Privacy Policy

1. Introduction

SafeNominee is a digital legacy vault service operated by Bitlooper ("we", "us", "our"). This Privacy Policy explains how we collect, use, and protect the personal data of every User ("you") of our service.

2. Personal Data We Collect

We collect the following categories of personal data:

2.1 Account Registration Data

• Full name, email address, and mobile number
• Password (stored as a one-way salted hash — we cannot recover your login password)
• Optional profile photograph (stored encrypted)

2.2 Identity Documents

• Documents you upload (Aadhaar, PAN, Will, Insurance policies, Property papers, etc.)
• Document metadata (file name, type, upload date, file size)
• Documents are encrypted with AES-256 before being stored on our servers

2.3 Nominee Information

• Nominee's full name, relationship, email address, and mobile number
• Nominee's access permissions as configured by you

2.4 Payment Information

• Payment transactions are processed exclusively by Razorpay (a PCI-DSS Level 1 compliant payment gateway)
• We store only transaction identifiers, subscription plan details, invoice numbers, and payment status — we never store your card number, CVV, UPI PIN, or bank credentials

2.5 AI-Generated Document Summaries (Smart Insight)

• When Smart Insight is enabled, the text content of your uploaded attachment is processed by our AI service and the resulting summary is stored in your encrypted vault
• Smart Insight summaries are stored encrypted alongside the corresponding document and are accessible only to you and your authorised nominees
• Users on paid plans may disable this feature per document; free users may request opt-out by contacting support (see Section 4A)

2.6 Usage and Technical Data

• Device type, operating system version, and app version
• Login timestamps and session activity (for security monitoring)
• Inactivity detection signals (used to trigger nominee notification per your settings)

3. How We Use Your Personal Data

We use your personal data only for the following specified purposes:

• To create and manage your account and authenticate you securely
• To store, organise, and retrieve your documents and vault contents
• To generate AI-powered Smart Insight summaries of your uploaded attachments, where enabled (see Section 4A)
• To notify your nominated individuals per your inactivity and release settings
• To process subscription payments and issue invoices via Razorpay
• To send transactional notifications (OTP, payment receipts, nominee alerts) via email or SMS
• To detect and prevent fraud, abuse, and unauthorised access
• To fulfil our obligations under applicable Indian law, court orders, or regulatory directions

4. Document Encryption and Data Security

We take the security of your stored documents seriously. The following measures are in place:

• Documents are encrypted with AES-256 before being stored on our servers
• Your master password is stored securely and is required to access your encrypted documents
• Access to vault contents is controlled by role-based access controls (RBAC)
• All data is transmitted over TLS 1.3 encrypted connections
• Login passwords are stored as salted bcrypt hashes and cannot be recovered
• Session management uses short-lived JWT tokens
• Regular security reviews are conducted to identify and address vulnerabilities

Despite these measures, no system is completely immune to all threats. You are responsible for keeping your login credentials and master password confidential. If you forget your master password, access to your encrypted documents may be restricted.

4A. AI-Powered Smart Insight Feature

SafeNominee offers an AI-powered feature called "Smart Insight" that automatically analyses the text content of documents and attachments you upload and generates a plain-language summary ("Insight"). The purpose of this feature is to help your nominees and authorised persons understand complex documents — such as insurance policies, property papers, and legal agreements — without requiring professional assistance.

4A.1 Data Processed

• When Smart Insight is active, the text content extracted from your uploaded attachment is transmitted to our AI processing service for analysis.
• Only the textual content of the document is processed — file names, metadata, and encryption keys are not shared with the AI service.
• The generated summary (Insight) is stored alongside your document in your encrypted vault and is subject to the same AES-256 encryption and access controls described in Section 4.

4A.2 AI Processing and Third-Party Services

Smart Insight relies on a third-party large language model (LLM) service to generate summaries. The text content of your document is transmitted to this service solely for the purpose of generating the Insight. This service provider is contractually bound not to use your data for model training, fine-tuning, or any purpose other than responding to the individual request. No personally identifiable information beyond the document text is shared. The processed text is not retained by the AI service after the response is returned.

4A.3 User Control and Opt-Out

Smart Insight is enabled by default for all users upon account creation. Users on paid subscription plans may disable Smart Insight on a per-document basis through the document editing interface within the application. The toggle applies to the current upload session; it does not retroactively affect previously generated Insights.

Users on the free subscription tier who wish to opt out of Smart Insight processing may exercise their right to withdraw consent by submitting a written request to bitlooper.org@gmail.com. Upon verification of the request, we will disable Smart Insight processing for the requesting user's account within 7 business days. Withdrawal of consent for Smart Insight processing will not affect the availability of other features of the platform. Previously generated Insights stored in your vault will not be retroactively deleted unless you explicitly request erasure under Section 7.2.

4A.4 Limitation of Liability

Smart Insight summaries are generated by an AI system and are provided for informational convenience only. They do not constitute legal, financial, or professional advice. Bitlooper makes no warranty as to the accuracy, completeness, or fitness for purpose of any generated summary. Users and nominees are advised to refer to the original documents for all legally significant decisions. SafeNominee and Bitlooper shall not be liable for any loss or damage arising from reliance on an AI-generated Insight.

5. Third-Party Service Providers

5.1 Razorpay (Payment Processing)

We use Razorpay for payment processing. When you make a payment, you interact directly with Razorpay's checkout interface, which is governed by Razorpay's Privacy Policy. We receive only payment confirmation data. Razorpay is PCI-DSS Level 1 certified.

