Privacy Policy

Privacy at a Glance

Promarvel Solutions (OPC) Private Limited ("Promarvel", "we", "us" or "our") operates the Promarvel Pro mobile application and related professional portals, services and support channels (collectively, the "Professional Platform"). The Professional Platform is used by authorised Promarvel employees and approved independent service partners ("Professionals").

We collect information needed to onboard and verify Professionals, allocate and complete services, protect customers, administer earnings and payouts, maintain safety and quality, prevent misuse, comply with law, and operate the Promarvel service network.

• Identity and onboarding information includes name, contact details, date of birth, gender, profile image, Aadhaar verification information, PAN, Police Clearance Certificate, background-verification results, professional experience, skills and certificates.
• Location is accessed only when required for an active, on-duty service workflow and to confirm arrival at or progress toward an assigned service location. Under the current design, Promarvel Pro does not continuously collect location after the app is moved to the background or closed.
• Customer phone numbers are not disclosed to Professionals. Calls are routed using call masking. Customer addresses are available only for active assigned services and become inaccessible to the Professional after completion or cancellation.
• Promarvel stores professional-to-customer chat messages and service media for operations, safety, quality assurance, support, dispute resolution and legal compliance.
• Professionals may request account deletion in the app or through support. Some data may be retained after deactivation or deletion where necessary for settlements, tax, accounting, contractual, fraud-prevention, safety, dispute or legal purposes.

1. Definitions

In this Policy, unless the context requires otherwise:

1. Account means an approved Promarvel Pro login associated with a Professional.
2. Applicable Law includes the Digital Personal Data Protection Act, 2023 ("DPDP Act"), the Digital Personal Data Protection Rules, 2025 ("DPDP Rules"), provisions brought into force from time to time, the Information Technology Act, 2000 and applicable rules, employment, tax, payment, consumer, telecom and other laws relevant to the processing activity.
3. Customer means a person who uses or requests services through Promarvel.
4. Data Principal, Data Fiduciary, Data Processor, Consent Manager and Personal Data have the meanings assigned under Applicable Law where those terms apply.
5. Employee means a person engaged by Promarvel under an employment arrangement.
6. Partner or Service Partner means an independently engaged and verified person or business approved to provide services through Promarvel, subject to the applicable agreement.
7. Professional means an Employee or Service Partner authorised to use Promarvel Pro.
8. Service Data means booking, assignment, location, chat, call-routing, media, completion, feedback, quality, incident and payment information generated in connection with a service.

2. Scope and Applicability

This Policy applies to Personal Data processed through Promarvel Pro, professional onboarding and verification, Promarvel websites or portals used by Professionals, Promarvel support, operations and payment workflows, and interactions with authorised vendors acting for Promarvel.

This Policy does not replace the Professional Terms of Use, employment documents, service-partner agreement, background-verification authorisation, payout terms, confidentiality obligations or other agreements. Where a document imposes a stricter privacy or confidentiality duty, the stricter duty applies to the extent permitted by law.

Customer-facing privacy practices are governed by the applicable Promarvel customer privacy policy. Professionals must not treat access to Customer information as permission to use it for personal or independent commercial purposes.

3. Our Role and Legal Framework

3.1 Data Fiduciary

For Personal Data for which Promarvel determines the purpose and means of processing, Promarvel acts as the Data Fiduciary. Vendors that process data on our documented instructions generally act as Data Processors, although a vendor may be an independent Data Fiduciary for processing it independently determines, such as certain regulated identity, telecom or payment functions.

3.2 DPDP alignment

Promarvel intends to process Personal Data for lawful purposes, provide appropriate notice, seek consent where required, permit withdrawal of consent where legally available, maintain reasonable security safeguards, facilitate applicable Data Principal rights, and erase data when its purpose is no longer served unless retention is required or permitted by law.

3.3 Employment and contractual context

Some processing may be necessary for an employment relationship, performance of a service-partner contract, protection of Customers and Professionals, compliance with legal obligations, responding to emergencies, or other uses permitted without consent under Applicable Law. Withdrawal of consent does not invalidate prior lawful processing and may make particular features or the professional relationship unavailable where the information is essential.

