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Privacy Grievance & DPDP Rights Mechanism

Effective Date: September 14, 2026 · Last Updated: September 14, 2026

Owned and operated by:
Vantageflow Technologies Private Limited
CIN: U62010BR2026PTC085214
Registered Office: H/O Subodh Kumar Jha, Ward No. 09, Pupri, Janakpur Road, Pupri, Sitamarhi – 843320, Bihar, India
Email: info@vantageflowtech.com
Website: https://mylifevault.co.in
Today, this process is handled by email — write to info@vantageflowtech.com and we will act on your request under the process described below. An in-app self-service Privacy Rights Centre, with request tracking and status updates, is planned but not yet built; this page will be updated the moment it is.

1. Purpose of This Document

Vantageflow Technologies Private Limited (“Vantageflow”, “Company”, “we”, “us” or “our”) is committed to protecting the personal data of users of MyLifeVault. This Privacy Grievance & DPDP Rights Mechanism (“Mechanism”) explains how users can exercise applicable rights relating to their personal data, submit privacy requests, withdraw consent where applicable, request correction or deletion, raise a privacy grievance, report unauthorized processing or access, report a personal-data security concern, escalate an unresolved grievance, and exercise other rights available under applicable law.

This Mechanism should be read together with the MyLifeVault Privacy Policy, the MyLifeVault Terms of Use, the MyLifeVault Disclaimer, the MyLifeVault Cookie Policy, and applicable provisions of the Digital Personal Data Protection Act, 2023 (“DPDP Act”) and rules made thereunder.

2. Our Role

For personal data processed by Vantageflow in connection with MyLifeVault, Vantageflow will act in the role applicable to it under the DPDP Act and other applicable data-protection laws. Where Vantageflow determines the purpose and means of processing personal data, it may act as a Data Fiduciary under the DPDP Act. Where another organization independently determines the purpose and means of processing, that organization may have separate responsibilities under applicable law.

3. Who Can Use This Mechanism?

This Mechanism is available to individuals whose personal data is processed by Vantageflow through MyLifeVault, subject to applicable law. A person submitting a request on behalf of another individual may be required to provide evidence of appropriate authority.

4. Contact Details

Privacy / Grievance Contact
Privacy / Grievance Team, Vantageflow Technologies Private Limited
Email: info@vantageflowtech.com
Postal Address: H/O Subodh Kumar Jha, Ward No. 09, Pupri, Janakpur Road, Pupri, Sitamarhi – 843320, Bihar, India

Security-related matters (suspected security vulnerabilities or unauthorized access): info@vantageflowtech.com
Customer Support: info@vantageflowtech.com · https://mylifevault.co.in

5. Available Privacy Requests

Subject to applicable law, users may contact Vantageflow to: request information about processing of their personal data; request access to applicable personal data; request correction of inaccurate information; request completion of incomplete information; request updating of information; request erasure of personal data; withdraw consent where consent is the basis of processing; request information concerning processing or sharing; raise a privacy grievance; report unauthorized processing; report a suspected personal-data breach; exercise applicable nomination rights; and exercise any other rights available under applicable law.

The DPDP Act expressly provides rights relating to correction, completion, updating and erasure, grievance redressal and nomination, subject to the conditions set out in the Act.

6. How to Submit a Request

A request may be submitted by emailing info@vantageflowtech.com. Where required, the request should include sufficient information to allow us to understand and process it.

7. Privacy Request Categories

Requests generally fall into one of the following categories:

Account and profile

Update profile information · Correct personal information · Delete account

Personal data

Request access · Request information about processing · Request correction · Request deletion/erasure

Consent

Withdraw optional consent · Review consent status · Change optional permissions

Sharing

Raise a concern regarding data sharing · Request information regarding applicable processing

Security

Report unauthorized account access · Report suspected data breach · Report suspicious communication

Grievance

Submit privacy complaint · Escalate unresolved privacy concern

8. Identity Verification

Because MyLifeVault may contain highly sensitive personal information, Vantageflow may need to verify the identity of the person making a privacy request. Verification may be performed using reasonable methods such as authenticated access to the user's MyLifeVault account, registered email verification, registered mobile verification, authentication through an approved identity provider, account-specific information, secure verification links, or another reasonable method appropriate to the request. We will seek to collect only information reasonably necessary to verify identity.

9. Requests Made by Authorized Representatives

If you submit a request on behalf of another person, Vantageflow may require evidence establishing your authority, such as authorization from the Data Principal, power of attorney, legal representation documents, guardianship documentation, or court documentation. Vantageflow may refuse to disclose personal data where sufficient authority cannot be established.

10. Right to Access Information

Subject to applicable law, you may request information concerning personal data processed by Vantageflow, including personal data being processed, purposes of processing, applicable processing activities, relevant categories of recipients, and other information required to be provided by law. We may provide information through a secure account interface, downloadable file, email or another appropriate method.

