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1. Introduction

This Privacy Policy ("Policy") explains how Lyfebynary 0103 LLP ("The Way Home", "we", "us", "our") collects, uses, shares, stores, and protects personal data when you use our websites and mobile applications under the brand The Way Home (collectively, the "Platform").

We are committed to protecting your privacy and processing your personal data in accordance with the Digital Personal Data Protection Act, 2023 ("DPDP Act") and applicable Indian laws.

By using the Platform, you acknowledge that you have read and understood this Policy.

2. Data Fiduciary Details

For the purposes of the DPDP Act:

Data Fiduciary: Lyfebynary 0103 LLP

Registered Address: B-2901 Adonia, Hiranandani Gardens, Powai, Mumbai - 400076

Country of Incorporation: India

Contact Email: info@thewayhome.app

3. Scope of This Policy

This Policy applies to:

  • Personal data collected in digital form, or
  • Personal data collected in non-digital form and later digitised,

through:

This Policy does not apply to:

  • Anonymised or aggregated data that cannot reasonably identify you
  • Non-personal data

4. Definitions

"Personal Data" means any data about an individual who is identifiable by or in relation to such data.

"Data Principal" means the individual to whom the personal data relates.

"Processing" means any operation performed on personal data, including collection, storage, use, sharing, or deletion.

5. Personal Data We Collect

We collect personal data only where necessary for providing our services.

5.1 Information You Provide Directly

This includes:

Profile and account details

  • Name, photograph, gender, date of birth, nationality
  • Email address, phone number, address
  • Similar details of family members added by you

Household and service information

  • Names and salaries of domestic staff
  • Household assets (vehicles, appliances, etc.)

Financial and transactional data

  • Bills, receipts, spending records
  • Bank, card, investment, retirement and tax documents

Uploaded documents

  • Identity documents (Aadhaar, PAN, passport, driving licence, voter ID, ration card)
  • Property, insurance, medical, career, income-tax and investment documents

Communications

  • Messages with customer support
  • Feedback, surveys, complaints
  • Information shared during legal or regulatory interactions

Providing this data is voluntary, but some services may not function without it.

5.2 Information Generated Through Your Use of the Platform

We collect data relating to your usage, including:

  • Clicks, searches, views, and actions
  • Features used and content created (to-do lists, calendars, uploads)
  • Time, frequency, and duration of use
  • Mentions by other users (where applicable)

5.3 Device and Technical Information

This may include:

  • Device identifiers (IMEI, IP address, UUID)
  • Operating system, browser, network information
  • Location data (where permitted)
  • App foreground/background activity
  • Error logs, performance data
  • Metadata associated with uploaded content

5.4 Information from Third Parties

We may receive personal data from:

  • Authentication providers (e.g., [Google / Meta] login)
  • Payment service providers
  • Analytics and infrastructure partners
  • Public databases or lawful sources

Such data is processed only where legally permitted.

6. Purposes of Processing

We process personal data only for the following purposes:

6.1 Providing Our Services

  • Creating and managing your account
  • Enabling household management features
  • Facilitating transactions and bill payments
  • Connecting you with partner services (with consent)

6.2 Improving and Securing the Platform

  • Feature development and testing
  • Analytics and usage insights
  • Security monitoring and fraud prevention
  • Internal research and system improvements

6.3 Communication

  • Service updates and notifications
  • Customer support and grievance handling
  • Feedback and surveys
  • Transaction confirmations and OTPs
  • Compliance with laws and court orders
  • Audits, investigations, and regulatory requests
  • Enforcement of legal rights

6.5 Other Purposes

  • Any other purpose for which you provide specific consent

8. Withdrawal of Consent

You may withdraw your consent by:

  • Accessing Privacy Settings within the The Way Home app, or
  • Writing to us at info@thewayhome.app

Upon withdrawal, we will stop processing the relevant personal data unless retention is required by law.

9. Sharing of Personal Data

We do not sell your personal data.

We may share personal data with:

9.1 Group Entities

For internal operations and service delivery, on a need-to-know basis.

9.2 Service Providers and Partners

Including:

  • Cloud hosting providers
  • Payment processors
  • Analytics and security vendors
  • Customer support and infrastructure providers

All such entities are contractually required to protect your data.

Where required by law, court order, or to respond to medical emergencies threatening life or health.

9.4 Public Disclosure by You

Where you voluntarily make information public through the Platform.

10. Cookies and Tracking Technologies

We use cookies, SDKs, and similar technologies to:

  • Enable core functionality
  • Remember preferences
  • Analyse usage and improve services

Third-party analytics and advertising cookies may be used, subject to your choices.

