Ettivo is an advertising analytics platform for lending businesses in India. This policy explains what personal data we handle, why, who we share it with, and what you can do about it. It is written to be read, not to be survived.
Ettivo handles two kinds of personal data, and our responsibility differs for each. Under India's Digital Personal Data Protection Act, 2023, these map to the roles of Data Fiduciary and Data Processor.
| Data | Our role | What that means |
|---|---|---|
| Account data — the people at a client business who sign in to Ettivo | Data Fiduciary | We decide why and how this is processed, and we answer to you directly for it. |
| Enquirer data — people who submitted a lead form on our client's advertisement | Data Processor | The client business is the Data Fiduciary. We process it only on their documented instructions. If you submitted a loan enquiry and want it corrected or deleted, the lender you enquired with is the right first contact, and we will assist them. |
Name, email address, role within the workspace, workspace name, and any logo the workspace uploads. Passwords are handled by our authentication provider and are stored only as salted hashes; we never see or store a password in readable form.
We read campaign, ad set and ad performance figures from advertising platforms the client connects, such as Meta and Google: spend, impressions, clicks, reach, frequency, results, campaign and creative names, budgets, delivery status and account settings. This is business data, not personal data. We store a daily history of it so performance can be compared over time.
Where a client business chooses to route its advertising enquiries through Ettivo, we process, on that client's behalf: name, phone number, email address if given, the answers submitted on the advertiser's lead form, the consent text shown at the time and the identifier of the exact form version that displayed it, the time of submission, which campaign and advertisement the enquiry came from, and the outcome the client's team later records.
Server logs recording request times, error diagnostics and the internal identifiers needed to keep the service working. We do not use advertising cookies and we do not track visitors across other websites.
We do not sell personal data. We do not share it for anyone else's advertising. We do not use enquirer data to build profiles for our own purposes.
Ettivo uses a large language model to turn advertising figures into readable analysis. We think you should know exactly what that model receives.
No decision that produces a legal or similarly significant effect on an individual is made by that model. It comments on advertising performance; it does not assess people, and it plays no part in any lending decision.
We use a small number of service providers, each processing data on our instructions under contract.
| Provider | What it does | Data involved |
|---|---|---|
| Supabase | Database, authentication and file storage | Account data, enquirer data, stored performance history |
| Vercel | Application hosting and delivery | Technical and request data in transit |
| OpenAI | Generates the written analysis | Advertising performance data only — see section 4 |
| Meta, Google | Sources of advertising data the client connects | We read from them; we do not send them enquirer data |
Some of these providers operate infrastructure outside India, so personal data may be processed abroad. We disclose personal data to a public authority only where the law requires it.
No system is perfectly secure. If a breach occurs that is likely to affect you, we will notify affected clients and the Data Protection Board of India as the law requires.
Under the Digital Personal Data Protection Act, 2023 you may ask us to confirm what personal data we hold about you and how it is processed; correct or complete inaccurate data; erase data we no longer need; nominate someone to exercise your rights if you die or become incapacitated; and raise a grievance.
Where you gave consent, you may withdraw it at any time; withdrawal does not undo processing already carried out lawfully.
If you submitted a loan enquiry: the lender you enquired with holds that data and decides what happens to it. Contact them first. If you cannot reach them, write to us and we will identify the correct business and pass your request on.
If you are not satisfied with how we handle a grievance, you may complain to the Data Protection Board of India.
Write to privacy@ettivo.com for any question about this policy, to exercise a right, or to raise a grievance. We aim to acknowledge within 72 hours and to resolve grievances within 30 days.
Ettivo is operated from India. Our registered entity details and named grievance officer are available on request and will be listed here.
If we change how we handle personal data we will update this page and move the date at the top. Where a change materially affects you, we will tell account holders directly rather than relying on you noticing.