Privacy Policy
1. Controller
Cool Max India, Dunetha Road, Nani Daman, Daman – 396210, Union Territory of Dadra and Nagar Haveli and Daman and Diu, India, is the controller of personal data processed through Blankfil QC. Privacy questions and requests: support@blankfil.com.
This policy is written to meet the EU General Data Protection Regulation (GDPR), the UK GDPR and India's Digital Personal Data Protection Act, 2023.
2. What we collect
- Account details: name, username, email, organisation, role, password (stored only as a secure hash).
- Content: documents, QC records, comments and support tickets you create or upload.
- Usage and security records: sign-in times, sampling-run counts, the audit trail of actions in the Service, IP address and browser type.
- Billing: plan, seats, payment status, amounts and invoice references. Card and UPI details are handled by Razorpay; we never see or store full card numbers.
- Consent records: the version of these documents you agreed to, when, from which IP address, and your marketing-email choice.
3. Why we use it and our legal basis
| Purpose | Legal basis (GDPR Art. 6) |
|---|---|
| Providing the Service, accounts, sharing and teams | Contract (6(1)(b)) |
| Billing, tax invoices and GST records | Legal obligation (6(1)(c)) and contract |
| Audit trail, security and fraud prevention | Legitimate interests (6(1)(f)): keeping regulated QC work traceable and the Service secure |
| Service emails (e.g. team ownership changes) | Contract |
| Marketing emails | Consent (6(1)(a)), which you can withdraw any time in your profile |
We do not sell personal data or use your documents to train AI models.
4. Patient data in documents
The Service is not intended for patient-identifiable data. You confirm when you agree to our Terms that you will only upload it if you are authorised and it is lawful to do so. Where documents do contain health data, it is special-category data under GDPR Art. 9, and you, as the uploader's organisation, are responsible for having a lawful condition for processing it. We process it only on your instructions to provide the Service.
5. Where data is stored and who processes it
Our application and database are hosted by Railway in its EU West region (Amsterdam, Netherlands). We use these service providers (sub-processors):
| Provider | What for | Location |
|---|---|---|
| Railway Corp. | Hosting and database | EU (Netherlands); company in the USA |
| Razorpay Software Pvt. Ltd. | Payments, subscriptions, invoices | India |
| Sendinblue SAS (Brevo) | Service emails | EU (France) |
| Anthropic, PBC | AI-assisted document review | USA |
| OpenAI, L.L.C. | AI-assisted document review | USA |
Where data goes outside the EU/EEA, including to India and the USA, we rely on an adequacy decision where one exists (such as the EU–US Data Privacy Framework for certified companies) or the European Commission's Standard Contractual Clauses, with additional safeguards where needed. Document text is sent to an AI provider only when you run an AI review.
6. How long we keep it
- Documents and account details: until you delete them or your account is deleted.
- Invoices and payment records: 8 years, as Indian GST law requires.
- Audit trail and consent records: for the life of the Service, as evidence of regulated QC activity and of your consent. After account deletion these entries keep only the email address recorded at the time.
7. Your rights
You can ask to access, correct, delete, restrict or move your personal data, object to processing based on legitimate interests, and withdraw consent at any time without affecting earlier processing. Many of these you can do in the Service:
- Profile → Privacy & consent shows when you agreed and lets you turn marketing emails on or off.
- "Withdraw consent and delete my account" sends a deletion request. An administrator reviews it and acts within 15 days, which is within the one month GDPR allows. If we have to refuse part of a request, for example to keep invoices, we will tell you why.
For anything else, email support@blankfil.com. You also have the right to complain to a data protection authority in the EU country where you live or work, or to the Data Protection Board of India.
8. Security
Data is encrypted in transit. Passwords are hashed. Sessions expire after inactivity, and access is limited by role. All account and plan changes are written to the audit trail.
9. Cookies
We do not use advertising or analytics cookies. The Service stores your sign-in token and preferences in your browser's local storage, which is strictly necessary for it to work.
10. Changes
When we change this policy we update the version above and ask you to agree again at your next sign-in.