regulatory Duties: Records must be retained for taxation, accounting, anti-money-laundering, law-enforcement, court-order, regulatory, audit, or other binding legal purposes.
• Trust & Safety Violations: If the account has been suspended for severe breaches of the Terms of Service (e.g., violating the Anti-Circumvention Policy or engaging in abusive behavior), relevant account identifiers may be retained for a proportionate period where necessary to investigate the violation, defend legal claims, prevent fraud, or protect users.

Planned experience, not live

The following controls, deletion outcomes, architectural restrictions, and fixed retention schedules describe a planned or proposed experience. They are not representations of current production behavior, have no committed delivery date, and remain subject to technical implementation and legal approval.

Infrastructure, location, communication, cache, and access-control targets

• secure cloud infrastructure Regional Confinement: Our primary backend infrastructure, including databases, object storage, and compute instances, is planned to be hosted exclusively within the ap-south-1 (Mumbai) region, ensuring strict adherence to Indian data localization requirements. - Historical Location Non-Archival: Geospatial data would be utilized dynamically by matchmaking queries and would not be archived to track historical movements. - our communication partner Non-Archival: For in-app chat and video consultations, a generated, temporary user token would be passed to our communication partner, and Pawgloo would not record, store, or archive raw video streams of consultations on its servers. - Idempotency & Concurrency Locks: When a booking is initiated, a temporary reservation lock would be generated in an in-memory cache. This lock would contain minimal identifier data and would be engineered with a strict Time-To-Live (TTL) to automatically self-destruct after 10 minutes.

• Non-Persistence: The caching infrastructure would be strictly utilized for transient state management and would never be used for the persistent archiving of personally identifiable information (PII). - Encryption: All data transmitted between your device and our backend APIs would be secured using modern TLS/SSL protocols. Data at rest within our databases and secure cloud storage buckets would be encrypted utilizing secure cloud infrastructure Key Management Service (KMS). - Role-Based Access Control (RBAC): We would enforce the principle of least privilege. Customer support personnel would only view booking statuses and would not access private chat histories or financial ledgers. Raw database access would be restricted to authorized engineering personnel via secure, audited jump hosts.

KYC vault and payout-scrubbing targets

• Verification Documents (KYC): Sensitive identity documents (e.g., Aadhaar, PAN, Veterinary Licenses) would be uploaded directly to an encrypted, private secure cloud storage bucket. Access would be restricted via strict Identity and Access Management (IAM) policies to authorized compliance personnel only. - Post-Verification Data Scrubbing: Upon successful confirmation of verification, Pawgloo would execute an automated routine to immediately and permanently scrub the raw account number and IFSC code from its memory caches and operational records.

• Retained Payout References: Following that planned scrubbing process, Pawgloo would retain only a system-generated, encrypted beneficiary reference issued by our payment aggregator, the binary verification status (verified / failed), and masked display strings (e.g., last 4 digits of the account number, partial IFSC) strictly for the Partner’s recognition within the app dashboard. - Archival of Government Identifiers: Government-issued identifiers (Aadhaar/PAN) required for statutory KYC and Section 194-O TDS compliance would be subjected to advanced encryption protocols and stored in an isolated, access-restricted secure cloud storage bucket. Access would be governed by strict Identity and Access Management (IAM) policies, limited exclusively to the designated Grievance/Compliance Officer for the sole purposes of statutory auditing, tax reporting, and dispute resolution.

Account, processor, and anonymization targets

• Account Deletion: Users would be able to request complete account deletion via the application settings. Upon verification, profile data in our primary databases and associated media in secure cloud storage would be permanently soft-deleted and subsequently hard-deleted within 30 days. - Full Processor Deletion: The planned deletion workflow would submit or coordinate deletion or anonymization actions for data held by our communication partner, our notification provider, our analytics provider, our error monitoring partner, and other processors, subject to our payment processor’s and each processor’s independent legal-retention obligations. - Cryptographic Anonymization: Upon the successful execution of an account deletion request, the user’s profile would be “soft-deleted.” Financial metadata linked to historical bookings, automated payouts, TDS deductions, and payment-gateway transaction references would remain preserved but would be irreversibly pseudonymized or stripped of direct identifiers (Name, Exact Location) to ensure platform ledgers remain balanced and legally auditable without compromising ongoing privacy.

• Immediate Action (0-7 Days): The account would be instantly deactivated, authentications would be revoked, and the user would be delisted from search indexing, partner directories, and the social Playdate feed. - Database Purge (30 Days): Personally Identifiable Information (PII), including Name, Phone Number, and Email, would be permanently scrubbed or irreversibly hashed from the primary operational databases. All associated media assets residing in secure cloud storage would be subjected to a hard delete. - Ledger Preservation: Numeric transaction logs would be preserved solely for statutory tax audits and would be fully decoupled from the user’s identity.

Fixed retention schedules pending legal approval

The following proposed fixed durations are pending legal review and approval and do not supersede the current category-based retention statements above:

• Media and Object Storage (secure cloud storage): Profile pictures, pet imagery, and uploaded chat attachments would be retained while the account is active. Upon the user-initiated deletion of a pet profile or the overriding of an existing image, the legacy media file would be permanently and irrevocably purged from our secure cloud storage buckets within a standard 30-day automated garbage-collection cycle. - Ephemeral State Data (In-Memory Cache): Transient operational data, such as active video call tokens, temporary booking holds, and cryptographic idempotency keys utilized to prevent duplicate transactions, would be strictly ephemeral. This data would be engineered with automated Time-To-Live (TTL) triggers and permanently flushed from the caching layer within 10 minutes to 7 days, contingent upon the specific service requirement.

• Customer Support & Grievance Logs: Communications directed to our support or Trust & Safety teams would be retained for a period of two (2) years to ensure quality assurance, facilitate dispute resolution, and maintain auditability for consumer protection claims. - Financial Ledgers & Transactional Invoices: Subject to legal approval, all data recorded within our double-entry accounting architecture (including transaction records, ledger entries, and payout batches) would be retained for a proposed minimum period of eight (8) years from the culmination of the relevant financial year. - Regulatory Retention: Subject to legal approval under the Income Tax

  Act, 1961, the Companies Act, 2013, the Central Goods and Services Tax (CGST) Act, 2017, and the Prevention of Money Laundering Act (PMLA), 2002, transactional records, ledger entries, and Partner KYC metadata would be securely archived in a restricted state for up to eight (8) years following account termination. - Partner KYC Archival: For Service Partners, statutorily mandated identity verification logs (Aadhaar/PAN) and corresponding tax deduction histories would be archived in an isolated, encrypted, and access-restricted vault for eight (8) years post-account termination.

Permanent suppression target

• Trust & Safety Violations: For an account permanently suspended for severe breaches of the Terms of Service, a cryptographic “hashed fingerprint” of the user’s device ID and mobile number would be retained permanently on an internal blocklist to prevent fraudulent re-registration and protect the ecosystem. Permanent suppression is not represented as a current live control and remains subject to legal approval, necessity, proportionality, and technical implementation.