Privacy Policy

1Controller, ownership and contact information

Ozontrix Technologies is the data controller (referred to as the "data fiduciary" under India's Digital Personal Data Protection Act, 2023) for the personal information described in this policy. Ozontrix Technologies is a wholly-owned venture of Fredx Investments, with its principal place of business in New Delhi, India.

• Privacy and data-protection enquiries: info@ozontrix.com
• Grievance redressal (required under the Digital Personal Data Protection Act, 2023 and the Information Technology Act, 2000): our designated Grievance Officer may be contacted at info@ozontrix.com. We acknowledge every complaint within 48 hours and resolve it within one month (or as otherwise required by applicable law).
• Postal correspondence: Ozontrix Technologies, c/o Fredx Investments, New Delhi, India, India.

2Information we collect

We collect only the personal information reasonably necessary for the purposes described in this policy. The categories of information we may collect include:

A. Information you provide directly

• Identity and contact details — such as your name, email address, telephone number, company name, job title, country of residence, and profile details you submit when creating an account or registering for our services.
• Account and service data — such as usernames, passwords and password hashes, preferences, account settings, and service-related activity.
• Billing and payment data — such as business address, tax identifiers, and transaction summaries. Card numbers are handled by our payment processors and are not stored by us in full.
• Communications — such as the content of messages you send to us (including support requests, sales enquiries, and feedback), and records of our conversations in any medium.
• Application data — such as the résumés, links, portfolios, and other information you submit when applying for roles or engagements with us, including via our careers page (careers@ozontrix.com).
• Survey and event data — such as responses to optional surveys, questionnaires, or event registrations you choose to complete.

B. Information collected automatically

• Device and browser data — such as device type, operating system, browser type and version, language preferences, screen resolution, and similar technical attributes.
• Usage and log data — such as the pages and features you visit or use, referring and exit URLs, search queries, timestamps, clickstream data, and system logs.
• Network and location data — such as Internet Protocol (IP) address, network provider, and an approximate geographic location derived from your IP address.
• Identifiers — such as cookie IDs, analytics identifiers, and other tracking technology identifiers, as described in our Cookie Policy.

C. Information we obtain from other sources

• Business and referral partners — such as contact details passed to us when a client, partner, or referrer recommends you or your company to us.
• Payment and fraud-prevention providers — such as address verification and fraud indicators, where applicable.
• Publicly available sources — such as information you make public on professional networks, websites, or repositories, where relevant to an engagement or application.
• Technical services — such as aggregated usage analytics provided through the analytics tools described in our Cookie Policy.

D. Sensitive personal information

We generally do not request or collect "special categories" of sensitive data (such as racial or ethnic origin, political opinions, religious beliefs, health, biometric, or genetic data). Where processing such information becomes genuinely necessary (for example, in candidate accommodation or statutory reporting), we only do so with your explicit consent or where we are legally permitted or obliged to process it.

3How we use your information

We use personal information for the following purposes, as applicable:

• To provide, operate, maintain, and improve our websites, products, and services — including account creation, authentication, personalisation, and feature delivery.
• To process transactions and payments — including invoices, receipts, renewal reminders, and billing support.
• To communicate with you — including responding to enquiries, providing support, sending service notices, and sending transactional and product-related messages.
• To engage in and perform client work — including project delivery, consulting, design, development, and vendor communication on behalf of our clients.
• To recruit and evaluate candidates — including processing job applications, conducting interviews, and maintaining talent-community records.
• To ensure security and integrity — including preventing fraud, abuse, spam, and security incidents, and protecting our systems and users.
• To analyse and improve — including understanding how our services are used, measuring performance, and developing new features.
• To market and promote — including sending newsletters and product updates where you have opted in or where permitted by law, and measuring campaign effectiveness.
• To comply with law and legal process — including responding to lawful requests, exercising or defending legal claims, and meeting regulatory and audit obligations.

4Legal bases for processing

• Performance of a contract — to provide services you have requested, to manage accounts, and to carry out pre-contractual steps at your request.
• Consent — for direct marketing, optional cookies and tracking, and any processing you have expressly agreed to. Consent may be withdrawn at any time with effect for the future.
• Legitimate interests — for service improvement, analytics, information security, fraud prevention, and reasonable direct communications, balanced against your rights and interests.
• Legal obligation — where processing is necessary to comply with applicable laws, regulations, court orders, or regulatory requests.
• Vital interests — in rare circumstances where processing is necessary to protect someone's life or physical safety.

