What we hold, why, and how to get rid of it

Zern is operated by [registered entity name to be published], with its registered office at [registered address to be published].

For privacy questions, write to privacy@zern.ai. If you are not satisfied with the answer, the grievance officer named in section 11 is the next step.

Under India’s Digital Personal Data Protection Act, whoever decides why personal data is being used is the data fiduciary. There are two separate relationships here.

• Your own account data — your name, email, phone, the business you described, your billing details. We decide how this is used, so we are the data fiduciary for it and this policy governs it directly.
• Your leads’ data— the people who filled in your Facebook or Instagram lead form, or messaged you from an ad. You decide why they are being contacted. You are the data fiduciary; we are your data processor, acting on your instructions and nobody else’s.

From you, our customer:

• Your name, email address and phone number, so you can sign in and be told when a lead turns hot.
• What you told us about your business — what you sell, your price range, service areas and working hours — because the agent needs it to answer questions truthfully.
• The Facebook and WhatsApp accounts you connect, and the access tokens for them. Tokens are encrypted at rest and never written to a log.
• Billing details, held by our payment provider rather than by us.

About your leads, on your behalf:

• Name, phone number and email address as submitted to your lead form, or the phone number attached to a WhatsApp message.
• The answers they gave on your form, and the ad, ad set and campaign the enquiry came from.
• The full WhatsApp conversation between them and your agent, including anything they sent us.
• What the agent worked out from that conversation — their answers to your qualification questions, their score, and why it scored that way.
• Notes, tasks, call outcomes and tags your team adds while working the lead.

We do not buy lists, we do not enrich a lead from third-party data sources, and uploading a cold list is blocked in the product. Every lead in Zern got there by submitting your form, clicking your ad, or opting in directly.

• To send the first WhatsApp reply within seconds of the enquiry arriving, and to keep the conversation going.
• To ask your qualification questions, score the answers and hand the strong leads to your rep with a summary.
• To follow up over the next two weeks if the lead goes quiet, within the limits described in your own agent settings.
• To tell Facebook that a lead qualified, so your ads are optimised towards people who buy rather than people who fill in forms. What we send is described in section 6.
• To show you what happened — reply times, qualification rates, what your messages cost.
• To keep the service running, bill you correctly, and investigate a problem when you report one.

We use it for those things and nothing else. We do not sell personal data, we do not share it for anyone else’s advertising, and we do not use your data or your leads’ conversations to train shared AI models. If we ever want to, we will ask you first and you will be able to say no.

This is the most sensitive thing we can do, so it gets its own section rather than a clause buried in a list.

We keep those audit records for the life of your account and you can ask us for the entries relating to your account at any time.

Running the product means a handful of other companies process some of this data for us. These are all of them.

• Meta— WhatsApp messages are sent and received through Meta’s WhatsApp Business Platform, and lead form submissions come from Facebook and Instagram. When a lead qualifies we also send Meta a conversion signal so your ads improve. That signal carries the identifier Meta already gave us for that lead, or a cryptographic hash of the phone number and email — never the conversation itself, never the score, never your notes.
• Anthropic— the agent’s replies are generated by Anthropic’s Claude models. The conversation so far, your business description and your qualification questions are sent to generate each reply. Anthropic does not train its models on this data.
• Supabase — our database, sign-in and file storage.
• Razorpay — subscription payments. They see your billing details. They never see lead data.

Beyond that, we disclose personal data only when the law actually requires it, and we will tell you when we can. If the business is ever sold or merged, your data moves with it under this same policy, and you will be told before it happens.

No lead ever crosses from one customer’s account to another. That separation is enforced in the database itself, on every single query, rather than by application code remembering to filter — so a bug in the application cannot leak one customer’s leads into another’s screen.

If you are an agency working across several client accounts, your staff see exactly the client accounts they have been granted, and nothing else.

Your data is hosted in [hosting region to be published]. Some of the companies in section 6 process data outside India as part of delivering their service; where that happens it is covered by their own contractual protections, which we hold.

Access tokens and other credentials are encrypted at rest. Credentials are never written to our logs.

• Conversations and lead records are kept for 24 months by default. You can shorten that to as little as 3 months in your account settings, and the change applies to data you already hold, not only to new leads.
• Past that point the conversation content is permanently deleted. We keep a minimal record that a lead existed and how it was counted for billing, because we have to be able to justify an invoice.
• If you close your account, everything is permanently deleted after a 30-day grace period. The grace period exists so a closure by mistake can be undone.
• Records we are legally required to keep — tax and invoice records, chiefly — are kept for as long as that law requires and nothing longer.

Under the Digital Personal Data Protection Act you can ask us to:

• Tell you what personal data we hold about you and who we have shared it with.
• Correct anything that is wrong or incomplete.
• Delete it.
• Nominate someone to exercise these rights for you if you cannot.
• Raise a grievance, and get an answer.

Start any of these at zern.ai/data-deletion or by writing to privacy@zern.ai. We respond within 30 days. There is no charge.

If your data is in Zern because a business you enquired with uses us, we will act on your request and also pass it to that business, since they are the ones who decided to contact you.

If something about how we handle your data is wrong and an email to privacy@zern.ai has not fixed it, this is the named person responsible.

We set one kind of cookie: the one that keeps you signed in. There is no advertising cookie, no third-party tracker and no analytics pixel on this site, so there is no consent banner to click through.

Zern is a tool for businesses and is not intended for anyone under 18. We do not knowingly process a child’s personal data. If you believe a lead in our system is a child, tell us and we will delete it.

When this policy changes materially we will email account owners before it takes effect, and the date at the top of this page will move. Continuing to use Zern after that date means the new version applies.