🇮🇳 India Privacy Policy (DPDP Act)
Digital Personal Data Protection Act, 2023
Affluense.ai
Last updated: February 2026
Purpose
This India Privacy Notice applies to individuals located in India and is issued in accordance with the Digital Personal Data Protection Act, 2023 (“DPDP Act”) and applicable rules.
In case of any inconsistency with the Global Privacy Policy, this Notice shall prevail for processing governed by Indian law.
Definitions
For the purposes of this Notice:
a) Personal Data means any data about an individual who is identifiable by or in relation to such data.
b) Data Principal means the individual to whom the Personal Data relates.
c) Data Fiduciary means the entity that determines the purpose and means of processing Personal Data.
d) Data Processor means any person who processes Personal Data on behalf of a Data Fiduciary.
e) Processing means any operation performed on Personal Data, including collection, storage, use, disclosure, or deletion.
f) Consent means any freely given, specific, informed, and unambiguous indication of agreement to processing.
g) Applicable Law means the DPDP Act and any related rules, amendments, or regulations in force in India.
Identity and Role of the Data Fiduciary
Affluense.ai is operated by Saleazy Technologies Private Limited (“Affluense”), which may act in different roles depending on the nature and source of Personal Data processed.
a) Affluense as Data Fiduciary
Affluense acts as a Data Fiduciary only with respect to Personal Data collected directly from customers or users, where Affluense independently determines the purpose and means of processing.
This includes:
i) user account registration and access data
ii) proprietary datasets, analytics, enrichment outputs, or research insights only to the extent that such information constitutes Personal Data under applicable law
iii) platform usage data, logs, and security monitoring information to the extent containing Personal Data
For clarity, publicly available data processed in accordance with Section 3(c)(ii) of the Digital Personal Data Protection Act, 2023 and AI-generated, aggregated, or inferred outputs that do not identify an individual are not treated as Personal Data processed by Affluense as a Data Fiduciary under this section.
b) Affluense as Data Processor
Affluense acts as a Data Processor only where it processes Customer Personal Data strictly on behalf of a customer in accordance with documented instructions and a valid contractual arrangement such as a Data Processing Addendum.
c) Customers as Independent Data Fiduciaries
Customers determine their own purposes for using platform outputs and therefore act as independent Data Fiduciaries under applicable law.
d) Sub-processors and Service Providers
Affluense may engage authorised service providers and sub-processors, including cloud infrastructure, analytics, communication, and security providers, to support platform operations.
All such entities are contractually bound to confidentiality, security, and data protection obligations.
A current list of sub-processors is available upon reasonable request to privacy@affluense.ai.
Customer Personal Data
“Customer Personal Data” means Personal Data provided or uploaded by or on behalf of a customer for processing through the Affluense platform in accordance with the customer’s documented instructions.
Customer Personal Data does not include:
a) publicly available personal data processed independently by Affluense
b) proprietary or licensed datasets controlled by Affluense
c) analytics, enrichment outputs, scoring, or AI-generated insights that do not identify an individual
d) platform telemetry, logs, or monitoring data processed in Affluense’s independent capacity
This definition is intended to align with the Data Processing Addendum.
Categories of Personal Data Processed
We process only Personal Data that is necessary and proportionate for lawful purposes, including:
a) name, email address, and phone number
b) professional and business-related information
c) account credentials and usage logs
d) customer-provided datasets
e) publicly available professional information
We do not knowingly process Personal Data of children below 18 years of age.
Sources of Personal Data
Personal Data may be collected:
a) directly from Data Principals
b) from customers using the platform
c) from publicly accessible sources
d) from licensed third-party data providers
e) through automated technical means such as logs or analytics
Purpose of Processing
Personal Data is processed only for specific, lawful, and disclosed purposes, including:
a) providing and operating the Affluense.ai platform
b) business intelligence, research, and analytics
c) account management and customer support
d) security, fraud prevention, and compliance
e) other legitimate uses permitted under the DPDP Act
Lawful Basis for Processing
Processing is carried out based on:
a) Consent of the Data Principal
b) Contractual necessity
c) Legitimate uses permitted under Applicable Law
d) Publicly available Personal Data as permitted under Section 3(c)(ii) of the DPDP Act
Consent and Withdrawal
Consent is obtained through clear affirmative action.
Data Principals may withdraw consent at any time via:
https://www.affluense.ai/contact
Upon withdrawal, Personal Data will be erased unless retention is required by law.
Rights of the Data Principal (Sections 11–14)
Data Principals have the right to:
a) obtain confirmation and access to Personal Data
b) request correction, completion, or updating
c) request erasure of Personal Data
d) withdraw consent
e) seek grievance redressal
f) nominate another individual to exercise rights in case of incapacity or death
All verified requests are addressed within ninety (90) days or earlier where required by law.
. Grievance Redressal Mechanism
Data Principals may submit grievances or rights requests via:
https://www.affluense.ai/contact
Affluense will:
a) acknowledge the request within a reasonable time
b) resolve the grievance within 90 days
c) provide at least 48 hours’ prior notice before permanent erasure of Personal Data, where applicable under DPDP Rules
If unresolved, Data Principals may approach the Data Protection Board of India in accordance with Applicable Law.
. Data Minimisation
Affluense collects and processes only the Personal Data that is necessary for the specified lawful purposes and does not retain excessive or irrelevant data.
. Data Retention and Erasure
Personal Data is retained only for as long as required for:
a) the stated processing purpose
b) legal or regulatory obligations
c) contractual requirements
Processing logs may be retained for a minimum of one (1) year.
Data is securely deleted or anonymised thereafter.
. Data Sharing and Cross-Border Processing
Personal Data may be shared only with authorised Data Processors and sub-processors bound by confidentiality and security safeguards.
Personal Data may be processed or stored outside India in compliance with Section 16 of the DPDP Act and Applicable Law.
. Personal Data Breach
In the event of a Personal Data breach:
a) affected Data Principals will be notified as required
b) the Data Protection Board of India will be notified where legally mandated
. Updates to This Notice
This Notice may be updated periodically to reflect legal, technical, or business changes.
Updated versions will be published with a revised “Last updated” date.
. Contact
For rights requests, grievances, or data protection queries:
