Privacy Policy

Legal Entity

Godrongo 82 Labs LLP

LLPIN

ACS-4184

Registered Address

406 Building 10, Shanti Park Apartments, Jayanagar 9th Block, Bangalore 560041, India

Godrongo 82 Labs LLP (LLPIN: ACS-4184), with its registered office at 406 Building 10, Shanti Park Apartments, Jayanagar 9th Block, Bangalore 560041, India ("Fonetic", "we", "us", or "our") operates the Fonetic AI sales automation platform, including the website fonetic.ai, the application at app.fonetic.ai, and related services (collectively, the "Service").

This Privacy Policy explains how we collect, use, store, share, and protect personal information in connection with the Service, in alignment with:

By accessing or using the Service, you acknowledge that you have read and understood this Privacy Policy.


1. Scope and Definitions

This policy applies to two distinct categories of individuals whose information we may process:

For data processed about End Users on behalf of a Customer, Fonetic acts as a Data Processor, and the Customer acts as the Data Controller (or Data Fiduciary, under the DPDP Act). Customers are responsible for establishing the lawful basis for their communications with End Users, including obtaining any required consent.


2. Information We Collect

We collect information in four ways: directly from Customers when they sign up and use the Service, from End Users via channels that Customers connect (such as Instagram or WhatsApp), automatically when you visit our website, and from the third-party services and sub-processors described in Sections 6 and 7.

2.1 Information from Customers

When you sign up for, evaluate, or use the Service, we collect:

2.2 Information from End Users (via connected channels)

When a Customer connects a channel to Fonetic (Instagram, WhatsApp, or others), we receive and process the following on the Customer's behalf:

2.3 Information from Website Visitors

We collect basic technical data when you visit fonetic.ai — IP address, browser type, referring URL, pages visited, and timestamps — primarily through cookies and analytics tools. See Section 9 for cookie details.

2.4 Information We Do Not Collect

Fonetic does not knowingly collect financial account numbers, payment card details, government-issued ID numbers, biometric data, genetic data, or health information. If you provide such information through messages or conversations, please be aware that it will be stored as part of the conversation record; we recommend not transmitting sensitive identifiers through the Service.


3. How We Use Your Information

We use the information described above to:

We do not sell personal information. We do not use personal information for cross-context behavioural advertising. We do not train AI or machine learning models on Customer or End User data (see Section 6).


4. Meta Platform Integration Disclosure (Instagram and WhatsApp)

The Service integrates with messaging platforms operated by Meta Platforms, Inc., including the Instagram Messaging APIs and the WhatsApp Business Platform (the latter accessed via our Business Solution Provider, Gupshup, where Fonetic is registered as a Tech Provider).

4.1 Data Processed from Meta Platforms

When a Customer connects their Instagram Business account or WhatsApp Business number to Fonetic, we may process the following platform data on the Customer's behalf:

This data is used solely to provide the Service to the Customer — to display conversations in the Fonetic inbox, enable human and AI replies, route and label conversations, produce analytics for the Customer, and operate the automation features the Customer has configured.

4.2 Limited Use Commitment

Fonetic's use and transfer of information received from Meta APIs will adhere to Meta's Platform Terms and Policies.

Specifically, Fonetic:

4.3 Data Residence on Meta Infrastructure

You acknowledge that messages and metadata exchanged on Instagram and WhatsApp are first processed by Meta's infrastructure (including the Meta Cloud API for WhatsApp, routed through Gupshup) before being delivered to Fonetic. Data on Meta's infrastructure is governed by Meta's own terms and privacy policies. Once data is delivered to Fonetic, it is hosted and processed as described in Section 10.

4.4 Revocation

Customers can disconnect a connected Instagram or WhatsApp account at any time from Fonetic's settings, or by revoking Fonetic's access via the respective platform's app permissions page on Instagram or Meta Business Settings. Upon disconnection, access tokens are immediately invalidated, and associated message data is retained or deleted in accordance with Section 8.


5. Lawful Basis for Processing

Where the GDPR or analogous laws apply, we rely on one or more of the following lawful bases:

Under the DPDP Act, processing of personal data of Indian data principals is carried out either (a) with consent for specified purposes, or (b) for legitimate uses recognised under the Act.

For End User data processed via connected channels, Fonetic acts as a Processor and processes such data only on documented instructions from the Customer, who is responsible for establishing and maintaining the lawful basis for the underlying communications.


6. AI and Machine Learning

Fonetic uses AI to power features such as conversational AI replies, draft suggestions, message summarization, sentiment analysis, and intent classification. To deliver these features, Customer and End User data is transmitted to AI sub-processors. This section explains how that works and what we commit to.

6.1 Our Commitments

6.2 AI Sub-processors and Model Routing

Fonetic accesses large language models through two aggregator services. Both route inference requests to a set of downstream model providers; the specific provider that handles a given request depends on the model selected, availability, and routing configuration.

6.3 AWS Bedrock — Provider Isolation

When Fonetic uses AWS Bedrock, the underlying model providers (Anthropic, Meta, and others) do not have access to prompts or completions. AWS publishes that "Amazon Bedrock does not store customer input data or model output data," "the service does not use customer inputs or outputs to train AWS models or share them with third parties," and that model providers cannot access Bedrock logs, prompts, or completions because each model is deployed into AWS-controlled accounts to which the model provider has no access. For full details, see AWS Bedrock data protection documentation.

