Privacy Policy

1. Introduction

This Privacy Policy ("Policy") explains how Kovention Solutions LLP, a limited liability partnership registered under the laws of India ("Company", "we", "us", "our", "Data Fiduciary") collects, uses, shares, and protects personal data when you use www.keshoo.com and the Keshoo portal (the "Platform").

We act as a Data Fiduciary under the Digital Personal Data Protection Act, 2023 ("DPDPA") and process your personal data in accordance with applicable Indian law. For users in other jurisdictions, we comply with applicable local data protection laws to the extent required.

We follow principles of data minimization, purpose limitation, and privacy by design.

2. Information We Collect

A. Information You Provide

Authentication Data

• Mobile number (to send OTPs for login and account security)

Profile Data

• Name (used for account personalization and invoicing)
• Gender (optional, for language personalization only)

Astrological Data (Required for Services)

• Date of Birth, Time of Birth, Place of Birth
• If you save multiple profiles, you may provide additional chart/profile labels

Voice Data (Optional)

• If you use the voice input feature, audio recordings of your spoken queries are temporarily processed for speech-to-text conversion. Audio is not stored after transcription is complete; only the resulting text transcript is retained as your query input.

Support and Feedback

• Messages you send to support, bug reports, and feedback

B. Information Collected Automatically

• Log/Device Data: IP address, browser type, device identifiers (where available), OS, time zone, pages/events visited, timestamps
• Cookies / Local Storage: Session cookies and/or local storage used to keep you logged in and store preferences
• Security Signals: Failed login attempts, rate limiting, and fraud/abuse detection signals

C. Information About Third Parties

You may enter birth details for individuals other than yourself, including family members, friends, or others. When you do so:

• You represent that you have the legal right to provide this information, or have obtained appropriate consent from the individual
• You accept responsibility for the accuracy and legitimacy of such data
• Keshoo processes this data based solely on your representations; we cannot independently verify consent

We do not use names or directly identifying information in our AI processing—only calculated chart data. This means outputs are associated with "a chart" rather than a named individual.

For minors' data: By entering a minor's birth details, you represent that you are the minor's parent or legal guardian, or have obtained verifiable consent from the parent or legal guardian. You accept responsibility for this data under applicable law.

2A. Lawful Basis for Processing (Legal Grounds)

We process your personal data on the following legal bases:

You may withdraw consent for non-essential processing at any time by contacting us. Withdrawal does not affect the lawfulness of processing conducted prior to withdrawal.

3. How We Use Your Information

We use your data to:

• Provide the Services: Calculate charts and generate outputs
• Authenticate and secure accounts: OTP, fraud prevention, abuse prevention
• Operate and improve the Platform: Performance monitoring, debugging, error resolution
• Communicate with you: Service updates, security notices, transactional messages (e.g., payment confirmations)
• Payments and credits: Process purchases and maintain your Credits balance

AI Training / Model Improvement (Important)

• We do not sell your birth data or use it for third-party advertising.
• By default, we use your data to generate your chart and outputs for you.
• We may use aggregated, de-identified analytics (e.g., feature usage counts, latency, error rates) to improve reliability.
• If we ever introduce an opt-in program to use de-identified user interactions to improve Keshoo's synthesis quality, we will provide clear controls and obtain explicit consent.

AI Processing and Data Separation

When you use our Services:

1. Your birth details (date, time, place of birth) are processed on our servers in India to perform astronomical calculations.
2. Only the calculated chart data (planetary positions, house placements, derived astrological metrics) and your age are transmitted to AI systems for narrative synthesis.
3. Your name, exact birth date, birth time, birth location, and other directly identifying information are NOT sent to third-party AI providers.
4. This architectural separation is designed to protect your privacy while enabling AI-powered interpretations.

Third-Party AI Providers: We use third-party AI services for narrative synthesis. These providers' data processing is subject to their respective privacy policies and data processing terms. Calculated chart data sent to these providers is not linked to your identity.

Voice Input Processing

If you use the voice input feature, your audio recording is transmitted to a third-party speech-to-text service solely for conversion to text. Only the audio recording is sent — your name, birth details, mobile number, and other account information are not shared with this provider. The resulting text transcript is then processed as a standard text query. Audio recordings are not stored by Keshoo or transmitted to any other third party after transcription is complete.

