LEGAL DOCUMENT

Privacy Policy

Effective: 1 June 2025 Last Updated: 1 June 2025 DPDPA 2023 · IT Act 2000 · SPDI Rules 2011 Web · PWA · Android APK

Table of Contents

  1. About This Policy & Scope
  2. Who We Are — Data Fiduciary
  3. Definitions
  4. Personal Data We Collect
  5. Sensitive Personal Data (SPDI)
  6. PWA & APK Specific Data
  7. How We Collect Data
  8. Lawful Basis for Processing
  9. Consent — Collection, Use & Withdrawal
  10. Purpose Limitation
  11. How We Use Your Data
  12. Data Processors & Third Parties
  13. Cross-Border Data Transfers
  14. Data Storage & Security
  15. Security Incident & Breach Notification
  16. Data Retention
  17. Your Rights as a Data Principal
  18. Multi-Tenancy & Employer Data
  19. Children's Privacy
  20. Marketing Communications
  21. Cookies & Local Storage
  22. Data Protection Board of India
  23. Governing Law & Jurisdiction
  24. Changes to This Policy
  25. Grievance Officer

Plain English Summary: We collect only what we need to run your ERP account. Your data is stored securely in India (Mumbai, AWS ap-south-1). We do not sell, rent, or share your data with advertisers. You own your data at all times. You may request access, correction, or deletion at any time. This platform is a B2B SaaS service. Disputes go to the Data Protection Board of India after our internal grievance process.

01 —

About This Policy & Scope

This Privacy Policy ("Policy") describes how Servyn AI, a sole proprietorship owned and operated by Rahul Birwadkar, trading as Servyn AI, with its principal place of business at 4A B.D.D. Chawl, Naigaon, Dadar, Mumbai – 400014, Maharashtra, India ("we", "us", "our") collects, uses, stores, shares, and protects personal data.

This Policy applies to all personal data processed through:

This Policy applies to: company administrators, managers, HR personnel, accountants, field technicians, and any individual accessing the platform under a company subscription, as well as website visitors and trial users.

This Policy complies with:

Note for PWA / APK users: The Servyn AI mobile experience is delivered as a Progressive Web App (PWA) or an Android APK. It functions like a native app but operates through the browser engine. All data practices described in this Policy apply equally to the PWA and APK versions.

02 —

Who We Are — Data Fiduciary

Under the DPDPA 2023, Servyn AI is a Data Fiduciary — the entity that determines the purpose and means of processing your personal data.

In relation to the personal data of your customers and employees that you enter into the platform, you (the subscribing business) are also a Data Fiduciary, and Servyn AI acts as your Data Processor. This dual relationship is governed by our Data Processing Agreement (see Section 12).

RoleEntityResponsibility
Data Fiduciary (for platform account data)Servyn AI (Rahul Birwadkar)Determines purpose and means of processing your account, billing, and usage data
Data Processor (for your business data)Servyn AI (Rahul Birwadkar)Processes customer records, employee data, and financial records on your instructions
Data Fiduciary (for your employee/customer data)You (the subscribing company)Responsible for obtaining lawful consent from your employees and customers before entering their data into the platform
03 —

Definitions

TermMeaning
Personal DataAny data about an individual who is identifiable by or in relation to such data (DPDPA 2023 S.2(t))
Sensitive Personal Data (SPDI)Passwords; financial information (bank account, card details); physical, physiological, and mental health condition; sexual orientation; medical records; biometric data; and any detail relating to the above as defined under SPDI Rules 2011
Data PrincipalThe individual to whom the personal data relates (DPDPA 2023 S.2(j))
Data FiduciaryAny person who determines the purpose and means of processing personal data (DPDPA 2023 S.2(i))
Data ProcessorAny person who processes personal data on behalf of a Data Fiduciary (DPDPA 2023 S.2(k))
ProcessingWholly or partly automated operations on personal data including collection, recording, storage, use, disclosure, sharing, transfer, or deletion
ConsentFree, specific, informed, unconditional, and unambiguous indication of agreement (DPDPA 2023 S.6)
PlatformThe Servyn AI web application, PWA, and Android APK collectively
04 —

Personal Data We Collect

We collect the following categories of personal data:

A. Account & Registration Data

B. Business Operational Data (entered by you)

C. Employee Records (entered by company admin)

D. Financial & Tax Data

E. Usage & Technical Data

F. Communication Data

05 —

Sensitive Personal Data (SPDI)