11. Right to Correction

You may request correction of inaccurate or misleading personal data, completion of incomplete information, or updating of outdated information. Where MyLifeVault provides self-service editing functionality, you may correct information directly through your account. For information that cannot be changed directly, you may submit a request to the Privacy / Grievance Contact.

12. Right to Erasure

Subject to applicable law, you may request erasure of personal data for which retention is no longer necessary or where another applicable basis for erasure exists. Vantageflow will assess the request against applicable legal and operational requirements. Erasure may be limited where retention is necessary for compliance with law, legal proceedings, fraud prevention, security, establishment or defence of legal claims, contractual obligations, or another lawful purpose. The DPDP Act provides for erasure upon request where applicable, subject to retention being necessary for the specified purpose or compliance with law.

13. Account Deletion

Users may request deletion of their MyLifeVault account by contacting info@vantageflowtech.com. Account deletion may result in deletion or de-identification of associated personal data subject to applicable retention requirements, legal obligations, security requirements, backup systems, dispute resolution, fraud prevention, and other legally permitted purposes. Users should export any information they wish to retain before deleting their account where an export facility is available.

A self-service “Delete Account” control inside Settings is planned but not yet built.

14. Document Deletion

Users may delete documents through the applicable MyLifeVault interface where such functionality is available. Deleting a document from an active account may not result in immediate deletion from all technical backup or disaster-recovery systems. Such copies will be handled according to the applicable retention and deletion lifecycle.

15. Withdrawal of Consent

Where processing is based on consent, you may withdraw your consent by contacting the Privacy / Grievance Team, or through in-app privacy settings where such controls exist. The DPDP framework contemplates that consent should be capable of being withdrawn through a process comparable to the process by which consent was given.

16. Effect of Withdrawing Consent

Withdrawal of consent does not affect the lawfulness of processing that occurred before withdrawal. Where the relevant processing is necessary to provide a requested feature, withdrawal may cause that feature to become unavailable — for example, withdrawing camera permission may prevent document scanning, and withdrawing notification permission may prevent push notifications. Withdrawing optional analytics consent should not ordinarily prevent core account functionality. Where processing can continue under another lawful basis permitted by applicable law, withdrawal of consent may not automatically require cessation of all processing.

17. Data Portability / Export

Where available, MyLifeVault may provide tools to export documents, account information, profile information, metadata, reminders, or other user-generated information. Where applicable law provides a specific portability right, Vantageflow will comply with the requirements applicable to that right.

Today: a self-service export tool is not yet built. Request an export by emailing info@vantageflowtech.com.

18. Nomination

The DPDP Act provides a Data Principal with a right to nominate another individual who may exercise the Data Principal's rights in the event of death or incapacity, subject to the Act and applicable rules. Where MyLifeVault implements nomination functionality, users may be able to designate a nominee through the applicable account settings. A nominee does not automatically receive access to a user's documents or account merely because they have been nominated — any access following death or incapacity will be subject to applicable law, MyLifeVault procedures, authentication, verification, the scope of the nomination, and any applicable court or governmental requirements.

Today: nomination functionality is not yet built.

19. Privacy Grievances

A user may raise a grievance where they believe personal data has been processed unlawfully, their privacy rights have not been respected, a privacy request has not been properly handled, personal data has been disclosed improperly, consent has not been handled appropriately, personal data has been retained contrary to applicable requirements, security measures appear inadequate, or another act or omission relating to personal data requires review.

20. How to File a Grievance

A grievance should be submitted to the Privacy / Grievance Team at info@vantageflowtech.com with subject line “MyLifeVault Privacy Grievance — [Account / Reference ID].” Where possible, include: your name; registered email/mobile number; MyLifeVault account identifier, where available; description of the concern; relevant dates; screenshots or supporting material, where appropriate; the action you are requesting; and any previous support/reference number. Do not send passwords, OTPs, encryption keys or other authentication secrets in a grievance.

21. Grievance Acknowledgement

Upon receipt, Vantageflow may assign a unique grievance or ticket reference number, which should be retained by the user for future correspondence. We may acknowledge receipt by email or another appropriate communication channel.

22. Grievance Review Process

Vantageflow follows an internal process with the following stages:

Stage 1 — Receipt

The grievance is received and assigned a reference number.

Stage 2 — Verification

We may verify the identity of the complainant where necessary.

Stage 3 — Classification

The grievance may be classified as a privacy request, account issue, security issue, data correction, deletion request, consent issue, unauthorized access, data-sharing concern, technical issue, or other privacy matter.

Stage 4 — Investigation

Relevant internal teams may review account records, access logs, consent records, processing records, support history, security logs, relevant third-party processing, and other information reasonably necessary to investigate.

