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Privacy Policy
Data Collection, Use & User Rights  ·  DPDP Act 2023 Compliant
TheWaterFirm
Version 1.0
Bengaluru, Karnataka
www.thewaterfirm.com/policies/privacy-policy
Perisync Technologies Pvt Ltd  ·  CIN: U72900KA2019PTC125482  ·  Data Fiduciary under DPDP Act 2023
Jurisdiction: Courts of Bengaluru, Karnataka, India
Current version always at:www.thewaterfirm.com/policies/privacy-policy ·  This policy explains what data we collect, why, and your rights over it.  · Privacy queries: support@thewaterfirm.com
1. Introduction & Data Fiduciary

This Privacy Policy ("Policy") explains how Perisync Technologies Pvt Ltd, operating under the brand name TheWaterFirm ("TWF", "we", "us"), collects, uses, stores, shares, and protects personal data in connection with our smart water metering products, services, website, and mobile application.

Perisync Technologies Pvt Ltd is the Data Fiduciary under the Digital Personal Data Protection Act, 2023 ("DPDP Act") for all personal data processed in connection with TWF's products and services. This means we determine the purpose and means of processing your personal data and are responsible for its protection.

This Policy is also governed by the Information Technology Act, 2000 and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 ("IT Rules").

By using TWF's products, platform, or services, you consent to the collection and use of your data as described in this Policy. If you do not agree, please discontinue use and contact support@thewaterfirm.com.
2. Who This Policy Applies To

This Policy applies to all individuals and entities whose personal data TWF processes, including:

  • Apartment Associations, RWAs, and their authorised representatives (Building Admins);
  • Individual flat owners, tenants, and residents who access the TWF platform;
  • Builders and developers who engage TWF for project deployments;
  • Commercial property owners and their representatives;
  • Visitors to TWF's website (www.thewaterfirm.com), including individuals who submit a demo request, contact form, or newsletter subscription;
  • Any individual whose personal data is provided to TWF in the course of service delivery.
3. What Data We Collect
CategoryData Collected
Identity DataFull name, designation (for Building Admins), Aadhaar number (where collected for e-sign or KYC purposes only)
Contact DataMobile phone number, email address
Property DataProperty address, flat or unit number, building or project name
Consumption DataWater consumption readings, flow rate data, usage patterns, billing data generated from meter readings
Account DataUsername, encrypted password, account preferences, login history
Device & App DataDevice type, operating system, app version, device identifiers (for mobile app), push notification tokens
Payment DataTransaction reference numbers, payment status. Full card/bank details are not stored by TWF — see Section 8
Usage DataPlatform access logs, features used, session duration, error logs
Communication DataSupport tickets, emails, and communications you send to TWF
Technical DataIP address, browser type, pages visited on the TWF website (collected via Google Analytics)
We do not collect sensitive personal data as defined under the IT Rules (such as passwords in unencrypted form, financial account numbers, health data, sexual orientation, or biometric data) beyond what is strictly necessary for specific, disclosed purposes such as payment processing or e-sign verification.
4. How We Collect Data

We collect data through the following means:

  • Directly from you — when you register an account, fill in a contact or demo request form, subscribe to our newsletter, contact support, or enter into a service agreement with TWF. Where you submit a form on the TWF website (demo booking, contact us, newsletter), the name, email, phone number, and message you provide are stored and used solely to respond to your enquiry or send the communications you subscribed to;
  • Automatically via the Platform — when you use the web or mobile application, usage and device data is collected automatically;
  • From IoT hardware — smart water meters and gateways installed at your premises transmit consumption readings and device health data to TWF's platform continuously during operation;
  • From the Building Admin — resident and tenant details (name, flat number, contact) may be entered into the platform by the Building Admin during onboarding. The Building Admin is responsible for ensuring they have the necessary authority to share resident data with TWF;
  • From payment gateways — transaction confirmation and status information is received from Razorpay, PayU, or equivalent authorised payment processors;
  • From Google Analytics — website visitor behaviour, traffic source, and usage statistics are collected via Google Analytics cookies on the TWF website.
5. Purpose of Data Collection
PurposeData Used
Service DeliveryProviding access to the platform, displaying consumption data, generating billing reports, sending alerts and notifications
Account ManagementCreating and managing user accounts, authentication, password reset, access control
Billing & PaymentsProcessing subscription and AMC payments, generating invoices, managing payment mandates
Technical SupportDiagnosing hardware and platform issues, responding to support tickets, conducting remote diagnostics
Maintenance & OperationsScheduling preventive maintenance visits, tracking hardware performance, firmware updates
CommunicationsSending service notifications, billing reminders, maintenance alerts, policy updates via email, SMS, and push notification
Legal & ComplianceMeeting obligations under applicable Indian law, responding to legal orders, maintaining statutory records
Analytics & ImprovementUnderstanding usage patterns, improving platform features, internal reporting — using anonymised and aggregated data only
Website AnalyticsUnderstanding website visitor behaviour via Google Analytics to improve website content and performance

TWF does not use your personal data for purposes beyond those listed above without obtaining your additional consent.

