Privacy Policy

We collect minimal data necessary to operate the service. This is broken down into the following categories:

We use your data solely for:

We use first-party analytics (Firebase) to improve app stability and performance. This data is not shared with third-party ad networks.

We use the following trusted third-party services:

• Firebase (Google): For authentication (phone OTP, Sign in with Google, Sign in with Apple), cloud storage, and privacy-preserving analytics (with Advertising ID disabled). Firebase processes data in accordance with Google's privacy policies and our strict configuration to block ad tracking.
• Sign in with Google: Optional sign-in method. When you choose this, Google authenticates you and shares your email address and display name with ShareLync. We do not request access to your Google contacts, calendar, or other Google services. Google's handling of your data is governed by Google's Privacy Policy.
• Sign in with Apple: Optional sign-in method. When you choose this, Apple authenticates you and shares your email address and (on first sign-in only) your full name with ShareLync. If you choose “Hide my email,” Apple provides a private relay address (‘xxxx@privaterelay.appleid.com’) which forwards email to your real address — we never see your real email in this case. Apple's handling of your data is governed by Apple's Privacy Policy.
• Firestore Database: Stores your encrypted profile data. We only store the encrypted blob - the actual content is unreadable without your unique link.
• Google Gemini AI: Used to analyze and extract information from uploaded biodata documents during profile creation. Documents are processed via Google's API and are not used for AI model training. Processing is governed by Google's Gemini API Terms of Service.
• Google Cloud Functions: Used to temporarily receive and process uploaded documents for AI extraction, and to compute the account-recovery hash described above. Documents are automatically deleted within 30 seconds of processing.
• Meta WhatsApp Business Cloud API: Used to deliver a one-time qualification message via our verified ShareLync Business number when you submit a phone number to the Introductions waitlist (see Section 6). Meta receives your phone number, the rendered text of our message, and Meta-side delivery status callbacks (sent / delivered / read / failed). Meta's handling of this data is governed by Meta's WhatsApp Business Policy and Privacy Policy.
• Razorpay: Payment processor for paid Hub Owner subscriptions (see Section 7). When you pay for a paid plan, Razorpay receives the payment instrument details you enter on their hosted checkout — ShareLync does NOT see or store your card / UPI / netbanking credentials. Razorpay returns only the payment status, transaction ID, and the masked instrument summary to our servers. Razorpay's handling is governed by their Privacy Policy.

We do NOT sell your data to advertisers or any third parties.

We do not sell, rent, or trade your personal data.

Since we cannot read your encrypted bio-data, we cannot share it with advertisers or third parties even if we wanted to.

Legal Requirements: If required by Indian Law Enforcement agencies under valid legal process, we may share your Account Information (Phone Number, Firebase UID). However, we cannot share your Bio-Data contents as they are end-to-end encrypted and we do not possess the decryption keys.

Profile Sharing: When you share your profile link with someone, they receive access to decrypt and view your profile. You control who receives this link.

Link Previews: When the Link Preview feature is enabled, a minimal public card (name, location, profession, photo) is stored in unencrypted form to generate social media preview cards (e.g., WhatsApp, Telegram, Twitter). This data is publicly accessible via the shared link but contains no sensitive details. You can disable this feature at any time, which immediately deletes the public card.

Family Hub is an optional feature that lets one ShareLync user (a “Hub Owner”) invite other users to add their biodatas to the Hub Owner's network. It is typically used by families managing biodatas on behalf of multiple relatives, or by community members who help others present their biodata. The feature is OFF by default and only becomes available when ShareLync enables it via Remote Config.

What the Hub Owner sees about you (if you join their Family Hub):

• The same minimal Link Preview fields described in Section 1 above: your name, city/state, profession, and primary photo.
• The fact that your biodata is part of their hub (an entry in their portal).
• Nothing else. Your encrypted biodata — date of birth, family details, partner preferences, contact information, additional photos, salary, education details — remains encrypted on your device with a key only you control. The Hub Owner cannot decrypt it without the link you choose to share.

