Your data. Your control. Transparent AI processing.
Zappio, operated by CODIQUBE TECHNOLOGIES (OPC) PRIVATE LIMITED ("Zappio", "we", "us", or "our"), provides AI-powered calling, messaging, lead qualification, CRM automation and related business communication services.
This Privacy, Data & AI Policy explains what information Zappio processes, how that information is used, how it is protected, how artificial intelligence interacts with the information, and what choices customers have regarding their data.
This Policy applies to customers, authorised users, and individuals whose information is processed through the Zappio platform on behalf of a customer.
This Policy covers information processed through:
This Policy primarily addresses how Zappio processes data in connection with the Services.
Specific contractual obligations, commercial terms, customer responsibilities, acceptable-use requirements, payment terms, liability, indemnification, suspension and termination rights are governed separately by the Zappio Terms & Conditions and applicable Service Agreement.
Depending on how the customer uses Zappio, we may process the following categories of information.
This may include:
Customers may upload or connect lead information to Zappio for calling, messaging, qualification and follow-up.
This may include:
Zappio's application and authorised technical systems may nevertheless process such information where necessary to provide the Services.
When Zappio places or manages AI-assisted calls, we may process:
Depending on the customer's configuration, Zappio may process:
When a customer connects Zappio with another platform, we may process information necessary to perform the requested integration.
This may include information from:
We may collect:
Payments may be processed through third-party payment providers.
Zappio does not intentionally store raw payment-card information where payment processing is handled directly by the applicable payment provider.
Zappio may use information for the following purposes.
We process data to:
Zappio may use information generated through the Services to:
Zappio may process information to:
Zappio may analyse usage patterns, system performance and interaction data to improve:
Zappio may process and retain information where necessary to comply with applicable laws, regulations, legal processes, governmental requests or lawful orders.
AI training and improvement is a fundamental component of Zappio's product development.
Unless the customer opts out, Zappio may use relevant customer-generated data for AI training, testing, evaluation and improvement.
This may include:
Zappio may use learning derived from one customer's use of the platform to improve Zappio's general AI capabilities and services made available to other customers.
For example, learning from conversation patterns, language usage, objection handling and qualification behaviour may contribute to improvements in Zappio's general AI systems.
Where Zappio provides customer-specific AI configuration, Zappio may use customer data to maintain, evaluate and improve that customer's AI configuration and workflows.
Such customer-specific configuration does not prevent Zappio from independently improving its general platform and AI capabilities.
Zappio may create aggregated, anonymised or otherwise de-identified information from data processed through the Services.
Information that no longer reasonably identifies a customer or individual may be retained and used indefinitely for:
If customer data has already been incorporated into:
an opt-out or subsequent deletion request does not automatically require Zappio to reverse or remove those technical improvements where doing so is technically impracticable.
AI training and model improvement is enabled by default.
Once an opt-out becomes effective:
For enterprise customers, the applicable AI training preference may additionally be documented in the Service Agreement or DPA.
Zappio may allow authorised members of its technical, engineering, support or quality assurance teams to access customer data, including call recordings, transcripts and conversation data, when reasonably necessary for:
Zappio personnel do not routinely monitor customer calls in real time.
Where human review of recorded calls or conversation data is required, access is limited to authorised personnel and is subject to appropriate confidentiality and access-control requirements.
Customer lead/contact information is protected separately through application-level encryption and access controls designed to prevent ordinary Zappio employees from viewing the underlying contact details.
The customer retains its rights and ownership in data supplied by the customer or processed by Zappio on the customer's behalf, subject to the rights granted to Zappio under the applicable agreements and this Policy.
Customer data may include:
Nothing in this Policy transfers ownership of:
Zappio retains the right to use aggregated, anonymised and otherwise permitted learnings and technical improvements generated through operation of the platform.
Customers are responsible for ensuring that they have the necessary rights, permissions, notices and lawful basis to provide personal data to Zappio and instruct Zappio to process it.
Customers are responsible for:
Zappio uses third-party infrastructure and technology providers to operate the Services.
These may include providers for:
Depending on the service, providers may include or change over time from providers such as:
Zappio may update or replace providers where reasonably necessary to operate or improve the Services.
Some third-party AI providers may process customer data to provide AI or infrastructure services to Zappio.
Depending on the applicable provider, service, account configuration and provider terms, a third-party provider may use submitted information for its own model improvement or training purposes.
Customers acknowledge that third-party providers operate under their own terms, policies and technical controls.
Zappio will use reasonable commercial efforts to select and manage service providers appropriate for the Services, but Zappio does not control the internal systems or policies of independent third-party providers.
Zappio's primary application data and customer data infrastructure is hosted on servers located in India.
Zappio currently uses Indian cloud infrastructure for primary storage.
However, certain third-party technology providers used to provide specific Services may process information in jurisdictions outside India.
Accordingly, Zappio does not represent that every item of data transmitted through every third-party service will always remain physically within India.
Where applicable, cross-border processing will be handled in accordance with applicable law and contractual or technical safeguards appropriate to the relevant processing activity.
Zappio uses technical and organisational controls designed to keep customer environments separated.
Customer information is logically isolated between customers.
Zappio employees do not have ordinary access to customer-uploaded contact details where those details are protected by the applicable application-level encryption.
Access to other customer data, including recordings and transcripts, is restricted to authorised personnel and systems where reasonably necessary.
Different categories of information are retained for different periods because they serve different operational, legal and AI-related purposes.
Following account termination, customer lead/contact data used for calling, messaging and operational workflows will generally be retained for up to 30 days to allow for account closure, export and operational handover.