6. Legal Basis for Processing

Under the DPDP Act, 2023 and the IT Rules, our processing of personal data is based on the following legal grounds:

  • Consent: Where you have given explicit consent at the time of account creation or service activation — for example, for marketing communications or optional analytics;
  • Contractual Necessity: Processing required to fulfil our obligations under your Service Contract or Subscription Agreement — for example, consumption monitoring, billing, and support;
  • Legal Obligation: Processing required to comply with applicable Indian law, regulatory requirements, or lawful orders of courts or government authorities;
  • Legitimate Interests: Processing necessary for TWF's legitimate business interests, such as platform security, fraud prevention, and service improvement — where such interests are not overridden by your data protection rights.
7. Data Sharing & Third Parties

TWF does not sell your personal data. We share personal data only in the following circumstances:

Service Partners & Processors
Third PartyPurposeData Shared
Amazon Web Services (AWS)Cloud hosting and infrastructure for the TWF platform and data storageAll platform data including consumption readings, account data, and usage data
Razorpay / PayU (or equivalent)Payment processing for subscriptions and AMCTransaction amount, customer name, contact details for payment initiation. Full card/bank details are handled by the gateway only
Google AnalyticsWebsite usage analyticsAnonymised website visitor behaviour data, IP address (pseudonymised), device and browser data
SMS / Email ProvidersDelivering service notifications, OTPs, and alertsMobile number and/or email address only
TWF-Authorised Installation PartnersOn-site installation and maintenance at Customer premisesSite address and contact name for scheduling purposes only
Disclosure to Authorities

TWF may disclose personal data to government authorities, law enforcement agencies, or courts when required to do so by applicable law, court order, or lawful direction from a competent authority. TWF will endeavour to notify affected users of such disclosure where legally permitted to do so.

Business Transfers

In the event of a merger, acquisition, or sale of all or part of TWF's business, personal data may be transferred to the successor entity. Users will be notified of any such transfer through the platform and this Policy will be updated accordingly.

No Other Sharing

TWF does not share personal data with advertisers, data brokers, or any third party for commercial profiling or targeted advertising purposes.

8. Payment Data

TWF uses authorised third-party payment gateways (Razorpay, PayU, or equivalent) to process all financial transactions. The following applies:

  • TWF does not store, retain, or have access to your full debit card, credit card, or bank account numbers. These are entered directly into the payment gateway's secure environment;
  • TWF receives only transaction confirmation, reference numbers, and payment status from the payment gateway;
  • For automated recurring payments (e-NACH, UPI Autopay, e-Mandate), the mandate details are held by your bank or the payment gateway under their own compliance framework. TWF does not store mandate credentials;
  • Payment data is processed by the gateway in compliance with PCI-DSS standards. TWF is not responsible for the security practices of the payment gateway;
  • For payment-related disputes or queries, contact the payment gateway directly or raise a support ticket with TWF at support@thewaterfirm.com.
9. Cookies & Analytics
What Are Cookies

Cookies are small text files placed on your device by websites you visit. They are used to make websites work, improve user experience, and provide analytics information to website operators.

Cookies We Use
TypePurposeCan Be Disabled?
Essential CookiesSession management, authentication, security. Required for the platform to function. Cannot be disabled without breaking core functionality.No
Analytics Cookies (Google Analytics)Tracking website visitor behaviour, pages visited, traffic source, and usage statistics on www.thewaterfirm.com. Data is pseudonymised and aggregated by Google Analytics before being shared with TWF.Yes
Preference CookiesRemembering your language, region, and display preferences.Yes
Google Analytics

TWF's website uses Google Analytics, a service provided by Google LLC. Google Analytics collects data about your website visit using cookies and transmits it to Google servers, which may be located outside India. Google uses this data to compile reports for TWF on website activity. Google may also use this data for its own purposes under Google's Privacy Policy. To opt out of Google Analytics tracking, you may install the Google Analytics Opt-out Browser Add-on.

Managing Cookies

You may disable non-essential cookies through your browser settings or through our cookie consent tool on the website. Disabling analytics cookies will not affect your ability to use the TWF platform or receive the Services.

10. Cross-Border Data Transfer

TWF's platform data is hosted on Amazon Web Services (AWS). AWS operates data centres globally and your data may be processed on servers located outside India, including in regions such as Singapore, the United States, or other AWS regions.

Similarly, Google Analytics processes website visitor data on Google's global infrastructure, which may include servers outside India.

