VROWTH

Draft, not yet reviewed by counsel. This text describes what the platform does today and is being finalised. Items in [square brackets] are still to be filled in.

Privacy notice

Draft version 0.1, last updated 20 October 2026.

1. Who we are

VROWTH is operated by [LEGAL ENTITY NAME], [REGISTERED ADDRESS], India (“we”, “us”). You can reach us at support@vrowth.in. Our grievance officer is [NAME], [EMAIL ADDRESS], [PHONE].

2. Whose data, and our role

VROWTH is software sold to agencies (“franchises”), who use it for their own clients. We therefore handle three kinds of people’s data:

3. What we collect

4. Cookies

We set only the cookies needed to sign you in and to connect accounts: your session (two cookies), the sign-in link check, and short-lived (about ten minutes) cookies while you connect Instagram or Google Calendar. We do not use advertising or third-party analytics cookies.

5. Why we use it

To provide the service you or your agency signed up for, to bill and issue invoices, to keep the platform secure, and to meet legal duties such as tax record keeping. Where the law requires consent we ask for it, and you can withdraw it. [Counsel to set out the legal bases.]

6. Who we share it with

We use these service providers to run the platform:

When an AI or media feature is switched on we may also send the relevant text, audio or video to: DeepSeek, Zhipu AI, Alibaba Cloud (language and vision models); Groq (transcription); ElevenLabs (voice); D-ID and fal.ai (avatar and video); Pexels (stock footage); and Apify (collecting public Reels). We keep this list current. Some of these providers are outside India, so personal data may be transferred abroad. [Counsel to confirm the transfer wording and the processor agreements.]

We do not sell personal data. An agency may export a list of the email addresses of people who engaged with a client, to use in that client’s own advertising. The agency is responsible for telling those people and for honouring objections.

7. How long we keep it

DataKept for
Leads and contactsThe agency sets 30 to 3,650 days; the default is 730 days
Automation runs that were sent30 to 365 days, set by the agency
Skipped or failed automation runs, and markers of deleted records30 days
Unpaid, abandoned orders7 days
Public Reels collected by Discover180 days since last seen
Records of calls to AI providers400 days
Security counters (rate limiting)About 2 days
Orders, invoices and payment recordsAs long as tax and accounting law requires; they are not erased on request
Consent records for voice and faceKept as evidence, including after a consent is withdrawn [counsel to confirm the period]

8. Your rights

You can ask to see, correct or erase your personal data, to withdraw consent, or to complain. Contact the agency or business you dealt with, or write to support@vrowth.in. An agency can erase a lead from its records, export a copy of a client’s data, and erase the personal data of all of a client’s customers; orders, invoices and payment records are kept (section 7). If you connected Instagram, you can also remove our access in Instagram, which sends us a deletion request. We aim to answer within [30] days. [Counsel to confirm the response times and any rights under the Digital Personal Data Protection Act, 2023.] You may also complain to the Data Protection Board of India once it is operating.

9. Security

Instagram and Google tokens, payment-account credentials and private media are encrypted with a key kept outside the database. Each agency’s data is separated from every other agency’s at the database level. Every payment webhook is signature-checked before it is processed, and reads of stored credentials are logged. No system is perfectly secure; if there is a breach that affects you we will tell you as the law requires.

10. Children

VROWTH is for businesses and is not meant for anyone under 18. [Counsel to confirm.]

11. Changes

We will update this notice when the platform changes and show the new date at the top.