Where the Digital Personal Data Protection Act, 2023 applies (typically, personal data processed in connection with goods or services offered to individuals in India), we process personal data on the grounds of your consent or a lawful purpose recognised under that Act, and we provide a notice of collection at the time of collection in clear and plain language. Where you decline to provide required information, we may be unable to provide certain services.

5Cookies and similar technologies

Our websites and products use cookies, local storage, and similar technologies to make services work, remember preferences, support security, and (where enabled) measure usage. For full details of the cookies we use, why we use them, and how to control them, please see our Cookie Policy.

6How we share your information

We do not sell personal information and we do not engage in cross-context behavioural advertising. We disclose personal information only in the following circumstances and only to the extent necessary:

• Service providers and processors — such as cloud hosting, infrastructure, email delivery, payment processing, analytics, customer support, AI and machine-learning providers, and professional advisers, who process information on our behalf under written data-processing terms.
• Within our corporate group — to Fredx Investments and other affiliated entities, for shared infrastructure, administration, and reporting, always under obligations consistent with this policy.
• Business transfers — in connection with a merger, acquisition, reorganisation, sale of assets, financing, or insolvency, where personal information may be transferred as a business asset, subject to applicable law.
• Clients, with your direction — when we operate as a processor for a client engagement, we share personal data in accordance with that client's lawful instructions and their own privacy commitments.
• Legal and regulatory authorities — where required by law, regulation, court order, or government request, or where disclosure is reasonably necessary to establish, exercise, or defend legal rights, protect our operations or users, or detect and prevent fraud or security threats.
• Other parties with your consent — in any other case, after informing you and, where required, obtaining your consent.

7International data transfers

Because Ozontrix Technologies operates across continents — with a presence in India, the United States, and Australia — personal information we collect may be transferred to, stored in, and processed in countries other than the one in which you reside, including India, the United States, Australia, and the countries where our service providers operate.

When we transfer personal information from the European Economic Area, the United Kingdom, or Switzerland to countries outside them, we rely on appropriate safeguards, including European Commission or UK adequacy decisions and Standard Contractual Clauses (a copy of which you may request). Where the Digital Personal Data Protection Act, 2023 applies to a transfer of personal data outside India, we rely on the mechanisms and conditions recognised under that Act, including consent and prescribed conditions for cross-border transfer.

8Data retention

• Account and billing records are retained while your account is active and afterwards for the period required to meet legal, tax, and audit obligations.
• Support and communications records are retained for as long as needed to resolve your enquiry and for a reasonable period afterwards for service-quality purposes.
• Application and recruitment records are retained for up to twelve (12) months after the relevant hiring decision, unless you ask us to keep them longer or applicable law requires otherwise.
• Usage logs and analytics are retained in aggregate or de-identified form where possible, and individual identifiers are kept only as long as needed for security and legal purposes.
• We delete or anonymise personal information when it is no longer needed for the purposes for which it was collected, unless retention is required by law, is necessary to establish or defend legal claims, or the information has been de-identified.

9Data security

We implement reasonable technical and organisational measures to protect personal information, including: encryption of data in transit and at rest where practicable; access controls and least-privilege permissions; regular security reviews and monitoring; secure software-development practices; and training for personnel who handle personal information. We maintain an incident-response process so that any personal-data breach is detected, contained, assessed, and — where required by law — reported to regulators and affected individuals. No method of transmission or storage is completely secure; while we work to protect your information, we cannot guarantee absolute security.

10Your privacy rights

Depending on where you live, you may have some or all of the following rights, subject to legal limitations and verification of your identity:

A. General data-protection rights

• Right of access — to receive a copy of the personal information we hold about you, together with details of how it is used.
• Right to rectification — to correct inaccurate or incomplete personal information.
• Right to erasure — to request deletion of your personal information, subject to legal retention requirements.
• Right to restriction — to restrict our processing of your personal information in certain circumstances.
• Right to data portability — to receive your personal information in a structured, machine-readable format, where technically feasible.
• Right to object — to object to processing based on legitimate interests or to direct marketing.
• Rights relating to automated decision-making — not to be subject to decisions with legal or similarly significant effects based solely on automated processing, where applicable.
• Right to withdraw consent — where processing is based on consent, to withdraw it at any time without affecting the lawfulness of processing before withdrawal.

