1. Our two roles
We process personal data in two distinct capacities. For data about your firm and its users (account holders), we are the data fiduciary. For data about your clients that you upload or generate while using the platform ("Customer Data"), you are the data fiduciary and we act as your data processor — we handle that data only to provide the service and on your instructions.
2. Data we collect
- Account data — name, email, phone, firm name, ARN, role, and authentication data (passwords are stored only as salted hashes).
- Customer Data you provide — investor/lead profiles, contact details, KYC-related fields, transactions, communications, and documents you upload.
- Usage data — log data, device/browser information, and actions taken in the platform, used for security and to operate the service.
- Payment data — handled by our payment processor; we receive subscription status and limited transaction metadata, not full card details.
3. How we use data
- To provide, secure, and operate the platform and its messaging, automation, and compliance features.
- To process subscriptions, billing, and invoicing.
- To provide support, send service notices, and respond to grievances.
- To detect, prevent, and investigate fraud, abuse, and security incidents.
- To comply with legal, regulatory, and tax obligations.
We do not sell personal data. We do not use your clients' Customer Data for our own marketing.
4. Legal basis and consent
We process account data to perform our contract with you and for our legitimate and legal interests in running the service. For Customer Data, you are responsible for obtaining the consent and lawful basis required from your clients (including under the DPDP Act and TRAI/DLT messaging norms) before uploading their data or messaging them through the platform.
5. Sub-processors
We use carefully selected third parties to deliver parts of the service. Each is bound to appropriate confidentiality and security obligations:
- Amazon Web Services (AWS) — Application hosting, database & encrypted file storage (Mumbai (ap-south-1), India).
- Resend — Transactional & campaign email delivery (United States / EU).
- Vartify — WhatsApp Business messaging (BSP) (India).
- MSG91 — DLT-compliant transactional SMS (India).
- Anthropic — AI assistance (message drafting & classification) (United States).
6. Data location and security
Application data and uploaded documents are hosted in India (AWS Mumbai region). We protect data with measures including encryption in transit, encryption at rest for sensitive secrets and documents, strict per-tenant database isolation (row-level security so one firm cannot access another's data), access controls, and audit logging. No method of transmission or storage is perfectly secure, but we work to protect your data and to notify affected parties of significant incidents as required by law.
7. Retention
We retain personal data for as long as your account is active and as needed to provide the service, comply with legal/regulatory obligations (including record-keeping norms applicable to distributors), resolve disputes, and enforce our agreements. On account closure you may export Customer Data for a reasonable period, after which we delete or anonymise it in line with our retention schedule.
8. Your rights
Subject to applicable law, individuals may request access to, correction of, or erasure of their personal data, and may withdraw consent. If you are a client of an MFD using Freedom LifeX, please direct your request to that MFD (the fiduciary for your data); we will assist them as their processor. For data we hold as fiduciary, contact our Grievance Officer below.
9. Cookies
We use strictly necessary cookies to keep you signed in and to secure the platform. We do not use advertising cookies.
10. Grievance Officer
In accordance with the DPDP Act and applicable IT rules, you may contact our Grievance Officer for any privacy concern or to exercise your rights:
- Grievance Officer — grievance@freedomlifex.in
- FreedomLifeX, India
11. Changes
We may update this Policy from time to time. Material changes will be notified through the platform or by email, and the "Last updated" date above will change.
12. Contact
General privacy questions: support@freedomlifex.in.