DRAFT — LEGAL REVIEW REQUIRED
This document is a draft prepared for review by a qualified Indian technology and privacy lawyer. Items in [square brackets] are placeholders that must be replaced with verified facts. Publication of this draft does not mean Apenther has completed a legal compliance review.
Privacy Policy
Effective date: [DATE]. Operator: [LEGAL OPERATOR NAME], [OPERATOR ADDRESS][, CIN if applicable]. Contact: apenther.support@gmail.com. Grievance Officer: [NAME], [EMAIL/PHONE].
1. What we collect
- From visitors: only the technical records every website keeps — connection logs such as IP address and browser type, kept for security and to operate the site. We do not track your browsing across other websites.
- Account details: your name, email address, and a password (handled by our authentication provider; we do not store your password).
- Your role choice: founder, investor, or both.
- Profile information you choose to add: photo, location, bio, achievements, current work, website and LinkedIn links, project or research details, funding goals, preferred funding types, industries, geographies, ticket sizes, past projects or investments, and matching preferences.
- Optional contact: a phone number in international format, only if you provide it, and your answer to whether the Apenther team may call you once for feedback or advice.
- Your choices: profile visibility (private, members-only, or public) and your notification preferences.
- Technical records: security and access logs kept to operate and protect the service.
We do not sell your data, and we do not run advertising or third-party analytics trackers on the website.
2. Why we use it
- To create and secure your account and your place on the free waitlist.
- To show your profile to other members or the public only at the visibility you choose, and only once your profile is complete.
- To send essential account messages, and — only if you opted in — launch and opportunity updates, which you can turn off anytime in your account.
- To contact you by phone only for a short feedback or advice call about Apenther, and only if you explicitly agreed. Agreeing is never permission for marketing calls or SMS.
- To detect abuse, keep records the law requires, and respond to lawful requests.
3. Who can access your information
- You: your full profile, waitlist place, and preferences in your account.
- Other signed-in members: only the profiles you have switched to members-only or public, and only once complete. Your email address and phone number are never shown on your profile.
- Visitors who are not signed in: only profiles you have switched to public, and only once complete.
- The Apenther team: for administration, support, security, and legal compliance, under access controls and an audit log of administrator actions.
4. Third-party services and data sharing
- Hosting, database, authentication, and email delivery are provided by managed cloud infrastructure engaged by the operator. Details of the processors and data locations: [LIST PROCESSORS AND, WHERE KNOWN, LOCATIONS].
- Google Fonts is loaded from Google's servers when you browse the site; this discloses your IP address and network information to Google.
- Signup alerts containing your name, email, and role go to the team inbox at apenther.support@gmail.com.
- We do not disclose your phone number or email address to other members as part of any current feature. If a future feature shares contact details, we will ask you separately first.
- We do not sell or rent personal information.
5. Cookies and tracking technologies
As of the date above, the website uses the following, and nothing else:
- Sign-in session storage: after you sign in, your sign-in session is kept in your browser's local storage. This is strictly necessary for you to stay signed in.
- Security cookie: a bot-management cookie set by our edge security provider (HttpOnly, Secure) to distinguish real visitors from automated abuse. Functional, not tracking.
- Deployment cookie: a short-lived cookie identifying the current deployment of the site. Functional, not tracking.
- No analytics, advertising, or marketing cookies are used, and no third-party analytics or advertising trackers load on the site.
- External request: fonts are loaded from Google Fonts (a third-party request, described in section 4). Self-hosting is planned to remove it.
6. How we store and protect it
- Information is stored on managed cloud infrastructure with encryption in transit.
- Access to member data is enforced by database-level row permissions: members can read or change only their own records, and administrator access is a server-verified role with an audit log.
- Profile photos are stored in a private storage area and are served only through short-lived, access-controlled links.
- No method of transmission or storage is perfectly secure. We follow documented security practices and report qualifying incidents as required by Indian CERT-In directions.
7. Data retention and deletion
- Your profile and account data are kept while your account is open.
- You can export your data and delete your account from your account page. Deletion removes your profile, photos, waitlist place, and preferences.
- Security and access logs are retained for [RETENTION PERIOD — state actual practice; at least 180 days is required by CERT-In directions].
- After deletion, limited records may be kept where law requires (for example legal claims or security logs), and copies in backups rotate out within [PERIOD].
8. Your rights and privacy requests
- Access, correction, and deletion: use the export and delete controls in your account, or email the Grievance Officer.
- Withdraw consent: turn off optional updates or the call permission anytime in your account; withdrawal takes effect in a reasonable time.
- Profile visibility: private by default; you control members-only or public.
- We respond to privacy requests within one month of receipt.
9. Children
The service is not directed at children under 18. [AGE POLICY TO BE CONFIRMED WITH COUNSEL: exclusion of minors or verification approach.]
10. Changes to this policy
We will post changes here with a new effective date and, for material changes affecting you, notify you by email or in the app.
11. Applicable Indian data-protection requirements
- This policy is written to meet the requirements of the Indian Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, which apply today, including publication of the policy and grievance handling within one month.
- India's Digital Personal Data Protection Act, 2023 and its rules introduce further obligations on a timetable set by the Government of India (main duties are notified to commence on 13 May 2027). This document will be updated for those requirements; Apenther does not claim to be DPDP-compliant today.
- Incident reporting follows the Indian CERT-In directions (2022), including reporting qualifying incidents without undue delay and retaining system logs for at least 180 days within India.
12. Grievance redressal
If you have a complaint or a privacy concern, contact the Grievance Officer:
- Grievance Officer: [NAME] — to be appointed and published.
- Email: apenther.support@gmail.com (designated contact for grievances).
- Postal/contact address: [ADDRESS — to be published where legally required].
How to complain: email your grievance with the subject "Grievance", including your account email and a description of the issue. We acknowledge grievances promptly and work to resolve them within one month of receipt, as required by the applicable Indian rules. If you are unsatisfied with the outcome, you may escalate as provided under applicable law.
13. Contact
Questions about this policy: apenther.support@gmail.com. Operator: [LEGAL OPERATOR NAME], [ADDRESS].