Privacy Policy

1. Who we are

The SVS service ("SVS", "the Service"), offered as The Bill Pro at thebillpro.in, is provided by The Bill Pro, a [[private limited company / limited liability partnership]] incorporated in India ([[CIN / LLPIN]]), with its registered office at [[REGISTERED OFFICE ADDRESS]] ("we", "us").

Contact for anything in this policy, including requests and grievances: support@thebillpro.in. Our grievance officer is named in §11.

2. Who this policy is about, and our role

SVS is business software for cable TV and broadband operators. Three groups of people are involved, and our role differs between them:

Whose data	Examples	Our role under the DPDP Act 2023
Operators: the businesses that subscribe to SVS, and their contact people	business name, GST number, address, contact person, phone, email	Data Fiduciary
Operator users: the operator's staff who sign in to SVS	name, username, phone, optional email, role, sign-in records	Data Fiduciary
Subscribers: the operator's own customers, and people the operator deals with (MSOs, suppliers)	see §3.3	Data Processor, acting only on the operator's instructions. The operator is the Data Fiduciary.

If you are a subscriber of a cable or broadband operator, your operator decides what it records about you and why, and is responsible for telling you and, where needed, obtaining your consent. Please contact your operator first. If you contact us, we will pass your request to your operator and help them answer it (§9).

3. What we collect

3.1 About operators and operator users (we are the fiduciary)

• Account and business details: operator name, GST number, address, logo, and the name, phone number and email of contact people; billing and subscription records for the Service.
• User accounts: full name, username, phone number, email (optional), role, the branch (Sub-LCO) a user belongs to, and account status.
• Sign-in credentials: passwords are held only by our identity service (a self-hosted Logto instance that we run in our own cloud account). They are stored as one-way salted hashes; we cannot read them.
• Security and usage records:
  • sign-in events, with time, IP address and browser details, in the identity service's logs;
  • for every request to the Service, our cloud provider's request logs record the IP address, browser details, time, and the full web address requested, including search terms typed into the Service (which can include a subscriber's name or phone number);
  • our own application logs record the type of request, the operator and user it was for, its outcome and timing, but not search terms or record contents;
  • error reports, with the same identifiers.
• Support: what you send us at support@thebillpro.in.

We do not use advertising or analytics tools, and we do not sell personal data.

3.2 Cookies and similar technologies

Cookie / storage	Set by	Purpose	Kind
Session cookie on thebillpro.in (encrypted, HttpOnly)	the Service	keeps you signed in	strictly necessary
Session and sign-in cookies on our sign-in domain	our identity service	sign-in, single sign-out	strictly necessary
googtrans	Google's translation widget, on our domain	remembers the language you picked	functional; set only when you choose a language

There are no analytics or advertising cookies. Strictly necessary cookies cannot be switched off without the Service ceasing to work.

3.3 About subscribers and other people (we process for the operator)

Operators enter and store, among other things:

• name, date of birth, gender, photograph;
• address, email, mobile and alternate phone numbers;
• an identity document (an image or PDF the operator uploads);
• GST number, electricity board number, post number, CAF number;
• connection, set-top-box and card numbers, packages and plans;
• bills, payments, dues, collection records;
• complaints and their notes;
• SMS messages composed for the subscriber and their delivery log;
• for MSOs and suppliers: business names, contact people, phone numbers, emails, addresses.

We process this data only to provide the Service to that operator: storing it, displaying it to that operator's authorised users, computing bills and reports, and producing exports the operator asks for. Each operator's data is isolated from every other operator's at the database level.

4. Why we use personal data, and on what basis

Purpose	Data	Basis
Provide the Service under the operator's contract	§3.1, and §3.3 as processor	the contract with the operator; the operator's own lawful basis for §3.3
Sign-in, security, abuse and fraud prevention, investigating incidents	sign-in records, request and application logs	legitimate use / legal obligation (DPDP Act s.7; IT Act 2000)
Billing the operator for the Service	operator billing details	the contract; tax law (GST)
Support and service communications	operator and user contact details	the contract
Backups and disaster recovery	everything above	keeping the Service available and the data safe
Translation, only when a user chooses a language	the text on screen at that moment	the user's request (see §5)

We do not use personal data for marketing to subscribers, profiling, or automated decisions about people.

