Effective Date: [●], 2026 · Last Updated: 30 June 2026
DRAFT FOR LEGAL REVIEW — NOT YET PUBLISHED This document is a drafting template prepared to help SPACIVO move quickly and stay compliant. It is not a substitute for advice from a qualified Indian lawyer. It must be reviewed, completed with final company details (CIN, registered office, Grievance Officer), and approved by legal counsel before it is published or relied upon.
1. Introduction
SPACIVO (“SPACIVO”, “we”, “us”, “our”) is operated by [SPACIVO Technologies Private Limited], a company proposed to be incorporated under the Companies Act, 2013, with its registered office at [Registered Office Address], India (CIN: [CIN once allotted]) (the “Company”). This Privacy Policy explains how we collect, use, store, share, and protect Personal Data when you use the SPACIVO website, mobile application, and related services (collectively, the “Services”).
This Policy is published in accordance with the Digital Personal Data Protection Act, 2023 (“DPDPA”), the Information Technology Act, 2000, the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (“SPDI Rules”), and the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021, each as amended from time to time.
By accessing or using the Services, you agree to the collection and use of information in accordance with this Policy. If you do not agree, please do not use the Services.
2. Definitions
- “Personal Data” means any data about an individual who is identifiable by or in relation to such data, as defined under Section 2(t) of the DPDPA.
- “Sensitive Personal Data” includes financial information, health records, biometric data, and government identifiers such as Aadhaar or PAN numbers, as recognised under the SPDI Rules.
- “Data Principal” means the individual to whom the Personal Data relates — that is, you.
- “Data Fiduciary” means SPACIVO, which determines the purpose and means of processing your Personal Data.
- “Processing” means any operation performed on Personal Data, including collection, storage, use, sharing, and erasure.
- “Consent Manager” means a person registered with the Data Protection Board of India to enable a Data Principal to give, manage, review, or withdraw consent.
3. Information We Collect
3.1 Information you provide directly:
- Account details: name, email address, mobile number, and date of birth.
- Information you enter for a Life Event (for example, relationship status or dependents).
- Documents uploaded to your encrypted Vault, which may include Aadhaar, PAN, passport, marriage certificates, insurance policies, medical records, and financial statements.
- Payment information processed via our third-party payment gateway. We do not store full card numbers.
- Communications you send us, including support requests, feedback, and survey responses.
3.2 Information collected automatically:
- Device information: device type, operating system, browser type, and IP address.
- Usage data: pages visited, features used, time spent, and crash logs.
- Approximate location derived from IP address. We do not collect precise GPS location unless you separately grant that permission for a specific feature.
3.3 Information from third parties:
- If you sign in using a third-party account (for example, Google), we receive the basic profile information you have authorised.
- Information from professional partners, such as a Chartered Accountant or law firm, only where you have explicitly authorised such sharing for a specific service.
4. Lawful Basis & Consent
We process your Personal Data on the basis of: (a) your free, specific, informed, and unambiguous consent, given through clear affirmative action, in accordance with Section 6 of the DPDPA; (b) the “legitimate uses” recognised under Section 7 of the DPDPA, including providing services you have requested, compliance with law, and responding to a medical emergency; and (c) performance of a contract between you and SPACIVO.
You may withdraw consent at any time through your Account Settings or by writing to our Grievance Officer. Withdrawal does not affect the lawfulness of processing carried out before withdrawal and may limit our ability to provide certain features.
5. How We Use Your Information
We use Personal Data to:
- create and manage your account and Vault;
- provide step-by-step guidance, document checklists, and deadline reminders for your selected Life Events;
- process payments and prevent fraud;
- provide customer support;
- improve and personalise the Services;
- send service-related communications — you may opt out of marketing communications at any time;
- comply with applicable law, regulation, legal process, or government request; and
- enforce our Terms of Service and protect the rights, property, and safety of SPACIVO, our users, and the public.
We do not use the contents of your uploaded documents to train artificial intelligence models, and we do not sell your Personal Data to any third party.
6. Data Storage & Security
- All Personal Data of Indian users is stored on servers located within India, in compliance with applicable data localisation requirements.
- Documents in your Vault are encrypted in transit using TLS 1.3 and at rest using AES-256 encryption.
- Access to production systems is restricted on a need-to-know basis and is logged.
- We conduct periodic security reviews and maintain reasonable security practices as required under Section 43A of the IT Act and the SPDI Rules.
- No method of transmission or storage is completely secure. While we strive to protect your Personal Data, we cannot guarantee absolute security.
7. Sharing & Disclosure of Information
We share Personal Data only in the following circumstances:
- Service providers — cloud hosting, payment gateways, SMS/email providers, and customer support tools, each bound by contractual confidentiality and data protection obligations.
