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Overview & Corporate Scope
This Privacy Policy (“Policy”) outlines how Kamal Intellect Private Limited (operating the KAMALO brand and the website located at https://kamalo.app, along with its mobile applications, Single Sign-On services, and rewards ecosystem; collectively, the “Platform”) collects, stores, processes, uses, and safeguards personal data provided by visitors, waitlist applicants, registered users, and merchant partners.
We design our data collection and protection architectures in strict compliance with the Digital Personal Data Protection Act, 2023 (“DPDPA”), the Information Technology Act, 2000, and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (“SPDI Rules”).
By accessing the KAMALO Platform, submitting your mobile number to join our launch waitlist, or enrolling in our services, you expressly consent to the practices described in this Policy.
Categories of Information We Collect
To deliver a secure, seamless, and rewarding experience, we collect specific categories of personal information provided by you or generated automatically during your interactions:
A. Waitlist Information
When joining the launch list, we collect your 10-digit mobile telephone number, referral invite code, submission timestamp, and approximate geographical region.
B. Profile & Identity Data
Upon full account registration: Legal name, date of birth, gender, residential address, verified email address, and mobile number.
C. KYC & Statutory Financial Data
For reward disbursements and statutory compliance: Permanent Account Number (PAN), masked Aadhaar data, Voter ID / Driving License / Passport copies, and bank verification details (account number, IFSC, cancelled cheque).
D. Transaction & Referral Telemetry
Transaction amount, merchant category, referral lineage graph (Direct and Indirect Referees across 5 levels), Hold Account balances, and Tax Deducted at Source (TDS) filings.
E. Device, Hardware & Telemetry Data
Internet Protocol (IP) address, operating system, device hardware model, International Mobile Station Equipment Identity (IMEI) or unique device identifier, telecom network provider, emulator detection signals, crash diagnostics, and session security tokens.
Purpose & Legal Grounds for Processing
We process your personal information strictly for lawful, legitimate, and specified purposes, including:
- Service Delivery & Account Management: Administering your waitlist access, Single Sign-On (SSOID) authentication, and maintaining your profile.
- Rewards, Clearing & Payouts: Calculating cashback, tracking 5-tier referral commissions between Hold, Under Clearing, and Commission accounts, and routing bank transfers.
- Statutory Compliance: Complying with Reserve Bank of India (RBI) directions, Prevention of Money Laundering Act, 2002 (PMLA), and Income Tax Act obligations (including mandatory TDS deductions on referral earnings).
- Fraud Detection & Device Integrity: Identifying automated bots, Android/iOS emulators, multi-SIM farming, synthetic identities, and preventing financial crime.
- Service Communications: Dispatching essential one-time passwords (OTPs), transaction alerts, security notices, and customer support responses.
- Personalized Offers: Providing relevant merchant rewards and platform updates, subject to your right to opt out of promotional messages.
Data Security Standards & Infrastructure
Kamal Intellect Private Limited implements rigorous technical and organizational security measures in compliance with ISO/IEC 27001 standards and the Information Technology (SPDI) Rules, 2011:
- Transit Encryption: All data transmitted to and from kamalo.app is encrypted using Transport Layer Security (TLS 1.3).
- Storage Encryption: Sensitive personal information, KYC indices, and financial identifiers are secured using AES-256 encryption.
- Cardholder Protection: Payment card credentials (CVV, card PIN) are never stored on KAMALO servers and are tokenized via RBI-mandated frameworks.
- Access Controls: Strict role-based employee access, multi-factor authentication, and automated intrusion detection monitoring.
Data Retention & Disposal Schedules
We retain personal data only for as long as necessary to fulfill the purposes for which it was collected, or to satisfy statutory, legal, accounting, and tax compliance requirements:
- Waitlist Information: Retained until the public launch of KAMALO or until you request its deletion.
- Active User Accounts: Maintained throughout your active membership tenure on the Platform.
- Statutory Financial & KYC Records: In accordance with the Prevention of Money Laundering Act and Indian tax regulations, KYC documentation and transaction ledger entries are retained for a minimum period of five (5) to eight (8) years following account termination or transaction closure.
Your Rights Under the Digital Personal Data Protection Act
As a Data Principal under the DPDP Act, 2023, you hold specific statutory rights:
Right of Access
Request a summary of your personal data processed by us and the identities of data processors with whom it has been shared.
Right to Correction & Updating
Request correction, completion, or updating of inaccurate or outdated personal records in your account profile.
Right to Erasure & Withdrawal
Withdraw your consent and request deletion of personal information, subject to mandatory statutory retention rules.
Right to Nominate
Designate another individual to exercise your privacy rights in the event of death or physical/mental incapacity.
Opt-Out & Promotional Communication Preferences
We provide all users with the opportunity to opt out of receiving promotional and marketing communications:
- To unsubscribe from promotional emails, click the “Unsubscribe” link located in the footer of any marketing email.
- To opt out of promotional SMS or push notifications, adjust your notification settings in your device preferences or email hello@kamalo.app.
- Note: Essential service communications (such as security OTPs, transactional receipts, legal updates, and fraud notifications) are mandatory and cannot be opted out of while maintaining an active account.
Support & Contact Details
If you have questions, concerns, or requests regarding our privacy practices, data handling, or wish to exercise your statutory rights under the DPDP Act, you may contact our dedicated Support and Redressal team:
Data Fiduciary
Kamal Intellect Private Limited
Platform: KAMALO (kamalo.app)
Jurisdiction & Corporate Seat
Mumbai, Maharashtra, India
Support Officer
Privacy & Customer Support Cell
Official Support Email
support@kamalo.appGeneral Inquiries
hello@kamalo.appPursuant to applicable Indian law, your support request will be acknowledged within 48 hours of receipt and addressed within thirty (30) days from the date of submission.