Privacy Policy

This policy covers purchases made through this interim checkout on behalf of ProdGem. It is deliberately narrower than ProdGem's own eventual platform privacy policy, because this flow collects far less data — there is no account, no password, and no browsing/analytics tracking. Where this policy is silent, read it as “we don't do that here.”

1. Who We Are

This checkout is operated by RAMSIO CLOUDSERVE INFOTECH PRIVATE LIMITED (CIN: U62091KA2025PTC210162), registered at #36, WeWork Prestige Central, Infantry Road, Bengaluru, Karnataka 560001, India. GST: 29AAPCR1639E1Z3. We are a data fiduciary under India's Digital Personal Data Protection Act 2023, and a data controller under GDPR for users in the European Economic Area.

2. Information We Collect

Because this is a one-time purchase flow with no account creation, we collect only:

• Payment/order information: your email, the product(s) purchased, order amount, Razorpay payment reference, and purchase timestamp. We never store card numbers or CVVs — Razorpay handles that entirely within its own PCI DSS Level 1 checkout.
• Delivery record: which download link was generated and when, and whether it's been used, solely so a fresh one can be issued if needed.
• Redownload request logs: if you use the redownload form, we log the email and timestamp (rate-limited) purely to prevent abuse of that form.

We do not collect passwords, browsing/analytics data, or marketing-consent cookies. Razorpay's own checkout page may set cookies necessary to process your payment — those are governed by Razorpay's own privacy policy, not this one.

3. How We Use Your Data

• To verify your payment and deliver your purchased product
• To generate a GST-compliant invoice, sent separately
• To send your download links, and fresh ones on request
• To prevent abuse of the redownload flow
• To keep the records Indian tax law requires

We never use your email for marketing unless you separately opt in elsewhere — purchasing here does not add you to any mailing list.

4. Legal Basis for Processing (GDPR Article 6)

For EEA users: contract performance (Art. 6(1)(b)) for order delivery, legal obligation (Art. 6(1)(c)) for tax records, and legitimate interests (Art. 6(1)(f)) for abuse prevention. For Indian users: consent given at checkout, and legitimate use under the DPDP Act 2023.

5. Your Rights

There's no account or dashboard in this flow — exercise any right by emailing our Grievance Officer (§10): access, erasure (tax records are anonymised rather than deleted outright, per §7), rectification of an email tied to an order, or withdrawal of consent. We respond within 30 days.

6. Sub-processors

• Razorpay (IN): payment processing, PCI DSS Level 1
• Cloudflare (global): file storage and delivery, SOC 2 + ISO 27001
• Resend (US): delivery and redownload emails, SOC 2

We do not sell, rent, or share your data with anyone for their own marketing.

7. Data Retention

Order records: 8 years, per Indian GST Act compliance. Redownload request logs: 90 days, then deleted.

8. Cross-Border Transfers

Data may transfer to our sub-processors in the United States, governed by the DPDP Rules (transfers only to non-blocked countries) and, where applicable, GDPR Standard Contractual Clauses. Card data never leaves Razorpay's infrastructure.

9. Children's Data

This product is not directed at children under 13 (globally) or under 18 without verifiable parental consent (India DPDP Act Rule 10).

10. Grievance Officer

Santhosh Suryavanshi
Email: grievance@prodgem.com
Phone: +91 91106 18988
Address: #36, WeWork Prestige Central, Infantry Road, Bengaluru 560001, Karnataka, India

We acknowledge requests within 3 business days and respond within 30 days.

11. Security

Files are delivered via single-use, time-limited tokens — never a permanent public link. All data in transit is encrypted via TLS. Redownload requests return the same response regardless of whether an email matches a real purchase, to prevent probing for who has bought what.

12. Policy Changes

We may update this policy to reflect changes in our practices or applicable law. The “Last updated” date above will change accordingly.