- Professional partners — where you explicitly request a referral or document share with a Chartered Accountant, lawyer, or insurance partner.
- Legal compliance — where required by a court order, government direction, or applicable law, including requests made under Section 36 of the DPDPA.
- Business transfers — in connection with a merger, acquisition, or sale of assets, subject to equivalent privacy protections.
We never sell, rent, or trade your Personal Data for advertising purposes.
8. Cross-Border Transfer of Data
Personal Data may be transferred outside India only to countries that are not restricted by the Central Government under Section 16 of the DPDPA, and only where necessary — for example, for certain cloud infrastructure sub-processors. Any such transfer is subject to contractual safeguards equivalent to those required under Indian law.
9. Data Retention
We retain Personal Data only for as long as necessary to fulfil the purposes outlined in this Policy, or as required by applicable law (for example, financial records under the Income Tax Act, 1961). You may request erasure of your Personal Data at any time (see Section 11), except where retention is mandated by law or necessary for the establishment, exercise, or defence of legal claims.
Upon account deletion, your Vault documents are permanently erased from active systems within 30 days, and from backups within 180 days, save as required by law.
10. Children's Data
Our Services are not directed at individuals below 18 years of age. Where SPACIVO processes the Personal Data of a child for a Life Event entered by a parent or lawful guardian (for example, “Having a Baby”), we rely on the verified consent of the parent or guardian as required under Section 9 of the DPDPA. We do not undertake tracking, behavioural monitoring, or targeted advertising directed at children.
11. Your Rights as a Data Principal
Subject to the DPDPA, you have the right to:
- obtain a summary of the Personal Data we hold about you and the processing activities undertaken (Section 11, DPDPA);
- seek correction, completion, updating, and erasure of your Personal Data (Section 12, DPDPA);
- have a readily available means of grievance redressal (Section 13, DPDPA);
- nominate another individual to exercise your rights in the event of your death or incapacity (Section 14, DPDPA); and
- withdraw consent at any time, with prospective effect only.
To exercise these rights, write to our Grievance Officer (see Section 16 below). We will respond within the timelines prescribed under the DPDPA and its Rules.
12. Cookies & Similar Technologies
We use essential cookies to operate the Services (for example, session management) and analytics cookies to understand usage patterns. You can control cookies through your browser settings; disabling essential cookies may affect functionality. We do not use cookies for cross-site behavioural advertising.
13. Third-Party Links
The Services contain deep links to government and regulatory portals, including UIDAI, IRDAI, Passport Seva, and NSDL/Protean. These are independent third-party websites; we are not responsible for their content, privacy practices, or security. Please review their respective privacy policies before sharing information with them.
14. Data Breach Notification
In the event of a personal data breach, we will notify the Data Protection Board of India and affected Data Principals as required under Section 8(6) of the DPDPA, describing the nature of the breach, its likely consequences, and the remedial measures taken.
15. Significant Data Fiduciary Obligations
Should SPACIVO be notified by the Central Government as a “Significant Data Fiduciary” under Section 10 of the DPDPA, we will additionally appoint a Data Protection Officer based in India, undertake periodic Data Protection Impact Assessments, and conduct independent data audits, as required.
16. Grievance Officer & Contact
In accordance with Rule 5 of the IT Rules and Section 13 of the DPDPA, the following Grievance Officer may be contacted for any questions, complaints, or requests relating to this Policy:
- Name: [Grievance Officer Name]
- Designation: Grievance Officer / Data Protection Contact
- Email: [privacy@spacivo.xyz — to be confirmed]
- Address: [Registered Office Address]
We will acknowledge grievances within 24 hours and resolve them within 15 days, as prescribed under the IT Rules.
17. Changes to this Policy
We may update this Policy periodically to reflect changes in our practices, technology, legal requirements, or other factors. The updated Policy will be posted on this page with a revised “Last Updated” date. Material changes will be notified to you via email or in-app notice.
18. Governing Law & Jurisdiction
This Policy is governed by the laws of India. The courts at Mumbai, Maharashtra shall have exclusive jurisdiction over any disputes arising out of or in connection with this Policy.
19. Copyright Notice
© 2026 [SPACIVO Technologies Private Limited]. All rights reserved. “SPACIVO”, the SPACIVO logo, and the “breathing dot” device mark are trademarks of [SPACIVO Technologies Private Limited] (applications pending registration under the Trade Marks Act, 1999, in Classes 9, 35, and 42). Unauthorised use, reproduction, or distribution of these marks, or of the content of this Policy, is strictly prohibited.