The following categories of data collected through Servyn AI qualify as Sensitive Personal Data or Information (SPDI) under Rule 3 of the SPDI Rules, 2011, and attract heightened protection obligations:

Data TypeWhy It Is SPDIHow We Protect It
Aadhaar numbersGovernment identity number — Rule 3(iii) of SPDI Rules; Aadhaar Act 2016 restrictions applyEncrypted at rest (AES-256); displayed masked (XXXX-XXXX-1234); access restricted to company admin only
PAN numbersTax identity — financial information under Rule 3(ii)Encrypted at rest; access restricted to company admin; not logged in audit trails
Bank account numbers & IFSCFinancial information under Rule 3(ii)Encrypted at rest; masked in UI; never transmitted in plain text
Salary & payroll dataFinancial information under Rule 3(ii)Role-based access control — only admin and HR roles can view payroll; field technicians cannot access salary data of colleagues
PasswordsPasswords under Rule 3(i)Stored as bcrypt hash only — never plain text, never logged

⚠️ Aadhaar data — legal restriction: Under the Aadhaar (Targeted Delivery of Financial and Other Subsidies, Benefits and Services) Act, 2016, private entities are prohibited from collecting, using, or storing Aadhaar numbers unless specifically permitted by law. You must ensure you have a legitimate legal basis before entering Aadhaar numbers of your employees into the platform. Servyn AI stores this data only on your instruction as your Data Processor and is not responsible for unlawful collection by you.

For all SPDI, we comply with Rule 5 of the SPDI Rules, which requires:

06 —

PWA & APK Specific Data

The Servyn AI mobile experience is delivered as a Progressive Web App (PWA) and an Android APK. The following device-level data may be accessed:

Permission / FeatureData AccessedPurposeCan You Refuse?
CameraPhotographs taken by the technician (job site photos, completion photos)Attaching evidence photos to job recordsYes — camera is optional; photos can be uploaded from gallery instead
Storage / FilesRead/write access to download or upload documents and photosUploading customer documents, downloading invoicesYes — storage access is needed only for file upload/download features
Notifications (Push)Device push notification token (if push notifications are enabled in future)Job alerts, schedule reminders — not currently activeYes — notifications are opt-in only
Offline / Service WorkerCached job records and pending sync queue stored in IndexedDB on deviceOffline functionality — allows technicians to update jobs without internetYes — offline mode is optional but reduces functionality
Device InfoBrowser/OS version, screen size, device type (not device identifier)Technical support, compatibility testingAutomatic — collected via browser headers; no device ID stored

Servyn AI does not access: GPS location, contacts, microphone, call logs, SMS, or any other device sensor not listed above.

PWA vs native app: Because Servyn AI is a PWA/APK built on web technology, it does not access device APIs beyond what the browser permits. It is not distributed via Google Play Store and therefore Google's data safety form requirements do not apply unless a Play Store listing is created in the future.

07 —

How We Collect Data

We do not purchase, obtain, or receive personal data from data brokers, marketing lists, or any third party not listed in Section 12.

08 —

Lawful Basis for Processing

Under DPDPA 2023 S.4 and S.7, we process personal data only when:

Data CategoryLawful BasisApplicable Section
Account registration dataConsent (explicit agreement to Terms and Privacy Policy at signup)DPDPA 2023 S.6
Subscription and billing dataContractual necessity (performance of subscription contract)DPDPA 2023 S.7(a)
Employee payroll, Aadhaar, PANLegitimate use — compliance with Indian labour and tax law (IT Act, EPF Act, ESIC Act)DPDPA 2023 S.7(b)(ii)
Job/service records entered by companyContractual necessity — core ERP functionDPDPA 2023 S.7(a)
Technical/usage logsLegitimate interest — platform security and performanceDPDPA 2023 S.7(f)
Marketing communicationsConsent (separate opt-in)DPDPA 2023 S.6
Financial/GST recordsLegal obligation (CGST Act 2017, Income Tax Act 1961)DPDPA 2023 S.7(c)
09 —

Consent — Collection, Use & Withdrawal

Under DPDPA 2023 S.6, consent must be free, specific, informed, unconditional, and unambiguous. We implement consent as follows:

Withdrawal of Consent

You may withdraw consent at any time by:

Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal. Withdrawal may result in inability to use certain platform features.

⚠️ Your obligation as Data Fiduciary: When you enter personal data of your employees or customers into the platform, you are responsible for obtaining valid consent from those individuals as required by DPDPA 2023. Servyn AI processes that data as your Data Processor and is not responsible for your failure to obtain consent from your employees or customers.

10 —

Purpose Limitation

Under DPDPA 2023 S.8(3), personal data may only be used for the specified purpose for which it was collected. We do not use your data for any purpose beyond those stated below:

We never use your data for: advertising to third parties, profiling for sale, training AI models on your business data, or any purpose not listed above.

11 —

How We Use Your Data

12 —

Data Processors & Third Parties

Under DPDPA 2023 S.8(1), we only engage Data Processors who provide sufficient guarantees regarding data protection. Our current Data Processors are:

ProcessorRoleData SharedLocationDPA Status
Supabase Inc.Database, authentication, file storage (primary infrastructure)All platform data including SPDIAWS ap-south-1, Mumbai, IndiaDPA signed (supabase.com/legal/dpa)
Google LLC (Gmail / Workspace)Business email communicationsName, email, message content of support communicationsGoogle servers (may be outside India)Google Workspace Business Terms apply
Meta Platforms (WhatsApp Business)Customer communication channelName, phone number of contacts who initiate WhatsApp contactMeta servers (global)WhatsApp Business Policy applies
Payment Gateway (TBD)Subscription payment processingBilling name, amount — card data is never stored by Servyn AIIndia (RBI-regulated)DPA to be signed before integration

We do not share your personal data with any other third party without your explicit consent, except as required by Indian law.

We do not sell, rent, or trade your personal data to any third party for commercial purposes.

Data Processing Agreement with Customers

By accepting our Terms of Service, you enter into a Data Processing Agreement with Servyn AI. Under this agreement, Servyn AI as your Data Processor agrees to:

13 —

Cross-Border Data Transfers

The primary database is hosted on AWS ap-south-1 (Mumbai, India) via Supabase. Your ERP data does not leave India.

The following limited cross-border transfers may occur:

Under DPDPA 2023 S.16, the central government may notify certain countries/territories to which data transfer is restricted. We will update this section if any such notification affects our operations.

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Data Storage & Security

We implement the following security measures as required under Rule 8 of the SPDI Rules 2011 and DPDPA 2023 S.8(5):

Technical Measures

Organisational Measures

No method of transmission over the internet or electronic storage is 100% secure. We cannot guarantee absolute security. In the event of a breach, we will follow the notification procedure in Section 15.

15 —

Security Incident & Breach Notification

In the event of a personal data breach as defined under DPDPA 2023 S.8(6):

  1. Containment: We will immediately take steps to contain the breach and prevent further unauthorised access
  2. Internal assessment: We will assess the nature, scope, and likely consequences of the breach
  3. Notification to the Data Protection Board of India (DPBI): We will notify the DPBI within 72 hours of becoming aware of the breach (once DPBI is operational)
  4. Notification to affected customers: We will notify you (the company admin) within 24 hours of becoming aware of a breach affecting your company's data, via email and WhatsApp
  5. Notification to Data Principals: Where required by DPBI direction, we will notify individual Data Principals (your employees/customers) affected by the breach

The breach notification will include: the nature of the data affected, the likely consequences, the measures taken, and the contact details of our Grievance Officer.

16 —

Data Retention

We retain personal data only for as long as necessary for the stated purpose, as required under DPDPA 2023 S.8(7):

Data TypeRetention PeriodLegal Basis for Retention
Active subscription data (all ERP records)Duration of active subscription + 30 days post-cancellationContractual necessity
Trial account data7 days from trial endConsent
GST/tax invoice records5 years minimum from financial year endCGST Act 2017 — legal obligation (overrides deletion request)
Income tax related records7 years from relevant assessment yearIncome Tax Act 1961 — legal obligation
Payroll records (if under Companies Act)8 yearsCompanies Act 2013 — legal obligation
Support communications12 monthsLegitimate interest
Audit/security logs90 days rollingLegitimate interest — security
Database backups30-day rolling cycleLegitimate interest — disaster recovery

⚠️ Important — Financial record legal hold: Even after subscription cancellation and data deletion, Servyn AI may be required to retain financial transaction records (invoices, payment records) for 5–8 years as required by Indian tax and company law. These records will be retained in a minimal, secure archive and used only for legal compliance purposes. We will notify you of any such retention.

