Draft for review. This document has not yet been approved by legal counsel. Highlighted items in brackets are placeholders for company details that are still being confirmed.
Last updated: [To be confirmed: publication date]
1. Who we are
GrowthX is operated by [To be confirmed: registered company name], registered at [To be confirmed: registered office address] (“GrowthX”, “we”). This policy explains what personal information we collect through our website, customer portal and partner portal, and how we use it.
2. Information we collect
- Account details: your name, email address, password and, if you give it, your business name.
- Subscription and billing details: the apps and plans you choose, invoices and payment status. Payments are entered in our payment provider's checkout; we do not see or store full card numbers or UPI PINs.
- Messages you send us: for example through the contact form or support requests.
- Sales partner details: if you join as a sales partner, the details needed to track referrals and pay commission, such as [To be confirmed: payout details collected (e.g. bank account, PAN)].
- Usage information: how the website is used, collected through Google Analytics only if you accept analytics cookies.
3. How we use it
- To create and run your account, set up your apps and provide support.
- To bill your subscription, send invoices and process payments through our payment provider.
- To credit the sales partner who referred you and calculate their commission.
- To send service messages, such as trial reminders, invoices and payment notices.
- To understand and improve the website, when you have agreed to analytics.
- To meet legal, tax and accounting obligations.
4. Your consent
We process your personal information on the basis of the consent you give when you create an account, send us a message, book a call or accept analytics cookies, and for the purposes listed above only. Where the law allows us to process data without consent, for example to meet a legal obligation, we do so only for that purpose.
You can withdraw your consent at any time, as easily as you gave it: email [To be confirmed: privacy contact email], or for analytics, clear this site's data in your browser. Withdrawing consent does not affect processing already done. If you withdraw consent we need to run your account, we may have to close it.
7. Data in your business apps
Information you and your staff enter into your GrowthX apps (for example your customers, orders and bookings) belongs to your business. We process it only to provide the service to you, and you can export it at any time, including after you cancel.
8. How long we keep it
We keep account and billing records for as long as your account is open and afterwards for [To be confirmed: retention periods (account data, invoices for tax law, app data after cancellation)].
9. Your rights
Under India's Digital Personal Data Protection Act, 2023 (as its provisions come into effect), you have the right to:
- Get a summary of the personal information we hold about you, what we do with it, and who we have shared it with.
- Have inaccurate or incomplete information corrected, completed or updated.
- Have your information erased when it is no longer needed for the purpose you gave it for, unless the law requires us to keep it.
- Withdraw your consent, as described above.
- Nominate another person to use these rights for you if you die or become unable to act.
- Have your grievances resolved by our Grievance Officer (see below).
To use any of these rights, contact us using the details below. We reply within [To be confirmed: response time for data requests and grievances]. If you are not satisfied with our answer, you can complain to the Data Protection Board of India.
10. Children
GrowthX is a service for businesses and is not meant for anyone under 18. We do not knowingly collect personal information from children. If you believe a child has given us their information, contact us and we will delete it.
11. Security
We use encrypted connections, access controls based on each person's role, and regular backups. No system is perfectly secure; if we become aware of a breach that affects you, we will notify you as the law requires.
12. Contact and grievance officer
Questions or requests about your personal information: [To be confirmed: privacy contact email]. Grievance Officer: [To be confirmed: grievance officer name], [To be confirmed: grievance officer email]. You can also reach us through the contact page.
13. Changes to this policy
We will post any changes on this page and update the date at the top. For significant changes, we will also notify account holders.