Data Processing Addendum (DPA)
Affluense.ai
Last updated: February 2026
1. Purpose and Scope
This Data Processing Addendum (“DPA”) applies only where Saleazy Technologies Private Limited, operating the Affluense.ai platform (“Affluense”), processes Customer Personal Data on behalf of a Customer in connection with the provision of the Affluense platform.
This DPA forms part of and is incorporated into the applicable Terms and Conditions or other written service agreement between the parties.
This DPA does not apply to processing activities where Affluense acts as an independent Data Fiduciary.
2. Definitions
a) Customer Personal Data means Personal Data provided or uploaded by or on behalf of the Customer to the Affluense platform for processing strictly in accordance with the Customer’s documented instructions.
Customer Personal Data does not include:
i) proprietary datasets created, licensed, or owned by Affluense
ii) publicly available or licensed third-party data independently collected by Affluense
iii) analytics, enrichment outputs, scoring, or AI-generated insights produced by the platform
iv) platform usage data, logs, telemetry, or security monitoring data processed by Affluense in its independent capacity
b) Data Fiduciary, Data Processor, Personal Data, and Processing have the meanings assigned under the Digital Personal Data Protection Act, 2023 (“DPDP Act”).
3. Roles of the Parties
a) Customer as Data Fiduciary (Limited Scope)
For Customer Personal Data only, being Personal Data provided or uploaded by or on behalf of the Customer for processing under the Customer’s documented instructions, the Customer determines the purpose and means of processing and therefore acts as the Data Fiduciary under the Digital Personal Data Protection Act, 2023.
This does not include publicly available data processed independently by Affluense or AI-generated, aggregated, or inferred outputs that do not identify an individual.
b) Affluense as Data Processor (Limited Scope)
Affluense acts solely as a Data Processor with respect to Customer Personal Data and processes such data only on documented instructions of the Customer and in accordance with this DPA.
c) Affluense as Independent Data Fiduciary
For all other Personal Data processed through or in connection with the platform — including proprietary datasets, publicly available or licensed data, analytics, enrichment outputs, AI-generated insights, platform usage data, logs, telemetry, and security monitoring — Affluense acts as an independent Data Fiduciary, and this DPA does not apply.
d) Independent Roles of Customers for Platform Use
Customers may act as independent Data Fiduciaries for their own downstream use of platform outputs, insights, or analytics, separate from any processing governed by this DPA.
4. Scope and Purpose of Processing
Affluense shall process Customer Personal Data only for:
a) providing and operating the Affluense platform
b) performing services requested by the Customer
c) maintaining platform security, integrity, and functionality
d) complying with lawful documented instructions of the Customer
Affluense shall not use Customer Personal Data for independent or unrelated purposes.
5. Processing Instructions
Affluense shall process Customer Personal Data only on documented instructions from the Customer, unless required to do so by applicable law.
If Affluense believes a processing instruction violates applicable law, it shall inform the Customer unless legally prohibited.
6. Security Measures
Affluense shall implement reasonable technical and organisational safeguards appropriate to the nature, scope, and risk of Customer Personal Data to protect against unauthorised access, disclosure, alteration, or loss.
7. Sub-Processors
Affluense may engage authorised sub-processors to support service delivery, including infrastructure, analytics, security, and communication providers.
Affluense shall ensure such sub-processors are bound by contractual confidentiality and data protection obligations consistent with this DPA.
Affluense remains responsible for sub-processor compliance with respect to Customer Personal Data.
A current list of sub-processors is available upon reasonable request to:
privacy@affluense.ai
8. Personal Data Breach Notification
Affluense shall notify the Customer without undue delay after becoming aware of a personal data breach involving Customer Personal Data and provide available information reasonably required for legal or regulatory compliance.
9. Assistance with Data Principal Rights
Affluense shall provide reasonable assistance to enable the Customer to respond to Data Principal rights requests relating to Customer Personal Data, to the extent required under applicable law.
10. Data Retention and Deletion
Upon termination or expiry of services, Affluense shall delete or return Customer Personal Data in accordance with Customer instructions, unless retention is required by applicable law.
Residual backup copies retained for legal, archival, or disaster-recovery purposes shall remain protected and not actively processed.
11. Confidentiality
Affluense shall ensure that personnel authorised to process Customer Personal Data are subject to appropriate confidentiality obligations.
12. Cross-Border Processing
Customer Personal Data may be processed outside India only in accordance with applicable data protection laws and appropriate contractual or legal safeguards.
13. Liability
Liability arising under this DPA shall be subject to the limitations of liability set out in the governing Terms and Conditions or service agreement between the parties.
14. Governing Law
This DPA shall be governed by and construed in accordance with the laws of India.
15. Contact
For questions regarding this DPA or Affluense’s data protection practices, please contact:
