Privacy Policy

Operated By: Sachin Rathod, operating as OuterCircle Labs

Effective Date: August 11, 2026

Version: v1.0.0

DPDP Act 2023 aligned

Summary

How PassPage collects, processes, secures, and shares your personal data in compliance with India's Digital Personal Data Protection Act, 2023.

Key Highlights

• Data minimization: only Name, Email, Phone, and Address are collected for wallet functionality.
• No sale of personal data.
• Processing is based on explicit consent and legitimate security operations.
• Data principal rights include access, correction, erasure, withdrawal of consent, and grievance redressal.

1. Introduction and Data Fiduciary Details

Sachin Rathod, operating as OuterCircle Labs, operates as a Data Fiduciary under the DPDP Act, 2023. This policy describes how data is collected, used, disclosed, and protected across the PassPage platform and developer ecosystem.

2. Personal Data We Collect

Minimum required profile data:

• Full Name
• Email Address
• Phone Number
• Physical Addresses

Technical and audit metadata includes consent ledger events, session records, and security diagnostics.

Explicit exclusions include Aadhaar, PAN, passport numbers, payment card details, bank credentials, health records, and biometrics.

3. Purpose of Processing and Legal Grounds

• Profile wallet maintenance and autofill readiness (Consent).
• User-approved data sharing with external apps (Consent).
• Security and fraud prevention (Legitimate use and system security).
• Regulatory and legal compliance, including audit logs (Compliance with law).

4. How Data is Shared and Disclosed

• With authorized third-party applications only after explicit consent.
• With vetted cloud processors under strict data processing agreements.
• With law enforcement only under valid legal mandate.
• Data is never sold, rented, or traded for advertising monetization.

5. International Data Transfers

Data is primarily stored and processed using secure cloud regions. Any cross-border transfer uses contractual and DPDP-compliant safeguards.

6. Your Rights under DPDP Act 2023

• Right to Access
• Right to Correction and Updating
• Right to Erasure or Deletion
• Right to Withdraw Consent
• Right to Nominate
• Right to Grievance Redressal

7. Security and Breach Notification

• TLS 1.3 for data in transit
• AES-256 encryption for data at rest
• RBAC and zero-trust access controls
• Breach notification to regulators and affected users without undue delay, aligned with statutory reporting expectations

8. Grievance Redressal Officer and Contact

Name: Sachin Rathod

Designation: Founder, OuterCircle Labs

Email: support@outercirclelab.com

Turnaround: Acknowledgment within 24-48 hours; statutory resolution within 30 days.