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Legal · Pre-Launch & Platform

Privacy Policy.

KINVIYO™ is built on a Privacy First foundation. We help families organise their most sensitive information — and we take that responsibility seriously. This policy explains exactly what we collect, why, and how we protect it.

EFFECTIVE DATE

April 5, 2026

VERSION

1.0

APPLICABLE LAW

DPDPA 2023, IT Act 2000

CONTACT

connect@kinviyo.com

1

Who We Are

This Privacy Policy is issued by Nexvoria Technologies Private Limited (“Nexvoria”, “we”, “us”, or “our”), the company that develops and operates the KINVIYO™ Family Awareness Platform.

Data Controller — Company Details

Nexvoria Technologies Private Limited

Unit 213 & 214, Welldone Tech Park, Drive Thru Lane, Sector 48, Gurugram, Haryana – 122018, India

connect@kinviyo.com · +91 85100 02475

No branch offices or subsidiaries in India or any other country.

This Privacy Policy applies to all users of the KINVIYO™ pre-launch website, the pre-booking process, and — upon launch — the KINVIYO™ platform itself, whether you are based in India or anywhere else in the world.

2

What Personal Data We Collect

We collect only the minimum data necessary to provide our services.

CategoryData CollectedWhy We Collect It
Registration DataFull name, email address, phone numberPre-booking confirmation; account creation; communication updates
Payment DataTransaction ID, amount, currency, payment status (via Razorpay)Confirming and processing your pre-booking payment
Usage DataPages visited, features used, session duration, device type, browser, IP addressPlatform security, performance monitoring, product improvement
Communication DataEmails, queries, feedback, support messages sent to usResponding to your enquiries and improving our support
Platform Content Data (post-launch)Family tree, asset/liability records, health info, insurance details entered by you voluntarilyProviding the core awareness and organisation features of the platform

What We Never Collect

We do not collect passwords, banking login credentials, OTPs, or any information that provides transactional access to your financial accounts. Platform content data (entered after launch) is stored in your own chosen cloud storage — Google Drive or Microsoft OneDrive — and is not held on Nexvoria’s servers.

3

How We Collect Your Data

We collect personal data through the following means:

Sources of Data Collection

  • Directly from you: When you visit our pre-launch website, register a pre-booking, fill in a form, or contact us by email or phone.
  • Through Razorpay: When you make a payment, Razorpay shares transaction-level confirmation data (not your card or banking details) with us to confirm your booking.
  • Automatically via cookies and analytics: When you browse our website, standard usage data is collected through cookies and analytics tools. See Section 11 for our Cookie Policy.
  • Through your voluntary use of the platform (post-launch): When you add family, asset, health, or insurance records on the KINVIYO™ platform.
4

Legal Basis for Processing Your Data

Nexvoria processes your personal data only where a valid legal basis exists under the Digital Personal Data Protection Act, 2023 (DPDPA) of India and, where applicable, equivalent laws of other jurisdictions.

Legal Bases for Processing

  • Consent: For registration, pre-booking, marketing communications, and use of your data for internal analysis and research. You may withdraw consent at any time.
  • Contractual Necessity: To process your pre-booking, send confirmations, manage payments, and provide platform access upon launch.
  • Legitimate Interests: For platform security, fraud prevention, performance monitoring, and improving our services — where these interests are not overridden by your rights.
  • Legal Obligation: Where processing is required to comply with applicable Indian law, court orders, or regulatory requirements.
5

How We Use Your Data

Primary Uses — To Operate the Service

  • To process and confirm your pre-booking and send booking confirmations.
  • To communicate launch updates, onboarding instructions, and platform announcements.
  • To provide and maintain access to the KINVIYO™ platform after launch.
  • To process payments via Razorpay and issue receipts or refunds.
  • To respond to your support queries, feedback, and grievance submissions.

Internal Analysis & Research Uses — Anonymised & Aggregated Only

  • Product Improvement: Analyzing aggregated usage patterns to improve existing features and fix issues.
  • Feature Development: Using anonymized behavioural data to design and prioritise new platform features.
  • Performance Monitoring: Monitoring platform stability, uptime, and load on an anonymized basis.
  • Internal Research & Reports: Generating aggregated insights on family financial awareness trends. No individual will be identifiable in any such report.

