KaunHoTum — Privacy Notice
1. Who we are
KaunHoTum is operated by SageWabbit LLP, Navi Mumbai, Maharashtra, India ("we", "us"). We are the Data Fiduciary for the personal data described in this notice.
Grievance Officer: Dr. Ankit Lokare — grievance@sagewabbit.com
2. What personal data we collect
| We collect | So we can | Required? |
|---|---|---|
| Name, date of birth, gender | Create your profile and confirm you're 18+ | Yes |
| Photos you upload | Show your profile and run photo verification | Yes |
| Your quiz answers & personality result | Match you and show chemistry | Yes |
| Chat messages | Let you message matches; keep the space safe | Yes |
| Approximate location | Show people near you | Optional |
| Device & usage data | Keep the app secure and working | Yes (security) |
| Payment status | Manage your subscription (via our payment processor — we do not store card details) | Only if you subscribe |
3. Why we process it
To create and show your profile; confirm you are 18 or older; match you and generate chemistry results; enable messaging between matches; keep the platform safe (moderation, fraud and CSAM detection); process subscriptions; secure and improve the service; and comply with law. We do not process your data for open-ended "business purposes".
4. Our legal basis
We process your personal data on the basis of your consent (DPDP Act §6), given on a standalone, itemised consent screen with nothing pre-ticked. A limited set of activities may rely on the narrow "legitimate uses" in DPDP Act §7 — for example, complying with a legal order, or responding to a safety or medical emergency.
5. Who we share it with
We share the minimum necessary with vetted Data Processors under contract: our identity-verification provider, content-moderation and CSAM-detection providers, cloud hosting, analytics, and our payment gateway. We do not sell your personal data. We may disclose data to law enforcement on a lawful request. We are legally required to report child sexual abuse material (CSAM) to Indian authorities, and we additionally report it to the NCMEC CyberTipline.
6. How long we keep it
We keep personal data only as long as needed for the purpose, and erase it when you withdraw consent or delete your account, except where law requires retention. Security logs are retained for at least one year (DPDP Rules, 2025, Rule 6).
7. Your rights
You can, at any time:
- Access a summary of your personal data and the processors it was shared with;
- Correct, complete, or update it;
- Erase it by deleting your account;
- Raise a grievance;
- Nominate someone to exercise your rights in the event of death or incapacity;
- Withdraw consent — as easily as you gave it.
Exercise these in the app under Settings › Your Data, or by writing to the Grievance Officer at grievance@sagewabbit.com. We acknowledge complaints within 24 hours and resolve content and intermediary-related complaints within 15 days (IT Rules, 2021); data-rights grievances under the DPDP Act are resolved within 90 days at the outside, and usually much sooner.
8. Children
KaunHoTum is strictly for users 18 and over. We do not knowingly process the data of anyone under 18. If we learn a user is a minor, we remove the account and delete the data. See also our Child Safety Standards.
9. How we protect your data
We use reasonable security safeguards — encryption in transit and at rest, access controls, and monitoring (DPDP Act §8(5)).
10. Cross-border transfer
If any processing or storage occurs outside India, we do so only to jurisdictions permitted under the DPDP Act and applicable government notifications.
11. Data breaches
If a personal-data breach occurs, we will inform the Data Protection Board of India and each affected user without delay, and submit a detailed report to the Board within 72 hours, as prescribed by Rule 7 of the DPDP Rules, 2025.
12. Grievances & complaints
Contact our Grievance Officer first (grievance@sagewabbit.com). If your grievance is not resolved, you may complain to the Data Protection Board of India through the Board's published complaint mechanism.
13. Changes to this notice
We will notify you of material changes and, where required, seek fresh consent.
14. Contact
SageWabbit LLP, Navi Mumbai, Maharashtra, India · grievance@sagewabbit.com