Privacy Policy

Blankfil QC · Version 2026-10-29 · Effective 29 October 2026
Draft for legal review. Not yet approved by counsel.

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

3. Why we use it and our legal basis

PurposeLegal basis (GDPR Art. 6)
Providing the Service, accounts, sharing and teamsContract (6(1)(b))
Billing, tax invoices and GST recordsLegal obligation (6(1)(c)) and contract
Audit trail, security and fraud preventionLegitimate interests (6(1)(f)): keeping regulated QC work traceable and the Service secure
Service emails (e.g. team ownership changes)Contract
Marketing emailsConsent (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):

ProviderWhat forLocation
Railway Corp.Hosting and databaseEU (Netherlands); company in the USA
Razorpay Software Pvt. Ltd.Payments, subscriptions, invoicesIndia
Sendinblue SAS (Brevo)Service emailsEU (France)
Anthropic, PBCAI-assisted document reviewUSA
OpenAI, L.L.C.AI-assisted document reviewUSA

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

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:

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.