4. Eligibility, Registration and Account Approval

1. Promarvel Pro is for persons aged 18 years or older.
2. Professionals may self-register and await approval. HR or authorised administrators may also create accounts for Employees or Partners.
3. Mobile-number verification is performed using a one-time password ("OTP"). Submission of an application does not guarantee approval.
4. Promarvel may require identity, skill, bank, background, training and contractual checks before activation and periodically thereafter.
5. Promarvel may refuse, suspend or deactivate an Account where information is incomplete, inconsistent, expired, fraudulent, unsafe, unlawful, or does not satisfy onboarding or performance requirements.
6. A Professional must provide accurate information and promptly update changes. Impersonation and account sharing are prohibited.

5. Personal Data We Collect

5.1 Identity and profile

Full name, mobile number, email address, date of birth, gender, profile photograph, signature or digital acceptance records where used, preferred language, and account identifiers.

5.2 Government and tax information

PAN details; Aadhaar verification information processed through Digio; Police Clearance Certificate; and other identity or eligibility documents reasonably required for verification. Promarvel should avoid storing a full Aadhaar number or unrestricted Aadhaar image unless legally permitted and operationally necessary. Masked or tokenised records should be used where feasible.

5.3 Professional and workforce information

Employee ID or Partner ID, joining or onboarding date, role, service categories, work area, experience, skills, qualifications, certificates, training, availability, assignments, acceptance or rejection history, completion information, feedback, quality records, incidents, complaints and performance indicators.

5.4 Background-verification data

Police Clearance Certificate, verification application details, verification status, results and flags provided by AuthBridge or other authorised providers, and records needed to evaluate eligibility and safety.

5.5 Face-verification data

A live selfie or facial image and the profile image used to confirm that the person accessing or completing a verification step matches the enrolled Professional. Under the current design, Promarvel uses an image-comparison process and does not itself create or retain a reusable biometric face template. A verification vendor may transiently process images according to its role, contract and privacy terms.

5.6 Financial and payment information

Bank-account details, IFSC, UPI ID, beneficiary name, payment tokens or references, tax information, wallet balance, customer price, platform commission, Partner earnings, payout status, payout history, refunds, adjustments, invoices and settlement records.

5.7 Location and service-journey information

Foreground GPS location during an active, on-duty service workflow; arrival or proximity status; timestamps; assigned service location; route or map interactions; and service status. See Clause 11.

5.8 Customer and booking information

For an active assigned service: Customer name, service address, booking details, instructions, relevant photos, chat messages and service requirements. Customer phone numbers and alternate numbers are not displayed; voice calls use call masking.

5.9 Communications and content

In-app chat, support tickets, emails, masked-call metadata, notification delivery data, referral details submitted with permission, before-and-after photos, selfies, completion photos, incident reports and other content submitted through the Professional Platform.

5.10 Device, usage and diagnostic information

Device model, operating system, app version, IP address, language, time zone, device or app instance identifiers, authentication events, session information, crash logs, diagnostic data, security events and interaction data. We do not use this Policy to authorise unrelated advertising tracking.

5.11 Information not currently collected as a standard feature

Promarvel Pro does not currently require Bluetooth or calendar access; does not currently upload service videos or customer signatures; and does not currently use voice recordings, AI-based fraud detection, AI quality scoring or AI attendance verification. Any introduction of these practices will require appropriate notices, permissions and app-store disclosure updates.

6. Sources of Personal Data

We receive Personal Data:

• directly from Professionals during registration, verification, support and service performance;
• from HR, administrators, managers, trainers and authorised Promarvel personnel;
• from Customers in connection with assigned services, chats, photos, feedback, complaints or safety matters;
• from Digio for Aadhaar or identity-verification workflows;
• from AuthBridge and Police Clearance Certificates for background checks;
• from payment providers, banks and UPI participants for settlements and verification;
• from Google Maps, device operating systems, Firebase, analytics and diagnostic services;
• automatically through use of Promarvel Pro, subject to settings and permissions; and
• from lawful public, government or regulatory sources where appropriate.