6.4 OpenRouter — Logging Disabled

OpenRouter operates as a proxy that routes requests to downstream model providers. We have configured our OpenRouter account so that prompt and completion logging is disabled by default. The current list of downstream providers OpenRouter may route to, along with each provider's data retention and training policy, is maintained by OpenRouter at openrouter.ai/docs/guides/privacy/provider-logging.


7. Sub-processors and Data Sharing

We share personal information only with the categories of recipients described below.

7.1 Infrastructure and Operational Sub-processors

Each sub-processor is engaged under terms that require them to process data only on our documented instructions, maintain appropriate security, and assist us with our compliance obligations. We do not appoint additional sub-processors with access to Customer or End User content without updating this policy.

7.2 Legal Reasons

We may disclose information when required by law, regulation, legal process, or a lawful government request, or where we believe in good faith that disclosure is necessary to protect our rights, our Customers, our End Users, or the public.

7.3 Business Transfers

In the event of a merger, acquisition, financing, reorganisation, or sale of all or part of our business or assets, personal information may be transferred to the successor entity, subject to this Privacy Policy or a successor policy with equivalent protections.

7.4 No Sale of Personal Information

We do not sell personal information, and we do not share personal information for cross-context behavioural advertising.


8. Data Retention and Deletion

8.1 Retention Periods

8.2 Deletion Requests

Customers can delete their account through the in-product settings, which initiates the retention period described above.

To request immediate deletion of specific records, email team@fonetic.ai with the subject line "Data Deletion Request" and sufficient information to identify the relevant account or data (such as the registered email address, business name, or connected channel). We will respond within 7 to 30 days of receiving a verified request, except where retention is required by law or to resolve a dispute.

8.3 End User Deletion Requests

End Users who wish to request deletion of their data from the Fonetic platform can either:

(a) contact the Customer (the business they messaged) directly, who can delete the relevant records from their Fonetic account; or
(b) email team@fonetic.ai with the subject line "Data Deletion Request" and sufficient information to identify the relevant data (for example, the Instagram username or WhatsApp number used, and the business they were communicating with).

We will coordinate with the Customer to action such requests within 7 to 30 days.

8.4 Deletion Upon Channel Disconnection

When a Customer disconnects an Instagram or WhatsApp channel, the associated OAuth tokens are invalidated immediately. Message data associated with that channel is retained per the standard retention period above, unless the Customer requests earlier deletion.


9. Cookies and Tracking

The Fonetic website and product use cookies and similar technologies for authentication, security, preference storage, and basic analytics. You can control cookies through your browser settings. Disabling certain cookies may affect the functionality of the Service. We do not use third-party advertising cookies or cross-site tracking pixels.


10. Data Storage and International Transfers

Application data is hosted on Railway infrastructure, with primary servers located in Singapore. Some sub-processors (including AI providers and email services) may process data in the United States, the European Union, India, or other regions.

Where personal data of EU/UK data subjects is transferred outside their jurisdiction, we rely on Standard Contractual Clauses or other appropriate safeguards required by the GDPR. Where personal data of Indian data principals is processed outside India, we maintain reasonable safeguards consistent with the DPDP Act and the IT Rules, 2011.

By using the Service, you consent to the international transfers described in this section.


11. Security

We implement administrative, technical, and physical safeguards designed to protect personal information, including:

No method of transmission or storage is 100% secure. While we strive to protect personal information, we cannot guarantee absolute security. If you become aware of a security issue, please email team@fonetic.ai.


12. Your Rights

Depending on your jurisdiction, you may have some or all of the following rights:

To exercise any of these rights, email team@fonetic.ai from the address associated with your account (or with sufficient information for us to verify your identity). We will respond within 30 days of a verified request, or as required by applicable law.


13. Children's Privacy

The Service is intended for use by businesses and is not directed to children. Under the DPDP Act, processing personal data of an Indian data principal under the age of 18 requires verifiable parental consent; we do not knowingly process such data without it. Under the GDPR, we do not knowingly collect data from children under 16 (or the lower age threshold set by applicable EU member state law). If you believe a child has provided personal information to us, please contact team@fonetic.ai and we will promptly delete it.


14. Grievance Redressal (DPDP Act – India)

In accordance with the Digital Personal Data Protection Act, 2023, Godrongo 82 Labs LLP has designated the following Grievance Officer:

Siddharth Das

Designation: Grievance Officer

Address: 406 Building 10, Shanti Park Apartments, Jayanagar 9th Block, Bangalore 560041, Karnataka, India

Email: siddharth@fonetic.ai

Acknowledgment: within 72 hours

Response: within 15 business days

Data principals in India may submit grievances related to personal-data processing or violation of their rights under the DPDP Act to the Grievance Officer.


15. Changes to This Policy

We may update this Privacy Policy from time to time. We will post any updated version on this page with a revised "Last updated" date. Material changes will be communicated via email to active Customers or via an in-product notice. Your continued use of the Service after an update constitutes acceptance of the revised policy.


16. Contact Us

For any privacy questions, security issues, or to exercise your rights:

Godrongo 82 Labs LLP
406 Building 10, Shanti Park Apartments
Jayanagar 9th Block, Bangalore 560041, Karnataka, India
Email: team@fonetic.ai
DPDP grievances: siddharth@fonetic.ai


This Privacy Policy is published in accordance with the Information Technology Act, 2000, the Digital Personal Data Protection Act, 2023, and applicable rules thereunder.