DPDP Notice & Your Data Principal Rights
This notice is provided under the Digital Personal Data Protection Act, 2023 ("DPDP Act") and its rules. It explains, in clear terms, the personal data Agamoni processes, why, and the rights you (the "Data Principal") have. It supplements the Privacy Policy at /privacy.
- Data Fiduciary
- Personal data we process and the purpose
- Legal basis: consent and legitimate uses
- Your rights as a Data Principal
- How to exercise your rights
- Grievance Officer
- Escalation to the Data Protection Board of India
- Retention
- Cross-border transfer
- Personal data breach
- Children and persons with a guardian
- Changes to this notice
Data Fiduciary
The Data Fiduciary that determines the purpose and means of processing your personal data is Zynapte Technologies Pvt Ltd, with its registered office at P-30, Lake Gardens, Kolkata – 700045, West Bengal, India.
Corporate identifiers: CIN U62091WB2024PTC275230; GSTIN 19AACCZ5280E1Z4; Udyam Registration UDYAM-WB-10-0144056.
We are not currently classified as a Significant Data Fiduciary. We do not engage a registered Consent Manager at this time; consent is collected and managed directly in the app and on the website.
Personal data we process and the purpose
- Phone number — to authenticate you over WhatsApp OTP and identify you within groups.
- Display name and optional photo — to show you to members of groups you join.
- A single latest location point (when signed in) and opt-in live location — to help you navigate and to share your position with a group you choose.
- Step, distance, duration and active-calorie estimates (only if you opt into the step tracker) — to show walking progress and award festive badges.
- Community submissions and issue reports — to review and, if approved, publish corrections for other users.
- Device, diagnostic and coarse region data — to keep the service stable and secure and to prevent abuse.
We collect only what a feature needs (data minimisation) and do not use your data for advertising or profiling.
Legal basis: consent and legitimate uses
We process your personal data on the basis of the consent you give when you sign in or enable a specific feature, and on the "certain legitimate uses" permitted by Section 7 of the DPDP Act — chiefly the purpose for which you voluntarily provided the data and for which you have not indicated that you do not consent.
Your consent is informed, specific, free, unconditional and unambiguous, and limited to the stated purpose. You may withdraw consent at any time; withdrawal is as easy as giving consent, and does not affect the lawfulness of processing done before withdrawal. If you withdraw consent for a purpose, we will stop that processing and erase the related personal data unless retention is required by law.
Your rights as a Data Principal
- Right to access information — a summary of the personal data we process about you, the processing activities, and the identities of any other Data Fiduciaries or Processors with whom it has been shared.
- Right to correction and erasure — correct inaccurate or misleading data, complete incomplete data, update it, and have it erased when it is no longer needed for the purpose or when you withdraw consent.
- Right of grievance redressal — a readily available means to raise a grievance with us about our processing or our response to your rights.
- Right to nominate — nominate another individual to exercise these rights on your behalf in the event of your death or incapacity.
- Right to withdraw consent — at any time, through the app or by contacting the Grievance Officer.
How to exercise your rights
In the app: Settings → Profile lets you view and edit your profile, manage permissions, reset step data and delete your account and data immediately.
By email: write to the Grievance Officer at [email protected] from your registered number's email address, stating the right you wish to exercise. We may ask you to confirm a one-time code over WhatsApp to verify ownership before we act.
We will acknowledge your request promptly and respond within 30 days. There is no fee for a reasonable request. You must provide accurate information and only exercise rights that are your own or that you are authorised to exercise.
Grievance Officer
Name / designation: Grievance Officer, Zynapte Technologies Pvt Ltd.
Email: [email protected].
Postal address: Zynapte Technologies Pvt Ltd, P-30, Lake Gardens, Kolkata – 700045, West Bengal, India.
We aim to resolve grievances within 30 days of receipt.
Escalation to the Data Protection Board of India
If you are not satisfied with our response, or we do not respond within the required time, you may lodge a complaint with the Data Protection Board of India in the manner prescribed under the DPDP Act and its rules. You may also have remedies before the courts of India.
Retention
We retain personal data only for as long as the stated purpose requires, or until you withdraw consent or delete your account. On erasure we also instruct our Data Processors to erase the corresponding data, unless retention is required for compliance with law. Non-identifying security logs may be kept for up to 90 days.
Cross-border transfer
We process personal data primarily on servers located in India. We will transfer personal data outside India only to countries or territories not restricted by the Central Government of India for such transfer, and subject to contractual and technical safeguards.
Personal data breach
If a personal data breach occurs, we will notify the Data Protection Board of India and each affected Data Principal, with the prescribed particulars and within the prescribed time, and we will take reasonable steps to mitigate harm.
Children and persons with a guardian
We do not process the personal data of a child (an individual under 18) or of a person with a disability who has a lawful guardian without verifiable consent of the parent or guardian, and we do not undertake tracking, behavioural monitoring or targeted advertising directed at children.
Changes to this notice
We will update this notice as our processing or the law changes, and record a new effective date and version.
Zynapte Technologies Pvt Ltd, P-30, Lake Gardens, Kolkata – 700045, West Bengal, India
[email protected]