Privacy policy

Last updated 6 November 2026

What personal data Milvao processes, for whom and why. Community owners decide how member data is used. A draft awaiting legal review, not yet in force.

1. 01Who is responsible for your data

   Milvao has two roles, depending on whose data it is:

   • Member data. The community that runs Milvao (its owner, usually the organisation or person behind the WhatsApp groups) is the data fiduciary under the DPDP Act and the controller under the GDPR. Milvao is its data processor: we process member data only to provide the service to that community, under our terms with it.
   • Operator accounts, website visitors and enquiries. Milvao is the data fiduciary and controller for the accounts of community owners and operators, for people who contact us or request a pilot, and for visitors to this website.

   If you are a member, your community's team is your first point of contact for questions and requests about your data. We help them answer, and you can also contact us directly.

2. 02Data we process for communities

   When a member uses Milvao through their community, we process:

   • Their WhatsApp phone number and the name shown on WhatsApp, received when they message the community's business number.
   • Profile details they enter: display name, city, skills, the cities they serve, a short description and their introduction preferences.
   • Which of the community's groups they joined from (through the group's join link), and whether an operator verified or removed that membership.
   • Consent records: each consent and withdrawal, its purpose, the wording version shown and the time.
   • Requests they send (the original message and the brief they confirm), introductions offered to them, their answers, and the delivery status of each message.
   • Signals about past introductions used for matching: how often they accept, how quickly they reply, introductions that worked out, and feedback from the people they helped.

   We do not collect the content, member lists or history of the community's WhatsApp groups.

3. 03Data we process for ourselves

   • Operator accounts: name, email address, a hash of the password (never the password itself), two-factor sign-in settings, sessions, and an audit trail of actions with the IP address and browser used.
   • Enquiries, pilot requests and the waitlist: what you enter in our forms (name, email or phone, community, community type, city, community size and your message), and any emails we exchange.
   • Website visits: our hosting provider records technical request data such as IP address, browser and pages requested, for security and to keep the site running. This website does not use advertising or analytics cookies. To see which pages and campaigns bring communities to us, it counts visits itself, without cookies: when a page loads, or you click a main button or send a form, your browser sends our app the page address (without anything after the question mark), the site that linked to it, any campaign tags in the link, your screen width and which button or form it was, and our hosting network adds your country. We keep only daily totals, never your IP address, an ID or anything stored in your browser, so the counts can't identify you or link your visits together. If your browser sends a Do Not Track or Global Privacy Control signal, nothing is sent. It sets one functional cookie, mv_region, which stores only “in” or “intl” (worked out from the country your visit comes from, not stored with your IP address) for 30 days, so that visitors in India see examples written in Hinglish. If you choose a light or dark theme, that choice is kept in your browser's local storage. Forms use Cloudflare Turnstile, which processes browser signals to tell people from bots. Every item is listed on our cookies page.
   • Security events: failed sign-ins, blocked requests and similar events, with IP address and time, kept in a separate log.

4. 04Why we use it, and on what basis

   Purpose	Basis
   Running private requests and introductions for a community	On the community's instructions, as its processor. The community relies on members' consent (DPDP Act s.6, GDPR Art. 6(1)(a)) or another lawful basis it determines.
   Sending a member introduction requests	The member's separate consent to receive offers, off until they turn it on.
   Sharing a contact between two members	The requester's consent for that request and the matched member's acceptance of that introduction, both checked again before sending.
   Operator accounts and providing the service to communities	Our contract with the community (GDPR Art. 6(1)(b)); data provided voluntarily for that purpose (DPDP Act s.7).
   Security, fraud prevention and audit trails	Our legitimate interest in keeping the service safe (GDPR Art. 6(1)(f)) and legitimate uses under DPDP Act s.7.
   Counting website visits (daily totals, no cookies or identifiers)	Our legitimate interest in knowing which pages and campaigns bring communities to us (GDPR Art. 6(1)(f)). The totals can't identify anyone.
   Replying to enquiries, planning pilots and contacting people on the waitlist	Your consent when you send the form, and steps you ask us to take before a contract.
   Meeting legal obligations	Legal obligation (GDPR Art. 6(1)(c), DPDP Act s.7).

5. 05Consent and how to withdraw it

   Members give consent in separate steps, each for one purpose: to receive introduction requests, to share their number for a specific request, and to accept a specific introduction. Withdrawing is as easy as giving it:

   • Reply PAUSE to stop introduction requests for a while, and RESUME to start again.
   • Reply STOP to turn off requests and other messages from Milvao about requests.
   • Turn off offers in the profile form at any time, or ask the community's team to delete the profile.

   Withdrawal stops future processing based on that consent and cancels pending offers. It cannot undo a contact that has already been delivered to another member, which is why a contact waits for both people to agree.

6. 06Automated matching

   By default, Milvao chooses which member to ask about a request automatically. It considers only members who have turned on offers and whose profile matches the request, and ranks them by profile fit, how often they accept, how quickly they reply, past introductions and feedback, with a rotation so the same members are not always asked. Each community can switch to having an operator approve every match.

   Being asked, or not being asked, about a request has no legal effect on a member, and a member can stop being considered at any time by turning off offers or replying PAUSE or STOP. Members can ask their community's team for a person to review how they are matched.

