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Legal Document

Privacy Policy

Entity: Eduloom Technologies OPC Pvt Ltd
Address: Mysore, Karnataka, India
Product: Chatmadi (chatmadi.com)
Effective Date: 1 January 2025
Contact: hello@chatmadi.com

This Privacy Policy governs the collection, processing, storage, disclosure, and protection of personal data by Eduloom Technologies OPC Pvt Ltd in connection with the Chatmadi platform. Prepared in compliance with the Digital Personal Data Protection Act, 2023 (DPDPA), the Information Technology Act, 2000, and the IT (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011.

1. Definitions and Interpretation

1.1 Personal Data

"Personal Data" means any data about an individual who is identifiable by or in relation to such data, as defined under the DPDPA. This includes names, contact information, identification numbers, location data, online identifiers, and any data specific to the physical, physiological, genetic, mental, economic, cultural or social identity of a natural person.

1.2 Data Principal

"Data Principal" means the individual to whom the Personal Data relates. Where such individual is a minor, the Data Principal includes the parent or lawful guardian.

1.3 Data Fiduciary

"Data Fiduciary" means any person who determines the purpose and means of processing Personal Data. Schools using Chatmadi are Data Fiduciaries with respect to their students, parents, and staff data.

1.4 Data Processor

"Data Processor" means any person who processes Personal Data on behalf of a Data Fiduciary. The Company acts as Data Processor when processing data uploaded by schools.

1.5 Processing

"Processing" means any wholly or partly automated operation performed on digital personal data, including collection, recording, storage, retrieval, use, disclosure, erasure or destruction.

2. Scope and Application

This Policy applies to all Personal Data processed in connection with the Chatmadi platform, including data from: (a) individuals who create accounts; (b) schools that upload student, parent, and staff data; (c) parents whose contact details and WhatsApp communications are processed; (d) students whose records are maintained; and (e) visitors to chatmadi.com.

This Policy does not apply to third-party websites or services linked from the platform.

3. Categories of Personal Data Collected

3.1 Account Data

Full name, email address, hashed password, role designation, date of account creation, and IP address at registration.

3.2 School Data

School name, board affiliation, city and state, geographic coordinates if provided, academic year, and optionally a school logo.

3.3 Student Data

Full name, date of birth, class assignment, gender, enrollment status, academic year, and attendance percentage. Uploaded by school administrators.

3.4 Parent Contact Data

Full name, mobile phone number (for WhatsApp matching), email address, and relationship to student.

3.5 WhatsApp Conversation Content

Exported conversation files in .txt format containing private communications between parents and teachers. May include references to student health, family circumstances, and financial situations. Schools are responsible for ensuring appropriate authority to upload such communications.

3.6 Academic Data

Examination results, subject scores, grade classifications, homework records, and academic performance data.

3.7 Fee Data

Fee structures, payment records, outstanding balances, payment confirmation data. The Company does not process credit card or bank account details. Billing handled by Razorpay.

3.8 Technical Data

IP address, browser type, operating system, device type, pages accessed, feature usage patterns, error logs, and session identifiers.

5. Artificial Intelligence Processing

5.1 AI Model

Chatmadi uses Claude Sonnet by Anthropic PBC. Conversation text is transmitted to Anthropic's API for processing, subject to Anthropic's privacy policy.

5.2 Nature of Processing

The AI extracts structured information from unstructured text across twenty-three defined analysis modes. It does not make autonomous decisions producing legal or significant effects without human review.

5.3 Human Oversight

Every AI output is presented as a "detection" requiring human confirmation or dismissal. No AI output is committed to permanent records without review. This human-in-the-loop architecture is a fundamental design requirement.

5.4 No AI Training

The Company does not use your data to train, fine-tune, or improve AI models, whether operated by us or by Anthropic.

5.5 Multilingual Processing

The system processes English, Hindi, and regional Indian languages including code-switched text. No additional personal data is collected as a result.

6. Purposes of Data Processing

We process Personal Data for: (a) service provision including AI analysis, dashboards, and all product features; (b) child safety and welfare monitoring; (c) billing and subscription management via Razorpay; (d) security and fraud prevention; (e) aggregate product improvement using anonymised data only; (f) customer support; and (g) legal compliance.

7. Data Storage, Security, and Retention

7.1 Infrastructure

Data stored on Supabase (PostgreSQL on AWS) in the Asia Pacific region.

7.2 Encryption

AES-256 encryption at rest. TLS 1.3 in transit. Unencrypted HTTP rejected and redirected.

7.3 Access Controls

Row-level security in PostgreSQL. Each school's data logically isolated. No cross-school data access possible.

7.4 Employee Access

Restricted on need-to-know basis. All internal access logged and auditable.

7.5 Data Retention

Data retained while account is active plus twelve months after termination. Deleted data removed within thirty days of request. Billing records retained seven years per tax requirements.

8. Disclosure of Personal Data

8.1 Third-Party Providers

(a) Anthropic PBC: AI processing. (b) Supabase Inc.: database infrastructure. (c) Vercel Inc.: hosting. (d) Razorpay Software Pvt Ltd: payment processing. All subject to data processing agreements.

8.2 Legal Disclosure

Where required by valid court order, regulatory authority direction, or applicable law.

8.3 Business Transfers

In event of merger or acquisition, data may transfer with reasonable advance notice to users.

8.4 No Sale of Data

The Company does not sell, rent, or transfer Personal Data to third parties for commercial purposes.

8.5 Cross-Border Transfers

Data may be transferred outside India for AI processing via Anthropic's API, subject to appropriate contractual safeguards.

9. Rights of Data Principals

9.1 Right to Access

Obtain confirmation of processing and summary of Personal Data held.

9.2 Right to Correction and Erasure

Request correction of inaccurate data, completion of incomplete data, and erasure of data no longer necessary.

9.3 Right to Grievance Redressal

Grievances addressed at hello@chatmadi.com. Acknowledged within 48 hours, resolved within 30 days.

9.4 Right to Nominate

Nominate an individual to exercise rights in event of death or incapacity, per DPDPA.

9.5 Data Portability

Export all data via CSV from the Export Data page at any time without charge.

9.6 Right to Withdraw Consent

Withdraw consent at any time without affecting prior lawful processing.

9.7 Right to Escalate

Escalate unresolved matters to the Data Protection Board of India.

10. Children's Data

Chatmadi processes data about minors on behalf of schools (Data Fiduciaries) who bear responsibility for obtaining parental consent. The Company does not collect data directly from children. Heightened care is applied to all student data, which is not used beyond providing the contracted service.

11. Cookies

Essential authentication cookies only (Supabase). No third-party advertising or cross-site tracking cookies. Optional first-party analytics cookies for aggregate product improvement. Cookie management available via browser settings.

12. Security Incident Response

The Company maintains a security incident response plan. In event of a breach likely to affect individuals, we will notify the Data Protection Board and affected schools within prescribed timeframes. Report suspected incidents to hello@chatmadi.com with subject "Security Incident Report".

13. Changes to This Policy

We may amend this Policy at any time. Material changes notified by email at least fourteen days before taking effect. Non-material changes may apply immediately. Continued use constitutes acceptance.

14. Contact and Grievance Officer

Grievance Officer
Eduloom Technologies OPC Pvt Ltd
Mysore, Karnataka, India
Email: hello@chatmadi.com
Subject: Privacy Policy Enquiry or Data Rights Request

Acknowledgement within 48 hours. Substantive response within 30 days.