How personal data is handled on CosmoOps Connect, under India's Digital Personal Data Protection Act, 2023.
Last updated 26 October 2026
CosmoOps Connect is a workspace platform. Applications built by us and by partners run on it. For the personal data processed on the platform, the platform operator named in the Grievance Officer section below is the Data Fiduciary, and a partner application running on Connect acts as a Data Processor on this notice.
If you reached a partner application and not Connect itself, this is still the notice that governs the data it processes through the platform. The partner may hold additional data of its own and will say so separately.
Not everyone whose data is here holds an account, and the difference matters for what we hold:
| If you are | We may process |
|---|---|
| An account holder | Name, email address, phone number, gender if you give it, profile photo, password credential, sign-in history, devices and browsers you sign in from, IP address and the approximate city it resolves to. |
| Running a workspace | Billing address, legal name, GSTIN, business type, payment instrument details held by our payment processor, invoices and payment history. |
| Completing identity or business verification | Legal name, a masked PAN, company identifiers, and the documents you upload - which may include a government photo ID such as Aadhaar, a passport, a voter ID or a driving licence. |
| Calling a number run on the platform | Your phone number, a recording of the call, a transcript of what was said, and facts extracted from the conversation such as your name, company or email address. |
| Booking an appointment or using a chat widget | Name, phone number, email address if given, anything you type into a notes field, and your IP address. |
| Buying from our shop | Name, email address, phone number, delivery address, order and payment history. |
We do not ask for your date of birth, and we do not build advertising profiles.
The Act allows processing on your consent (s.6) or for one of the certain legitimate uses listed in s.7. That list is closed - there is no general balancing test - so each purpose below names which applies.
| Purpose | Basis |
|---|---|
| Creating and running your account, workspace and subscriptions; signing you in; delivering the product you asked for. | Data voluntarily provided for the specified purpose (s.7(a)), and consent for anything beyond it. |
| Sending transactional messages: invoices, payment notices, verification links, sign-in codes, appointment confirmations and reminders. | s.7(a) - you gave the address or number for exactly this. |
| Answering calls with an AI agent, recording and transcribing them, and recording facts from the conversation. | Consent, given on the call before anything else is said. |
| Sending WhatsApp messages. | Consent, recorded against the number before any business-initiated message. |
| Identity and business verification, tax invoicing, and keeping statutory records. | Compliance with law (s.7(g)) - and for financial records, Indian tax and company law require them to be kept. |
| Detecting fraud, bots and suspicious sign-ins; keeping an audit trail. | s.7(a), and compliance with law for the audit trail. |
Where we rely on consent, you can withdraw it at any time and it is as easy to withdraw as it was to give. Withdrawing consent does not undo processing already carried out lawfully, and it may mean we can no longer provide part of the service.
We do not sell personal data. We share it with the processors below, who act on our instructions. Under s.11(b) you may ask us for this list and a description of what was shared with each - this is that list.
| Processor | What it does | What it receives | Where |
|---|---|---|---|
| Google Cloud Platform (Firestore, Cloud Storage, Realtime Database) | Primary data store and file storage for the platform. | account and profile data; workspace and billing records; uploaded files, including identity and business verification documents; call recordings and transcripts; contact records | India (asia-south1) |
| Google Identity Platform | Authentication - holds the credential itself. | email address; password credential; phone number; user identifier | Google-managed, multi-region |
| Vercel | Application hosting and compute. | every request payload in transit; IP address and approximate location derived from it; runtime logs | India (bom1) for functions |
| Amazon Web Services - Simple Email Service | Sending transactional email: invoices, verification links, notices, reminders. | email address; name; message content, including invoice details | As configured by AWS_SES_REGION |
| Amazon Web Services - End User Messaging Social, and Meta Platforms | Sending WhatsApp notifications. Meta is the messaging platform behind it. | phone number; name; appointment and invoice details carried as template parameters; one-time sign-in codes | AWS region of the WhatsApp Business Account; Meta processes globally |
| Plivo | Voice telephony - carries calls and records them before the audio is fetched here. | calling and called phone numbers; call audio | United States and Plivo's global carrier infrastructure |
| Google Cloud Vertex AI and Google AI Studio (Gemini) | The AI that answers calls, assists in the product, and extracts structured facts from a conversation. | live call audio; call transcripts; prompts and conversation content; documents uploaded for extraction; workspace and agent configuration | Vertex 'global' endpoint for text and vision; us-central1 for live audio and retrieval corpora. The native-audio live models are not offered in asia-south1. |
| Google BigQuery | The contact directory, product analytics and the audit trail, for search and investigation. | contact names, phone numbers and email addresses; actor email address and IP address on audited actions; product analytics events | United States by default. A BigQuery dataset's location is fixed at creation, so changing it means recreating the dataset. |