5.2 Cloud Infrastructure

We use cloud infrastructure providers to host our services. These providers are contractually bound to process data only on our instructions and implement adequate security measures. Data is stored in servers located within India where feasible.

5.3 Communication Services

We use third-party email and SMS providers exclusively to deliver transactional messages (OTPs, payment receipts, nominee notifications). These providers do not receive document content.

5.4 AI Processing Service (Smart Insight)

For the Smart Insight feature, we transmit the text content of your uploaded attachments to a third-party AI language model service. This provider is bound by a data processing agreement that prohibits use of your data for any purpose other than generating the requested summary. The provider does not retain the text after processing, does not use it for model training, and does not share it with any other party. You may opt out of this processing as described in Section 4A.3.

5.5 Google Analytics (Usage Statistics)

We use Google Analytics to measure how our website and web application are used. It receives your IP address (shortened by Google before storage), your device and browser type, your approximate location, and which pages or screens you open. It never receives the contents of your vault, anything you type, or any information identifying you to us — see Section 11. You may opt out at any time without affecting your use of SafeNominee.

6. Sharing of Your Personal Data

We share your personal data only in the following limited circumstances:

• With Razorpay to process subscription payments
• With nominees you have explicitly designated, limited to the documents and information you have authorised
• With law enforcement or government agencies when required by a valid court order, warrant, or applicable Indian law
• In the event of a business merger or acquisition, subject to the acquirer maintaining equivalent data protection standards and you being notified

7. Your Rights Under the DPDP Act, 2023

As a data principal under the Digital Personal Data Protection Act, 2023, you have the following rights:

7.1 Right to Access

You may request a summary of your personal data we process and the purposes for which it is processed.

7.2 Right to Correction and Erasure

You may request correction of inaccurate personal data or erasure of personal data that is no longer necessary for the purpose it was collected, subject to legal retention requirements.

7.3 Right to Withdraw Consent

You may withdraw consent for processing activities based on consent. This will not affect the lawfulness of processing before withdrawal.

7.4 Right to Nominate

You may nominate an individual to exercise your data rights on your behalf in the event of your death or incapacity.

7.5 Right to Grievance Redressal

You may file a grievance with our Grievance Officer (details in Section 13). If not resolved within 30 days, you may approach the Data Protection Board of India.

To exercise any right, email: bitlooper.org@gmail.com

8. Inactivity Detection and Nominee Notifications

SafeNominee monitors account activity to detect extended inactivity per your configured settings. If you remain inactive beyond your set threshold:

1. A warning notification is sent to your registered contact
2. If no response is received, your designated nominees may be notified and given access per your vault settings

This feature is entirely controlled by you. You can configure or disable it in Settings. We recommend keeping your inactivity period settings accurate to avoid unintended nominee notifications.

9. Data Retention

We retain your personal data as follows:

• Account data: For the duration of your account plus 5 years after closure (for legal and audit purposes)
• Documents: Until you delete them or close your account (deleted documents are permanently purged within 30 days)
• Payment records: 8 years as required under the Indian Companies Act and GST regulations
• Security logs: 2 years for fraud detection and legal compliance
• Support messages: 2 years after the request is closed, or until you close your account if that is sooner. A reference number and any payment or refund reference are kept for our records.

After retention periods expire, data is securely deleted or anonymised in accordance with DPDP Act requirements.

10. Children's Privacy

SafeNominee is not directed at children under 18 years of age. We do not knowingly collect personal data from minors. If we become aware that we have inadvertently collected personal data from a person under 18 without verifiable parental consent, we will delete such data promptly. If you believe we have collected data from a minor, please contact bitlooper.org@gmail.com.

11. Cookies and Tracking Technologies

Strictly necessary cookies. On our web platform we use cookies to keep you signed in. You may disable cookies in your browser settings, but you will then be unable to use any feature that requires signing in.

Analytics. We use Google Analytics to understand how our website and web application are used — how many people visit, which pages and screens they open, roughly where in the world they are, and what device and browser they use. This helps us decide what to improve. Google Analytics sets its own cookies and receives your IP address, which Google shortens before storing.

What analytics never receives. Nothing you store with us and nothing you type. No document, file name, note or message; no name, email address, phone number or account identifier; nothing about your nominees, claims or payments. Within the application we send only the name of the screen being viewed — for example "Documents" or "Nominees" — never what is on it. The contents of your vault are encrypted and are never shared with any analytics provider.

Advertising. We do not use advertising cookies, we do not allow cross-site tracking for advertising, and we do not sell or share your personal data with advertisers.

How to opt out. You can install Google's official Analytics opt-out browser add-on, or block analytics cookies in your browser settings. The application works normally either way — opting out of analytics never affects your access to your vault.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. When we make material changes, we will update the "last updated" date at the top of this Policy, send a notification to your registered email address, and display an in-app notification on your next login. Your continued use of SafeNominee after changes are posted constitutes your acceptance of the revised Policy.

13. Grievance Officer

In accordance with the Information Technology Act, 2000 and the DPDP Act, 2023, the details of our Grievance Officer are:

Department: Legal & Compliance — SafeNominee
Organisation: Bitlooper
Email: bitlooper.org@gmail.com
Response Time: Within 30 days of receiving a complaint

14. Contact Us

For any questions about this Privacy Policy, your personal data, or data rights:

Email: bitlooper.org@gmail.com
Website: safenominee.com
Organisation: Bitlooper, India

This document shall be governed by the laws of the Republic of India.