Privacy Policy

Hindi summary available. Yeh dastaavez English me legally valid hai. Hindi summary ke liye grievance@digitaliiisla.co.in par likhein — 72 ghante me PDF bhej denge.

1. Who we are

This Privacy Policy describes how Digitaliiisla Technologies Private Limited (“Digitaliiisla”, “we”, “us”) collects, uses, discloses, retains and protects personal data in connection with the DigiSurvey application and the Digitaliiisla website (together, the “Service”). This policy is our notice under section 5 of the Digital Personal Data Protection Act, 2023 (“DPDPA”) and is read with the Information Technology Act 2000 and the rules thereunder.

2. The personal data we collect

We collect only what is necessary for the Service. In DPDPA language, each category below has a defined purpose and a legal basis; both are stated in Section 4.

2.1 Surveyor profile data

• Name, email, mobile number, password (hashed with bcrypt / argon2 — never stored in plain text).
• IRDAI licence number, licence category, firm name, firm registration, GSTIN, PAN (business), bank account details for payouts.
• Postal address, service areas, specimen signature, profile photo, specimen letterhead.

2.2 Survey & claim data (uploaded by the surveyor)

• Insured’s name, contact, policy number, claim number, vehicle registration, chassis / engine, odometer, place of loss, date of loss.
• Photographs captured on-site, which may contain vehicle number plates, VIN plates, damage close-ups, odometer face, driving licence and RC images, cheque leaves and policy copies.
• Video recordings of live inspection calls (initiated by the surveyor; not retained by default once the report is finalised).
• GPS co-ordinates and camera timestamp embedded in photo EXIF when the surveyor’s device grants location permission.
• Assessment figures, parts list, repair / replace recommendation, salvage value, and the final signed PDF.

2.3 Transactional & usage data

• Payment metadata via Razorpay (order ID, transaction ID, payer email, invoice amount, GST breakdown). We do not see or store the full card number, CVV, UPI PIN, or any bank-password equivalent.
• Access logs: IP address, browser user-agent, time of request, URL path, HTTP status — used for abuse prevention and audit.
• Device identifiers for the mobile app (install ID; no advertising ID is collected).

2.4 What we never collect

• Credit / debit card numbers, CVV, UPI PIN, net-banking passwords.
• Biometric templates for identity (we store a photograph you upload; we do not generate a face-print).
• Marketing cookies, advertising identifiers, social-media “like” pixels, or third-party ad network trackers.
• Data of minors — the Service is strictly for adult IRDAI-licensed surveyors and professional insurer users.

3. Why we collect each category

Category	Purpose
Surveyor profile	Account creation, authentication, invoice generation, IRDAI-compliance evidence, payout settlement.
Survey photos & OCR data	Report preparation, number-plate & document extraction (OCR), damage detection, insurer delivery.
Insured contact	Appointment scheduling, insured sign-off collection, policy-copy verification.
Payment metadata	Billing, tax invoice, GST filing, dispute resolution with the payment gateway.
Access logs	Security monitoring, forensic investigation of suspected abuse, DPDPA breach forensics.
Device identifier	Push notifications, offline-queue stability, device-level revocation on account deletion.

4. Legal basis under the DPDPA 2023

Each processing activity rests on at least one of the DPDPA grounds:

• Consent (s. 6) — obtained at sign-up through a clear, unbundled checkbox. Covers: surveyor profile, marketing emails (opt-in only), optional analytics.
• Legitimate use — performance of contract (s. 7(b)) — the Service you subscribed to cannot run without processing your survey data. Covers: survey storage, OCR, report delivery.
• Legitimate use — employment / professional engagement (s. 7(i)) — where an insurer appoints the surveyor and the processing is incidental to that appointment.
• Compliance with law (s. 7(d)) — IRDAI (Insurance Surveyors and Loss Assessors) Regulations retention, income-tax audit retention, lawful court / regulator orders.
• Response to medical / public-interest emergencies (s. 7(f)–(g)) — location data of an insured may be used strictly for emergency medical response during a live inspection; invoked only on written request.

