DPDP ACT 2023 COMPLIANT • SECURE & PRIVATE

Privacy Policy & Data Protection Notice

Last Updated & Effective Date: October 4, 2026

Statutory Notice under the Digital Personal Data Protection (DPDP) Act, 2023:
This Privacy Policy serves as the mandatory itemized notice under Section 5 and Section 6 of the DPDP Act, 2023. By using PhoneGuard: Lost Phone Recovery (the "App"), you ("Data Principal") are informed about the collection, processing, purpose, storage, and rights associated with your digital personal data processed by Kyvronix Technologies ("Data Fiduciary").

PhoneGuard: Lost Phone Recovery is dedicated to providing lost mobile recovery and anti-theft defense. We operate under strict principles of Data Minimization, Purpose Limitation, and Affirmative Consent. We do not sell personal data, do not profile users for behavioral advertising, and only process telemetry necessary to safeguard your device.

1. Identity of the Data Fiduciary

The entity determining the purpose and means of processing your personal data is:

2. Itemized Categories of Personal Data Collected

In accordance with Section 5 of the DPDP Act, the table below provides an itemized breakdown of each category of data processed, the collection trigger, and the specific lawful recovery purpose:

Data Category Specific Data Elements Processed Purpose of Processing Lawful Basis
User Profile Name, Email Address, Registered Mobile Number, Firebase User Identifier (UID). Account authentication, synchronizing security settings across devices, and accessing the Web Recovery Dashboard. Consent (Section 6)
Emergency Contacts Mobile numbers designated by you as "Trusted Numbers". Dispatching automated emergency recovery SMS alerts (containing GPS links and battery status) upon verified trigger commands. Consent (Section 6)
Real-Time Location High-accuracy GPS coordinates, altitude, accuracy radius, and background location. Locating and tracking your lost or stolen device on a live map 24/7, even when the screen is locked or the app is closed. Explicit Consent & Runtime Permission
Cell Tower Telemetry Cell ID (CID), Location Area Code (LAC), Mobile Country Code (MCC), Mobile Network Code (MNC). Fallback location triangulation when GPS is disabled by an intruder or unavailable indoors. Legitimate Security Purpose
SIM & ICCID Telemetry SIM Slot Index, Carrier Name, Subscription ID, ICCID (SIM Chip Hardware Serial Number), and detected swapped mobile number. Detecting unauthorized SIM card swapping, alerting trusted contacts immediately, and logging SIM hardware changes to your secure dashboard. Legitimate Security Purpose & Consent
Intrusion Photos Front-camera photographs silently captured during failed screen unlock attempts (PIN/pattern/biometric) or upon remote "Photo" trigger. Generating photographic evidence of the unauthorized person possessing your phone and uploading it to your private dashboard. Explicit Consent & Camera Permission
Message Keyword Matching Temporary in-memory inspection of incoming notification text strictly for your pre-configured secret trigger keyword. Executing remote commands (Siren, Lock, GPS locate) over RCS and SMS. Note: Personal conversations, OTPs, and sender chats are never stored, read, or transmitted. Explicit Consent & Notification Access
Payment & Subscription Google Play purchase token, order ID, product identifier. Fulfilling premium subscriptions via the official Google Play In-App Billing library. (We never access or store credit cards or banking details). Contractual Fulfillment

3. Android System Permissions & Prominent Disclosures

In adherence to both Google Play Developer Policies and the DPDP Act, PhoneGuard displays prominent in-app disclosure dialogs before requesting sensitive device capabilities:

4. Third-Party Data Processors & Cross-Border Transfers

To provide reliable, high-availability security infrastructure, we engage the following trusted third-party Data Processors:

Any cross-border transfer of digital personal data complies with Section 16 of the DPDP Act and is restricted to jurisdictions permitted under applicable Indian Government notifications.

5. Data Retention & Storage Limitation Policy (Section 8(7))

Under the DPDP Act principle of Storage Limitation, personal data is retained only as long as necessary to satisfy the purpose for which it was collected:

6. Protection of Children’s Personal Data (Section 9)

PhoneGuard is designed as an anti-theft tool for device owners. In strict compliance with Section 9 of the DPDP Act:

7. Statutory Rights of the Data Principal (Sections 11, 12 & 14)

Under Chapter III of the DPDP Act, 2023, you are endowed with enforceable statutory rights regarding your digital personal data:

  1. Right to Access Information (Section 11): You have the right to obtain a summary of your personal data processed by us and the list of third-party processors with whom it has been shared.
  2. Right to Correction & Erasure (Section 12): You have the right to correct inaccurate data, update incomplete records, and request the complete erasure of your personal data.
  3. Right to Withdraw Consent (Section 6(4)): You may withdraw your consent at any time as easily as it was given, by toggling off permissions, turning off specific features, or deleting your account.
  4. Right of Grievance Redressal (Section 13): You have the right to register a grievance with our designated Grievance Officer regarding any matter relating to your personal data.
  5. Right to Nominate (Section 14): You have the statutory right to designate another individual who shall, in the event of your death or incapacity, exercise your rights as a Data Principal under the DPDP Act.

🛡️ Our Privacy & Security Guarantee

PhoneGuard strictly adheres to end-to-end transport encryption (TLS 1.3) and AES-256 cloud encryption at rest. We never sell your personal data, never monitor your private calls or chats, and never trigger camera or screen lock actions without your verified authorization.

8. Grievance Redressal Mechanism & Officer Details (Section 8(9) & 13)

If you have any questions, concerns, or grievances regarding the processing of your personal data or wish to exercise your statutory rights (including nomination or erasure), you may contact our designated Grievance Redressal Officer:

  • Designation: Grievance Officer, Data Privacy & Cybersecurity
  • Company: Kyvronix Technologies
  • Grievance Email: grievance@kyvronix.com
  • Support Email: support@kyvronix.com
  • Statutory Acknowledgment: Within 48 hours
  • Resolution Timeline: Within 30 days of receiving the grievance

9. Escalation to the Data Protection Board of India (DPBI)

In accordance with Section 13(3) of the DPDP Act, if you are not satisfied with the resolution provided by our Grievance Officer or if a response is not received within 30 days, you have the statutory right to file a formal complaint with the Data Protection Board of India:

  • Regulatory Authority: Data Protection Board of India (DPBI)
  • Ministry: Ministry of Electronics and Information Technology (MeitY), Government of India
  • Website: www.meity.gov.in