Stage 5 — Resolution

Where appropriate, Vantageflow may correct information, delete information, restrict processing, restore or revoke access, explain the applicable processing, correct a technical issue, investigate a security event, provide additional information, or explain why a requested action cannot be taken.

23. Grievance Response Time

Vantageflow will respond to grievances within the period prescribed by applicable law. The applicable statutory timeframe may depend on the type of request and the legal framework in force at the time the request is received. We may provide an interim response where an investigation requires additional time.

24. Complex or Security-Sensitive Grievances

Certain matters may require additional investigation, particularly where they involve suspected account takeover, suspected personal-data breach, identity fraud, multiple accounts, legal proceedings, third-party processing, law-enforcement requests, or technically complex incidents. In such cases, Vantageflow may request additional information necessary to investigate, while seeking to avoid unnecessary collection of additional personal data.

25. Security Incident Reporting

If you believe your MyLifeVault account has been compromised, report it immediately to info@vantageflowtech.com. Your report should, where possible, include your account email, approximate date/time, nature of the suspected compromise, suspicious activity observed, affected device, screenshots (if safe to provide), and any relevant support reference. Do not include passwords, OTPs, recovery codes, private keys or other authentication secrets.

26. Suspected Personal-Data Breach

If Vantageflow receives information indicating a potential personal-data breach, we may initiate our internal incident-response process, including incident identification, containment, access restriction, forensic investigation, impact assessment, identification of affected information, remediation, security improvement, legal/regulatory assessment, and notifications where required. Where applicable law requires notification to affected Data Principals or authorities, Vantageflow will follow the applicable requirements.

27. Third-Party Processors

Where a grievance concerns a third-party service provider, Vantageflow may investigate the relevant processing and, where appropriate, contact the processor, request information, require corrective action, restrict the relevant integration, or suspend the relevant feature. Where the third party is an independent Data Fiduciary, the user may also need to raise the matter directly with that third party.

28. Grievance Involving Authentication Providers

If a concern relates specifically to Google or another external identity provider, Vantageflow may not control the relevant provider's processing. Vantageflow will investigate the portion of processing under its control, and the user may also need to contact the relevant identity provider regarding its independent processing.

29. Grievance Involving Payment Providers

Where a grievance concerns a payment processed by a third-party payment provider, Vantageflow will investigate the portion of processing under its control. The payment provider's own dispute-resolution and support process may also apply.

Today: MyLifeVault has no payment processing, so this section is not yet applicable.

30. False or Frivolous Requests

Users are expected to provide accurate and authentic information when exercising privacy rights. The DPDP Act places duties on Data Principals, including not impersonating another person, not suppressing material information in specified circumstances, not filing false or frivolous grievances, and furnishing verifiably authentic information when exercising applicable correction or erasure rights. Vantageflow may take reasonable steps to verify suspicious requests. Nothing in this section limits a user's legitimate right to raise a genuine grievance.

31. Protecting Other Users' Data

A privacy request must not be used to obtain another person's personal information without lawful authorization — for example, another user's documents, account information, private communications, or authentication information. Vantageflow may redact or withhold information where necessary to protect another person's privacy or comply with law.

32. Privacy Requests Relating to Shared Documents

Where a document contains information belonging to multiple individuals, Vantageflow may need to balance the requester's rights against the privacy rights of other individuals. Where necessary, we may redact information, restrict disclosure, request additional authorization, or decline disclosure to the extent required by law.

33. Children's Data Requests

Where a request concerns the personal data of a child, Vantageflow may require verification of the child's identity, the requester's identity, parental or guardian authority, and any other information required under applicable law. Additional safeguards may apply to children's data.

34. International Requests

If you access MyLifeVault from outside India, privacy rights applicable in your jurisdiction may differ. Vantageflow will assess requests according to the laws applicable to the relevant processing and the rights available to the requester. Nothing in this Mechanism is intended to remove a mandatory right available under applicable law.

35. Escalation

If you are dissatisfied with the response to your privacy grievance, you may request an internal review by emailing the Privacy / Grievance Team at info@vantageflowtech.com, including the original grievance reference number. Where applicable, the request will be reviewed by a person or team independent from the original handling of the matter to the extent reasonably practicable.

36. Escalation to the Data Protection Board of India

Under the DPDP Act, a Data Principal is required to exhaust the opportunity for grievance redressal provided by the Data Fiduciary before approaching the Data Protection Board of India. Accordingly, users should first submit their grievance to Vantageflow and allow the applicable grievance process to be completed. Where a user remains dissatisfied and the applicable statutory requirements have been satisfied, the user may have the right to approach the Data Protection Board of India in accordance with the Act and applicable Rules. The applicable procedure, filing mechanism, jurisdiction and timelines will be those prescribed by the Government of India and the Board.

