Privacy policy
Last updated:
This policy explains how [Company legal name] ("Zero One Creation", "we"), [Registered address], India, handles personal data in ZOC Campaign. It is written to meet the EU and UK General Data Protection Regulation (GDPR) and India's Digital Personal Data Protection Act, 2023 (DPDP Act).
1. Our two roles
- Processor for your contacts. When you upload contacts and send campaigns, you (our customer) decide why and how that data is used. You are the controller (the "data fiduciary" under the DPDP Act) and we process it only on your instructions. Contacts who want to exercise their rights should contact the sender; we will help the sender respond.
- Controller for account data. For people who sign up, sign in, pay or contact us, we decide how the data is used and are responsible for it.
2. Data we process
- Account data: name, email address, workspace and role, sign-in and security records.
- Billing data: billing name and address, GSTIN, invoices and payment status. Card details are handled by Razorpay, not stored by us.
- Customer contact data (as processor): email addresses and any fields you upload, plus consent and unsubscribe records.
- Delivery and engagement events: sends, deliveries, bounces, complaints, opens and clicks, including IP address and user agent where available.
- Technical data: logs and, if enabled, error reports needed to run and secure the service.
3. Why we use account data
- To provide the service you signed up for (contract).
- To bill you and keep tax records (legal obligation).
- To secure the service, prevent abuse and protect deliverability (legitimate interests).
- To send product updates you have opted into (consent; you can withdraw at any time).
Under the DPDP Act we rely on your consent or on the legitimate uses the Act allows.
4. Where data is stored
Application data is stored in PostgreSQL and event analytics in ClickHouse, hosted in India (AWS ap-south-1, Mumbai) unless stated otherwise below. Where data is transferred outside India or the EEA we rely on lawful transfer mechanisms such as standard contractual clauses.
5. Sub-processors
We use these service providers to run ZOC Campaign:
| Provider | Purpose | Location |
|---|---|---|
| Amazon Web Services | Email sending (SES), file storage (S3) and application hosting | India (ap-south-1, Mumbai) |
| Razorpay | Payment processing | India |
| Vercel | Web application hosting | [Region] |
| Sentry | Error monitoring (only if enabled) | [Region] |
We will give notice of new sub-processors at least [number] days before they start processing.
6. Retention
We keep data only as long as we need it. A daily job deletes data when its period ends:
| Data | How long | What happens then |
|---|---|---|
| Contacts who unsubscribed, hard-bounced or reported an email as spam | 30 days after the unsubscribe, bounce or complaint | Name, email address and other details are erased. Only a one-way code (a keyed hash) of the address stays on the do-not-email list, so the person is never emailed again. |
| Send, delivery, open and click records | 25 months after the event | Deleted automatically. These records hold contact ids, never names or email addresses. |
| Mail in the shared mailbox (received mail, replies and attachments) | While the organization's account is active | Kept while the organization's account is active. Deleted when a user deletes it, or with the rest of the organization's data 90 days after the organization is deleted. |
| Uploaded import files, import error reports and contact export files | 30 days after the upload or export | The files are deleted from storage. The import or export record (counts and status) stays. |
| Activity log (who did what, and when) | 24 months after the action | Deleted. |
| Processing and security logs kept by us | At least 1 year after the log entry | Kept for at least one year (DPDP Rules 2025, rule 8(3)); never deleted earlier. Logs hold no names or email addresses. |
| Invoices, wallet transactions and cost estimates | At least 8 years after the end of the financial year | Kept for at least eight years for tax law, even after an organization is deleted. Never deleted earlier. |
| Everything else an organization stored, after the organization is deleted | 90 days after the deletion | Contacts, lists, templates, campaigns, automations, domains, mailbox, files and reports are purged. Billing records and the activity log follow their own periods. |
- Account data: while your account is active, then deleted within [number] days of closure.
- Other customer contact data: until you delete it or your organization is deleted.
- Do-not-email records (unsubscribes, hard bounces, complaints): kept permanently, as a one-way code of the address only, so we never email those addresses again on your behalf.
7. Your rights
Depending on where you live, you can ask us to:
- access the personal data we hold about you, or receive a copy of it;
- correct, complete or update it;
- erase it, or restrict or object to its use;
- withdraw consent at any time, without affecting earlier processing;
- nominate another person to exercise your rights (DPDP Act).
You can also complain to your data protection authority or the Data Protection Board of India. Write to [Privacy email]; we reply within the time the law requires.
8. Security
We use encryption in transit, access controls, workspace isolation and monitoring. We will notify affected customers and authorities of a personal data breach as the law requires.
9. Children
ZOC Campaign is for businesses and is not intended for anyone under 18.
10. Grievance officer
Under the DPDP Act and the Information Technology Act, 2000, you can contact our grievance officer: [Grievance officer name], [Registered address], email grievance@example.com.
11. Changes
We will post updates here and change the date above. Material changes will be notified in the app.