Notice & Consent
Privacy notice published, cookie consent banner, granular consent capture, withdrawal mechanism, and a maintained consent log.
Data Management
ROPA, data inventory, purpose limitation, minimization, retention timelines, and anonymization of personal data attributes.
Data Subject Rights
Access, rectification, erasure, restriction, portability, objection, and rights around automated decision-making.
Security of Processing
Access restriction, encryption at rest and in transit, periodic VAPT, WAF, audit logging, and timely security updates.
Accountability
Documented roles, data protection policy, periodic training, monitoring & review, ROPA, DPIA, and prior consultation.
Privacy in SDLC
Change management approvals, environment segregation (dev / test / prod), and no production data used in testing.
Data Protection Officer
DPO appointed, independent, reporting to top management, with the resources, training and expertise to act.
Disclosure & Subprocessors
Data Processing Agreements executed with all third parties; integrations expose only the minimum personal data required.
International Transfers
Transfers protected by Standard Contractual Clauses, adequacy decisions, and approved codes of conduct.
1. Our role: processor, not controller
FireAI operates as a data processor on behalf of its customers (data controllers). Purpose, scope, and attributes of personal data processed are defined by the controller; the personal data we process is non-sensitive in nature. Customer data is handled in a transient manner and is not persistently stored beyond operational requirements such as caching, logging, or audit.
2. Your rights as a data subject
Data subjects can exercise the rights below by writing to mohit@fireai.in. Our Privacy Policy at fireai.in/privacy documents each of these rights.
- Right to be informed: Clear notice of how personal data is processed, via our Privacy Policy and timely updates.
- Right of access: Obtain a copy of personal data held about you.
- Right to rectification: Request corrections to inaccurate or incomplete data.
- Right to be forgotten: Request deletion where there is no overriding legal basis to retain (Art. 17).
- Right to restrict processing: Limit how we process your data while an objection is reviewed.
- Right to data portability: Receive your data in a structured, machine-readable format.
- Right to object to processing: Object to processing of your personal data.
- Automated decisions & profiling: Rights in relation to automated decision-making and profiling under Art. 22.
3. Notice, consent & cookies
FireAI defines and documents a process to inform users via a Privacy Notice when collecting and processing their personal data, and notifies users of changes to the privacy notice (Art. 12, 13, 14). A cookie consent banner aligned to GDPR requirements lets users accept or decline the cookie policy, and consent records — including the ability to withdraw — are maintained (Art. 7).
4. Data management & minimization
We maintain Records of Processing Activities (ROPA) and a Data Asset inventory capturing the type, source, and category of personal data, along with retention schedules (Art. 30). Personal data attributes are minimized to what is required for the controller's stated purpose, and access is granted and revoked through a documented process (Art. 5, 17, 18, 21). Anonymization and de-identification are applied wherever possible.
5. Retention & deletion
Retention timelines are defined contractually with the customer and aligned with applicable law (Art. 5). Personal data from the application is deleted as per the defined timelines and when the client requests deletion; otherwise the data is retained throughout the duration of the contracted service. FireAI does not generate insights from personal data of data subjects through aligned processing activities — insights generated relate only to application performance and availability.
6. Security of processing
Security controls audited by Aegisra Assurance LLP against Art. 32 include:
- Encryption at rest: Personal data stored in the product and its databases is protected with a secure level of encryption.
- Encryption in transit: All client–server communication is protected with TLS.
- Access restriction: Access to personal data is restricted to authorized personnel only.
- Web Application Firewall: A WAF is deployed to protect the product from malicious attacks.
- Vulnerability assessment: Periodic VAPT is performed; critical vulnerabilities are patched without undue delay.
- Backups: Critical data in the product and its databases is backed up on a periodic basis.
- Audit logging: Audit logs are enabled on all systems and can be extracted across products.
- Secure integrations: Backend integrations use secure APIs and web services with appropriate security measures.
- Timely security updates: Security updates are released promptly when vulnerabilities or enhancements are identified.
7. Breach notification
FireAI notifies the relevant customer (data controller) of a personal data breach within 48 hours of becoming aware of it, unless the breach is unlikely to result in a risk to the rights and freedoms of data subjects (Art. 33). Where a breach is likely to result in a high risk to data subjects, communication to affected individuals follows without undue delay (Art. 34).
8. Privacy in the SDLC
Privacy is built into how the product is engineered. Proposed changes affecting how personal data is processed require management approval before development begins (Art. 35). Development, test, and production environments are segregated; access to production is restricted to authorized personnel; and no production data is used in test environments. Privacy assessment findings are mitigated in a timely manner.
9. DPIA & prior consultation
Periodic Data Protection Impact Assessments are conducted, and identified medium and high risks are treated in a timely manner (Art. 35). Where a DPIA indicates that processing would result in a high risk in the absence of measures to mitigate the risk, the supervisory authority is consulted prior to processing (Art. 36).
10. Data Protection Officer
FireAI has appointed a Data Protection Officer who operates independently and reports directly to the highest management level (Art. 37–38). The DPO has the necessary expertise, professional competence, resources, and training, and is accessible to data subjects and supervisory authorities. Reach the DPO at mohit@fireai.in.
11. Disclosures & subprocessors
Data Processing Agreements are executed with all third parties that may access personal data processed by the application (Art. 28). Integrations with third-party services — including analytics engines — expose only the minimum necessary personal data attributes, and processor contracts require compliance with data protection regulations.
12. International transfers
Personal data transferred outside the EU is protected through Standard Contractual Clauses or binding corporate rules (Art. 44, 46). Transfers to jurisdictions outside the applicable jurisdiction are made only where the level of protection is adequate (Art. 45). FireAI adheres to approved codes of conduct and certifications as a mechanism to demonstrate compliance with GDPR for international data transfers (Art. 40, 42).
13. Note on applicability
Two controls were marked Not Applicable in the audit. FireAI does not collect personal data of children below the legal age, so the parental consent control (Art. 8) does not currently apply. FireAI does not have clients in the EU currently, so an EU representative (Art. 27) has not been appointed.