Your consent and your rights:

• Affirmative consent. Before your biodata enters a Hub Owner's portal, you must tick a consent checkbox on the invite landing page that explicitly identifies the Hub Owner and the data fields they will see. The Continue button is disabled until you tick it.
• Leave at any time. You can remove yourself from a Family Hub from your dashboard. The Hub Owner stops seeing your biodata immediately; your biodata itself stays yours and untouched.
• Erasure. If you delete your ShareLync profile, your entry is removed from the Hub Owner's portal automatically and the invite that bound you to the hub is invalidated.
• Independent users. Hub Owners are independent ShareLync users, not ShareLync employees or agents. We do not control how a Hub Owner uses the information you choose to publish.

DPDPA 2023 notice (recipients of your personal data):

For the purposes of Section 5 of the DPDPA 2023, the following parties may receive your personal data when you join a Family Hub:

• ShareLync (Data Fiduciary) — receives the encrypted biodata and the minimal Link Preview card, as described in Sections 1, 3, and 4 above.
• The Hub Owner you joined — receives the Link Preview card fields (name, city/state, profession, photo) and the fact of your hub membership. The Hub Owner becomes a recipient of your personal data; we do not control their downstream use.
• Anyone with the invite link — can see the inviter's display name, the name the inviter typed for you, and any short note they wrote. Do not forward invite links carelessly.

ShareLync operates an invitation-only waitlist for the Introductions product (the Hub Owner customer relationship management surface at hub.sharelync.app). Two web surfaces accept waitlist submissions: the “Introductions” section on the main landing page at sharelync.app, and the dedicated outreach page at sharelync.app/for-matchmakers (the latter being an unindexed page disclosed to potential customers in the course of one-to-one outreach). This Section describes the categories of Personal Data we collect through those forms, the purposes for which we process them, the lawful basis under the DPDPA, the third parties to whom we disclose them, and the manner in which you may exercise your rights.

Lawful basis (DPDPA Sections 6 & 7):

Processing of waitlist submissions and any subsequent outreach communications is grounded on your consent under DPDPA Section 7(a), signified by your affirmative action of clicking the “Request early access” or “Join the waitlist” button after having been shown, immediately above the button, a plain-English notice describing what will happen (including, if you have submitted a phone number, that you will receive a one-time WhatsApp Business message). You may withdraw this consent at any time by the means described in “How to opt out” below; withdrawal does not affect the lawfulness of processing carried out before withdrawal.

What the waitlist form collects:

• Your name (required) — used to address you in the qualification message.
• WhatsApp number or email (at least one required) — the channel we'll use to reach you. The phone number is normalised to international E.164 format (e.g. +91…) using the country you pick from the dropdown.
• City (optional) — helps us route you to a peer matchmaker we already work with in your area.
• Approximate biodatas you handle today (optional — 1-5, 5-20, or 20+) — qualifies the lead so we can prepare the onboarding conversation.
• Source tag — automatically set to the form you used (landing-introductions or for-matchmakers). Used to measure which outreach channels work.
• Submission timestamp.

Cross-border transfer disclosure (DPDPA Section 16):

The WhatsApp Business Cloud API is operated by Meta Platforms, Inc. (a company incorporated in the United States), through subsidiaries and affiliates. Where the WhatsApp Business contact described above occurs, Personal Data (your phone number, the message content, and Meta-side delivery metadata) is transferred to Meta's servers, which may be located outside India, including in the United States and the European Union. We rely on the standard data-processing terms made available by Meta to advertisers and businesses using the WhatsApp Business Cloud API, and on the safeguards Meta represents to maintain under applicable data-protection laws. The Central Government has not, as of the “Last Updated” date above, notified any country as a restricted territory under DPDPA Section 16; if any such notification is made, we will reassess this transfer mechanism. Email transactional messages are delivered by our email provider, which is similarly headquartered outside India; the same disclosure applies. See Section 16 below for the consolidated cross-border-transfer notice.

How we use this information:

• One-to-one outreach. A human on the ShareLync team reads your submission and writes back, on WhatsApp or by email, within a working day. No automated drip campaigns. No third-party advertising lists.
• Onboarding readiness. The qualification answers help us decide whether the product is a fit for you and what to demo on a working call.
• Distribution analytics. We track the count and source of signups internally to measure outreach health. These analytics never include your name or contact details — only the aggregate count per source tag per day.

