Privacy Policy

1. Introduction

Frixn ("Frixn", "we", "us") respects your privacy and is committed to protecting personal data in compliance with India's Digital Personal Data Protection Act, 2023 ("DPDP Act") and the Information Technology Act, 2000.

This Privacy Policy explains what data we collect, how we use it, and your rights. It applies to both subscribers (users of our dashboard) and prospects (people whose contact information is captured through Frixn NFC cards or links).

2. Who We Are

Data Fiduciary (under DPDP Act): Frixn.

• For subscriber data: Frixn acts as the Data Fiduciary.
• For lead/prospect data captured by subscribers: The subscriber (e.g., a real estate brokerage or individual agent) is the Data Fiduciary. Frixn acts as a Data Processor on their behalf.

3. Information We Collect

3.1 From Subscribers (users paying for Frixn):

• Account data: Name, email, phone number, company name, role, profile photo
• Authentication data: Password (hashed), login timestamps, IP address
• Payment data: Handled entirely by Razorpay. We store only the subscription ID and transaction reference, never card numbers or bank details.
• Usage data: Pages visited in the dashboard, features used, device type, browser type
• Communication data: Emails exchanged with our support team

3.2 From Prospects (people whose cards are tapped):

• Contact data: Phone number, name (if shared via Google/LinkedIn OAuth), email (if shared), company (if shared), job title (if shared)
• Meeting context: Event name or location (as configured by the subscriber), timestamp of capture, agent who captured the lead
• Technical data: IP address at time of tap, device type, browser — used for analytics and security

3.3 Data We Do NOT Collect:

• Aadhaar numbers
• Bank account details
• Biometric data
• Location data (we would capture the city of the lead captured but we dont collect the absolute location)
• Data from minors (under 18) — we do not knowingly process this

4. How We Use Data

4.1 For Subscribers:

• Provide and maintain the Service
• Process payments and manage subscriptions
• Send transactional emails (receipts, account alerts, security notifications)
• Improve the platform based on usage analytics
• Respond to support requests
• Comply with legal obligations (GST filings, tax reporting)

4.2 For Prospects:

• Enable the subscriber (agent/company) to contact you about their products or services
• Facilitate the opening of a WhatsApp conversation between you and the agent
• Provide data to the subscriber's connected CRM (if configured)

5. Legal Basis for Processing

Under the DPDP Act 2023, we process personal data based on:

• Consent: for prospects who voluntarily share their data by tapping a card and submitting the form
• Contract performance: for subscribers who have signed up for paid services
• Legitimate interest: for analytics, security, and fraud prevention
• Legal obligation: for compliance with Indian law

6. Data Sharing

We share data with:

• Payment processors (Razorpay or other Authorised Payment Service Providers) — for subscription billing
• Communication providers (Meta/WhatsApp Business API) — for message delivery
• Cloud infrastructure (Railway, Vercel, Cloudflare, or equivalent) — for hosting
• CRM platforms (Zoho, HubSpot, Salesforce, LeadSquared or other enablers) — only when configured by the subscriber
• Analytics providers — anonymized usage data only
• Law enforcement — only when legally required under Indian law

We do NOT sell personal data to third parties under any circumstances.

7. Data Retention

• Subscriber account data: Retained while subscription is active + 90 days after cancellation for recovery
• Lead/prospect data: Retained as long as the subscriber's account is active. Subscribers can delete specific leads at any time.
• Payment records: Retained for 8 years as required by Indian tax law
• Logs and analytics: Retained for 12 months then anonymized

8. Your Rights Under DPDP Act 2023

For all individuals whose data we process:

• Right to access: Request a copy of your personal data we hold
• Right to correction: Request correction of inaccurate data
• Right to erasure: Request deletion of your data (subject to legal retention requirements)
• Right to grievance redressal: Raise concerns about how your data is handled
• Right to nominate: Nominate another person to exercise your rights in case of death or incapacity
• Right to withdraw consent: Withdraw consent for processing at any time

9. Data Security

We implement reasonable security measures:

• All data transmitted over HTTPS with TLS 1.3
• Passwords hashed using bcrypt
• Database encryption at rest
• Role-based access control for internal staff
• Multi-tenant isolation ensuring company data cannot be accessed across accounts
• Regular security audits and penetration testing

No system is 100% secure. In the event of a breach affecting your data, we will notify the Data Protection Board of India and affected users within 72 hours as required by DPDP Act.

10. International Data Transfers

Data is primarily processed within India. Some third-party services (e.g., Meta, Google, cloud providers) may process data outside India under standard data protection safeguards. By using Frixn, you consent to these transfers.

11. Cookies and Tracking

Our website uses:

• Essential cookies — for authentication and session management (cannot be disabled)
• Analytics cookies — for usage statistics (can be disabled in settings)

We do not use advertising cookies or tracking pixels from third-party ad networks.

12. Children's Privacy

Frixn is intended for users 18 years and older. We do not knowingly collect data from minors. If we discover that a minor's data has been collected, we will delete it immediately.

13. Changes to This Policy

We may update this Privacy Policy. Material changes will be notified via email to subscribers and via a banner on frixn.in at least 30 days before taking effect.

14. Contact

For questions about this Privacy Policy: