Data Processing Addendum
Last updated: 21 October 2026 · Part of the Terms of Service
This addendum applies when JMVAS Telecommunications Private Limited (OPC) (“Processor”) processes personal data of a merchant's customers (“Customer Data”) on behalf of the merchant (“Data Fiduciary”) while providing D2C Fiber (d2cfiber), under India's Digital Personal Data Protection Act, 2023.
1. Scope and instructions
- Customer Data includes names, phone numbers, addresses, orders, messages and delivery details of the merchant's customers.
- We process it only to provide the Service and on the merchant's documented instructions — the settings, automations and actions they configure or approve.
- We never sell Customer Data or use it for our own marketing, and never share one merchant's Customer Data with another merchant.
2. The merchant's responsibilities
- Give customers the notices and obtain the consents the law requires (including opt-in for WhatsApp marketing).
- Handle customers' requests to access, correct or erase their data; we help on request.
3. Confidentiality and security
- Only staff who need access have it, under confidentiality obligations.
- Encryption in transit; platform tokens encrypted at rest; role-based access; audit logs of every action; backups. See Security.
4. Sub-processors
We use these sub-processors: Railway (hosting), Neon (database), Anthropic and Google (AI), Meta and MSG91 (WhatsApp messaging), Bolna (voice calls, if enabled), Cloudflare (network). We bind them to equivalent obligations and will update this list before adding new ones.
5. Personal data breaches
If we become aware of a breach affecting Customer Data, we notify the merchant without undue delay (target within 24 hours), share what we know and the steps taken, and support the merchant's notifications to the Data Protection Board and affected people.
6. Deletion and return
When the merchant's account ends, we return Customer Data on request (export) and delete it within 30 days, except where the law requires us to keep it.
7. Audits
On reasonable written request (not more than once a year), we provide information needed to show compliance with this addendum.
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