7. Why We Process Personal Data

We process Personal Data for the following specified purposes:

1. Account creation and authentication: registration, OTP verification, login, one-active-device enforcement, recovery and security.
2. Eligibility and identity: confirming identity, age, qualifications, role and authority to provide services.
3. Background and safety: police and third-party verification, risk assessment, incident response and protecting Customers, Professionals and Promarvel.
4. Service operations: matching or assigning jobs, scheduling, navigation, confirming arrival, enabling communications, documenting completion and handling rescheduling or cancellation.
5. Customer experience: delivering requested services, quality assurance, support, complaint handling and dispute resolution.
6. Financial administration: calculating price, commission and earnings, operating wallets, processing payouts, reconciliation, invoices, tax and audit.
7. Employment administration: workforce records, role management, training, assignment, performance and compliance, as applicable to Employees.
8. Partner administration: onboarding, availability, allocation, commissions, payouts, performance, contractual compliance and partner support.
9. Security and misuse prevention: detecting impersonation, account sharing, unauthorised access, customer solicitation, platform bypass, fraud or policy violations.
10. Communication: service notifications, operational updates, email, support and masked calls.
11. Analytics and improvement: understanding reliability, app performance, service outcomes and improving the Professional Platform.
12. Legal compliance: maintaining statutory records, responding to lawful requests, asserting or defending claims, and enforcing agreements.
13. Corporate administration: audits, financing, restructuring, merger, acquisition, transfer of business or insolvency, subject to safeguards.

8. Consent and Other Permitted Processing

8.1 Notice and affirmative action

Where consent is required, we will provide or link to a notice describing the Personal Data and purpose, and seek consent through a clear affirmative action, such as an unchecked box, permission prompt, OTP confirmation, digital acceptance or document authorisation.

8.2 Withdrawal

A Professional may withdraw consent using available account controls or by contacting us. Withdrawal is as easy as the method reasonably available for giving consent. It does not affect processing already undertaken lawfully. Where a permission or data item is necessary for a feature, withdrawing it may prevent use of that feature or continuation of certain professional activities.

8.3 Permitted uses

We may process Personal Data without fresh consent where Applicable Law permits, including for employment-related purposes, responding to medical emergencies or threats to safety, compliance with a judgment or legal obligation, or other recognised legitimate uses.

8.4 Registration consent wording

9. Identity, Aadhaar and Face Verification

9.1 Aadhaar through Digio

Where Aadhaar is used, the verification workflow is provided through Digio APIs or related authorised infrastructure. Information may be transmitted to Digio and relevant verification systems to confirm identity. Promarvel will use the outcome and minimum necessary verification record for onboarding, compliance and fraud prevention.

Aadhaar is not the only acceptable identity mechanism where Applicable Law requires a voluntary alternative. Promarvel will not publicly disclose Aadhaar information, use it for unrelated marketing, or retain unrestricted copies longer than necessary. Developers must implement masking, access controls and encryption and ensure the workflow follows applicable Aadhaar, UIDAI and vendor requirements.

9.2 Face comparison

Face verification compares a live selfie or captured facial image with the Professional's enrolled profile image to reduce impersonation. Promarvel does not currently create a persistent mathematical biometric template for reuse. Images and verification results may be retained for the period necessary to document verification, investigate misuse and comply with law, subject to the retention framework.

9.3 Failed verification

If automated or assisted verification fails, the Professional may be asked to retry or complete a manual review. Promarvel should not make a materially adverse decision solely on an unreliable automated match without an appropriate human review process.

10. Background and Police Verification

Professionals may be required to submit a Police Clearance Certificate and authorise background verification through AuthBridge. Checks may include identity, address, criminal-record or police-record checks where legally available, employment, education, professional licence, reference, sanctions or other checks appropriate to the role and expressly disclosed.

Promarvel may receive verification status, reports, discrepancies and supporting information. Access is limited to personnel and processors with a need to know. Results may be used to approve, condition, reject, suspend, investigate or deactivate professional access, subject to Applicable Law and reasonable opportunity to correct inaccurate information.

Professionals must not submit forged or altered documents. Promarvel may share suspected fraudulent material with the verification provider, law enforcement or other authorities where lawful and necessary.

11. Location Data

11.1 When location is collected

Promarvel Pro requires location access for service operations. Under the current design, precise GPS is collected in the foreground while the Professional is on duty and actively using an assigned service workflow, including to support navigation and confirm whether the Professional has reached or is near the service location.

11.2 No continuous background collection

Promarvel Pro does not currently continuously collect location after the app is minimised, moved to the background or closed. Location collection also ceases when the applicable service workflow ends. The production app must be configured consistently with this statement.