B. Rights under India's Digital Personal Data Protection Act, 2023

• The right to obtain information about the processing of your personal data, including a summary of the personal data processed, the purposes of processing, and the identity of other data fiduciaries or processors with whom your data has been shared.
• The right to request correction, completion, and updating of your personal data.
• The right to request erasure of your personal data where retention is no longer necessary for the specified purpose or required by law.
• The right to withdraw consent previously given, in accordance with the Act.
• The right to grievance redressal through our grievance mechanism, and the right to approach the Data Protection Board of India if you are dissatisfied with our response.

C. Rights under the CCPA/CPRA (California residents)

• The right to know — to request disclosure of the categories and specific pieces of personal information we have collected, the purposes of collection, and the categories of third parties with whom we share it.
• The right to delete — to request deletion of personal information we have collected about you, subject to statutory exceptions.
• The right to correct — to request correction of inaccurate personal information.
• The right to opt out of sale or sharing — we do not sell or share personal information as those terms are defined under the CCPA, so we do not currently offer an opt-out from such activities.
• The right to non-discrimination — we will not discriminate against you for exercising any privacy right, including by denying services, charging different prices, or providing a different level of quality or service.
• Limits on use of sensitive personal information — we only use sensitive personal information, where applicable, for permitted business purposes.
• Minors — we do not knowingly sell or share the personal information of minors under 16 years of age, and we obtain parental consent where applicable law requires it.

D. How to exercise your rights

• Submit a request by email to info@ozontrix.com, describing the right you wish to exercise and the personal information concerned.
• We will verify your identity using reasonable measures (which may include matching information you provide against our records) before acting on your request. Where you submit a request through an authorised agent, we may require proof of authorisation.
• We respond to verified requests within the timeframes required by applicable law (generally within 30 days, extendable in complex cases with notice to you).
• Most requests are free of charge. Where a request is manifestly unfounded, excessive, or repetitive, we may charge a reasonable fee or decline to act, in accordance with applicable law.
• If you are not satisfied with our response, you may lodge a complaint with the relevant supervisory or regulatory authority — for example, your local data-protection authority in the EEA or UK, the Data Protection Board of India, or (for California residents) the California Privacy Protection Agency.

11Children's privacy

Our websites, products, and services are not directed to children under the age of 16 (or 13 in jurisdictions where that is the applicable threshold), and we do not knowingly collect personal information from children. If you believe a child has provided us with personal information without verifiable parental consent, contact us at the address below and we will investigate and delete such information promptly.

12Third-party links and services

Our websites and products may contain links to third-party websites, services, or integrations that we do not control. This policy does not apply to those parties. We encourage you to review the privacy practices of any third party before providing them with your information.

13Do Not Track and Global Privacy Control

Some browsers transmit "Do Not Track" (DNT) signals or support the Global Privacy Control (GPC) signal. Where required by applicable law, we honour such signals when received and respond to GPC requests where required to do so. Because standards for DNT are not yet uniform, we treat DNT signals as a request for increased privacy and minimise tracking wherever technically feasible.

14Automated decision-making and profiling

We may use analytics and profiling techniques to understand usage, improve our services, and detect abuse. We do not use automated decision-making that produces legal or similarly significant effects about you unless (i) it is necessary to enter into or perform a contract with you, (ii) it is authorised by law, or (iii) you have provided your explicit consent. Where our products include AI-assisted output, that output is designed to support — and never replace — independent human judgment and is not used to make decisions that profile you as a data subject.

15Marketing communications

• Where we send marketing or product-update communications, you have the right to opt out at any time using the unsubscribe link in each message or by contacting us.
• We will continue to send non-marketing service and transactional messages (such as billing notices and security alerts) even if you opt out of marketing.

16Changes to this policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or legal requirements. The "Last updated" date at the top of this page indicates when the policy was most recently revised. Where changes are material, we will provide a more prominent notice, such as an email to registered users or a notice on our website, before the change becomes effective. By continuing to use our services after changes take effect, you accept the updated policy.

17Contact us

If you have questions or concerns about this Privacy Policy or our data practices, or if you wish to exercise any of the rights described above, please contact us:

• Email: info@ozontrix.com
• Attn: Privacy & Data Protection Team, Ozontrix Technologies, c/o Fredx Investments, New Delhi, India, India.