20. Contact Us
For any questions about this Privacy Policy, please contact us at: [privacy@spacivo.xyz]
Effective Date: [●], 2026 · Last Updated: 30 June 2026
DRAFT FOR LEGAL REVIEW — NOT YET PUBLISHED This document is a drafting template prepared to help SPACIVO move quickly and stay compliant. It is not a substitute for advice from a qualified Indian lawyer. It must be reviewed, completed with final company details (CIN, registered office, Grievance Officer), and approved by legal counsel before it is published or relied upon.
1. Acceptance of Terms
These Terms of Service (“Terms”) constitute a legally binding agreement between you (“User”, “you”) and [SPACIVO Technologies Private Limited] (“SPACIVO”, “we”, “us”, “our”) governing your access to and use of the SPACIVO website, mobile application, and related services (the “Services”). By creating an account or otherwise using the Services, you accept these Terms in full. If you do not agree, you must not use the Services.
2. Eligibility
You must be at least 18 years of age and competent to contract under the Indian Contract Act, 1872 to create an account. If you use the Services on behalf of a minor or dependent family member as part of a Life Event (for example, “Having a Baby” or “Raising a Child with a Disability”), you represent that you are their parent or lawful guardian and are authorised to manage their information.
3. Description of Service
SPACIVO is a life-administration platform that helps Indian households identify, organise, and track the documents, deadlines, and steps associated with major life events. SPACIVO provides organisational guidance and document storage tools; it does not provide legal, financial, tax, medical, or insurance advice (see Section 10).
4. Account Registration & Security
You agree to provide accurate, current, and complete information during registration and to keep it updated. You are responsible for maintaining the confidentiality of your login credentials and for all activities under your account. Notify us immediately at [security@spacivo.xyz] of any unauthorised use of your account.
5. Subscription Plans, Fees & Payment
- SPACIVO offers a free plan (preview access, one fully unlocked Life Event, and a 20-document starter Vault), a Single Event Pass (a one-time fee for a specific Life Event), and an annual or monthly Membership unlocking all Life Events, as described on our Pricing page.
- All fees are quoted in Indian Rupees (₹), inclusive of applicable taxes (GST) unless stated otherwise, and are processed through our authorised third-party payment gateway.
- Where a Membership is elected as auto-renewing, it will renew automatically at the then-current price unless cancelled at least 24 hours before the renewal date, consistent with the RBI's e-mandate framework for recurring payments.
- Refunds are governed by our Refund Policy, consistent with the Consumer Protection (E-Commerce) Rules, 2020. Save where required by law, fees already paid for a Single Event Pass, or for a part-used Membership period, are non-refundable.
- We may change our fees prospectively upon notice; continued use after the effective date constitutes acceptance of the new fees.
6. Your Content & the Vault
- You retain all ownership rights in the documents and information you upload to your Vault (“User Content”).
- You grant SPACIVO a limited, non-exclusive, royalty-free licence to host, store, encrypt, back up, and display your User Content solely to provide the Services to you, and for no other purpose, including AI model training.
- You represent that you hold all necessary rights and consents to upload User Content — including any third party's personal data contained within it, such as a spouse's Aadhaar number — and that doing so does not violate applicable law or any other person's rights.
- You may export or delete your User Content at any time through the app; deletion is subject to the retention timelines in our Privacy Policy.
7. Acceptable Use
You agree not to:
- use the Services for any unlawful purpose, including fraud, identity theft, or money laundering;
- upload malicious code, attempt to gain unauthorised access to our systems, or interfere with the integrity of the Services;
- reverse-engineer, decompile, or attempt to extract the source code of the Services, except as permitted by law;
- scrape, harvest, or systematically extract data from the Services using automated means;
- misrepresent your identity or impersonate any person or entity; or
- upload User Content that infringes any third party's intellectual property, privacy, or other rights.
We reserve the right to suspend or terminate accounts that violate this Section.
8. Intellectual Property
All right, title, and interest in the Services — including the SPACIVO name, logo, “breathing dot” device, software, design, text, and step-by-step guides (excluding your User Content) — are and remain the exclusive property of [SPACIVO Technologies Private Limited] and its licensors, protected under the Copyright Act, 1957 and the Trade Marks Act, 1999. Nothing in these Terms grants you any right to use our trademarks, logos, or trade dress without our prior written consent.
9. Government Portals & Third-Party Links Disclaimer
SPACIVO provides direct links to official government and regulatory portals — including UIDAI, IRDAI/Bima Bharosa, Passport Seva, NSDL/Protean, RBI, and the National Cyber Crime Reporting Portal — purely for your convenience. SPACIVO is not affiliated with, endorsed by, or acting as an agent of any government body. Procedures, fees, forms, and deadlines on third-party portals are subject to change without notice and are outside SPACIVO's control. You must independently verify all such information with the relevant authority before relying on it.