After the applicable period, such data will be permanently deleted, subject to legal, security, fraud-prevention or other lawful retention requirements.
Call recordings and transcripts may be retained after account termination where necessary for:
The retention period for recordings and transcripts may therefore differ from the retention period applicable to customer lead/contact data.
Aggregated or anonymised information that cannot reasonably identify a customer or individual may be retained indefinitely.
Certain information may be retained for longer periods where required for:
Customers may request deletion of eligible customer data by contacting: connect@zappio.in
Following account termination, customer lead/contact data will generally be deleted after the applicable 30-day transition period.
Deletion does not necessarily require deletion of:
Where deletion is legally required and technically feasible, Zappio will process the applicable deletion request in accordance with applicable law.
Customers can export their available customer data through the Zappio platform.
Depending on the features enabled and the type of data involved, exports may include:
Zappio implements technical and organisational security measures designed to protect information against unauthorised access, alteration, disclosure, misuse or destruction.
Measures may include:
If Zappio becomes aware of a confirmed security incident affecting customer data, Zappio will take reasonable steps to:
Zappio will notify affected customers without undue delay where required by applicable law or contractual commitments.
Where reasonably practicable, Zappio will provide information concerning the known nature, scope and remediation of the incident.
Nothing in this section limits Zappio's obligation to comply with mandatory regulatory reporting requirements.
Certain cyber incidents may be subject to specific reporting requirements under Indian law, including CERT-In requirements.
Zappio provides technology and infrastructure for AI-assisted calling.
Customers remain responsible for ensuring that their calling campaigns comply with applicable laws, regulations, telecom requirements and customer-consent requirements.
This includes responsibility for:
Zappio may provide technical controls intended to assist customers with compliance.
TRAI's commercial-communications framework addresses unsolicited commercial communications and the roles of senders/principal entities and registered telemarketers. Customers should ensure their campaigns satisfy the requirements applicable to their particular communication activity.
Zappio's Services may involve AI-generated or AI-assisted conversations and call recording.
Customers are responsible for configuring and conducting campaigns in accordance with applicable disclosure, consent and recording requirements.
Zappio may provide or introduce functionality supporting AI disclosures, recording notices and related compliance requirements.
The absence of a particular automated disclosure feature in the platform does not transfer the customer's legal responsibilities to Zappio.
Zappio may provide WhatsApp and other messaging automation through applicable third-party platforms.
Customers are responsible for:
Zappio may pause, restrict or terminate messaging activity where it reasonably believes that a campaign violates applicable law, third-party platform requirements or Zappio's Terms & Conditions.
Message delivery, messaging limits, account quality ratings and other platform-level restrictions may be determined by third-party messaging providers and are not fully controlled by Zappio.
Customers may connect Zappio to third-party CRMs, lead portals or other systems.
When an integration is enabled:
Customers should review the privacy and security practices of any third-party platform they connect to Zappio.
Zappio may generate:
Customers are responsible for reviewing and appropriately using AI-generated outputs, particularly where the outputs involve:
Zappio does not independently verify the accuracy or legality of customer-provided campaign instructions, scripts, offers or claims.
Zappio may suspend, restrict or disable access to calling, messaging, AI or other functionality where reasonably necessary to:
Where appropriate, Zappio may suspend an individual campaign without immediately terminating the customer's entire account.
Serious or repeated violations may result in account termination in accordance with the applicable Terms & Conditions.
Depending on the applicable law and the individual's relationship with the customer or Zappio, individuals may have rights relating to their personal data.
These may include, where applicable:
Where Zappio processes data on behalf of a customer, requests relating to that customer's lead or end-user data may need to be directed through the relevant customer, because the customer determines the purpose and context of that processing.
Zappio will reasonably assist customers with applicable requests where required under the applicable agreement or law.
Requests to Zappio may be sent to: connect@zappio.in
Zappio's Services are business-oriented and are not designed to intentionally target children.
Customers must not knowingly upload or use Zappio to process children's personal data where doing so would violate applicable law.
If Zappio becomes aware of unlawful processing involving children's data, it may take appropriate corrective action, including deletion or suspension.
Zappio's primary infrastructure and storage is located in India.
Certain third-party technology providers may process information outside India as part of providing their services.
Where cross-border processing occurs, Zappio will take reasonable steps to ensure that such processing is conducted under applicable contractual, technical and legal safeguards.
Customers acknowledge that third-party providers may independently determine the location of certain processing activities within their infrastructure.
If Zappio undergoes a merger, acquisition, restructuring, sale of assets or similar transaction, customer information may be transferred as part of the transaction.
Where required, Zappio will provide appropriate notice.
Any successor entity will remain subject to applicable contractual and legal obligations concerning the information transferred to it.
Zappio may also change infrastructure, technology providers or service providers where reasonably necessary to operate or improve the Services.
Enterprise customers may request or be provided with a separate Data Processing Agreement.
Where a DPA, Service Agreement or Order Form contains specific data-processing obligations that conflict with this Policy, the applicable contractual document will govern to the extent of the conflict.
Enterprise-specific requirements may include:
Zappio may update this Policy from time to time to reflect:
Material changes may be communicated through the Zappio platform, email or other reasonable means.
The latest version will be made available on the Zappio website.
As part of onboarding, customers are required to review and acknowledge this Privacy, Data & AI Policy together with the applicable Zappio Terms & Conditions before activating the relevant Services.
By activating or continuing to use the Services, the customer acknowledges that it has reviewed this Policy and understands:
For questions regarding this Policy, data processing, deletion, export, AI training preferences or privacy matters, contact:
CODIQUBE TECHNOLOGIES (OPC) PRIVATE LIMITED
Last Updated: 25 September 2026