What We Do Not and Will Not Do With Your Data

  • Sell your personal data to any third party for any purpose.
  • Use your identifiable personal data for advertising, targeting, or profiling.
  • Share your data with third parties for their own commercial use.
  • Access or analyse the specific personal records of any individual user.
  • Use your data in any manner inconsistent with the DPDPA 2023 or other applicable laws.
6

Who We Share Your Data With

Nexvoria does not sell, rent, or trade your personal data. We share your data only in the following limited and necessary circumstances:

RecipientPurposeCompliance Basis
RazorpayProcessing pre-booking paymentsRBI-regulated; bound by their Privacy Policy and PCI-DSS compliance
Cloud Infrastructure ProvidersHosting, storage, and delivery of the platformBound by Data Processing Agreements (DPAs); data used solely to operate the service
Email / Communication Service ProvidersSending booking confirmations, updates, and support repliesAuthorised processors; no access to platform content data
Legal AuthoritiesCompliance with Indian law, court orders, or regulatory requirementsOnly to the extent required by law; we will notify you where legally permitted to do so
7

Use of Data for Internal Analysis and Research

As stated in our Terms and Conditions, Nexvoria uses aggregated and fully anonymized data derived from platform usage for internal analysis.

Anonymisation Standard

Before any data is used for internal analysis or research, all personally identifiable information (PII) — including name, email, phone number, family member identities, and specific asset or health details — is removed or generalised so that no individual user can be identified, directly or indirectly, from the resulting dataset.

1

Product Improvement & Feature Development

Understanding which features are most used, where users encounter friction, and what new capabilities would add the most value.

2

Usage Analytics & Performance Monitoring

Tracking platform health metrics such as load times, error rates, and peak usage periods — all at an aggregated, non-identifiable level.

3

Internal Research

Studying broad patterns in family financial awareness and preparedness in India and other markets, to better understand the problem KINVIYO™ is solving.

4

Aggregated Reports

Producing high-level statistical reports for internal business planning. These reports will never contain information traceable to any individual or family.

Your Right to Opt Out

You may withdraw your consent to this specific use of your data at any time by writing to connect@kinviyo.com. Opting out of internal analysis will not affect your access to the KINVIYO™ platform or any of its features.

8

How Long We Retain Your Data

We retain personal data only for as long as is necessary for the purposes described in this policy, or as required by applicable law.

Data TypeRetention PeriodReason
Pre-booking registration dataUntil account deletion or 3 years after last activity, whichever is earlierContractual necessity and legal compliance
Payment transaction records7 years from transaction dateIndian financial and tax regulations (GST, IT Act)
Platform usage / analytics data24 months on a rolling basis (anonymized after 90 days)Product improvement and performance monitoring
Support and communication records3 years from last correspondenceGrievance resolution and legal protection
Platform content data (post-launch)Until you delete it or close your accountUser-controlled; stored in your own cloud (Google Drive / OneDrive)
Anonymised research dataIndefinitely (as it contains no personal identifiers)Internal research and product development

Upon expiry of the applicable retention period, personal data will be securely deleted or irreversibly anonymized. If you request deletion of your account before the retention period ends, we will delete your data promptly, except where retention is required by law.

9

Your Privacy Rights

Under the Digital Personal Data Protection Act, 2023 (DPDPA) and other applicable laws, you have the following rights in respect of your personal data:

Right to Access

You may request a copy of the personal data we hold about you at any time.

Right to Correction

You may ask us to correct any inaccurate or incomplete personal data.

Right to Erasure

You may request deletion of your personal data. We will comply promptly, subject to any legal retention obligations.

Right to Withdraw Consent

You may withdraw any consent you have given (including for marketing or internal analysis) at any time. Withdrawal does not affect prior lawful processing.

Right to Data Portability

Where technically feasible and required by law, you may request your data in a structured, commonly used format.

Right to Grievance Redressal

You have the right to raise a complaint with our Grievance Officer or with the relevant data protection authority.

Right to Nominate

Under the DPDPA 2023, you may nominate another individual to exercise your rights on your behalf in the event of your death or incapacity.