We do not rely on any blanket “legitimate interest” ground beyond what the DPDPA permits, and we do not process the personal data of children (persons under 18) for any purpose.

5. Who processes your data (sub-processors)

We never sell your data. The only third parties that touch it are the sub-processors we contract with to run the Service. Each operates under a written Data Processing Addendum (DPA) and may not use the data for any purpose outside our instructions. The current list is on /legal/subprocessors.html and is reproduced here:

Sub-processor	Role	Region	Certifications
Supabase	Primary database (Postgres), authentication, object storage.	India (ap-south-1 — Mumbai)	SOC 2 Type II, ISO 27001 (platform)
Cloudflare	CDN, DNS, DDoS protection, Workers (edge routing), WAF.	Global edge; Indian POPs serve Indian traffic	SOC 2 Type II, ISO 27001, PCI DSS
Cloudflare R2	Hot-tier object storage for edge-cached media.	Global object store with APAC + India POP delivery	SOC 2 Type II, ISO 27001, ISO 27018
AWS S3 Mumbai (ap-south-1)	Encrypted archival storage, tier 2 (India-resident copy for IRDAI 7-year audit tail).	India (ap-south-1, Mumbai)	SOC 1/2/3, ISO 27001/27017/27018, PCI DSS, HIPAA
Google Gemini AI	OCR & vision inference on uploaded photos only (number plate, RC, DL). Photo bytes transit a Google data centre (which may be outside India) for the duration of a single inference call, typically under 2 seconds. Google is contractually prohibited from retaining or training on the content under the Google Workspace DPA.	Google India & US data centres under Google’s DPA (Standard Contractual Clauses)	SOC 1/2/3, ISO 27001, ISO 27701
Resend	Transactional email (sign-up, password reset, invoice). No survey content ever transmitted.	EU & US (DPA with SCCs)	SOC 2 Type II
Zoho Campaigns	Marketing email (opt-in only; one-click unsubscribe).	India datacentre (Chennai)	SOC 2 Type II, ISO 27001
Backblaze B2	Backblaze B2 — ciphertext stored in eu-central and us-west dual-region; decryption passphrase held only by Digitaliiisla, so Backblaze cannot read content.	eu-central & us-west dual-region (ciphertext only)	SOC 2 Type II, ISO 27001
Razorpay	Payment gateway (card / UPI / netbanking). PCI-DSS tokenisation; we never see the card number.	India	PCI DSS Level 1, ISO 27001

If we add or replace any sub-processor we publish the change on /legal/subprocessors.html at least 14 days before engagement. Enterprise customers under a signed DPA may object and terminate in that window.

6. Transfers of personal data outside India

Primary data (surveyor accounts, survey records, photos, videos, assessment PDFs) is stored on servers physically located in India (Mumbai, ap-south-1). Limited categories cross the border only through the sub-processors shown above:

• Google Gemini AI may process a photo in a Google data centre outside India for inference; the photo is not retained by Google beyond the inference call under the Enterprise DPA.
• Resend relays transactional email through EU / US infrastructure. Only the email body (template + first name + link) is transmitted — never survey content.
• Backblaze B2 encrypted blobs: the ciphertext is replicated across regions; the decryption passphrase is held only by Digitaliiisla.

All cross-border transfers are backed by Standard Contractual Clauses with the respective sub-processor. The Central Government’s notified list under DPDPA s. 16 is not yet published at the date of this policy; we will update this section as and when it is.

7. Our zero-commercial-use pledge

8. Retention schedule

We keep data only as long as needed and then delete it on an automated schedule. The full table is at /legal/data-retention.html. Headline numbers:

• Final survey reports, photos, assessment PDFs — 7 years from report delivery (IRDAI Surveyors Regulations 2015, reg. 13; Companies Act books-of-account retention). Then automated deletion from live storage and from Backblaze backups.
• Account & profile data — until deletion requested, plus a 12-month grace window for billing dispute resolution, then purged.
• Payment metadata & tax invoices — 8 years (Income-tax Act s. 44AA requirement for professionals).
• Access & audit logs — 18 months rolling.
• Marketing email list — until unsubscribe (one-click; immediate).
• Deleted-row shadow log — 7 years (immutable DB-side audit trigger that records who deleted what, used only for restore & forensic purposes; not shared).

