Draft for review. Highlighted items are details FWC must confirm. This text has not yet been reviewed by a lawyer.
1. In short
- We collect what you give us to run a professional network and marketplace, plus the minimum technical data needed to keep it secure.
- We do not sell your personal data, show you advertising, or use third-party analytics or advertising trackers.
- Your messages are visible only to the people in the conversation. Identity documents and seller applications are seen only by FWC's review team.
- You can see and correct your data, ask us to delete it, and complain to our Grievance Officer or the Data Protection Board of India.
2. Who we are
[Legal entity name] ("FWC", "we", "us"), [registered address], operates fwc.network and is the Data Fiduciary for the personal data described here. This policy forms part of our Terms of Service.
3. What we collect
Information you give us
| When | What |
|---|---|
| Creating an account | First and last name, email address and password. The password is stored only as a salted bcrypt hash, never in readable form. Optionally, headline and industry. |
| Your profile | Photo, cover image, headline, about, location, industry, website, skills and experience, as you choose to add them. |
| Using the network | Posts, comments, likes, reposts, saved posts, articles, connection requests, follows, chapter memberships, event RSVPs, program enrolments and investor requests. |
| Messaging | The messages you send and when they were read. |
| Business Pages | Page details you enter, such as name, logo, industry, website and description. |
| Buying | Cart, wishlist, orders, "Get Best Price" enquiries, reviews, and saved delivery addresses (name, phone number, address and PIN code). We record the payment method you chose, but we never receive card, UPI or bank credentials. |
| Selling | Seller application: business name, business type, phone, email, address, city, state, PIN code and GSTIN. Also your listings and your replies to enquiries. |
| Verification | Legal name, document type and a copy of the document you upload. See section 4. |
| Safety | Reports you make and members you block. |
Information collected automatically
- Session cookie to keep you signed in (see section 8).
- IP address, used to limit repeated sign-in and password-reset attempts. It is stored with each password-reset request and appears in our server logs.
- Post impressions: which members saw a post, at most once per member per day. The author sees only the total count, never who viewed it.
- Business Page visits: counted with a one-way scrambled code made from the visitor's IP address, browser and date, so the page owner sees a visitor count but cannot identify anyone.
Information from others
- Google sign-in: if you choose it, Google shares your name, email address and profile photo with us.
- Other members may mention you, message you, report you or place orders with you.
4. Verification documents
Identity documents (such as a passport, driving licence or national ID) and seller applications are optional. You only share them to get verified or to sell.
- We use them only to review your request and to investigate fraud.
- They are never shown on your profile or to other members. Only FWC reviewers are given access to them.
- Do not upload an Aadhaar number in full. If a document shows it, mask all but the last four digits first.
- The uploaded document is deleted as soon as a reviewer approves or rejects your request. We keep only the outcome, your legal name and the document type, as a record of the decision.
5. How we use your data
- To run FWC: create your account, show your profile and posts, deliver messages, process Marketplace orders and enquiries between buyers and sellers, and run Business Pages, chapters, events and programs.
- To send you emails the service needs: confirming your address, resetting your password, and notices about your account, orders and content. We do not send marketing email without your consent.
- To keep FWC safe: prevent abuse, fraud and account takeover, review reports, verify members and sellers, and enforce our Terms.
- To meet legal obligations: tax and consumer-protection records, and lawful requests from authorities.
We process your data with your consent, which you give when you create an account and when you choose to add information. We also rely on the "legitimate uses" the DPDP Act allows, such as complying with the law. You can withdraw consent at any time (see section 11). Withdrawing does not affect processing that happened before, and some features cannot work without the data they need.
6. Who can see what
| Data | Visible to |
|---|---|
| Profile, posts, comments | Signed-in FWC members. Members you have blocked, or who have blocked you, cannot see your posts. |
| Business Pages, chapters, events, published articles | Anyone, including visitors who are not signed in. |
| Messages | Only the members in the conversation. |
| Saved posts, blocks, reports you make | Only you (and FWC moderators, for reports). |
| Order and delivery details | You and the seller of that order. |
| Enquiries | You and the seller you asked. |
| Post impressions, page analytics | Totals only: the post author or the page owner. |
| Seller applications, identity documents | Only authorised FWC reviewers. |
| Email address | Not shown on your profile. It is visible to FWC administrators and, for moderation, alongside reports about you. |
FWC staff access personal data only as their role requires. We do not read your messages, except to investigate a report, protect someone's safety or security, or comply with the law.
9. How long we keep it
- Account and profile data: while your account is open.
- Sign-in sessions: expire after 7 days.
- Password-reset links: expire after 60 minutes. Email-confirmation links: expire after 48 hours.
- Deleted accounts: we delete your profile, posts, comments, connections, saved items and uploads within [30] days of a verified request. Messages you sent are deleted with it.
- Orders and seller records: kept for [8 years] where tax or consumer-protection law requires, then deleted.
- Backups: [describe the backups actually in use, e.g. "database backups made by our hosting provider are kept for up to [N] days", and say that deleted data disappears from them within that time].
- Server logs: [90 days].
10. Security
We protect your data with HTTPS encryption in transit, bcrypt password hashing, session cookies that page scripts cannot read, rate limits on sign-in and password reset, signing you out of other devices when you change your password, access limited by role[, and regular backups]. No system is perfectly secure. If a breach affects your personal data, we will tell you and the Data Protection Board of India as the DPDP Act requires.
11. Your rights
Under the Digital Personal Data Protection Act, 2023, you can:
- Access: ask what personal data we hold about you, how we use it, and who we have shared it with.
- Correct and update: edit your profile at any time, or ask us to correct anything you cannot edit yourself.
- Erase: ask us to delete your account and personal data, except where the law requires us to keep it.
- Withdraw consent: as easily as you gave it, by deleting information or closing your account.
- Nominate: name someone to exercise these rights for you if you die or become incapacitated.
- Grievance redressal: complain to our Grievance Officer (section 15). If you are not satisfied with the response, you can complain to the Data Protection Board of India.
To use any of these rights, email [privacy@fwc.network] from the email address on your account. We may ask you to confirm your identity, and we respond within [30] days.
12. Children
FWC is for people aged 18 and over. We do not knowingly collect data from children. If you believe a child has created an account, tell us and we will delete it.
13. Where your data is stored
Your data is stored on servers located in [country / region of the Hostinger data centre]. Where it is processed outside India, we do so only as Indian law permits, and under safeguards that protect it as this policy describes.
14. Changes to this policy
We update this policy when our practices or the law change, and revise the "Last updated" date above. For significant changes, we notify you on FWC or by email before they take effect.
15. Contact and grievances
[Name], Grievance Officer
[Legal entity name], [registered address]
Email: [grievance@fwc.network] ยท Phone: [+91 phone]
We acknowledge complaints within 24 hours and resolve them within 15 days. For privacy requests, write to [privacy@fwc.network].