Privacy Policy

Last updated: 28 May 2026

Respawn Technologies Private Limited ("PRIMO", "we", "us", "our") respects your privacy. This Privacy Policy explains what personal data we collect, how we use it, who we share it with, and the choices you have. It applies to our website, WhatsApp, and home-service interactions. We comply with the Digital Personal Data Protection Act, 2023 (DPDPA) and the Information Technology Act, 2000 and its rules.

The short version: We collect your photos, contact details, and address only to deliver our consultation and home service. We never sell your data. We do not post your photos publicly without your written consent. You can ask us to delete everything any time.

1. Data We Collect

Identity & contact: name, phone, email, WhatsApp number.
Scalp photos: the 6 photos you upload for consultation, plus any progress photos taken during home visits.
Address: your home address for service delivery.
Payment metadata: handled by Razorpay. We receive only the order ID and status; we do not store your card or UPI details.
Communication history: WhatsApp messages, emails, and call notes with our team.
Website usage: standard cookies and analytics (page views, device type, referrer).

2. How We Use Your Data

To assess whether PRIMO is right for you and provide our founder consultation.
To schedule, deliver, and improve your home installation and monthly service.
To process payments and refunds.
To send service updates, appointment reminders, and account notices.
To respond to support requests and grievances.
To meet our legal, accounting, and tax obligations.

We do not use your scalp photos for advertising, public marketing, or social media without separate written consent from you.

3. Legal Basis

We process your data based on (a) your consent given at signup, (b) the contract you enter when booking a service, and (c) legal obligations such as tax and consumer protection laws.

4. Who We Share Data With

Hair-system manufacturers: we share head measurements and hair specs (never your photos or identity) to produce your custom unit.
Field experts: the barber or technician assigned to your visit receives your name, address, and phone. Every team member has signed a confidentiality agreement.
Razorpay: for payment processing.
Cloud and software vendors: AWS / Google Cloud for hosting, WhatsApp Business API for messaging, accounting and analytics tools — all bound by data-protection terms.
Authorities: when required by law (court orders, tax notices, government requests).

We never sell, rent, or trade your personal data.

5. Data Storage & Security

Your data is stored on encrypted servers in India. We use TLS in transit, access controls on all internal systems, and regular backups. Photos are stored in a private bucket with signed URLs and are not publicly accessible.

6. Retention

We keep your account data for as long as you are an active customer plus 3 years thereafter, for warranty and legal reasons. Scalp photos are kept while you are an active customer; you can request earlier deletion at any time. Invoices and tax records are retained for 8 years as required by Indian law.

7. Your Rights

Under the DPDPA you have the right to:

Access a copy of the personal data we hold about you.
Correct any data that is wrong or out of date.
Withdraw consent and request deletion.
Nominate someone to exercise these rights on your behalf if you are unable to.
File a grievance with our Grievance Officer (see below) and, if unresolved, with the Data Protection Board of India.

To exercise these rights, email privacy@useprimo.in. We respond within 30 days.

8. Cookies

We use a small set of cookies to keep you logged in, remember site preferences, and measure traffic. You can disable cookies in your browser, but parts of the site may stop working.

9. Children

PRIMO is for adults only. We do not knowingly collect data from anyone under 18. If you believe a minor has provided us data, contact us and we will delete it immediately.

10. Changes to This Policy

We may update this policy from time to time. The "Last updated" date at the top reflects the latest change. Material changes will be communicated by email or WhatsApp.

11. Grievance Officer

In line with the IT Act, 2000 and the DPDPA, 2023:

Rohan Jagdish Nayak
Grievance Officer & Director, Respawn Technologies Private Limited
Email: grievance@useprimo.in
WhatsApp: +91 98334 96915

Respawn Technologies Private Limited
301, Kitty Park CHS Ltd, Bawdi Cross Lane,
Nr. Medona Building, Valnai Orlem,
Malad West, Mumbai 400064, Maharashtra
GSTIN: 27AANCR2609A1ZL