TWF acknowledges its obligations under the DPDP Act, 2023 regarding cross-border transfer of personal data. Where the Government of India, through notification, restricts transfer to specific countries, TWF will comply with such restrictions. We rely on the contractual terms and security standards of AWS and Google, which include appropriate safeguards for international data transfers.

Your data is processed in accordance with TWF's instructions regardless of where AWS or Google infrastructure is located. TWF remains responsible as Data Fiduciary for the protection of your personal data at all times.
11. Data Retention
Data CategoryRetention Period
Account & Identity DataFor the duration of the active service relationship, and for 3 years after account closure or contract termination, for legal and compliance purposes
Water Consumption DataFor the duration of the active contract, and for 2 years after contract termination. Aggregated, anonymised consumption data may be retained indefinitely for analytical purposes
Payment & Billing Records7 years from the date of transaction, as required under Indian accounting and tax law
Support & Communication Data2 years from the date of the last communication
Website Analytics Data (Google Analytics)As per Google Analytics default retention settings (typically 14 months). TWF does not independently retain raw website analytics data
Legal & Regulatory RecordsAs required by applicable law, which may exceed the above periods

After the applicable retention period, personal data will be deleted or anonymised. TWF does not guarantee retrieval of data after the retention period has elapsed.

Data on subscription lapse: Where a subscription is suspended or terminated due to non-payment, data captured during the active period prior to suspension is retained per the above schedule. Data not captured during the suspension period cannot be recovered.
12. Your Rights Under DPDP Act 2023

Under the Digital Personal Data Protection Act, 2023 and the IT Rules, you have the following rights with respect to your personal data:

Right to Access
Request a summary of the personal data TWF holds about you and the purposes for which it is being processed.
Right to Correction
Request correction of inaccurate or incomplete personal data. You may update most account data directly through the Platform.
Right to Erasure
Request deletion of your personal data where it is no longer necessary for the purpose it was collected, subject to legal retention obligations.
Right to Grievance Redressal
Raise a grievance with TWF's designated Grievance Officer at support@thewaterfirm.com. TWF will respond within 30 days of receiving your grievance.
Right to Withdraw Consent
Withdraw consent for processing based on consent, at any time. Withdrawal does not affect processing carried out before withdrawal or processing based on other legal grounds.
Right to Nominate
Nominate another individual to exercise your data rights on your behalf in the event of your death or incapacity, as permitted under the DPDP Act.
How to exercise your rights: Submit a written request to support@thewaterfirm.com. TWF will respond within a reasonable timeframe as required under applicable law. Some rights may be subject to conditions — for example, erasure may not be possible where data must be retained for legal or contractual purposes.
13. Security

TWF implements reasonable technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These include:

  • Encrypted data transmission (HTTPS/TLS) between devices and the platform;
  • Encrypted storage of sensitive data at rest on AWS infrastructure;
  • Role-based access controls ensuring that TWF staff access only the data necessary for their function;
  • Regular security reviews of the platform and infrastructure;
  • Password hashing — TWF does not store plaintext passwords.
No system is completely secure. While TWF takes reasonable steps to protect your data, we cannot guarantee absolute security. In the event of a data breach that is likely to cause harm to you, TWF will notify affected users and the relevant authorities as required under applicable Indian law.
Data Loss — Liability

TWF's liability for any loss, corruption, or unavailability of data is governed by the Limitation of Liability section in TWF's Terms & Conditions.

14. Children's Data

TWF's Platform and Services are not directed at children under the age of 18. TWF does not knowingly collect personal data from minors. If you are a Building Admin who provides resident data to TWF, you confirm that the data you provide relates to individuals who are 18 years of age or older, or that you have the necessary parental or guardian consent where a user is under 18.

If TWF becomes aware that it has collected personal data from a minor without appropriate consent, it will take steps to delete that data promptly. Contact support@thewaterfirm.com if you have concerns about a minor's data.

15. Updates to This Policy

TWF may update this Privacy Policy from time to time to reflect changes in our data practices, applicable law, or business operations. The current operative version is always available at www.thewaterfirm.com/policies/privacy-policy. Updates take effect upon publication. For material changes, TWF will make reasonable efforts to notify active users via platform notification or email. It is your responsibility to review this Policy periodically.

16. Grievance Officer & Contact

In accordance with the IT Rules and the DPDP Act, 2023, TWF has appointed a Grievance Officer to address privacy-related complaints and queries:

Grievance Officer — TheWaterFirm
NameMohammed Azam
DesignationDirector & Grievance Officer / Data Protection Contact
Response TimeWithin 30 days of receipt of grievance
Address#85, SV Arcade Building, Brigade Millennium Road, JPNagar 7th Phase, Bengaluru, Karnataka 560076
TheWaterFirm — Perisync Technologies Pvt Ltd  ·  Bengaluru, Karnataka, India
Version 1.0  ·  www.thewaterfirm.com/policies/privacy-policy

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