Storage, security measures, and retention (DPDPA Section 8):

• Submissions are written to a Firestore collection (introducer_waitlist) operated by Firebase / Google Cloud. The collection is gated by Firestore Security Rules so that no client can read, list, update, or delete its documents; only authenticated members of our admin-users allowlist can. Field-level validation rules enforce a minimum and maximum length on each field, a regular-expression check on phone numbers (E.164) and email addresses, and a closed set of permitted source tags.
• Inbound and outbound WhatsApp messages exchanged with our Business number are stored in a separate server-only collection (whatsapp_messages) to maintain a complete conversational record. We store the message text, the recipient or sender phone number, the Meta-generated message identifier (the “wamid”), and delivery-status timestamps (sent / delivered / read / failed). We do not store WhatsApp media payloads (photographs, voice notes, documents) on our servers — only text.
• Qualification emails sent through our transactional-email queue (Firestore collection mail) carry your name, city, biodatas-count answer, and the rendered HTML body, retained for delivery-audit purposes.
• Inbound webhook payloads from Meta are authenticated using HMAC-SHA-256 signature verification against the Meta App Secret before any database write occurs (DPDPA Section 8(4) — reasonable security safeguards).
• Retention period. We retain waitlist submissions, conversational records, and qualification emails for the duration necessary to (a) onboard you as a customer or (b) demonstrate that we have responded to your submission. If you do not respond to our outreach within twelve (12) months and have not been onboarded as a customer, we will treat the purpose as having been served (DPDPA Section 8(7)) and erase your record automatically at the next quarterly retention sweep. If you have withdrawn consent, we will erase the record within seven (7) working days of receipt of the withdrawal request, retaining only that minimum information (your contact identifier and the timestamp of withdrawal) that is necessary to demonstrate compliance with the request itself, for a further period of three (3) years from withdrawal, after which it too is erased.

How to withdraw consent or request erasure:

• Before submission — do not submit the form. The notice above the submit button is the consent moment; the form is not transmitted to our servers until you click the button.
• By WhatsApp, after submission — reply STOP, UNSUBSCRIBE, OPT OUT, or any clear refusal to the qualification message. Our webhook records the inbound message immediately upon receipt; we will not send any further proactive messages and the conversation closes.
• By email, after submission — write to contact@sharelync.app with the subject “Remove me from the Introductions waitlist”, identifying yourself by the phone or email you submitted. We will acknowledge within 72 hours and delete the record (along with the corresponding WhatsApp thread, if any) within seven (7) working days, retaining only the proof-of-erasure entry described above.
• Withdrawing consent does not affect the lawfulness of any processing carried out before the withdrawal takes effect (DPDPA Section 6(4)). Messages that have already been delivered to your WhatsApp client or email inbox are not within our control to retract; you may delete them from your own client.

DPDPA 2023 notice — categories of recipients (Section 5(i)(c)):

• ShareLync (the Data Fiduciary) — reads your submission and any WhatsApp or email replies, and uses them to determine whether to extend an onboarding invitation.
• Meta Platforms, Inc. (Data Processor under DPDPA Section 8(2), acting on documented instructions of ShareLync through the WhatsApp Business Cloud API terms) — processes the WhatsApp messages we exchange. Meta receives your phone number, the message text and template parameters, and returns delivery-status metadata. Meta's servers are located outside India; see Section 16 (Cross-Border Data Transfer).
• Google LLC / Google Cloud / Firebase (Data Processor) — provides the underlying infrastructure on which the Firestore collections, Cloud Functions, and authentication services operate. Personal Data at rest is stored within Google's multi-region storage; servers may be located outside India.
• Our transactional-email provider (Data Processor) — delivers the qualification email if you submitted an email address. The provider receives your name, email, and the rendered email body. The provider is identified in Section 16.

If you are accepted into the Introductions program, you will receive a one-time invitation token entitling you to claim a Hub Owner account at hub.sharelync.app. This Section describes the categories of Personal Data we collect, retain, and process in connection with the Hub Owner account — distinct from the consumer biodata data described in Sections 1–4 and the candidate-member data described in Section 5. By claiming a Hub Owner account, you accept the additional terms set out in our separate Hub Owner Terms of Service.

