Privacy policy
Who we are
Sustenza LLP, MR-4, Plot No. A-26, Block B, Mohan Cooperative Industrial Estate, New Delhi – 110044. Email info@sustenza.in, phone +91 81785 50225. We decide why and how the personal data described here is used (in the words of the Digital Personal Data Protection Act, 2023, we are the data fiduciary).
Grievance officer: the Grievance Officer, Sustenza LLP, at the email and phone above. Write with "Privacy" in the subject; see Your rights for how quickly we answer.
What we collect, and why
| What | Why |
|---|---|
| Your email address, first and last name | To create and run your account and to send you sign-in codes and links. |
| If you sign in with Google: your name, your verified email address and Google's identifier for your account | To create and run your account without a password. Google does not send us your Google password, and we do not read your Google contacts, mail or files. The button loads Google's script, so your browser contacts Google when the sign-in page opens. |
| Your password | We never store it. We keep only a one-way PBKDF2 digest, which cannot be turned back into the password. |
| Your phone number (optional at sign-up) | The payment processor requires a phone number to create a payment; it is asked for at checkout if you did not give one. |
| Billing name, address, state, PIN code and GSTIN if registered | To determine the place of supply, calculate GST and issue your payment invoice. Billing drafts stay in memory while checkout is open; the server keeps the details with the order and accounting invoice. |
| What you record in the Dashboard: entries, targets, calculations, counterparties, prices, notes and your settings | To show you your EPR position. This is your data; we do not use it for anything else. |
| Questions you ask the Assistant, the answers, and the recent turns of your conversation | To answer you, to let you continue a conversation, and to check answers for quality and abuse. For each answer our servers also keep a record of the question, the passages and citations used, and the answer, for up to 90 days. Answers that are clean and fully cited may be kept for up to 7 days so that the same question is not paid for twice. Your conversations (titles, questions and answers) are kept against your account so you can open them on any device where you are signed in; you can delete a conversation at any time and it is removed from every device. |
| What you send through the consultation form or by email: name, work email, company, phone, role, annual volume, the streams and services you pick, and your message | To reply to your request. |
| Technical records our servers keep: time, the address of the request, and errors | To keep the service secure, to limit abuse and to find faults. |
We process this data on the basis of your consent and to provide the service you asked for. We do not use analytics, advertising or tracking tools, and we do not sell personal data.
Who we share it with
- Hetzner Online GmbH hosts our servers, in Nuremberg, Germany. The service runs there, and so does your account data.
- Netlify hosts this website's pages.
- Cashfree Payments processes payments. Card and bank details are entered on Cashfree's own page; we never see or store them.
- The Assistant's providers. To answer a question, we send the question, the library passages it needs and, for a follow-up, the recent turns of the conversation to a language model: OpenAI's, reached through OpenRouter. We send the question to Voyage AI to find and rank the right passages. We do not send your Dashboard records. These providers are companies outside India; we do not control how long they keep what they receive, and we cannot promise that they do not keep it. Their own terms govern that, so do not put anything into the Assistant that you are not willing to share with them.
- Brevo sends our emails: sign-in codes, links and payment invoices, including the billing information on those invoices.
- Our website server records consultation requests and uses our configured email provider to notify our team and send a receipt to the email address entered.
- Google: Sign-In (accounts.google.com), only if you choose to sign in with Google, confirms to us who you are; Google Fonts serves the site's typeface, so your browser contacts Google when a page loads.
- Authorities, where the law requires it, and our professional advisers, under a duty of confidence.
Some of these providers are outside India, so your data is processed in Germany and in the countries where they operate, which for the Assistant's providers includes the United States. If you do not want this, do not use the Assistant, and tell us if you want your account closed.
What stays in your browser
We use your browser's local storage, not cookies, to keep you signed in, to remember your theme, and to keep unsent drafts and a fast copy of your Assistant conversations on your device (the conversations themselves are also kept on our servers, as described above, so they appear when you sign in on another device). Signing out removes the sign-in token.
How long we keep it
- Account and Dashboard data: until you close your account.
- Consultation form records and delivery status on our website server: up to 30 days. Consultation emails in our mailbox: 24 months from the last message, then deleted.
- Payment records: 8 years, as tax and accounting law requires. They keep the amount, dates and order references; once your account is closed, your email address on them is replaced by a one-way code. Issued tax invoices retain the billing name, address and GSTIN needed for accounting and statutory records. Closing an account erases its email delivery queue and unissued billing drafts, but does not erase issued tax invoices.
- Assistant answer records (the question, passages, citations and answer kept for each answer): up to 90 days, then deleted. Cached answers: up to 7 days. The conversation itself stays until you delete it or close your account.
- Server technical records, including the counters that apply your plan's limits: up to 90 days.
Closing your account
You can close your account yourself from Account → Close account. It permanently erases your account, every sign-in session, your saved calculations and your whole Dashboard, including its edit history. It also deletes your Assistant conversations held on our servers; answer records kept for up to 90 days (above) are removed on that schedule. Our providers' own copies, if any, are outside our control. It cannot be undone, so export anything you need first (the Dashboard exports to CSV). Copies in our backups are overwritten as the backups rotate, within 35 days.
How we protect it
Connections to the service are encrypted. Passwords are stored only as one-way digests. Access to the servers is restricted, the service is limited in how fast it can be called, and backups are encrypted. No system is perfectly secure; if a breach affects your personal data we will tell you and the authority as the law requires.
Your rights
You can ask to see, correct or erase your personal data, to withdraw consent, and to name someone to act for you, by writing to info@sustenza.in from the email address on your account (so that we know it is you). We acknowledge within 7 days and answer within 30 days. If you are not satisfied with our answer, you can complain to the Data Protection Board of India once it is constituted and the law allows.
Children
The service is for businesses and professionals and is not meant for anyone under 18. We do not knowingly collect data about children.
Changes
We will post any change here with a new "last updated" date, and tell you in the app if it affects you materially.