To exercise any of these rights, please write to us at connect@kinviyo.com from your registered email address. We will acknowledge your request within 48 hours and respond fully within 30 days.

10

How We Protect Your Data

Nexvoria takes the security of your personal data seriously. We implement appropriate technical and organizational measures to protect your information against unauthorised access, loss, alteration, or destruction.

🔐

Encryption

All data transmitted between your device and our servers is encrypted using industry-standard TLS (Transport Layer Security).

👤

Access Controls

Access to personal data within Nexvoria is restricted on a need-to-know basis. All staff with access are bound by confidentiality obligations.

🚫

No Password Storage

KINVIYO™ never stores banking passwords, credentials, or OTPs. We do not create any such vulnerability.

☁️

User-Controlled Cloud Storage

Your family and financial awareness data (post-launch) is stored in your own Google Drive or Microsoft OneDrive — not on Nexvoria's servers.

💳

Third-Party Security

Service providers such as Razorpay are PCI-DSS compliant and handle payment data under their own robust security frameworks.

🔔

Incident Response

In the event of a data breach, we will notify you and the relevant regulatory authority within the timeframes prescribed by applicable law.

Despite our best efforts, no method of internet transmission or electronic storage is 100% secure. We encourage you to use strong, unique passwords for your email account and to keep your devices secure.

11

Cookies and Tracking Technologies

Our pre-launch website uses cookies and similar tracking technologies to enhance your browsing experience and gather usage analytics.

Cookie TypePurposeCan You Opt Out?
Essential CookiesNecessary for the website to function (e.g., session management, security). Cannot be disabled without breaking core functionality.No — required for site operation
Analytics CookiesCollect anonymized data on how users navigate the website (pages visited, time spent, device type) to improve performance and user experience.Yes — via cookie consent banner or browser settings
Preference CookiesRemember your language, region, or display preferences to personalise your experience.Yes — via cookie consent settings
Marketing CookiesCurrently not used. We do not run targeted advertising campaigns through our website.N/A — not used

You may manage or disable cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of our website.

12

International Users & Cross-Border Data Transfers

KINVIYO™ is accessible to users worldwide. Nexvoria is incorporated and operates solely in India, with no offices or subsidiaries in any other country. When users outside India use our website or register a pre-booking, their personal data is processed and stored in India, subject to Indian data protection law (DPDPA 2023).

By using our website or registering a pre-booking from outside India, you consent to your personal data being transferred to and processed in India.

For Users in the European Economic Area (EEA) or United Kingdom

If you are accessing our website from the EEA or UK, please note that India is not currently designated as providing an “adequate” level of data protection under EU/UK standards. However, Nexvoria adopts measures consistent with internationally recognised privacy principles. By using our website, you acknowledge and consent to this transfer. You may contact us at connect@kinviyo.com for further information on the safeguards we apply.

13

Grievance Officer and How to Contact Us

In accordance with the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021, and the Digital Personal Data Protection Act, 2023, Nexvoria designates a Grievance Officer to address privacy-related complaints and requests.

Privacy & Grievance Contact

Company: Nexvoria Technologies Private Limited

Product: KINVIYO™

Address: Unit 213 & 214, Welldone Tech Park, Drive Thru Lane, Sector 48, Gurugram, Haryana – 122018, India

Grievance Officer

Desh Hajela

Grievance Email: grievance@kinviyo.com

Acknowledgement within 48 hours · Resolution within 30 days

14

Changes to This Privacy Policy

Nexvoria reserves the right to update this Privacy Policy at any time to reflect changes in our practices, technology, legal requirements, or for other operational reasons. When we make material changes, we will notify you by email to your registered address at least 7 (seven) days before the updated policy takes effect, and we will post the revised policy on our website with an updated effective date.

Your continued use of the KINVIYO™ website or platform after the effective date of any revised policy constitutes your acceptance of the changes. If you do not agree to the revised policy, you may close your account and request deletion of your data as described in Section 9.

KINVIYO™

A product of Nexvoria Technologies Private Limited

© 2026 Nexvoria Technologies Private Limited. All rights reserved.

Version 1.0 (Final) · Effective April 5, 2026 · Jurisdiction: Gurugram, Haryana, India