Birth Place Lookup

When you search for a birth location, your search text is sent to a third-party geocoding service to return matching locations and geographic coordinates. No other personal data is included in these requests.

4. "No Selling" Policy

We are explicit:

• We do not sell your personal data.
• We do not rent your birth details.
• We do not share your personal data with data brokers.
• We do not use your data for third-party targeted advertising.

5. When We Share Information

We share data only in limited, necessary circumstances:

5.1 Service Providers (Processors)

All processors are bound by data processing agreements and confidentiality obligations.

5.2 Legal Requirements

We may disclose information when required by law, regulation, court order, or government authority, or to:

• Comply with legal process
• Protect our rights, property, or safety
• Prevent fraud or illegal activity
• Enforce our Terms and Conditions

5.3 Business Transfers

In the event of a merger, acquisition, or sale of assets, your data may be transferred to the successor entity. We will provide notice if a materially different privacy policy will apply.

5.4 With Your Consent

We may share data in other circumstances with your explicit consent.

5.5 What We Never Do

• We never sell your personal data
• We never share your data with data brokers
• We never use your data for third-party advertising
• We never share your birth details with third-party AI providers (only calculated chart data)
• We never share your name, birth details, or account information with our speech-to-text provider
• We never link AI-generated outputs to named individuals—charts are processed anonymously

6. Data Storage and International Transfers

6.1 Primary Storage

Your personal data is stored on servers located in India.

6.2 International Transfers

In limited circumstances, data may be processed outside India:

• AI synthesis requests: Calculated chart data (not PII) may be processed by our AI providers' infrastructure, which may operate globally.
• Speech-to-text requests: Audio recordings (not PII) are processed by our speech-to-text provider's infrastructure.
• Place lookup requests: Birth place search queries may be processed by our geocoding provider's infrastructure.
• If you access the Platform from outside India, your data is transmitted to our Indian servers.

6.3 Safeguards for International Transfers

Where data is transferred outside India, we ensure appropriate safeguards through:

• Contractual protections with service providers
• Compliance with applicable data transfer mechanisms
• When the Government of India notifies permitted countries under DPDPA, we will ensure compliance with such requirements

6.4 Users Outside India

If you are located in the European Economic Area (EEA), United Kingdom, or other jurisdictions with data protection laws:

• We process your data based on your consent
• You have additional rights as described in Section 8
• Our legal basis and safeguards are designed to meet applicable requirements

7. Data Retention and Deletion

7.1 Retention Periods

7.2 Deletion Process

You may request deletion of your account and personal data by:

• Using the "Delete Account" feature in account settings, OR
• Emailing support@keshoo.com

Upon receiving a valid deletion request:

• We will verify your identity
• Your account will be deactivated within 7 days
• Personal data will be deleted from active systems within 90 days
• Some data may be retained longer where required by law or for legitimate fraud prevention purposes
• Anonymized/aggregated data that cannot identify you may be retained

7.3 Third-Party and Family Member Data

If you have created profiles for other individuals (family members or others), you may delete individual profiles at any time. Deleting your account will delete all associated profiles you created.

8. Your Rights

8.1 Rights Under Indian Law (DPDPA 2023)

As a Data Principal under the Digital Personal Data Protection Act, 2023, you have the right to:

• Access: Request confirmation of whether we process your data and obtain a summary of your personal data and processing activities
• Correction: Request correction of inaccurate or incomplete personal data
• Erasure: Request deletion of your personal data, subject to legal retention requirements
• Grievance Redressal: Lodge a complaint with our Grievance Officer or the Data Protection Board of India
• Nomination: Nominate another individual to exercise your rights in the event of your death or incapacity

8.2 Additional Rights for Users in Other Jurisdictions

EEA/UK (GDPR):

• Right to data portability
• Right to restrict processing
• Right to object to processing
• Right not to be subject to automated decision-making
• Right to lodge a complaint with your local supervisory authority

California (CCPA/CPRA):