10. No Professional Advice
The information, checklists, and guides provided through the Services are for general informational and organisational purposes only and do not constitute legal, financial, tax, medical, or insurance advice. You should consult a qualified Chartered Accountant, lawyer, doctor, or licensed financial or insurance advisor before making any decision based on information obtained through the Services. SPACIVO is not a registered investment adviser, insurance broker, or law firm.
11. Mental Health & Emergency Content Disclaimer
Life Event guides relating to mental health, medical emergencies, or financial distress — including the Depression/Anxiety, Burnout, Debt, and Cyber Safety guides — are informational only and are not a substitute for professional medical, psychiatric, legal, or crisis-intervention services. If you or someone you know is in crisis, please contact emergency services (112) or a recognised helpline such as Tele-MANAS (14416) immediately.
12. Disclaimer of Warranties
The Services are provided on an “as is” and “as available” basis. To the maximum extent permitted by applicable law, SPACIVO disclaims all warranties, express or implied, including warranties of merchantability, fitness for a particular purpose, accuracy, and non-infringement. We do not warrant that the Services will be uninterrupted, error-free, or completely secure.
13. Limitation of Liability
To the maximum extent permitted under the Indian Contract Act, 1872 and other applicable law, SPACIVO's aggregate liability arising out of or relating to these Terms or the Services shall not exceed the amount paid by you to SPACIVO in the twelve (12) months preceding the claim, or ₹5,000, whichever is higher. SPACIVO shall not be liable for any indirect, incidental, special, consequential, or punitive damages, including loss of data, profits, or goodwill, except in cases of our gross negligence, wilful misconduct, or fraud, or to the extent such limitation is prohibited by law.
14. Indemnification
You agree to indemnify and hold harmless SPACIVO, its directors, officers, employees, and agents from any claims, damages, losses, or expenses (including reasonable legal fees) arising out of your breach of these Terms, your User Content, or your violation of any law or third-party right.
15. Termination
You may close your account at any time through the app. We may suspend or terminate your access to the Services, with or without notice, if you breach these Terms, engage in fraudulent or unlawful activity, or where required by law. Upon termination, your right to use the Services ceases immediately; the Sections relating to Intellectual Property, Limitation of Liability, Indemnification, and Dispute Resolution shall survive termination.
16. Dispute Resolution & Arbitration
Any dispute, controversy, or claim arising out of or relating to these Terms shall first be addressed through good-faith negotiation. If unresolved within thirty (30) days, the dispute shall be referred to and finally resolved by arbitration under the Arbitration and Conciliation Act, 1996, by a sole arbitrator appointed by mutual agreement (or, failing agreement, in accordance with the Act). The seat and venue of arbitration shall be Mumbai, Maharashtra, and the language of arbitration shall be English. Nothing in this Section prevents either party from seeking urgent injunctive relief from a competent court.
17. Governing Law & Jurisdiction
These Terms are governed by the laws of India. Subject to Section 16 above, the courts at Mumbai, Maharashtra shall have exclusive jurisdiction.
18. Force Majeure
SPACIVO shall not be liable for any failure or delay in performance resulting from causes beyond its reasonable control, including acts of God, natural disasters, war, terrorism, civil unrest, government action, internet or telecommunications failure, or pandemic.
19. Severability & Waiver
If any provision of these Terms is held invalid or unenforceable, the remaining provisions shall continue in full force and effect. No waiver of any provision shall be deemed a further or continuing waiver of that provision or of any other provision.
20. Entire Agreement
These Terms, together with our Privacy Policy and any other policies referenced herein, constitute the entire agreement between you and SPACIVO regarding the Services, superseding any prior agreements.
21. Changes to These Terms
We may revise these Terms from time to time. We will notify you of material changes via email or in-app notice at least 15 days before they take effect. Continued use of the Services after the effective date constitutes acceptance of the revised Terms.
22. Grievance Officer
In accordance with the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021, the following Grievance Officer may be contacted for complaints relating to the Services:
- Name: [Grievance Officer Name]
- Email: [grievance@spacivo.xyz — to be confirmed]
- Address: [Registered Office Address]
23. Copyright Notice
© 2026 [SPACIVO Technologies Private Limited]. All rights reserved. “SPACIVO” and the SPACIVO logo are trademarks of [SPACIVO Technologies Private Limited] (applications pending). No part of the Services may be reproduced, distributed, or transmitted without prior written permission, except as permitted under the Copyright Act, 1957.
24. Contact Us
For questions about these Terms, contact us at: [legal@spacivo.xyz]