7. 07AI processing

   To turn a request into a short brief, Milvao sends the request text, with contact details removed, and the community's list of categories to Anthropic's Claude model. The member directory, phone numbers and other members' data are never sent. The model does not decide who is asked; matching uses Milvao's own rules. [TODO: confirm and state Anthropic's data retention and training terms for our account.]

8. 08Who we share data with

   We share personal data only with the service providers below, who process it for us under contract, and when the law requires it. We do not sell personal data. The current list, with where each provider processes data and how we announce changes, is on our sub-processors page.

   Provider	What for	Data
   Vercel	Hosting for the website and the app	Requests to the website and app (IP address, browser), app logs, and the data the app handles while it runs
   Neon (PostgreSQL) or a managed MySQL provider	Database for community data and, separately, the logs	All workspace and member data; audit, security and AI call logs
   Meta (WhatsApp Cloud API)	Sends and receives WhatsApp messages on your community's business number	Message content and phone numbers in transit
   Anthropic (Claude)	Turns a request into a short brief	Redacted request text and your community's category and city names only
   Cloudflare (Turnstile)	Stops bots on public forms and sign-in	Browser signals during form checks
   SMTP email provider (Amazon SES in production, Mailtrap for testing)	Email to owners, operators and staff	Email addresses and email content (invites, password resets, notifications, billing mail)
   Stripe	Card payments in US dollars	Billing contact, invoices and payment status. Card details stay with Stripe
   Razorpay	Payments in rupees (UPI, cards, net banking)	Billing contact, invoices and payment status. Card and UPI details stay with Razorpay
   Amazon Web Services (S3) or Vercel Blob	File storage	Blog images today; later, profile photos, community logos and data exports
   cron-job.org	Runs Milvao's scheduled jobs and uptime checks	No personal data: it calls Milvao's job addresses on a schedule

   Within a community, member details are visible to that community's owner and operators, with phone numbers masked by default. Another member receives a contact only after both people agree. Messages travel through WhatsApp, which Meta operates under its own terms and privacy policy.

9. 09Where data is stored

   Milvao's database is hosted in Singapore. Some providers above, such as Meta and Anthropic, may process data in other countries, including the United States. Under the DPDP Act, transfers outside India are permitted except to countries the Central Government restricts; we will stop any transfer to a restricted country. Where the GDPR applies, we rely on the European Commission's standard contractual clauses or another valid transfer mechanism. [TODO: confirm transfer mechanisms with each provider and list them.]

10. 10How long we keep data

    Data	Kept for
    Raw message data received from WhatsApp	7 days
    Message text	90 days
    Audit and security logs	1 year
    Website visit counts (daily totals that can't identify anyone)	25 months
    Member profiles, consent records and introduction history	While the member is part of the community on Milvao, or until the community or member asks for deletion
    Operator accounts	While the account is active, then [TODO: period] after the community's subscription ends
    Enquiries and pilot requests	[TODO: period, for example 24 months after the last contact]

    When a member's profile is deleted, Milvao cancels outstanding introductions, removes their profile and message content, and keeps only counts that cannot identify them. Backups are overwritten on a rolling basis. [TODO: backup retention period.]

11. 11How we protect data

    • All traffic uses HTTPS. Members' phone numbers and WhatsApp access tokens are encrypted at rest.
    • Join links, profile links and invites are stored only as one-way hashes. Profile links work once and expire after 60 minutes.
    • Each community's data is kept apart in the database itself, so one community cannot reach another's records.
    • Operator and staff actions are recorded in an audit log kept in a separate database. Two-factor sign-in is available to everyone, and staff need it to open a community's workspace through support access.
    • Public forms are protected with Cloudflare Turnstile and rate limits. Full phone numbers, message text and secrets are never written to logs.

    No system is perfectly secure. If a personal data breach happens, we will inform the affected community without undue delay so it can meet its duties, and notify the Data Protection Board of India, affected people and, where the GDPR applies, the supervisory authority, as the law requires. More detail: Security at Milvao.

12. 12Your rights

    Under the DPDP Act you can ask for a summary of your personal data and how it is processed, ask for it to be corrected, completed, updated or erased, withdraw consent, nominate someone to exercise your rights if you die or become incapacitated, and have grievances addressed.

    Where the GDPR applies you also have the right to access, rectification, erasure, restriction, data portability and to object, and to complain to your local supervisory authority.

    Members: send requests to your community's team, or to us at [TODO: privacy contact email, for example privacy@milvao.com] and we will pass them to your community and help it respond. Everyone else: write to us directly. We will respond within [TODO: response time, for example 30 days] and may need to confirm your identity first.

13. 13Grievance officer

    Under the DPDP Act, our grievance officer is [TODO: grievance officer name], reachable at [TODO: grievance officer email] and [TODO: registered office address]. If you are not satisfied with our response, you may complain to the Data Protection Board of India.

14. 14Children

    Milvao is meant for adults in professional and business communities. Communities must not onboard anyone under 18. If we learn that we hold a child's data, we will ask the community to remove it and delete it.

15. 15Changes to this policy

    We will update this page when our practices change and change the date at the top. For significant changes, we will tell community owners by email before they take effect, and communities will update the notice their members see.

16. 16Contact

    Privacy questions: [TODO: privacy contact email, for example privacy@milvao.com]. Anything else: hello@milvao.com. Post: [TODO: company legal name], [TODO: registered office address].