Lawful basis (DPDPA Sections 6 & 7):

• Provision of the contracted service — we process your Hub Owner profile, member roster, notes, pairings, share log, activity log, and helper records to provide the Introductions service you have engaged ShareLync to provide.
• Consent (DPDPA Section 7(a)) — for any processing beyond the strict contractual minimum, including diagnostic analytics and product-improvement signals.
• Legitimate use — compliance with a legal obligation (DPDPA Section 7(b) and Section 8(7)) — for the retention of billing, invoice, and audit-trail records to the extent required by applicable tax, accounting, and audit laws.
• Performance of a contract — for the processing of payment instructions and the issuance and settlement of invoices through Razorpay.

Important — your status as an independent Data Fiduciary for your members:

Data the Hub Owner provides directly:

• Account identifiers — the Firebase Auth identity you signed in with (phone number, Google email, or Apple email/relay), plus a Firebase User ID.
• Hub Owner profile stored in the hub_owners/{uid} document: display name, optional photo, optional bio, primary city, the slug you publish at /i/<cardSlug> as the Introducer attribution card, and your billing plan / status (see “Billing” below).
• Member roster — the people who accepted your invite. Each entry stores the candidate's Link Preview card fields (name, city/state, profession, photo) plus the binding to your hub. Encrypted biodata content stays with the member — you (and we) cannot decrypt it without the link the member chooses to share.
• Per-member private notes stored at family_hub_notes/{hubOwnerUid}__{memberPublicHash} — freeform text you write about each candidate. Only you can read or write your own notes (Firestore rules enforce this). v1 stores notes in plaintext on the server; v2 will encrypt them with a Hub-Owner-derived key.
• Pairings board (Matches) stored at family_hub_matches/{matchId} — the two candidates you're pairing, the current stage (considering / in motion / engaged / married), stage history, and timestamps. Snapshot fields (name, age, city, photoUrl) are captured at create-time so your record survives even if a candidate later deletes their biodata.
• Activity log stored at hub_activity/{eventId} — an append-only log of share events, member joins, helper invites, and other operational events for your own audit trail.
• Share log — when you share a candidate's biodata link with a family, we record the candidate, the recipient family name (a freeform string you type), channel (WhatsApp / link copy / etc.), and timestamp.

Helpers (Phase B):

You may invite up to a small number of Helpers (a daughter, niece, assistant) to access your hub on your behalf. Each Helper accepts a one-time invite that gives them either full editor or read-only access. We store:

• The Helper's Firebase identity (phone or email + UID).
• The Helper-to-hub binding (which hub they belong to, their permission tier, the timestamp they joined).
• An audit trail of which Helper performed which write (so you can review who edited a member or sent a share).

You can revoke a Helper's access at any time from hub.sharelync.app/team. Revocation is immediate — their session is invalidated and they lose write/read access on the next request. The audit log entries they generated while active are preserved as part of your record (we do not retroactively rewrite history when a Helper leaves).

Billing (paid plans):

• Plan + status stored on your hub_owners document: plan id, billing status (active / trial / past-due / cancelled), monthly rate, currency.
• Invoices stored at billing_invoices/{invoiceId} with the period covered, amount, status, paid-at timestamp, and the Razorpay-side payment link or transaction id.
• Payment instrument data is NEVER stored by ShareLync. All card / UPI / netbanking detail is captured by Razorpay on their hosted checkout page. Razorpay returns to us only the transaction id, paid amount, masked instrument summary (e.g. “Visa ending 4242”), and the payment status webhook. See Section 3 (Third-Party Services).
• Billing audit log — every plan change, custom-rate override, refund, or admin intervention is appended to billing_audit_log/{eventId} for our own books and DPDPA accountability.

Admin / staff access:

A small number of ShareLync staff hold admin privileges (the admin_users allowlist). Admins can: (a) provision a new Hub Owner account by minting a one-time claim link, (b) view billing state and invoice history, (c) suspend or revoke a Hub Owner, (d) edit a Hub Owner's profile fields on their behalf during a support call. Every admin write is recorded in the audit log with the admin's UID. Admins cannot read your members' encrypted biodatas — the encryption keys live with the members, not on our servers.

