Data Processing Agreement
This Data Processing Agreement forms part of the agreement between Prisello Private Limited and the Customer relating to the Customer's use of DigiPix Flow.
Last updated 25 September 2026
1. Roles of the parties
DigiPix Flow is a software-as-a-service product owned and operated by Prisello Private Limited (CIN U47912UP2023PTC193074).
For the personal data a Customer uploads or captures into its workspace — leads, contacts, companies, deals, messages, files and form submissions — the Customer is the controller and Prisello Private Limited is the processor.
For the Customer's own account and billing data, and for the usage and security telemetry needed to operate the platform, Prisello Private Limited is the controller. That processing is described in the Privacy Policy.
2. Processing instructions
We process Customer personal data only on the Customer's documented instructions. The agreement, this DPA and the Customer's use of the product's own features are those instructions.
We do not sell Customer personal data, and we do not use it to train models or to build profiles for any purpose other than delivering the service the Customer asked for.
If we believe an instruction breaches applicable data protection law, we will say so rather than carry it out silently.
3. Subject matter and duration
The subject matter is the provision of the CRM service. Processing lasts for the term of the subscription, plus the limited period described under Return and deletion.
The categories of data subject are the Customer's own leads, contacts and customers, and the Customer's staff who use the workspace.
- Identification and contact data — names, phone numbers, email addresses, company
- Commercial data — enquiries, deal stage, proposals, order values
- Communications — email, WhatsApp and SMS content exchanged through the platform
- Files and form submissions the Customer or its leads upload
- Technical data — IP address, device and access logs, for security and audit
4. Confidentiality
Personnel authorised to process Customer personal data are bound by confidentiality obligations and are granted access only where their role requires it.
Access is role-based and logged. Administrative access to production is limited to named operators.
5. Security measures
We maintain technical and organisational measures appropriate to the risk. The measures currently in place are described below.
No certification is claimed. Where a Customer requires an independent audit or a specific certification, that is addressed in a separate written agreement.
- Tenant isolation — each workspace's records live in its own database schema, not a shared table filtered by an ID column
- Encryption in transit (TLS) and at rest for the database, object storage and backups
- Role-based access control inside the product, with a permission catalogue enforced server-side
- Multi-factor authentication available on every plan, and required for platform operators
- Append-only audit logging of administrative and data-access events
- Automated backups with restore testing
- Secrets held in a managed secrets store, never in source control
6. Subprocessors
Prisello Private Limited engages the subprocessors below to deliver the service. Each is bound by a written agreement imposing data protection obligations no less protective than this DPA.
We will give notice of any new subprocessor before it begins processing Customer personal data, so that a Customer has the opportunity to object on reasonable data protection grounds.
Some subprocessors are engaged only where the Customer enables the corresponding feature — for example the WhatsApp or SMS channels.
- Amazon Web Services — hosting, database, object storage, backups (India region)
- Amazon SES — outbound and inbound transactional email
- Amazon End User Messaging — SMS delivery
- Meta Platforms — WhatsApp Business messaging and Lead Ads capture, where enabled
- Google — Ads lead-form capture and account sign-in, where enabled
- Razorpay — subscription payments and mandates
- Cloudflare — anti-abuse checks on public forms
7. International transfers
Customer personal data is hosted in India. Where a subprocessor processes data outside India, that transfer is covered by an appropriate transfer mechanism in our agreement with them.
Customers with data residency requirements beyond this should raise them before onboarding so they can be addressed in writing.
8. Data subject requests
The product includes a data-privacy request tool that lets a Customer's administrator locate, export or erase an individual across their whole workspace — leads, contacts, messages, files and captured form payloads — without needing to contact us.
Where a data subject approaches us directly about a Customer's records, we do not action the request ourselves. We identify the workspace and refer the individual to the Customer, who is the controller, and assist the Customer in responding.
9. Personal data breach
We will notify the Customer without undue delay after becoming aware of a personal data breach affecting their data, and in any case within the timeframe required by applicable law.
The notification will describe the nature of the breach, the categories and approximate volume of data affected, the likely consequences, and the measures taken or proposed. Where the full picture is not yet available, we will provide information in phases rather than delay the first notice.
10. Return and deletion
On termination the Customer may export their data from the product. After the subscription ends, the workspace moves to a read-only state for a limited window so that an accidental lapse is recoverable, and is then permanently deleted along with its stored files.
We retain only what the law requires us to keep — for example invoices and completed transactions — together with the audit record that a deletion occurred. That audit record notes that data was removed; it does not preserve the data that was removed.
Suppression fingerprints are retained in one-way hashed form so that an unsubscribe or STOP continues to work after deletion. Discarding them would let the next import start contacting the same person again.
11. Audit and compliance
On reasonable written request, and no more than once a year unless required by a supervisory authority, we will make available the information reasonably necessary to demonstrate compliance with this DPA.
Where a Customer requires an on-site audit, the scope, timing and cost are agreed in writing in advance and are subject to confidentiality.
12. Contact
Questions about this DPA, requests for a countersigned copy, and subprocessor objections can be sent to privacy@digipixflow.com.
Write to privacy@digipixflow.com with your workspace name and the entity that should be named as controller, and we'll return an executed copy.