17 —

Your Rights as a Data Principal

Under DPDPA 2023 Chapter III, you have the following rights:

RightWhat It MeansHow to ExerciseResponse Time
Right to Access (S.11)Obtain a summary of your personal data being processed and the processing activitiesEmail with subject "Data Access Request"30 days
Right to Correction (S.12)Correct inaccurate or misleading personal data; complete incomplete dataEmail with subject "Data Correction Request"10 business days
Right to Erasure (S.12)Delete your personal data when the purpose is fulfilled or consent is withdrawn (subject to legal retention obligations)Email with subject "Data Deletion Request"10 business days
Right to Grievance Redressal (S.13)Have grievances addressed by the Grievance Officer within a reasonable timeEmail Grievance Officer — see Section 2530 days
Right to Nominate (S.14)Nominate another individual to exercise rights on your behalf in the event of death or incapacityEmail with subject "Nomination Request"10 business days
Right to Withdraw ConsentWithdraw consent at any time (see Section 9)Email or account settingsImmediate

To exercise any of the above rights, contact: founder@servynai.in

We may ask you to verify your identity before processing any rights request.

18 —

Multi-Tenancy & Employer Data

Servyn AI is a multi-tenant SaaS platform. Each subscribing company ("tenant") has a completely isolated data environment.

If you are an employee using the platform under your employer's subscription:

19 —

Children's Privacy

Servyn AI is a business-to-business (B2B) ERP platform intended for use by adults in a professional capacity. We do not knowingly collect personal data from individuals under the age of 18.

If you believe a minor has inadvertently provided personal data through the platform, please contact founder@servynai.in immediately and we will delete such data promptly.

Under DPDPA 2023 S.9, processing of personal data of children requires verifiable parental consent and is subject to additional restrictions. We do not process children's data in the ordinary course of business.

20 —

Marketing Communications

We may send you product updates, feature announcements, and occasional promotional communications only if you have explicitly opted in during registration or at any other time.

21 —

Cookies & Local Storage

The web application and PWA use the following storage mechanisms:

MechanismName / TypePurposeDuration
Cookieauth_tokenEncrypted session token (JWT) — keeps you logged in; httpOnly, cannot be read by JavaScript8 hours (standard) / 30 days (Remember Me)
Cookieactive_companyIdentifies which company account is active in multi-tenant context; httpOnlySession
Cookiecsrf_tokenCSRF attack prevention tokenSession
IndexedDB (PWA)offline_jobs_cacheCaches job records for offline access on the device; cleared on logoutUntil logout or data sync
Service Worker CacheApp shell assetsCaches app UI for offline loadingUntil PWA is uninstalled or cache cleared

We do not use advertising cookies, analytics cookies, or any third-party tracking cookies. See our separate Cookie Policy for full details.

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Data Protection Board of India — Your Right to Complain

Under DPDPA 2023 Section 13, if you have exhausted the internal grievance redressal process described in Section 25 and are not satisfied with our response, you have the right to file a complaint with the Data Protection Board of India (DPBI).

Data Protection Board of India (DPBI)
Website: www.dataprivacy.gov.in (once operational)
The DPBI will be established and complaints will be accepted once the Government of India notifies the relevant rules under DPDPA 2023.

The process for filing a complaint with the DPBI is:

  1. First raise the matter with our Grievance Officer (Section 25) and allow 30 days for resolution
  2. If unsatisfied, file a complaint with the DPBI via their online portal once operational
  3. The DPBI may inquire into the complaint and impose penalties on us if we are found to be in violation

You may also approach the Adjudicating Officer under the IT Act 2000 for claims relating to cybersecurity or unauthorised access to your data.

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Governing Law & Jurisdiction

This Privacy Policy shall be governed by and construed in accordance with the laws of the Republic of India. Any disputes arising from this Policy shall be subject to the exclusive jurisdiction of the courts at Mumbai, Maharashtra, India, subject to the arbitration provisions in our Terms of Service.

24 —

Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or legal obligations. When we make material changes:

We recommend reviewing this Policy periodically. The DPDPA 2023 implementation rules are still being notified by the Government of India; we will update this Policy as required when those rules come into effect.

25 —

Grievance Officer

In accordance with Rule 5(9) of the SPDI Rules 2011 and DPDPA 2023 S.13, Servyn AI has designated a Grievance Officer to address any complaints or concerns regarding the processing of personal data.

Grievance Officer — Servyn AI

Name: Rahul Birwadkar

Designation: Founder & Sole Proprietor, Servyn AI

📧 founder@servynai.in

📞 +91 97684 46498

📍 4A B.D.D. Chawl, Naigaon, Dadar, Mumbai – 400014, Maharashtra, India

Response time: Grievances will be acknowledged within 3 business days and resolved within 30 days of receipt.

Please include the following in your grievance: your name, email address registered with Servyn AI, description of the issue, and any supporting documentation.