Retention period for Hub Owner data:

• While your account is active — for as long as you remain a Hub Owner.
• After account closure — thirty (30) days for the substantive records (hub_owners profile, member roster, notes, pairings, share log, activity log, helper records), after which the substantive records are permanently erased. We retain billing records (invoices, payment status, billing audit log) for a longer period as required by applicable tax and accounting law — typically eight (8) years from the close of the financial year in which the transaction occurred — under DPDPA Section 8(7) legal-obligation basis.
• Consent records and audit-trail entries that demonstrate your members' affirmative consent to join your Hub are tombstoned (not hard-deleted) and retained for three (3) years from the date of revocation or hub closure, as audit evidence under DPDPA Section 11 read with the DPB Rules.
• Backup copies of erased data may persist in our or our Data Processors' encrypted backups for a maximum of ninety (90) days after the primary erasure, after which the backups are themselves overwritten or erased.

Your rights as a Hub Owner (DPDPA Sections 11–14):

• Right of access (Section 11). Email founders@sharelync.app with the subject “Data export request” from the contact address registered against your Hub Owner account. We will provide, in a structured, commonly used and machine-readable format (JSON), a copy of your hub_owners document, member roster, notes, pairings, share log, activity log, invoice history, and helper records, together with a summary of the categories of Personal Data we hold, the identities of Data Processors, and the purposes of processing. We aim to respond within seven (7) working days and in any event within thirty (30) days, subject to the verification of your identity as required under DPDPA Section 14.
• Right of erasure (Section 12). Email the same address with the subject “Delete my hub account”. We will: (a) erase the substantive Hub Owner records within thirty (30) days; (b) retain only the categories of data identified under “Retention period” above for the stated longer periods on the lawful basis identified for each; (c) tombstone consent records and audit-trail entries that we are required to preserve under DPDPA Section 11 read with the DPB Rules. Erasure of your Hub Owner account does not erase your members' own biodatas — those are personal data of the respective members held on their own ShareLync consumer accounts, in respect of which the members are the Data Principals. We will remove the bindings between your closed hub and each member, terminate any helper authorisations, and notify Razorpay to cancel future billing.
• Right of correction and completion (Section 12). Edit your Hub Owner profile fields at hub.sharelync.app/settings at any time; for fields that are not user-editable, write to founders@sharelync.app and we will action the correction within seven (7) working days.
• Right of nomination (Section 13). You may nominate any individual who shall, in the event of your death or incapacity, exercise your rights under the DPDPA on your behalf. To make a nomination, write to the same address with the subject “Nomination under DPDPA Section 13”, providing the nominee's name, relationship to you, and a contact identifier.
• Right of grievance redressal (Section 13(1)(d)). Write to the Grievance Officer at the address in Section 14 below. We will respond within 72 hours and act on substantive matters within thirty (30) days. If your grievance is not resolved to your satisfaction, you may approach the Data Protection Board of India.

You are in control. You can delete your profile at any time from the app settings.

When you delete your profile:

• Your encrypted data is permanently erased from our cloud servers
• All active shared links immediately stop working
• Your profile photos are deleted from cloud storage
• Local data on your device is cleared
• This action is irreversible - we cannot recover deleted data

Inactive accounts may be automatically deleted after 12 months of no activity.

We implement industry-standard security measures:

• AES-GCM Encryption: Your profile data is encrypted using AES-GCM before leaving your device
• SHA-256 Hashing: Your profile slug is hashed and never stored in plain text on our servers
• Secure Transport: All data transmission uses HTTPS/TLS encryption
• Firebase Security Rules: Database access is restricted by authenticated user ID
• Minimal Public Surface: The optional Link Preview card exposes only 4 fields (name, location, profession, photo thumbnail). All sensitive data (income, education, family, religion, caste, lifestyle preferences) remains exclusively in the encrypted vault.

