Privacy Policy

Humble Progress

Operated by Humble Solutions Pvt Ltd · India

Effective:June 28, 2026 Version:1.0
Grievance Officer Humble Solutions Privacy Team · executives@humblesolutions.in · +91 9588561910

01Scope and Applicability

This Privacy Policy ('Policy') governs the collection, use, storage, disclosure, and deletion of personal data by Humble Solutions Pvt Ltd ('Company', 'we', 'our', or 'us') in connection with the Humble Progress mobile application ('App'). Humble Progress is a secure, internal, role-gated web application with two main modules: a Finance Module and a Project Module.

This Policy applies to all users of the Humble Progress App, regardless of the device or operating system used. By creating an account or using the App, you ('User', 'Data Principal') acknowledge that you have read, understood, and agree to this Policy. If you do not agree, you must discontinue use of the App immediately.

This Policy does not apply to: (a) third-party websites or applications that may be linked from within the App; (b) data that has been irreversibly anonymised and cannot identify any individual.

02Definitions

Data Fiduciary / Data Controller: Humble Solutions Pvt Ltd, the entity that determines the purpose and means of processing personal data. References to 'Data Controller' are used interchangeably with 'Data Fiduciary' as defined under the Digital Personal Data Protection Act, 2023 ('DPDPA').
Data Processor: Any third party that processes personal data on behalf of the Company under a written agreement, including Google LLC (Firebase) and Apple Inc. (APNs).
Data Principal / User: The natural person to whom the personal data relates, i.e., the registered user of the Humble Progress App.
Personal Data: Any data about an individual who is identifiable by or in relation to such data, as defined under the DPDPA.
Processing: Any operation performed on personal data, including collection, recording, storage, retrieval, use, sharing, disclosure, deletion, or destruction.
Consent: A freely given, specific, informed, and unambiguous indication of the Data Principal's agreement to the processing of their personal data.

Certain categories of personal data such as email may require enhanced protection due to their nature. While the Digital Personal Data Protection Act, 2023 does not classify 'sensitive personal data' separately, we apply higher safeguards to such data as a matter of policy.

03Identity and Contact Details of the Data Fiduciary

Company Name: Humble Solutions Pvt Ltd
Country of Operation: India
Grievance Officer / Privacy Contact: Humble Solutions Privacy Team
Phone: +91 9588561910

The Grievance Officer is responsible for addressing all data protection queries, access requests, correction requests, deletion requests, and complaints. All requests must be submitted in writing to the email address above. We will acknowledge receipt within 72 hours and respond substantively within 30 days of receipt, or sooner where required by applicable law.

04Personal Data We Collect

We collect only the minimum personal data necessary to operate the App and deliver our services.

4.1 Data You Provide Directly

Email (Mandatory): Collected during sign-up to create and authenticate your account. Lawful basis: contractual necessity (the account cannot function without it).

4.2 Data Collected Automatically

Photos / Media, Microphone, Camera: Accessed for chatting features within the App. Lawful basis: consent, which may be withdrawn at any time by disabling access in device settings.
Push Notification Token (FCM / APNs): Generated by your device when you permit notifications. Stored on our servers solely to deliver notifications. This token is never shared with third parties for commercial, marketing, or advertising purposes. Lawful basis: consent, revocable via device notification settings.

4.3 Data We Do Not Collect

We explicitly confirm that we do not collect:

  • Payment card numbers, bank account details, or UPI credentials;
  • Government-issued identification including Aadhaar, PAN, or passport numbers;
  • Biometric data of any kind;
  • Contents of your contact list, photo library, files, or any other device storage;
  • Browsing history, cookies, or data from other applications;
  • Any data for advertising, cross-app tracking, or profiling.

05Lawful Basis for Processing

For each category of personal data we process, the applicable lawful basis under the DPDPA is set out below.

Contractual Necessity: Email. Processing is required to provide the service you have requested and to fulfil the account creation and authentication.
Consent: Photos / Media, Microphone, Camera, Push Notification Token. You provide explicit consent at the point of collection. Consent may be withdrawn at any time without affecting processing conducted prior to withdrawal.
Operational Necessity: Device metadata, anonymised usage analytics. Processing is necessary for diagnosing technical issues, ensuring platform security, and improving App performance. This does not override your fundamental rights and freedoms.
Legal Obligation: Any data processed in response to a valid order from a court, tribunal, or regulatory authority under applicable Indian law.
Where consent is the lawful basis, you have the right to withdraw consent at any time. Withdrawal will not affect the lawfulness of processing conducted prior to withdrawal, nor will it affect processing conducted on a separate lawful basis such as contractual necessity.