9. Your rights as a Data Principal (DPDPA 2023)

Under Chapter III of the DPDPA you have the following rights, exercisable free of charge up to once per quarter:

• Right to information & access (s. 11) — a human-readable summary of the personal data we hold about you and the identities of the Data Fiduciaries / Processors with whom it has been shared.
• Right to correction, completion, update, erasure (s. 12) — we will correct inaccuracies or erase data no longer necessary for the stated purpose. Erasure requests are fulfilled within 30 days unless a legal retention obligation delays it (we will say which obligation and until when).
• Right of grievance redressal (s. 13) — raise a grievance with our Grievance Officer below. If unresolved in 72 hours, you may complain to the Data Protection Board of India.
• Right to nominate (s. 14) — nominate another individual to exercise these rights in the event of your death or incapacity. Email the Grievance Officer with the nominee’s name, relationship and government ID to register.
• Right to withdraw consent (s. 6(4)) — as easy as giving it. Does not affect processing already done, nor data retained under a legal basis other than consent.
• Right to data portability — export your surveys, reports, photos and account data as a ZIP in standard formats (JSON for records, original filenames for media) from Account → Export my data.

To exercise any right, email grievance@digitaliiisla.co.in from your registered email. We will verify your identity (one-time code to your registered email + mobile) and respond within 72 hours for acknowledgement and 30 days for substantive fulfilment.

10. Grievance Officer

If our response is unsatisfactory, you may approach the Data Protection Board of India under section 27 of the DPDPA (board address will be published by MeitY in the Official Gazette).

11. Cookies & tracking

We use session-only, first-party cookies to keep you signed in and to protect against CSRF. We do not deploy advertising, retargeting, analytics-profiling, or social-widget cookies. Our site works with third-party cookies blocked. A full inventory:

Cookie	Purpose	Lifespan
sb-access-token / sb-refresh-token	Supabase authentication session	Session + 7-day refresh
__cf_bm, cf_clearance	Cloudflare bot mitigation (strictly necessary)	30 minutes / session
__diisla_pref	Theme / language toggle (local preference)	12 months

12. Children’s data

The Service is for adult IRDAI-licensed surveyors and professional insurer / loss-assessor users only. We do not knowingly process personal data of persons under 18 (per DPDPA 2023 s.2(f)). If we learn that we have inadvertently done so, we delete the data without delay. Under DPDPA s. 9 we do not undertake behavioural monitoring or targeted advertising directed at children.

13. Breach notification

In the event of a “Personal Data Breach” as defined in DPDPA s. 2(u):

• Affected users are notified within 72 hours of detection with the facts of the breach, likely impact and the remediation steps they should take.
• The Data Protection Board of India is notified in the form and timeline prescribed under the Rules (presently 72 hours; subject to the final Rules notified by MeitY).
• Insurer customers under a DPA are notified within 24 hours as a stricter contractual obligation.

Our full Breach Notification SOP is at /legal/breach-notification.html.

14. Changes to this policy

Material changes are published on this page with a new “Last updated” date and summarised in a changelog at the top. Users receiving the Service continuously are notified by email 15 days before a material change takes effect. Prior versions remain accessible at /privacy.html and in version-controlled form in our git history.

15. Governing law

This policy is governed by the laws of India. Any dispute arising out of or in connection with this policy is subject to the exclusive jurisdiction of the courts at Jaipur / Jhunjhunu, Rajasthan, without prejudice to a Data Principal’s statutory right to approach the Data Protection Board of India.

16. Contact

General privacy queries: support@digitaliiisla.co.in
DPDPA rights & grievances: grievance@digitaliiisla.co.in
Phone: +91 83026 98307
Postal: Digitaliiisla Technologies Private Limited, Khemi Sati Road, Jhunjhunu, Rajasthan – 333001, India.