1. Scope & Multi-Tenant Operating Architecture
ImpactFlow ("ImpactFlow", "Platform", "we", "us") operates an enterprise multi-tenant operating system designed for Non-Governmental Organizations (NGOs), Section 8 non-profit companies, public charitable trusts, Farmer Producer Organizations (FPOs), Corporate CSR entities, and accredited Chartered Accountant (CA) audit firms.
This Privacy Policy describes our mandatory data collection, cryptographic verification, processing, retention, and deletion practices across our central domains (impactflow.site, hub.impactflow.site) and tenant NGO portals ({tenant}.impactflow.site).
2. Statutory Grounding & Governing Laws
All personal data processing, cryptographic hashing, and certificate generation executed by ImpactFlow is legally grounded in specific statutory mandates under Indian and international public compliance frameworks:
- Digital Personal Data Protection Act (DPDP Act, 2023) — Sections 4, 6, 7 & 8: Transparent purpose specification, explicit verifiable consent, and robust technical measures.
- Income Tax Act, 1961 — Sections 12A, 80G(5)(vi), 139A, and Rule 18AB: Mandatory collection of donor PAN/Govt ID for 80G deductions and annual filing of Form 10BD with the CBDT.
- Foreign Contribution (Regulation) Act, 2010 (FCRA) & 2020 Amendments — Section 17: Regulatory mandate requiring foreign remittances to route exclusively through the State Bank of India (SBI) New Delhi Main Branch (NDMB) account.
- Information Technology Act, 2000 & 2021 Intermediary Rules — Sections 43A and 72A: Implementation of reasonable security practices and procedures for sensitive personal data.
- Aadhaar (Targeted Delivery of Financial and Other Subsidies, Benefits and Services) Act, 2016 — Regulations governing authorized OTP e-KYC without local plain-text UID storage.
- International Standards: EU/UK General Data Protection Regulation (GDPR / UK DPA 2018) and US 501(c)(3) Internal Revenue Code rules for international multi-jurisdiction tenants.
3. Categories of Data Collected & Purpose of Processing
We do not collect unnecessary data. Every field collected is tied to an explicit statutory requirement:
| Stakeholder Persona | Data Points Collected | Statutory Purpose |
|---|---|---|
| Individual & Institutional Donors | Name, Email, Mobile, PAN (mandatory > ₹50,000), Address, Donation Amount, Payment Reference (UPI / UTR). | Issuance of valid Section 80G tax receipts and generation of the statutory Form 10BD statement filed with the Income Tax Department. |
| NGO Trustees & Authorized Signatories | Legal Name, Designation, Official Email, Phone, PAN, Trust Deed/Registration Number, 80G/12A URNs, FCRA Registration, Bank Details. | Identity verification to prevent ghost NGOs, automated digital signature affixation on tax certificates, and verification of Section 12A exemption status. |
| Corporate CSR Donors | Company Name, Corporate Identity Number (CIN), Corporate PAN, CSR Committee Signatories, Milestone Allocations. | Bilateral CSR Grant Agreement execution under Companies Act 2013 Section 135 and Schedule VII statutory utilization reporting. |
| Chartered Accountants & Auditors | CA Name, ICAI Firm Registration Number (FRN), Membership Number, Official Audit Review Sign-Off Logs. | Statutory audit trail governance, independent sign-off verification, and export packaging for Tally and Zoho Books reconciliation. |
4. DigiLocker & Ephemeral Aadhaar/PAN Verification
During organization onboarding, authorized signatories may authenticate via Government of India DigiLocker / API Setu services. ImpactFlow operates a Zero-Plaintext-UID Architecture:
- No Plaintext Aadhaar Storage: The platform never stores full 12-digit Aadhaar numbers in databases, logs, or cache. Only masked representations (
XXXX-XXXX-1234) are recorded. - Ephemeral OTP Verification: OTPs and biometric vectors are processed exclusively by UIDAI / DigiLocker endpoints and never touch or reside on ImpactFlow server disks.
- Cryptographic Consent Artefact: Each verification creates an immutable, timestamped consent receipt containing the signatory's name, verification timestamp, scope, and SHA-256 digest.
5. Statutory 8-Year Retention Mandate
Under the Income Tax Act, 1961 (Section 149) and FCRA Rules, charitable trusts and non-profit institutions are legally obligated to maintain complete books of accounts, donation registers, donor identity records, and bank statements for a statutory period of not less than eight (8) assessment years.
6. Cryptographic Hash Anchoring & Public Trust Engine
ImpactFlow computes a deterministic SHA-256 cryptographic hash for every issued donation receipt, Form 10BD batch, and auditor sign-off. These hashes are aggregated into Merkle trees and anchored to immutable public ledgers.
Zero PII Exposure on Chain: Only the irreversible mathematical hash (digest) is anchored. Neither donor names, PANs, addresses, nor donation amounts are ever published to the public blockchain, ensuring total privacy alongside verifiable mathematical immutability.
8. Data Principal Rights (DPDP Act, 2023)
All individuals whose data is processed within ImpactFlow possess the following statutory rights under the DPDP Act 2023:
9. Grievance Redressal Officer & Statutory Contact
In compliance with Section 10 of the DPDP Act 2023 and the Information Technology (Intermediary Guidelines) Rules, the designated Data Protection & Grievance Officer for ImpactFlow is:
Meera Iyer, Lead Grievance & Compliance Officer
Entity: ImpactFlow Technologies Private Limited
Address: Compliance & Governance Wing, Cyber City, DLF Phase 2, Gurugram, Haryana 122002, India
Direct Email: dpo@impactflow.in / grievance@impactflow.in
Statutory Response SLA: Formal acknowledgment within 48 hours; complete resolution within thirty (30) calendar days.