Reflexo Privacy Notice

Draft, not legally reviewed. Version privacy-notice-2026-10-18-draft1. To be reviewed by a lawyer before the public launch (BETA_10 §14).

This notice is for shop owners, their staff, and people who write to the Reflexo number. If you are a customer of a shop that uses Reflexo, the shop's own privacy notice applies to you: its link is in the first reply you get.

Who is responsible

HolonCode (Udyam registration UDYAM-GJ-22-0618785), 402, Summer Queen Apartment, Bheem Kachchhi Mohallo, Surat, Gujarat 395001, India, provides Reflexo. For the data in this notice, we are the Data Fiduciary under India's Digital Personal Data Protection Act, 2023 and its Rules.

Grievance officer: Taha Sadikot, privacy@holoncode.in.

What we collect, and why

Data	Why we use it
Your name, phone number, email and shop details	To create and run your account and your shop's assistant
The numbers and accounts you connect (WhatsApp, Instagram, Facebook, Telegram, Razorpay, tools) and their access tokens	To answer your customers on those channels. Tokens are stored encrypted
Your messages to the Reflexo number and in the owner app	To carry out your instructions (prices, rules, approvals) and keep a record of them
Your staff's names, numbers and roles, if you add staff	To route conversations to them
Your choices and consents (the terms you accepted, settings)	To show what you agreed to and when
Usage and cost records (how many messages, AI usage)	To run the service, keep it within limits, and fix problems
Messages from people who write to the Reflexo number without an account	To answer them and help them reach a shop or sign up

We do not sell your data and we do not use it for advertising.

Your customers' data

For your customers' messages and orders, you decide, and we process them for you, as our Seller Terms say. Your customers can read your shop's notice at your shop's privacy page.

Who we share it with

Only the service providers that run Reflexo, listed in the Seller Terms (Google, Deepgram, LiveKit, Meta, Telegram, Razorpay, Amazon Web Services and the tools you connect), and authorities when the law requires it.

How long we keep it

Your account data: while your account is open, and one year after. Logs of processing: at least one year, as the Rules require, and at most 400 days. Records of consent and requests: seven years.

Your rights

You can:

see the data we hold about you, and get a copy;
correct it or complete it;
have it deleted, when we no longer need it by law;
withdraw a consent you gave, as easily as you gave it (a setting, or a message to the Reflexo number);
name someone to act for you if you cannot;
complain to us, and then to the Data Protection Board of India.

To use a right: in the web app (Settings, then Privacy), on the Reflexo number, or by email to privacy@holoncode.in. We answer within 30 days, and aim for 7. See our rights page for details.

Children

Reflexo is for businesses. It is not meant for anyone under 18, and we do not knowingly collect a child's data.

Changes

If we change this notice in a way that matters, we tell you before it applies.