06How We Use Your Personal Data

We use personal data only for the purposes described in this Policy and do not use it for any other purpose without obtaining fresh consent or having a separate lawful basis.

Account Authentication: Your email is used exclusively to verify your identity and maintain secure access to your account.
Chatting Features: Photos / Media, Microphone, and Camera access are used to facilitate communication within the App.
Notifications: Your push notification token is used to deliver real-time updates and alerts relevant to your use of the App.
Customer Support and Dispute Resolution: Your email is used to process support requests, complaints, and data rights requests.
Product Analytics: Anonymised usage data is used to identify areas for improvement and make informed product decisions.
Legal and Regulatory Compliance: Personal data may be processed where required to comply with applicable Indian law, to respond to valid legal process, or to protect the rights, safety, or property of the Company or its users.

07Disclosure and Sharing of Personal Data

We do not sell, rent, lease, or trade your personal data. We share data only in the following strictly defined circumstances.

7.1 Data Processors (Third-Party Technology Providers)

We engage the following Data Processors who process your data strictly on our instructions under binding data processing agreements. Each provider is governed by their own privacy policy, links to which are provided below.

Firebase Authentication (Google LLC): User authentication and session management. Processes email and authentication tokens. Privacy Policy: policies.google.com/privacy
Firebase Firestore (Google LLC): Cloud database storing account and profile data. Processes email and related records. Privacy Policy: policies.google.com/privacy
Firebase Cloud Messaging (Google LLC): Push notification delivery on Android. Processes FCM device token. Privacy Policy: policies.google.com/privacy
Apple Push Notification Service (Apple Inc.): Push notification delivery on iOS. Processes APNs device token. Privacy Policy: apple.com/legal/privacy

Certain core functionalities of the App depend on third-party infrastructure, including Google Firebase. We are not responsible for outages, disruptions, or failures attributable to such third-party services. Where a disruption is caused by a third-party provider, our liability is limited to the extent permitted by applicable law.

7.2 Cross-Border Data Transfers

Google Firebase infrastructure operates on Google Cloud servers located globally, including in the United States and the European Union. By using the App, you acknowledge that your personal data may be transferred to, stored in, and processed in countries outside India. All such transfers are governed by Google's Data Processing Addendum, which incorporates Standard Contractual Clauses and complies with applicable data protection laws including DPDPA requirements for international transfers.

We will not transfer your personal data to any country or jurisdiction specifically restricted by the Government of India pursuant to DPDPA Section 16 or any subsequent government notification.

7.3 Legal Disclosure

We may disclose your personal data to government authorities, regulatory bodies, courts, or law enforcement agencies where we are legally required to do so under applicable Indian law. We will, where permitted by law, notify you before complying with any such request.

7.4 Business Restructuring

In the event of a merger, acquisition, restructuring, or sale of all or substantially all of our assets, your personal data may be transferred to the acquiring or surviving entity. We will notify you via a prominent in-app notice at least 30 days prior to any such transfer. The acquiring entity will be required to honour the commitments in this Policy or obtain your fresh consent before applying a materially different policy.

08Data Storage and Security

All personal data is stored on Google Firebase Firestore, a cloud database service operated by Google Cloud. Data is encrypted in transit using TLS 1.2 or higher and encrypted at rest using AES-256 encryption, consistent with industry standards.

We implement and maintain the following technical and organisational security measures:

No method of transmission over the internet or method of electronic storage is completely secure. While we apply commercially reasonable security measures, we cannot guarantee absolute security against all threats. In the event of a personal data breach that is likely to result in harm to Data Principals, we will notify the Data Protection Board of India and affected users in accordance with DPDPA Section 8(6) within the timeframe prescribed by law.

09Push Notifications

We deliver push notifications exclusively for transactional events relevant to your use of the App. We do not send promotional, marketing, or unsolicited commercial notifications. You may disable push notifications at any time via your device Notification Settings. Disabling notifications will not affect your ability to access App features.

10Data Retention

We retain personal data only for the period necessary to fulfil the purpose for which it was collected, or as required by applicable law. The following retention schedule applies.