• Right to know what personal information is collected
• Right to delete personal information
• Right to opt-out of sale/sharing (Note: We do not sell your data)
• Right to non-discrimination for exercising your rights

8.3 How to Exercise Your Rights

To exercise any of your rights, contact us at:

• Email: support@keshoo.com or grievance@keshoo.com
• We will respond within 30 days (or shorter if required by applicable law)
• We may need to verify your identity before processing your request

8.4 Rights Regarding Third-Party Data You Entered

If you entered birth details for another individual and that individual contacts us to exercise their data rights (access, correction, deletion), we will:

• Verify their identity to the extent possible
• Notify you of the request
• Comply with valid requests in accordance with applicable law

You acknowledge that individuals whose data you have entered may have independent rights to request deletion of their information.

9. Security

We use reasonable security safeguards including:

• Encryption of data in transit (TLS/SSL)
• Encryption of sensitive data at rest (PII encryption)
• Access controls and authentication
• Reputable hosting providers
• Regular security assessments

No system is 100% secure; we cannot guarantee absolute security.

10. Personal Data Breach

If we become aware of a breach involving personal data, we will:

• Take reasonable steps to investigate and mitigate
• Notify affected users when required by applicable law
• Notify regulators (including the Data Protection Board of India) when required by applicable law

11. Children's Privacy

11.1 Direct Use by Minors

Keshoo is not intended for direct use by individuals under 18 years of age. We do not knowingly allow minors to create accounts. If we become aware that a minor has independently created an account, we will terminate the account and delete associated data.

11.2 Charts for Minors Created by Adults

The Platform allows adult users (parents/guardians) to create astrological charts for their minor children as part of profiles. When doing so:

• The adult user represents they have parental authority or guardian consent
• The adult user is responsible for the accuracy of the minor's data
• The adult user controls access to and deletion of the minor's profile
• We process this data based on the adult's consent on behalf of the minor

11.3 Parental Rights

Parents or legal guardians may:

• Review data entered for their minor children
• Request correction or deletion of such data
• Contact us at support@keshoo.com for any concerns

11.4 Age Verification

We rely on the user's self-declaration of age during registration. We do not independently verify age but may request verification if we have reason to believe a user is a minor.

11A. Cookies and Tracking Technologies

11A.1 What We Use

11A.2 Analytics

We use Google Analytics on our marketing website to understand how visitors interact with our site. This service may collect:

• Pages visited and time spent
• Referring website
• General location (country/city level)
• Device and browser type

We have enabled IP anonymization for additional privacy. Analytics cookies are only loaded after you provide consent via our cookie banner.

11A.3 Your Choices

When you first visit our marketing website, you will see a cookie consent banner. You can accept or decline analytics cookies. Your choice is stored locally and remembered for future visits.

Most browsers also allow you to refuse or delete cookies. However, disabling essential cookies may prevent the Platform from functioning correctly.

11A.4 Do Not Track

We do not currently respond to "Do Not Track" signals as there is no industry standard for compliance.

12. Third-Party Links

The Platform may contain links to third-party websites. We are not responsible for their privacy practices.

13. Changes to This Policy

13.1 We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors.

13.2 For material changes, we will:

• Update the "Last Updated" date at the top of this Policy
• Provide notice via email or in-app notification at least 7 days before changes take effect
• Where required by law, obtain your consent to material changes

13.3 Your continued use of the Platform after the effective date of changes constitutes acceptance of the updated Policy. If you do not agree with changes, you may delete your account before the effective date.

13.4 We encourage you to review this Policy periodically.

14. Contact and Grievance Officer

For privacy-related inquiries:

General Support: support@keshoo.com

Grievance Officer (pursuant to DPDPA 2023, IT Act 2000, and Consumer Protection E-Commerce Rules 2020):

• Name: Kalpana Vyas
• Email: grievance@keshoo.com
• Address: 59, Sharda Soc, Paldi, Ahmedabad, Gujarat, India

The Grievance Officer shall:

• Acknowledge your complaint within 48 hours
• Resolve complaints within 30 days from receipt
• Provide you with information on escalation to the Data Protection Board of India if you are unsatisfied with the resolution

For users in the EEA: You may also lodge a complaint with your local data protection supervisory authority.