37. No Waiver of Statutory Rights

Nothing in this Mechanism is intended to restrict a right available under applicable law, prevent a user from approaching a competent authority, exclude mandatory statutory protections, or prevent a lawful complaint or regulatory proceeding. Where this Mechanism conflicts with a mandatory requirement of applicable law, the mandatory legal requirement will prevail.

38. Privacy Request Records

Vantageflow may maintain records of privacy requests and grievances for purposes including demonstrating compliance, preventing abuse, resolving disputes, auditing, security, quality assurance, regulatory compliance, and improving the privacy process. Such records will be retained in accordance with applicable retention requirements.

39. Privacy Request Security

Privacy requests may contain sensitive information. Vantageflow may therefore use secure communication channels and verification procedures. Users should not send sensitive documents through ordinary email unless specifically requested through a secure process.

40. Response Communication

Responses may be provided through the registered email address, MyLifeVault account, secure in-app messaging, or another appropriate channel. We will seek to avoid disclosing sensitive personal information through insecure communication channels.

41. Request Tracking

Where the Platform supports it, users may track requests through MyLifeVault → Settings → Privacy → Privacy Requests, showing request type, submission date, reference number, current status, required action, response date, and resolution.

Today: this in-app tracking interface is not yet built; status updates are provided by email against your reference number.

42. Privacy Request Statuses

Where request tracking is available, statuses may include: Submitted (request received); Verification Required (additional identity or authorization verification needed); Under Review (request being assessed); Action Required (additional information required from the user); Resolved (request completed); Partially Resolved (some requested actions completed, others could not be); Declined (request could not be fulfilled for a documented legal, security or other permissible reason).

43. Reasons a Request May Be Limited or Refused

A request may be limited or refused where permitted by applicable law, including where the requester cannot be adequately authenticated; the requester lacks authority; disclosure would adversely affect another person's rights; retention is required by law; processing is necessary for legal proceedings; disclosure would compromise security; the request is manifestly fraudulent or abusive; fulfilling the request would violate another legal obligation; or another lawful exemption applies. Where required, Vantageflow will explain the applicable reason.

44. Consent Records

Where consent is relied upon for processing, Vantageflow may maintain appropriate records concerning consent provided, consent withdrawn, date/time, relevant notice, processing purpose, applicable feature, and other information necessary to demonstrate consent management, in accordance with legal and operational requirements.

45. Consent Management

MyLifeVault may provide mechanisms through which users can provide, review or withdraw consent, manage optional permissions, and understand the purpose of consent. Where a registered Consent Manager is used, the relevant Consent Manager's terms and privacy practices will also apply. Vantageflow does not represent itself as a registered Consent Manager and has not obtained such registration.

46. Grievance Channel Availability

The privacy grievance mechanism should remain reasonably accessible to users. Vantageflow seeks to provide a published privacy email address, an accessible request mechanism, and clear information explaining how users can exercise applicable rights, consistent with the DPDP framework's requirement of a readily available means of grievance redressal.

47. No Password Request

Vantageflow's Privacy / Grievance Team will not require users to disclose passwords, OTPs, recovery codes, private encryption keys or equivalent authentication secrets as part of an ordinary privacy request. If an individual claiming to represent Vantageflow requests such information, do not provide it.

48. Privacy Fraud Warning

Be cautious of individuals falsely claiming to be Vantageflow employees or MyLifeVault representatives. Vantageflow will not ask you to share an OTP or password, transfer money to resolve a privacy complaint, install unknown software, provide remote access to your device, or disclose private encryption credentials through an unsolicited communication. Report suspicious communications to info@vantageflowtech.com.

49. Contact Information

Privacy / Grievance Team
Vantageflow Technologies Private Limited
Email: info@vantageflowtech.com
Registered Office: H/O Subodh Kumar Jha, Ward No. 09, Pupri, Janakpur Road, Pupri, Sitamarhi – 843320, Bihar, India
Security Contact: info@vantageflowtech.com
Customer Support: info@vantageflowtech.com · https://mylifevault.co.in

50. Changes to This Mechanism

Vantageflow may update this Mechanism to reflect changes in applicable law, regulatory guidance, changes to MyLifeVault functionality, changes to privacy procedures, changes to contact information, changes to grievance processes, or improvements to user rights management. The Last Updated date will indicate when this Mechanism was most recently revised. Where required by law, appropriate notice will be provided.

51. Related Privacy Documents

  • MyLifeVault Privacy Policy
  • MyLifeVault Cookie Policy
  • MyLifeVault Terms of Use
  • MyLifeVault Disclaimer
  • MyLifeVault Security & Responsible Disclosure Policy

52. Effective Date

This Privacy Grievance & DPDP Rights Mechanism is effective from the date specified at the beginning of this document.

© 2026 Vantageflow Technologies Private Limited. All Rights Reserved.