Email and authentication data: Retained for the duration of the active account. Deleted upon account deletion.
Photos / Media, Microphone, Camera access: Access is session-based and not stored. Revocation of access is immediate.
Push notification tokens: Refreshed automatically by the device. Expired tokens deleted within 30 days. Deleted upon account deletion or revocation of notification permission.
Anonymised usage analytics: Retained indefinitely. This data is non-identifiable and cannot be linked to any individual.
Data held under legal obligation: Retained as required by applicable Indian law. Deleted upon expiry of the legal retention period.

Upon expiry of a retention period, data is permanently and securely deleted from our systems. We do not retain personal data beyond the periods specified above except where compelled by a valid legal obligation.

11Account and Data Deletion

You may permanently delete your Humble Progress account and all associated personal data at any time. The deletion process is as follows:

  1. Open the App and navigate to the Profile tab.
  2. Scroll to the bottom of the profile screen and tap 'Delete Account'.
  3. Review the two-step confirmation prompt disclosing what will be deleted.
  4. Verify your identity by entering the OTP sent to your registered email.
  5. Upon successful verification, your deletion request is submitted.

Within 30 days of a confirmed deletion request, all personal data associated with your account (including email and device tokens) will be permanently and irrecoverably deleted from our active systems. Backups are purged in the next scheduled backup rotation cycle, which occurs within 60 days.

Anonymised, aggregated data derived from your usage that cannot be attributed to you individually may be retained beyond this period for analytical purposes.

If you are unable to complete in-app account deletion due to a technical issue, you may request deletion by contacting us at executives@humblesolutions.in. We will process such requests within 30 days of receipt of a verifiable request.

12Children's Privacy

The Humble Progress App is not intended for use by individuals under the age of 18 years. In accordance with the Digital Personal Data Protection Act, 2023 (Section 9), we do not knowingly collect personal data from any individual below the age of 18 without verifiable parental or guardian consent.

By using the App, you represent that you are at least 18 years of age, or that you are using the App under the supervision of a parent or legal guardian who has reviewed and consented to this Policy on your behalf.

We do not intentionally collect personal data from children and rely on user declarations during account creation. If we become aware that an individual under the age of 18 has created an account without appropriate parental consent, we will immediately suspend the account, delete all associated personal data, and, where appropriate, notify the parent or guardian if contact information is available.

Parents or guardians who believe their minor child has registered on the App should contact us immediately at executives@humblesolutions.in. We will take action within 72 hours of receiving a verifiable report.

13Your Rights as a Data Principal

Under the Digital Personal Data Protection Act, 2023, you have the following rights with respect to your personal data.

Right to Information (Section 11): You have the right to request a summary of the personal data we hold about you and the processing activities conducted on that data.
Right to Correction (Section 12): You have the right to correct inaccurate or incomplete personal data. Email may be updated directly in the App under Profile Settings.
Right to Erasure (Section 12): You have the right to delete your personal data using the in-app deletion flow described in Section 11, or by submitting a written request to executives@humblesolutions.in.
Right to Grievance Redressal (Section 13): You have the right to lodge a complaint with the Grievance Officer (details in Section 3) if you believe your data is being processed unlawfully. If you are not satisfied with our response, you may escalate your complaint to the Data Protection Board of India.
Right to Withdraw Consent: You may withdraw consent for optional data fields (Photos / Media, Microphone, Camera) by disabling access in device settings, and for push notifications through your device system settings, at any time.
Right to Data Portability: You may request a copy of your personal data in a structured, commonly used, machine-readable format (JSON or CSV) by submitting a written request to executives@humblesolutions.in. We will fulfil such requests within 30 days.
Right to Nominate (Section 14): You have the right to nominate another individual to exercise your data rights in the event of your death or incapacity. Nomination requests must be submitted in writing to executives@humblesolutions.in.
To exercise any of the above rights, write to us at executives@humblesolutions.in or call +91 9588561910. We will acknowledge your request within 72 hours and respond substantively within 30 days of receipt.

14Cookies and Tracking Technologies

The Humble Progress mobile application does not use browser cookies. We do not employ cross-app tracking, advertising identifiers (including Apple's IDFA or Google's GAID), or any form of behavioural advertising. We do not participate in data broker ecosystems or interest-based advertising networks.

15App Store and Play Store Data Practices Disclosure

15.1 Apple App Store (Privacy Nutrition Label)

Data Used to Track You: None. Humble Progress does not use any data to track you across apps or websites owned by other companies. We do not use any third-party SDKs for advertising, analytics tracking across apps, or user profiling.
Data Linked to You: Email (authentication), Photos / Media, Microphone, Camera (app functionality).
Data Not Linked to You: Device metadata, anonymised usage analytics.
Optional Data: Photos / Media, Microphone, Camera (provided with consent and not linked to your identity for tracking purposes).