Entities using cookies: [■ REQUIRED INPUT – list entities and purposes]

You may manage cookies through browser or device settings.

11. Data Retention

We retain personal data only as long as necessary for the purposes stated above.

Indicative retention periods:

  • Account data: until account deletion + [■ REQUIRED INPUT]
  • Financial records: [■ REQUIRED INPUT – statutory period]
  • Support communications: [■ REQUIRED INPUT]
  • Security logs: [■ REQUIRED INPUT]

Where deletion is requested, data may be retained if required for legal or safety reasons.

12. Data Security

We implement reasonable technical and organisational safeguards to protect personal data, including:

  • Encryption
  • Access controls
  • Monitoring and incident response procedures

13. Personal Data Breach

In the event of a personal data breach, we will:

  • Notify the Data Protection Board of India, where required
  • Inform affected Data Principals, as applicable

14. Children and Persons with Disability

  • The Platform is intended for individuals 18 years and above
  • Personal data of children is processed only with verifiable parental or guardian consent
  • We do not engage in targeted advertising or profiling of children

15. Your Rights as a Data Principal

You may:

  • Request access to a summary of your personal data
  • Request correction or updating of inaccurate data
  • Request erasure of personal data
  • Withdraw consent
  • Nominate another person to exercise your rights in case of death or incapacity

Requests can be made through [■ REQUIRED INPUT – rights request mechanism].

16. Grievance Redressal

Grievance Officer:

Name: Prashant Katiyar

Email: 📧 info@thewayhome.app

Phone: 📞 +91 99300 00170

If you are not satisfied with our response, you may have the right to escalate the matter to the Data Protection Board of India in accordance with applicable law.

17. Cross-Border Data Transfers

Your personal data may be processed or stored outside India, subject to applicable law and safeguards.

Primary hosting regions: [■ REQUIRED INPUT]

18. Changes to This Policy

We may update this Policy from time to time. Material changes will be communicated through the Platform. Continued use of the Platform constitutes acceptance of the updated Policy.

Annexure A – Data Retention Schedule

The Way Home | DPDP Act, 2023

Assumed Technical Architecture (for transparency)

This annexure assumes the following (adjust if needed):

  • Auth: Firebase Authentication
  • App DB: Firebase Firestore / Realtime DB
  • Files & documents: AWS S3 (private buckets)
  • Payments: Razorpay / Stripe-like PSP
  • Analytics: Firebase Analytics + Mixpanel
  • Logs & monitoring: AWS CloudWatch
  • Backups: Automated daily backups (30–90 day lifecycle)

1. General Retention Rules (Applied Globally)

  • Active users: Data retained while account is active
  • Account deletion:
    • Soft delete → 30 days
    • Hard delete → after 30 days
  • Backups: Overwritten within 90 days
  • Anonymised analytics: Retained indefinitely

2. Data Retention Table

Data Category Storage Location Retention Period Post-Deletion
Profile & Account Data Firebase Auth + Firestore While account active 30 days soft delete, then permanent
Uploaded Documents AWS S3 While account active 30 days, then permanent deletion
Financial Records Firestore + S3 7 years (statutory) Retained even post-deletion
Payment Transactions PSP (Razorpay) + Firestore 7 years Retained for compliance
Support Communications Firestore / Email 3 years Deleted unless legal hold
Usage Analytics Firebase Analytics, Mixpanel 14 months (raw), indefinite (anonymised) Anonymised retained
Security Logs AWS CloudWatch 1 year Auto-deleted after 1 year
Session Data Firebase Auth 30 days inactive Auto-purged
Backups AWS S3 Glacier 90 days rolling Overwritten automatically

3. Cross-Border Data Storage

Safeguard: No storage in restricted jurisdictions

4. Exceptional Retention (Overrides)

Data may be retained beyond stated periods if required for:

  • Legal proceedings
  • Regulatory investigation
  • Fraud / abuse investigation
  • Enforcement of contractual rights

Such data is:

  • Access-restricted
  • Logged
  • Reviewed periodically

5. Deletion & Anonymisation Workflow (Operational)

  1. User triggers Delete Account
  2. Account enters 30-day cooling-off
  3. After 30 days:
    • Firestore records deleted
    • S3 objects permanently removed
    • Auth account destroyed
    • Backups overwritten within 90 days
    • Analytics anonymised

6. Review Cycle

  • Reviewed annually
  • Updated on:
    • Feature changes
    • Infrastructure changes
    • DPBI guidance