5. Who we share it with

We do not sell or rent personal data. These third parties receive personal data when the Service runs:

Third party	What they receive	Where	Why
Google Cloud (Google Cloud India Private Limited / Google LLC)	all Service data: hosting, database, file storage, backups, logs, error reports, secrets	India only: Mumbai (asia-south1) and Delhi (asia-south2)	infrastructure provider; processes on our instructions
Google Translate website widget (Google LLC)	only when a user picks a language: the text of the page being translated, which can include subscriber names, addresses and phone numbers shown on screen, plus the user's IP address and browser details	Google's global infrastructure; may be outside India	translating the interface on the user's request
Google Fonts (Google LLC)	on every page load: the user's IP address and browser details, when the browser fetches font files (no cookies, and no page content)	Google's global infrastructure; may be outside India	displaying text in Indian scripts
Our email provider for support@thebillpro.in: [[EMAIL PROVIDER]]	what you send to that address	[[EMAIL PROVIDER LOCATION]]	answering support and privacy requests

We may also disclose personal data where Indian law requires it (for example, a lawful order of a court or government authority), and to a successor if the business is transferred, subject to this policy.

Not yet in use: SMS messages are not sent through any gateway today; the Service records them only. When an SMS gateway is connected, it will receive subscriber phone numbers and message text, and this policy will be updated first.

6. Where data is stored, and transfers outside India

All Service data, including backups, logs and uploaded files, is stored in Google Cloud in India (Mumbai and Delhi). The only flows that can leave India are the two in §5 that a user's browser makes directly to Google: translation (only when a user chooses a language) and font files (IP address and browser details). We transfer personal data outside India only to countries the Government of India has not restricted under s.16 of the DPDP Act.

7. How long we keep it

Data	Kept
Operator account, user accounts, subscriber data and uploaded files	for as long as the operator's subscription is active
After the subscription ends	the operator may ask for an export within 30 days; we then delete the operator's data within 90 days of the subscription ending, unless the law requires us to keep part of it
Our invoices and payment records for the Service	as long as tax law requires (GST: at least the statutory period)
Request and application logs, error reports	30 days (to change: see the note below)
Identity-service sign-in logs	[[RETENTION — to be configured]]
Database backups	automated backups: 7 days; point-in-time recovery: 7 days; nightly disaster-recovery copy: 30 days, plus up to 7 days in soft-deleted state
A deleted uploaded file	recoverable for 7 days, then permanently deleted

Deleted data disappears from backups only as they expire, within the periods above. During that time it is not used for anything except restoring the Service after a failure.

Note for review: from May 2027, DPDP Rule 6(1)(e) requires security logs to be kept for one year. Our log retention will be extended before then.

8. Security

• All traffic is encrypted in transit (HTTPS). Data at rest is encrypted by our cloud provider.
• Each operator's data is isolated by database-enforced row-level security; one operator's users cannot read another's.
• Access within an operator follows the roles the operator assigns (six roles, with branch-level restrictions).
• Passwords are hashed by the identity service; sessions can be revoked.
• Uploaded files are private, can be read only by the uploading operator's signed-in users, and are stored in two Indian regions.
• Backups are tested by restoring them.
• Access to production systems is limited to named administrators.

No system is perfectly secure. If a personal data breach affects you, we will tell you, and the Data Protection Board of India where required, as the law requires (DPDP Rule 7). Where we act for an operator, we notify that operator without delay so it can notify its subscribers.

9. Your rights

Operators and operator users can, by writing to support@thebillpro.in:

• get a summary of the personal data we hold about them and how it is used;
• have it corrected, completed or updated;
• have it erased, where we no longer need it and no law requires us to keep it (an operator's admin can also deactivate users directly in the Service);
• withdraw consent where we rely on it (this does not affect the contract basis);
• nominate another person to exercise these rights if they die or become incapacitated;
• raise a grievance (§11), and then complain to the Data Protection Board of India.

Subscribers: please contact your operator, which controls your data. If you write to us, we will forward your request to your operator within 7 days and help the operator respond.

We may need to verify your identity before acting on a request.

10. Children

The Service is for businesses. Operator users must be at least 18 years old. We do not knowingly process personal data of children (under 18) as a fiduciary. Operators must not record a child as a subscriber unless they have obtained verifiable consent from the child's parent or lawful guardian, as the DPDP Act requires.

11. Grievance officer

[[GRIEVANCE OFFICER NAME]], [[designation]], The Bill Pro, [[REGISTERED OFFICE ADDRESS]] — support@thebillpro.in

We acknowledge grievances within 3 working days and resolve them within 30 days, which is within the limit under the IT (Reasonable Security Practices) Rules 2011 and well within the 90-day limit under DPDP Rule 14.

12. Changes to this policy

We will post any change here with a new effective date. For a material change, we will tell operators by email or in the Service at least 15 days before it takes effect.