15.2 Google Play Store (Data Safety)

Data Collected: Email, Photos / Media, Microphone, Camera, device info, FCM token.
Data Shared with Third Parties: Profile data stored via Google Firebase (Data Processor).
Security Practices: Data encrypted in transit and at rest. Users may request deletion of their data.
Advertising: No data is collected or used for advertising or marketing purposes.

16Platform Status, Limitation of Liability, and User Obligations

16.1 Intermediary Status

Humble Solutions Pvt Ltd operates Humble Progress solely as a technology intermediary platform under applicable Indian law, including the Information Technology Act, 2000, and the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021. The Company does not provide services directly, does not employ staff for services, and is not a party to any service contract between users and third parties. Humble Solutions acts solely as an intermediary platform and does not control, supervise, or guarantee the services provided by third parties.

16.2 Disclaimer of Warranties

To the maximum extent permitted by applicable Indian law, Humble Solutions Pvt Ltd disclaims all warranties, express or implied, including any implied warranty of merchantability, fitness for a particular purpose, or non-infringement. The App and all services accessible through it are provided on an 'as available' basis without guarantee of uninterrupted access, error-free performance, or complete accuracy of information.

16.3 Limitation of Liability

To the maximum extent permitted by applicable Indian law, Humble Solutions Pvt Ltd shall not be liable to any user for any direct, indirect, incidental, special, consequential, or punitive damages arising from: (a) the quality, safety, or outcome of any service accessed through the App; (b) a third party's failure to honour, confirm, or fulfil a service; (c) personal injury, property damage, or financial loss arising from a user's engagement with a third party; (d) fraudulent or unauthorised use of the App arising from the user's failure to protect their credentials or device; (e) disruptions, outages, or data loss attributable to Firebase infrastructure or other third-party services; or (f) inaccuracies in information provided by third parties displayed in the App.

16.4 Account Suspension Rights

We reserve the right to suspend, restrict, or permanently terminate user accounts, without prior notice, in cases of suspected fraud, misuse, platform abuse, repeated violations, or violation of this Policy or any applicable law. The Company shall not be liable for any loss suffered by a user as a result of account suspension carried out under this provision.

16.5 User Indemnity

You agree to indemnify and hold harmless Humble Solutions Pvt Ltd, its directors, employees, contractors, and affiliates from any claims, damages, losses, costs, and liabilities (including legal fees) arising out of your misuse of the App, violation of this Policy, breach of applicable law, or any activity conducted through your account.

17Governing Law and Jurisdiction

This Policy is governed by and construed in accordance with the laws of India, including the Digital Personal Data Protection Act, 2023, the Information Technology Act, 2000, the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021, and any regulations or notifications issued thereunder.

Any dispute, claim, or controversy arising out of or in connection with this Policy shall be subject to the exclusive jurisdiction of the competent courts located in India. Users who access the App from outside India do so at their own risk and are responsible for compliance with the laws of their jurisdiction.

18Changes to This Privacy Policy

We reserve the right to update or modify this Policy at any time to reflect changes in our data practices, applicable law, or App functionality. Material changes are defined as changes that affect the nature of data collected, the purpose of processing, the categories of data shared with third parties, or user rights.

When we make material changes, we will: (a) update the 'Effective Date' and 'Version' at the top of this Policy; (b) notify all active users via a prominent in-app notice upon their next App launch; and (c) where required by law, seek fresh consent before processing data under the updated terms.

Non-material changes (such as typographical corrections or clarifications) will be updated silently with a revised date. Your continued use of the App following the effective date of any update constitutes your acceptance of the revised Policy. If you do not agree to the changes, you must delete your account and discontinue use of the App prior to the effective date of the change.

19Contact and Grievance Redressal

For all privacy-related queries, data access requests, correction requests, deletion requests, withdrawal of consent, or complaints, please contact our Grievance Officer:

Grievance Officer

OfficerHumble Solutions Privacy Team
Phone+91 9588561910
CompanyHumble Solutions Pvt Ltd, India

We will acknowledge receipt of your request within 72 hours and will provide a substantive response within 30 days. If you are dissatisfied with our response or believe your data has been processed in violation of the DPDPA, you may escalate your complaint to the Data Protection Board of India once constituted and operational under the DPDPA.