How Milvao supports India's DPDP Act

Last updated 5 November 2026

Your community is the data fiduciary and Milvao your processor. How Milvao handles notice, consent per purpose, data requests, retention and breaches.

1. 01Who is responsible under the Act

   The DPDP Act calls the person who decides why and how personal data is processed the data fiduciary, and a company that processes it on their behalf a data processor. The people the data is about are data principals.

   • Your community (its owner) is the data fiduciary for members' data: you choose to use Milvao, which groups join, and which profile questions are asked.
   • Milvao is your data processor. It processes members' data only to run the service for you, under a contract (see the data processing agreement).
   • Milvao is a data fiduciary itself for operator accounts, billing, website visitors and enquiries.

2. 02Notice and consent

   The Act expects a clear notice when consent is asked for, and consent that is free, specific, informed, unambiguous and as easy to withdraw as to give. In Milvao:

   • The first message a member receives links to the privacy notice, and the notice version is recorded with the member.
   • Consent is collected separately for each purpose: receiving introduction requests (off until the member turns it on), sharing their number for a specific request, and accepting a specific introduction.
   • Each consent and withdrawal is stored as an event with its purpose, the wording version shown and the time, so you can show what a member agreed to.
   • Withdrawing is one word: PAUSE stops requests for a while, STOP turns off requests and other messages, and offers can be switched off in the profile.

   Members join through a link and message your number themselves, so nobody is added without taking that step.

3. 03Purpose limitation and data minimisation

   • Milvao never joins, reads or posts in your WhatsApp groups. It handles only one-to-one messages sent to your business number.
   • A member's number is shared with another member only after two consents, both checked again right before sending.
   • Every custom profile question needs a purpose members can read. Sensitive topics need the owner's confirmation, and government ID numbers are refused.
   • Only redacted request text goes to the AI model that writes the brief. Profile answers, numbers and the directory are never sent.
   • Milvao does not sell members' data or use it for advertising.

4. 04Data principal rights

   Right under the Act	How it works in Milvao
   Access to a summary of their data and how it is processed	The member sends MY DATA. The owner exports the member's data from Settings, Data requests and sends it to them.
   Correction, completion and updating	Members edit their own profile through a private link (send PROFILE). Operators can correct details, and the member is told by default.
   Erasure	The member sends DELETE MY DATA and confirms. Offers stop at once, and the owner completes the deletion from the dashboard.
   Withdrawing consent	PAUSE, STOP, or switching offers off. Pending offers are cancelled.
   Grievance redressal	Members contact your team first, or Milvao directly (below). Every request is tracked with a due date.
   Nomination	A nominee can contact your team or Milvao, and the request is logged for the owner to handle.

   Each request gets a 30-day due date and is marked overdue after it. Requests, exports and deletions are recorded in the audit trail. Step by step: Handling members' data requests.

5. 05Retention and erasure

   The Act asks fiduciaries to erase data once it is no longer needed for its purpose. Daily jobs enforce these periods:

   Data	Kept for
   Raw message data received from WhatsApp	7 days
   Message text	90 days
   AI call logs (redacted)	90 days
   Copies of Razorpay payment events	30 days, with contact and card details removed
   Audit trail and security events	1 year
   Member profiles, consent records and introduction history	Until the member or the community asks for deletion

   Deleting a member removes their profile, profile answers, number, and request and message text. De-identified counts and consent records remain, so metrics add up and consent can be proven. A contact already delivered to another member can't be recalled.

6. 06Security safeguards and breaches

   The Act requires reasonable security safeguards. Milvao encrypts phone numbers and tokens, separates each community's data in the database, offers two-factor sign-in to everyone and requires it for staff support access, and records every action in a separate audit log. The full list, and what is still planned, is on the security page.

   If a breach affects your members' data, Milvao tells you without undue delay with what is known, and helps you inform the Data Protection Board of India and the members affected, as the Act and Rules require. A written breach notification runbook is planned.

7. 07Where data is stored

   Milvao's database is hosted in Singapore. Some providers process data in other countries, listed on the sub-processors page. The Act allows transfers outside India except to countries the Central Government restricts, and Milvao will stop any transfer to a restricted country.

8. 08Children

   Milvao is meant for adults in professional and business communities. Communities must not onboard anyone under 18, since the Act requires verifiable parental consent for children's data.

9. 09Grievance contact

   Members should contact their community's team first. Milvao's grievance officer is [TODO: grievance officer name], reachable at [TODO: grievance officer email], or write to hello@milvao.com. If a grievance is not resolved, a data principal may complain to the Data Protection Board of India.