11.3 Uses

Location may be used for assignment suitability, estimated arrival, navigation, arrival confirmation, customer support, safety, service verification, incident investigation and preventing false completion. It is not used for unrelated advertising.

11.4 Controls

A Professional may manage location permission in device settings, but disabling required location access may prevent the Professional from receiving, starting, navigating to or completing assigned services.

12. Device Permissions

Promarvel Pro may request permissions only when relevant and should use just-in-time explanations:

Bluetooth and calendar permissions are not currently used. Permission denials must not be treated as consent, and permissions must not be requested for unrelated purposes.

13. Customer Data and Confidentiality

13.1 Limited access

Professionals receive only Customer information reasonably necessary for an active assigned service. This may include the Customer's name, address, service instructions, relevant uploaded photos and chat messages.

13.2 Address controls

The service address is available only during the active assignment and becomes inaccessible to the Professional after completion or cancellation. Promarvel may retain it in restricted systems for support, disputes, tax, fraud prevention and legal purposes.

13.3 Phone-number protection

Customer phone numbers and alternate phone numbers are not displayed. Calls are routed through a call-masking service. Professionals must not attempt to discover, request or circumvent masking to obtain a Customer's personal number.

13.4 Prohibited conduct

Professionals must not copy, photograph, screenshot, export, save, share, sell, publish or otherwise retain Customer information except within authorised Promarvel workflows. They must not share personal numbers, take a Customer offline, solicit repeat services outside Promarvel, market unrelated products, or use Customer data for personal purposes.

13.5 Consequences

Unauthorised Customer-data use may result in access restriction, investigation, deactivation, disciplinary or contractual action, recovery of losses, reporting to authorities and other remedies.

14. Communications, Chat and Call Masking

14.1 In-app chat

Promarvel stores messages and permitted photos exchanged in the Professional-to-Customer chat. Messages may be reviewed by authorised personnel for customer support, safety, complaint handling, service verification, quality assurance, fraud prevention, enforcement and legal compliance. Professionals must keep communications service-related and respectful.

14.2 Calls

Calls between a Professional and Customer are connected using number masking. Promarvel may process call metadata such as participants' masked identifiers, timestamps, duration, connection status and routing logs. Promarvel does not currently state that it records call audio. If call recording is introduced, Promarvel must provide a specific notice and obtain consent where required.

14.3 Notifications and email

We send push notifications and operational emails about registration, verification, assignments, service status, safety, policy, payment and support. SMS and WhatsApp are not currently used as standard outbound communication channels, apart from OTP delivery where applicable. Professionals can control optional notifications through device or app settings, but essential service or legal notices may still be sent.

15. Photos, Selfies and Service Media

Professionals may upload profile images, identity or certificate images, live selfies, before-and-after photos, service-completion photos, chat images and incident evidence. Videos and customer signatures are not currently standard features.

Promarvel may retain and use submitted service media for:

• verification of identity, attendance at a particular workflow step or service completion;
• quality assurance, audit, training and process improvement;
• customer support, refunds, claims and dispute resolution;
• safety, fraud prevention and investigation;
• legal compliance and evidence preservation; and
• marketing only where a separate lawful basis, appropriate permission and customer/professional consent have been obtained.

Professionals must avoid capturing unrelated persons, private areas, documents, screens or household details. Images must be limited to what is necessary for the service. Promarvel does not claim ownership of every image merely by upload; however, the Professional grants Promarvel a non-exclusive, worldwide, royalty-free licence to host, reproduce, analyse and use the media for the operational and legal purposes described above for as long as those purposes continue.

16. Earnings, Wallet and Payout Data

For Service Partners, Promarvel Pro may display Customer price, platform commission or fee, net earnings, wallet balance, adjustments and payout history. Employees may see role-appropriate operational or incentive information where enabled; salaried compensation may be administered through separate HR or payroll systems.

Promarvel receives Customer payments and arranges settlement or Partner payout through payment providers such as Razorpay, Juspay, banks, UPI or other authorised payment systems. We process financial records to verify beneficiaries, calculate amounts, prevent duplicate or fraudulent payouts, handle reversals, maintain accounts, generate invoices and comply with tax and audit obligations.

Payment providers may independently collect KYC, device, bank or transaction information under their own legal obligations and privacy terms. Promarvel generally does not store full card credentials.

17. Employee-Related Processing

For Employees, Personal Data may be processed for onboarding, role and location assignment, service allocation, training, work supervision, quality, safety, performance, investigation, disciplinary processes, payroll-linked administration, benefits, statutory compliance, separation and post-employment obligations. This Policy does not create a term of employment or limit rights under employment documents and law.

Access to employee information is role-based. Managers should receive only the information reasonably necessary to supervise operations. Promarvel will not use Professional Platform data for unlawful discrimination or unrelated intrusive monitoring.

18. Service-Partner Processing

For Partners, Personal Data may be processed for approval, contract administration, availability, service matching, assignment acceptance, commission and payout calculation, tax records, ratings or quality indicators, complaint management, safety, suspension, deactivation and enforcement of platform terms.

The Professional Platform supports both trained Promarvel Employees and verified Service Partners. All Professionals are expected to meet applicable quality, safety, hygiene and customer-service standards. Nothing in this Privacy Policy by itself determines whether a person is an employee or independent contractor; that status is governed by the actual relationship, written agreement and Applicable Law.

19. When We Disclose Personal Data

We may disclose Personal Data to:

1. Customers: limited profile, name, photo, role, service status, rating or other information needed for trust and completion.
2. Promarvel personnel and affiliates: HR, operations, finance, safety, support, technology, legal, audit and management personnel on a need-to-know basis.
3. Processors and vendors: identity and background verification, cloud hosting, maps, communications, analytics, security, customer support, payments, messaging and software providers.
4. Banks and payment networks: to verify and process settlements, payouts, refunds and compliance.
5. Professional advisers: lawyers, accountants, auditors, insurers and investigators subject to duties of confidentiality.
6. Authorities: courts, law enforcement, regulators, tax authorities or government agencies where required by law, lawful process, safety or protection of rights.
7. Corporate transaction participants: potential or actual investors, purchasers, successors, lenders or advisers in a merger, restructuring, financing, asset transfer or insolvency, subject to safeguards.
8. At your direction: persons or services you ask us to interact with, such as a referral contact, where the relevant person's privacy is respected.

Promarvel does not sell Professional Personal Data for monetary consideration. We do not authorise vendors to use it for unrelated behavioural advertising.

20. Service Providers and Integrations

The production app may integrate the following categories and providers:

This list must be checked against the final SDK inventory before publication. A provider may change, and Promarvel may use a functionally equivalent provider. We require appropriate contractual, confidentiality, security and data-use commitments where applicable.

21. Data Hosting and Cross-Border Processing

Promarvel primarily operates in India. Some cloud, analytics, security, communications or support providers may process or access data from locations outside the Professional's State or outside India, subject to Applicable Law and any government restrictions on transfer to specified countries or territories.

Where cross-border processing occurs, Promarvel will take reasonable steps to use reputable providers, define purposes and security obligations contractually, apply access controls and comply with applicable transfer restrictions. Professionals may contact us for current information about material processing locations, subject to security and confidentiality limitations.

22. Security Safeguards

Promarvel uses reasonable technical and organisational safeguards appropriate to the nature and risk of the data, which may include encryption in transit and at rest, access controls, role-based permissions, authentication, one-active-device controls, logging, backups, vendor due diligence, vulnerability remediation, secure development, incident response and confidentiality obligations.

No system is completely secure. Professionals must protect their credentials and device, promptly install updates, avoid untrusted networks, report suspicious activity, and not store Customer data outside approved tools. Promarvel is not responsible for compromise caused by a Professional's deliberate sharing, unauthorised screenshots, malware or failure to secure the device, except to the extent liability cannot lawfully be excluded.

23. Account and Device Security

1. Promarvel Pro permits one active logged-in device per Professional Account.
2. A new-device login may invalidate or require re-verification of the previous session.
3. Professionals must not share OTPs, passwords or devices used for active services.
4. Promarvel may require OTP, selfie or other identity verification following a risk event.
5. Promarvel may remotely invalidate sessions for suspected compromise, separation, suspension or policy violation, even if a user-facing remote-logout feature is not currently available.
6. Lost or stolen devices must be reported immediately through support.

24. Data Retention

24.1 General rule

We retain Personal Data only for as long as necessary for the specified purpose or as required or permitted by law. Retention is determined by the nature of the data, employment or partner status, settlement and tax cycles, safety risk, dispute limitation periods, audit requirements and legal holds.