As a Data Principal under the Digital Personal Data Protection Act, 2023, you have the following statutory rights in respect of Personal Data processed by ShareLync:

• Right to access information about Personal Data (Section 11(1)(a) and (b)). You have the right to obtain from ShareLync, on request, (i) a summary of the Personal Data being processed by ShareLync and the processing activities undertaken with respect to such Personal Data, (ii) the identities of all other Data Fiduciaries and Data Processors with whom the Personal Data has been shared, along with a description of the Personal Data so shared, and (iii) any other information related to the Personal Data and its processing as may be prescribed.
• Right to correction, completion, updating, and erasure (Section 12). You have the right to require ShareLync to: (a) correct inaccurate or misleading Personal Data; (b) complete incomplete Personal Data; (c) update Personal Data; and (d) erase Personal Data that is no longer necessary for the purpose for which it was processed, unless retention is necessary for compliance with applicable law (see Section 8 above for our retention schedule).
• Right of grievance redressal (Section 13). You have the right to a readily available means of grievance redressal in respect of any act or omission of ShareLync regarding the performance of its obligations under the DPDPA or your exercise of your rights. Our Grievance Officer is identified in Section 14 below.
• Right to nominate (Section 14). You have the right to nominate, in the manner prescribed, any other individual who shall, in the event of your death or incapacity, exercise the rights of the Data Principal in your stead. Send your nomination to admin@sharelync.app.

How to make a request:

Email admin@sharelync.app from the registered contact on your account, identifying the right you wish to exercise and, where applicable, the specific Personal Data to which your request relates. We will acknowledge your request within 72 hours and substantively respond within 30 days, subject to our right to verify your identity under DPDPA Section 14 where reasonably necessary to prevent unauthorised access or disclosure.

We do not charge a fee for the exercise of these rights. We may, in accordance with the DPDPA and rules thereunder, decline to act on a request that is manifestly unfounded or excessive, or repeats a request to which we have already responded; in that case we will inform you of the reason for our decision and of your right to complain to the Data Protection Board of India.

ShareLync is intended exclusively for use by individuals who have attained the age of majority in their jurisdiction (in India, 18 years of age) for the purpose of creating, managing, and sharing personal biodatas in the context of arranged-marriage introductions. The terms of service prohibit individuals under 18 from creating an account or submitting any waitlist or contact form.

In accordance with DPDPA Section 9, we (i) do not knowingly collect Personal Data of any child (individual under 18); (ii) do not undertake tracking, behavioural monitoring, or targeted advertising directed at children; and (iii) do not undertake any processing of Personal Data of children that is likely to cause any detrimental effect on their well-being. Analytics collection is disabled for users self-declaring as under 18, in compliance with this section.

If we become aware that we have inadvertently collected Personal Data of an individual under 18 — including a report from a parent, guardian, or any other person — we will erase that Personal Data without undue delay and in any event within seven (7) working days, and will discontinue any further processing. Parents or guardians who believe their child has provided personal data should write to admin@sharelync.app identifying the account in question.

We may update this policy as our technology evolves or as required by law. Significant changes will be notified via:

• In-app notification
• Email (if provided)
• Update notice on this page

Continued use of the service after changes implies acceptance of the updated terms.

In compliance with Section 8(9) of the DPDPA 2023 and Rule 22 of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (to the extent still operative), ShareLync has designated the following officer to receive and act upon complaints, requests, and other communications from Data Principals concerning the processing of their Personal Data:

If you are not satisfied with the response of the Grievance Officer, or if no response has been received within the timelines stated above, you may complain to the Data Protection Board of India constituted under Chapter V of the DPDPA. Particulars of the Board, its address, and the procedure for filing a complaint will be published by the Central Government and are available at meity.gov.in.

We will cooperate fully with any inquiry or direction lawfully issued by the Board.

ShareLync maintains a written incident-response procedure to identify, contain, investigate, and remediate any “personal data breach” as that term is defined under DPDPA Section 2(t) (any unauthorised processing of Personal Data, or accidental disclosure, acquisition, sharing, use, alteration, destruction or loss of access to Personal Data, that compromises the confidentiality, integrity, or availability of Personal Data).

In the event of a personal data breach, we will:

• Notify the Data Protection Board in the form and manner prescribed by the DPB Rules, within the timeline so prescribed.
• Notify each affected Data Principal in the form and manner prescribed by the DPB Rules, providing a description of the breach, the categories of Personal Data affected, the likely consequences, the measures taken or proposed to address the breach, and the contact details of the Grievance Officer.
• Implement remedial measures to mitigate the consequences of the breach and to prevent recurrence, including, where appropriate, the rotation of compromised secrets, the revocation of compromised authentication tokens, and the strengthening of security controls.
• Maintain a written record of the breach and the response, for at least three (3) years.

