Effective: September 2026

Privacy Policy & Data Governance

Comprehensive privacy practices governing customer relationship management, Meta Cloud API WhatsApp messaging, AI workflow processing, and Razorpay payment transactions.

Data Deletion

WhatsApp Cloud API v24.0

Direct official Meta infrastructure with 256-bit transit encryption, strict 24h service window, and instant STOP opt-out.

PCI-DSS Tokenized Payments

Zero raw credit/debit card numbers or banking PINs stored on our servers. All transactions securely tokenized via Razorpay.

DPDP Act 2023 Compliant

Full data subject rights supported including access, correction, restriction, and permanent data deletion within 30 days.

COEDLOITE PRIVATE LIMITED ("Company", "we", "our", or "us"), operating platforms including NAC 360, NAC Gen AI, and NAC MICRO COLLEGE (https://nacgenai.in), is committed to safeguarding your privacy and protecting your personal data in accordance with the Information Technology Act, 2000 and the Digital Personal Data Protection Act, 2023.

This Privacy Policy applies to personal data collected through our websites, conversational interfaces, omnichannel CRM workspaces, customer support services, and official WhatsApp Business accounts powered by the Meta Cloud API.

1. Information We Process

Depending on how you interact with our platform, we collect and process the following categories of personal data:

  • Contact & Profile Details: Full name, verified mobile phone number, WhatsApp phone number, email address, company/institution name, and communication preferences.
  • Enquiry & Commerce Data: Course inquiries, order cart items, delivery addresses, transaction references, support tickets, and service preferences.
  • WhatsApp Business Message Data: Inbound and outbound message text, media attachments (images, PDFs), timestamps, message statuses (sent, delivered, read), and opt-in/opt-out consent timestamps.
  • Technical & Log Information: IP address, device type, browser specifications, access timestamps, and session diagnostics necessary for cybersecurity and abuse prevention.

2. Legal Bases & Processing Purposes

We process personal data only where permitted by law, specifically for:

  • Delivering requested services, course materials, product catalogs, and transactional order confirmations.
  • Operating our omnichannel team inbox and conversational customer relationship management workflows.
  • Routing incoming inquiries to qualified counselors, support agents, or automated assistants.
  • Reconciling financial transactions and issuing GST-compliant tax invoices via our payment provider.
  • Ensuring platform integrity, preventing fraud, and adhering to statutory legal obligations.

3. WhatsApp Cloud API & Opt-Out Compliance

Our WhatsApp communication infrastructure is powered exclusively by the official Meta Cloud API (v24.0) under Meta Platforms Inc. enterprise partner terms:

  • Explicit Consent (Opt-In): We initiate outbound notifications (such as invoice receipts, appointment reminders, and shipping updates) only to users who have explicitly provided opt-in consent via our website forms, checkout, or prior communication.
  • 24-Hour Customer Care Window: When you send a message to our official WhatsApp number, a 24-hour service window opens wherein our team and AI assistants may converse to resolve your query.
  • Instant Opt-Out (STOP Keywords): You may opt out of promotional messages at any time simply by replying "STOP", "UNSUBSCRIBE", or "CANCEL" in the WhatsApp chat. Opt-out takes effect immediately.

4. Artificial Intelligence (AI) Processing & Guardrails

Our platform integrates Google Genkit and Gemini models to assist internal operations in summarizing customer context, drafting responses, and scheduling appointments:

  • AI processing operates strictly under enterprise confidentiality agreements and customer data is NOT used to train public foundation models.
  • Zero Payment Authority Invariant: AI models possess ZERO authority to declare payments received or issue receipts. Official transaction verification is exclusively performed via server-authoritative payment webhooks.
  • Human agents maintain oversight and can take over live conversations at any point.

5. Payment Gateway & Financial Security

All commercial payments, course fees, and subscriptions are processed through Razorpay Software Private Limited:

  • Zero Raw Card Storage: We do NOT collect, store, or process complete credit/debit card numbers, CVVs, or UPI PINs on our servers.
  • All payment card data is tokenized directly via Razorpay's Level 1 PCI-DSS compliant checkout interface with 256-bit TLS encryption.
  • Our databases store only non-sensitive transaction tokens (Payment ID, Order ID, amount, timestamp, and status) required for auditing and order fulfillment.

6. Data Sharing & Cloud Sub-Processors

We do not sell, rent, or monetize your personal information. We share data strictly with verified cloud infrastructure providers required to deliver our services:

  • Hosting & Cloud Database: Google Cloud Platform / Firebase App Hosting & Cloud Firestore.
  • Messaging Infrastructure: Meta Platforms, Inc. (WhatsApp Business Cloud API).
  • Payment Processing: Razorpay Software Private Limited (RBI Authorized Payment Aggregator).
  • AI Intelligence: Google Cloud Genkit / Gemini Enterprise API.

7. Technical & Security Safeguards

We maintain enterprise-grade security protocols, including:

  • HMAC SHA-256 webhook signature verification on all incoming Meta and Razorpay payloads.
  • End-to-end encryption for WhatsApp messages in transit.
  • Role-Based Access Control (RBAC) restricting customer records strictly to authorized staff members.
  • Automated audit logging of all sensitive administrative modifications.

8. Data Retention & Permanent Deletion

We retain personal data only for as long as necessary to fulfill active customer services, resolve inquiries, and comply with tax and legal requirements:

  • WhatsApp conversation records are retained for a maximum of 24 months, after which they are automatically archived or purged.
  • Financial transaction ledgers are retained as required by Indian accounting and taxation statutes.
  • To request deletion of your personal data at any time, visit our User Data Deletion Page.

9. Your Statutory Rights & Grievance Officer

Under the Digital Personal Data Protection Act, 2023, you have the right to request access, correction, restriction, or erasure of your personal data.

Corporate Contact & Grievance Redressal:

Merchant Legal Entity: COEDLOITE PRIVATE LIMITED
Operational Address: Embassy Tech Village, Bangalore, Karnataka, PIN: 560103