24.2 Separation or deactivation

When a Professional leaves Promarvel or is deactivated, operational access is disabled. Promarvel does not immediately erase all records if payments, returns, complaints, investigations, equipment, customer issues, tax, accounting, audit, litigation or legal obligations remain outstanding.

24.3 Restricted archival

Information retained after deactivation should be moved to restricted or archived access where practical and used only for permitted purposes. Identifiers may remain in service history to preserve accurate financial, safety and audit records.

24.4 Deletion and anonymisation

At the end of the applicable period, data is deleted, securely destroyed or irreversibly anonymised, unless a legal hold or continuing lawful purpose applies.

25. Account Deletion and Deactivation

25.1 How to request

Professionals may request deletion through the in-app account-deletion option or by contacting support at the address in Clause 34.

25.2 Verification and settlement

We may verify the requester's identity and require completion of pending services, customer matters, wallet adjustments, payouts, equipment return, investigations or contractual obligations before final closure.

25.3 What deletion means

Deletion removes or de-identifies data that is no longer required. It does not require Promarvel to erase records that must or may lawfully be retained, including invoices, payout history, tax and accounting records, identity and verification evidence, fraud and security logs, customer complaints, chat or service evidence, and records needed to establish, exercise or defend legal claims.

25.4 App-store account deletion

The in-app process should clearly explain the steps, expected consequences, categories retained and a support route. A web deletion route may also be provided. Developers must ensure the implemented process matches Apple and Google account-deletion requirements.

26. Your Rights and Responsibilities

26.1 Rights

Subject to Applicable Law and verification, a Professional may have the right to:

• obtain a summary of Personal Data being processed and processing activities;
• request correction, completion or updating of inaccurate or incomplete data;
• request erasure where the purpose is no longer served and retention is not required;
• withdraw consent for consent-based processing;
• raise a grievance and receive an appropriate response;
• nominate another individual to exercise rights in the event of death or incapacity, where applicable; and
• approach the competent authority or Data Protection Board as permitted by law after using available grievance channels.

26.2 How to exercise rights

Submit a request through in-app support or the contact in Clause 34. We may request information necessary to authenticate the Account and protect against fraudulent requests. We may decline or limit a request where permitted by law and will explain the basis where appropriate.

26.3 Professional duties

Professionals must comply with Applicable Law, provide authentic information, not impersonate another person, not suppress material information, not register false or frivolous grievances, protect Customer data and cooperate with reasonable verification.

27. Grievance Redressal

Privacy grievances should include the Professional's registered mobile or email, a clear description, relevant dates and supporting material. Promarvel will acknowledge and address grievances within the period required by Applicable Law and its internal grievance process.

These placeholders must be replaced before publication. The same contact should appear consistently in the app, website, Play Console, App Store Connect and related policies.

28. Personal-Data Breaches

Promarvel maintains an incident-response process to identify, contain, investigate, remediate and document Personal Data breaches. Where required, we will notify affected Data Principals and the Data Protection Board or other authority in the form and timeframe prescribed by Applicable Law.

Professionals must immediately report a lost device, exposed OTP, unauthorised screenshot, accidental Customer-data disclosure, suspicious login, phishing message or other security incident. Professionals must not conceal, independently publicise or destroy evidence of an incident.

29. Future Automation, AI and Enhanced Verification

Promarvel may introduce enhanced identity verification, video verification, background-verification updates, digital agreements, AI-assisted quality monitoring, anomaly detection or fraud-prevention tools. Before materially new processing begins, Promarvel will assess necessity and proportionality, update notices and app-store disclosures, obtain consent where required, and implement appropriate human review and security safeguards.

Promarvel does not currently use AI quality scoring, AI fraud detection, AI attendance verification or voice recording as standard Promarvel Pro features. This clause is not blanket consent for undisclosed future processing.

30. Children and Age Restriction

Promarvel Pro is not intended for persons under 18 years of age. We do not knowingly approve a minor as a Professional. If we discover that an Account belongs to a minor, we may suspend it and delete or restrict the data, subject to legal and safety requirements.

31. Legal Requests, Claims and Corporate Events

We may preserve or disclose Personal Data when reasonably necessary to comply with law or lawful process, protect life or safety, investigate fraud or misconduct, enforce agreements, collect amounts, or establish, exercise or defend legal claims. We review requests for appropriate authority and scope where practicable.