Security incidents may be reported to admin@sharelync.app with the subject line “Security incident report”. We welcome responsible disclosure from security researchers and will acknowledge receipt within 72 hours.

ShareLync is operated from India and the principal site of storage for Personal Data is Google Cloud's Indian multi-region. However, certain Personal Data is necessarily transferred to and processed in jurisdictions outside India by the Data Processors listed below. The Central Government has not, as of the “Last Updated” date above, exercised its power under DPDPA Section 16 to restrict the transfer of Personal Data to any specific country or territory. The following is a consolidated list of the countries and entities to which Personal Data is transferred and the safeguards on which we rely:

• Google LLC / Google Cloud / Firebase (United States; processing occurs in multi-region storage including India, the United States, and the European Union depending on the service). Safeguard: the data-processing addendum that forms part of the Google Cloud Terms of Service, supplemented by Google's Standard Contractual Clauses for international transfers; Google's certifications under ISO/IEC 27001, 27017, 27018, SOC 1/2/3, and the EU–US Data Privacy Framework.
• Meta Platforms, Inc. (United States and Ireland; WhatsApp Business Cloud API processing). Safeguard: the WhatsApp Business Solution Terms incorporated by reference at the time of API integration; Meta's certification under the EU–US Data Privacy Framework and the UK and Swiss extensions thereof.
• Google Gemini API (United States, processing of biodata documents during AI extraction). Safeguard: the Gemini API Additional Terms of Service which expressly prohibit the use of submitted content for training Google's AI models. Documents are deleted from our temporary storage within 30 seconds of processing.
• Apple Inc. (United States; only where you choose Sign in with Apple). Safeguard: Apple's data-processing terms applicable to Sign in with Apple integrators.
• Razorpay Software Private Limited (India). Safeguard: domestic transfer; Razorpay is a payment aggregator authorised by the Reserve Bank of India, governed by the RBI Master Direction on Payment Aggregators and Payment Gateways, and certified under the Payment Card Industry Data Security Standard (PCI-DSS Level 1).

In each case, the transfer is necessary for the provision of the service or the performance of your contract with us. Where the Data Processor is located outside India, ShareLync has entered into data-processing terms that require the Data Processor to process the Personal Data only on documented instructions of ShareLync, to maintain confidentiality, to implement appropriate technical and organisational security measures, to assist us in responding to Data Principal rights requests, to notify us of personal data breaches without undue delay, and to delete or return Personal Data on termination of services.

If the Central Government, by notification under DPDPA Section 16, restricts the transfer of Personal Data to any country or territory in which one of the above Data Processors operates, we will reassess and, where necessary, terminate the relevant processing arrangement or transition to an alternative provider located in an unrestricted territory.

This Privacy Policy is governed by, and shall be construed in accordance with, the laws of the Republic of India, including (without limitation) the Digital Personal Data Protection Act, 2023, the Information Technology Act, 2000 and the rules made thereunder, and the rules notified by the Data Protection Board under the DPDPA. Any dispute, controversy, or claim arising out of or relating to this Privacy Policy, or to the processing of Personal Data by ShareLync, shall be subject to the exclusive jurisdiction of the courts at Bengaluru, Karnataka, India; provided that nothing in this clause shall preclude a Data Principal from exercising the statutory right to complain to the Data Protection Board of India or any other competent regulatory authority.

If any provision of this Privacy Policy is found by a court or other competent authority to be invalid, unlawful, or unenforceable in whole or in part, that provision shall be deemed severed from this Privacy Policy and the remaining provisions shall continue in full force and effect.

No failure or delay by ShareLync in exercising any right under this Privacy Policy or under the DPDPA shall operate as a waiver of that right, nor shall any single or partial exercise of any right preclude any further exercise of it.

For all enquiries about this Privacy Policy, to exercise any of the rights described in Sections 10 and 11 above, or to report a security incident or concern:

We may, in our reasonable discretion, request verification of your identity before acting on an access, correction, or erasure request, where such verification is necessary to prevent unauthorised disclosure or erasure of Personal Data (DPDPA Section 14).