Privacy Policy

Last updated: 19 May 2025  ·  Effective: 19 May 2025

This Privacy Policy describes how Joule & Torr Private Limited ("Company", "we", "us", or "our") collects, uses, stores, and protects your personal data when you use Spire ("Platform", "Service") at spire.buzz. This policy is compliant with the Digital Personal Data Protection Act, 2023 (DPDP Act) and applicable Indian law.

By using Spire, you consent to the collection and use of your data as described in this policy.

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1. Who We Are

Data Fiduciary: Joule & Torr Private Limited
Contact: jouleandtorr@gmail.com

2. Data We Collect

We collect the following categories of personal data:

• Profile data you provide: Job title, city, years of experience, current CTC, industry, company size, current company name
• Contact data: Your name, mobile number (collected before blueprint unlock)
• Payment data: Transaction ID, payment status (processed via Razorpay — we do not store card or bank details)
• Usage data: Pages visited, actions taken, timestamp of interactions
• Device data: IP address, browser type, operating system (collected automatically)

We do not collect sensitive personal data such as financial account numbers, passwords, biometric data, or government ID numbers.

3. How We Use Your Data

We use your data to:

• Generate your salary diagnosis, career benchmark, and Career Blueprint
• Process payments and issue transaction confirmations
• Improve the accuracy of our salary and skills benchmarking data (in aggregated, anonymised form)
• Send you service-related communications (not marketing unless you opt in)
• Comply with legal obligations
• Prevent fraud and abuse of the platform

We do not use your data for automated profiling that produces legal or similarly significant effects without your knowledge.

4. Legal Basis for Processing

Under the DPDP Act 2023, we process your personal data on the following grounds:

• Consent: You explicitly provide your data to receive the diagnosis and blueprint
• Contract performance: To deliver the paid service you have purchased
• Legitimate interests: To improve the platform and prevent misuse
• Legal compliance: Where required by applicable law

5. Data Sharing

We do not sell, rent, or trade your personal data. We share data only in the following limited circumstances:

• Razorpay: Payment processing. Subject to Razorpay's Privacy Policy.
• OpenAI: Your career profile data is sent to OpenAI's API to generate your diagnosis, blueprint, and coaching responses. OpenAI processes this as a data processor under API terms. Data is not used to train OpenAI models under current API agreements.
• Google (Sheets/Apps Script): Lead data (name, phone, company, profile) is stored in Google Sheets as an interim data store.
• Vercel: Our hosting provider processes request data for deployment and performance.
• Legal authorities: Where required by law, court order, or government directive.

All third-party processors are required to handle your data in accordance with applicable data protection law.

6. Data Storage and Retention

Your data is stored on servers within the United States (Vercel/AWS infrastructure) and processed via services that may be located outside India. By using Spire, you consent to this cross-border transfer.

We retain your data for as long as necessary to provide the service and comply with legal obligations, typically no longer than 24 months from your last interaction. You may request deletion at any time (see Section 8).

7. Data Security

We implement appropriate technical and organisational measures to protect your personal data, including:

• HTTPS encryption for all data in transit
• Access controls limiting who within our team can access personal data
• No storage of payment card or bank account details on our servers

No method of transmission over the internet is 100% secure. We cannot guarantee absolute security but will notify you of any significant data breach as required by law.

8. Your Rights Under DPDP Act 2023

As a data principal under the DPDP Act 2023, you have the right to:

• Access: Request a summary of personal data we hold about you
• Correction: Request correction of inaccurate or incomplete data
• Erasure: Request deletion of your personal data (subject to legal retention requirements)
• Grievance redressal: Lodge a complaint with our Grievance Officer
• Withdraw consent: Withdraw consent at any time (this will not affect prior processing)

To exercise any of these rights, email us at jouleandtorr@gmail.com with the subject line "Data Rights Request". We will respond within 30 days.

9. Grievance Officer

In accordance with the DPDP Act 2023 and Information Technology Act 2000, the details of our Grievance Officer are:

Name: Grievance Officer, Joule & Torr Private Limited
Email: jouleandtorr@gmail.com
Response time: Within 30 days of receiving the complaint

10. Cookies

Spire uses minimal cookies — primarily session cookies required for the platform to function. We do not use third-party advertising cookies. You can disable cookies in your browser settings, though this may affect platform functionality.

11. Children's Privacy

Spire is intended for professionals aged 18 and above. We do not knowingly collect data from individuals under 18. If you believe a minor has submitted data to us, please contact us and we will delete it promptly.

12. Changes to This Policy

We may update this Privacy Policy from time to time. The updated version will be posted at spire.buzz/privacy with a revised "Last updated" date. Continued use of the platform after changes constitutes acceptance of the revised policy.

13. Contact Us

For any privacy-related queries:
Joule & Torr Private Limited
jouleandtorr@gmail.com