If Promarvel undergoes financing, restructuring, merger, acquisition, sale, transfer or insolvency, Personal Data may be reviewed or transferred as part of the transaction, subject to confidentiality, security and Applicable Law. A successor must use the data consistently with applicable notices unless a new lawful basis and notice are provided.

32. Apple App Store and Google Play Disclosures

32.1 Consistency requirement

Promarvel's Apple App Privacy responses, Google Play Data safety form, permission declarations, in-app notices and this Policy must accurately and consistently reflect the production app, including data collected by SDKs and vendors.

32.2 Likely categories linked to a Professional

Depending on the final implementation, disclosures may include contact information, identifiers, financial information, precise location, photos, user content, app interactions, diagnostics, and other data linked to the Professional. Data used solely for app functionality or fraud prevention should be classified accurately and not as advertising tracking unless actually used for tracking.

32.3 Prominent disclosures

Where app-store rules require a prominent in-app disclosure-particularly for precise location, sensitive permissions, background behaviour or collection outside reasonable user expectation-Promarvel will present the disclosure before the permission or collection and obtain the required consent.

32.4 SDK review

Developers must maintain an SDK inventory, review each SDK's data practices and manifests, disable unnecessary collection, and update disclosures whenever an SDK, permission, purpose or data flow changes.

33. Changes to This Policy

We may update this Policy to reflect changes in law, technology, vendors, services or business practices. The "Last updated" date will be revised. Where a change materially affects the purpose of processing or your rights, Promarvel will provide an appropriate notice and obtain fresh consent where required.

Continued use after a non-consent-based update takes effect is subject to the updated Policy. A Professional may stop using the Professional Platform and request account closure, subject to retention and outstanding obligations.

34. Contact Us

Promarvel Solutions (OPC) Private Limited
Registered office: [INSERT COMPLETE REGISTERED OFFICE ADDRESS]
Privacy email: [INSERT PRIVACY EMAIL, e.g., privacy@promarvel.com]
Support email: support@promarvel.com
Support URL: https://www.promarvel.com/support
Telephone: [INSERT OFFICIAL BUSINESS NUMBER]

For faster handling, use the subject "Promarvel Pro Privacy Request" and provide the registered mobile number or email, without sending passwords or OTPs.

Annexure A - Data Processing Schedule

Annexure B - Permission and Disclosure Checklist

1. Request camera only at the point of photo, selfie, document or service-media capture.
2. Use selected-photo or limited-library access where supported.
3. Request foreground precise location with a clear explanation tied to active services.
4. Do not request "always" or background location unless the policy and app are formally changed and the feature is essential.
5. Prefer SMS Retriever / OTP autofill APIs without broad SMS permission. Broad SMS permissions require strict Google Play eligibility.
6. Request contacts only after the Professional starts a referral flow; do not upload or retain the entire contact list.
7. Keep microphone and phone permissions optional and tied to a specific call function.
8. Provide an in-app account-deletion path and publish a matching web deletion route if required.
9. Show customer addresses only for active assignments and remove access on completion/cancellation.
10. Implement one active device, session invalidation and risk-based re-verification.
11. Maintain a current data-flow map and SDK register for each release.
12. Review Apple Privacy Nutrition Labels and Google Data safety answers before every submission.

Annexure C - Retention Framework for Legal Review

The following is a governance framework, not a final statutory schedule. Counsel and finance should approve exact periods:

Annexure D - Mandatory Professional Privacy Duties

1. Use Customer data only to complete the assigned Promarvel service.
2. Do not save Customer details to personal contacts, notes, messaging apps, galleries or cloud drives.
3. Do not photograph the Customer, home, office, documents or belongings except where the service workflow specifically requires it.
4. Do not disclose addresses, chats, images, service details or Customer identity to another person.
5. Do not exchange personal phone numbers or bypass call masking.
6. Do not solicit or accept off-platform repeat business from a Promarvel Customer.
7. Keep the device locked and do not share the Account, OTP or credentials.
8. Report accidental disclosure, lost devices, suspicious access and safety incidents immediately.
9. Delete any locally cached data when instructed and on separation.
10. Cooperate with lawful privacy, security, support and audit requests.