| Razorpay | Payment processing and recurring debits. | name; email address; phone number; GSTIN; payment instrument details held by Razorpay, never by us | India |
| Google reCAPTCHA Enterprise | Bot and fraud detection on sign-in, sign-up and payment. | a hashed account identifier; email address and card last four digits on payment risk checks; IP address and browser signals | Google-managed, multi-region |
| Composio | Holds the authorisation tokens for integrations a workspace connects, such as Gmail or Calendar. | third-party OAuth tokens; whatever an integration is asked to read or write on the workspace's behalf | United States |
| Google Cloud KMS | Encrypts the secrets a workspace gives its agents. | secret values in transit for encryption | As configured by AGENT_SECRET_KMS_KEY |
| Browser push services (Google, Mozilla, Apple) | Delivers web push notifications to a device that asked for them. | push endpoint identifier; notification content | Vendor-managed, global |
| Google Cloud Logging, Trace and Monitoring | Operational telemetry, and the 400-day audit trail. | actor identifier and email address; IP address on security-relevant actions; request traces | Cloud Logging bucket is 'global' |
| Endpoints a workspace configures itself | An agent skill may be pointed at an MCP server or an HTTP endpoint chosen by the workspace. Where that is configured, data flows to whoever operates it. | whatever the agent sends to that endpoint during a conversation | Determined by the workspace, not by the platform |
We also disclose personal data where the law requires it, and to a buyer if the business is sold - in which case this notice travels with it.
Our primary database, file storage and application servers are in India. Several processors above are not: AI processing of call audio, transcripts and prompts reaches Google in the United States and on Google's global endpoints, because the models we use are not offered in the Indian region; our contact directory, product analytics and audit trail are held in Google BigQuery datasets in the United States; and our telephony, integration and messaging providers process outside India.
Section 16 of the Act permits transfers to any country the Central Government has not restricted. None are currently restricted. We disclose these transfers here rather than describing everything as Indian, because the disclosure is the obligation.
We erase personal data once the purpose it was collected for is served. The periods below are the ones actually implemented.
| Data | Kept for |
|---|---|
| Sign-in sessions and device records | 30 days after they expire |
| An account you stop using entirely | 3 years from last sign-in, after notice to you first, then erased |
| Your account and its personal data when you delete it | Erased after a 30-day grace period during which you can cancel |
| A workspace and its contents when it is deleted | Erased after a 30-day grace period |
| Call and conversation transcripts | 365 days from the conversation, then erased automatically |
| Call recordings, contacts and bookings | For the life of the workspace that collected them, and erased when it is deleted |
| Identity and business verification documents (PAN, photo ID) | 90 days after the verification expires, then deleted automatically |
| The verification decision itself (status, date, reviewer) | Kept while the account exists, and erased when your account or the workspace is deleted |
| Invoices, payments and tax records | 8 financial years, because the Companies Act and the GST law require it. These are kept under a deleted workspace rather than erased with it. |
| Audit trail of security-relevant actions | 400 days |
| Website visitor sessions | 24 hours, and at most 7 days |
| Documents uploaded for onboarding extraction | 30 minutes |
| Email addresses that bounced or complained | Kept, so we do not keep mailing an address that cannot receive. Deleting it would resume the mail. |
You can ask us to:
Account holders can see and correct much of this directly under Profile, and delete the account there. For anything else - and for any request if you do not hold an account - write to the Grievance Officer below. We may need to verify who you are before acting, which is a protection for you rather than an obstacle.
Please note that the Act makes you responsible for the accuracy of what you give us, and for not raising frivolous or false complaints.
This platform is intended for business use by adults. You must be 18 or older to create an account, and we do not knowingly process the personal data of a child. We do not track children, monitor their behaviour, or direct advertising at them.
If you believe a child's personal data has reached us - for instance through a public booking form or a phone call - tell the Grievance Officer and we will erase it.
Access to the database is server-mediated only; no client can read or write it directly. Secrets a workspace gives its agents are encrypted with Google Cloud KMS. Every security-relevant action is written to an audit trail. Sign-ins are risk-assessed, and a new device or an unusual location triggers a one-time code. Access within the platform is governed by role-based permissions enforced on every request.
If a personal data breach occurs, we will tell you and the Data Protection Board as the Act requires.
If we change how we process personal data, we will update this page and change the date at the top. Where a change needs your consent, we will ask for it rather than assume it.
If you have a complaint about how your personal data is handled, contact our Grievance Officer. Under the Digital Personal Data Protection Act, 2023 this is the channel a Data Principal uses to exercise their rights and to complain.
If you are not satisfied with the outcome, you may complain to the Data Protection Board of India.