This notice explains how Zpoa Inc ("ZPOA", "we", "us") processes personal data in connection with the ciyora.com website and the Ciyora Fabric service, including Ciyora Console, Ciyora Client and the Ciyora modules. It is written to meet our obligations under the Digital Personal Data Protection Act, 2023 (the "DPDP Act") and the rules made under it.
Our two roles
As a data fiduciary. We decide why and how personal data is processed when you visit this website, write to us, ask for a demo, or hold an account with us as a customer contact or billing contact.
As a data processor. When an organization uses Ciyora Fabric, it decides what data about its employees, contractors, devices and systems is processed, and it is the data fiduciary for that data. We process it only on that customer's documented instructions and under our agreement with them. If you are an employee of one of our customers and have a question about data held about you, please contact your employer first; we will help them respond.
What we collect as a data fiduciary
- Contact details you send us, such as your name, work email address, organization and role.
- The content of your messages, demo requests and support requests.
- Account and billing details for customer administrators and billing contacts.
- Technical data needed to serve this website securely, such as IP address, browser type and request time, kept in server logs for a limited period.
This website does not use advertising or analytics cookies. It stores two preferences in your browser: your colour theme and, on the pricing page, the country you chose. They never leave your device.
Why we use it
- To answer your enquiry, arrange demos and provide the service you have asked for.
- To manage customer accounts, billing and contractual communications.
- To keep this website and the service secure, and to investigate misuse.
- To meet legal obligations, including tax, accounting and lawful requests from authorities.
We process this data on the basis of your consent, which you give when you contact us, or for the legitimate uses permitted by the DPDP Act, such as providing a service you asked for or complying with law. We do not sell personal data, and we do not use it to train general-purpose AI models.
Where data is stored
Ciyora Fabric and this website are hosted on OVHcloud infrastructure; India hosting is being set up. Where personal data is processed outside India, we do so only as the DPDP Act and the rules under it permit, and under contracts that require appropriate safeguards.
How long we keep it
We keep enquiry data for as long as needed to respond and follow up, and customer account data for the term of the contract plus the period required by law. Customer data processed in Ciyora Fabric is retained according to the retention settings the customer chooses and is deleted or returned at the end of the contract as agreed with them.
How we protect it
We apply the safeguards described on our security page, including encryption in transit, tenant isolation, role-based access and a tamper-evident audit trail. If a personal data breach occurs, we will notify the Data Protection Board of India and affected people as the DPDP Act requires, and, where we act as a processor, we will inform the customer without undue delay.
Your rights
Under the DPDP Act you may:
- ask for a summary of the personal data we process about you and how we process it;
- ask us to correct, complete, update or erase your personal data;
- withdraw consent you have given, as easily as you gave it;
- nominate another person to exercise your rights in the event of death or incapacity; and
- have your grievances addressed by us.
If you are not satisfied with our response to a grievance, you may complain to the Data Protection Board of India.
Grievance officer
For any request or grievance about personal data, write to our grievance officer at [email protected]. Please tell us which right you want to exercise and how we can verify your identity. We aim to acknowledge requests promptly and to resolve them within the period set by the DPDP Act and its rules.
Children
This website and Ciyora Fabric are intended for organizations and their staff. We do not knowingly collect personal data from children.
Changes to this notice
We will update this notice when our practices or the law change, and we will change the date at the top. Where a change materially affects how we use personal data you gave us with consent, we will tell you before it takes effect.