Last updated: April 20, 2026. This policy explains what data SmartAqua collects, why we collect it, and the rights you have over that data under Indian law.
SmartAqua ("we," "our," "us") respects your privacy and is committed to protecting the personal data we hold about you. This Privacy Policy describes how we collect, use, share, and safeguard information when you use our website, mobile application, and IoT-enabled water purifier service ("Services"). This policy is governed by the Digital Personal Data Protection Act, 2023 ("DPDP Act") and other applicable Indian laws.
SmartAqua is a water purifier subscription service operating in India. The data fiduciary under the DPDP Act 2023 is SmartAqua. Any reference to "Company" in our Terms and Conditions also applies here.
You can reach our Data Protection Officer ("DPO") at support@smartaquapurifiers.com or by calling +91 99999 99999.
2.1 Information you provide directly:
2.2 Information collected automatically from the SmartAqua App:
2.3 Information collected from the IoT purifier:
We process your personal data only for specified, lawful purposes:
3.1 To create and manage your subscription, install your device, and deliver the Services.
3.2 To monitor device health, schedule proactive service, and replace filters before they degrade.
3.3 To send transactional notifications — payment reminders, service schedules, device alerts.
3.4 To provide customer support and resolve service requests.
3.5 To comply with legal obligations, including KYC, GST, and consumer protection requirements.
3.6 To improve our Services through aggregated, de-identified analytics.
3.7 To send marketing communications — only with your consent, which you can withdraw at any time.
4.1 Your SmartAqua purifier continuously sends operational telemetry (water volume, TDS readings, filter health, temperature, connectivity status) to our secure cloud platform.
4.2 Telemetry data is used strictly for: (a) monitoring device health and scheduling service, (b) validating active subscription status on the device, (c) improving future device firmware.
4.3 Telemetry data is not used to build a behavioural profile of you, and is not sold or shared with advertisers.
4.4 All device-to-cloud communication is encrypted in transit using TLS 1.2 or higher.
4.5 You can request a copy of your raw telemetry data at any time by emailing support@smartaquapurifiers.com.
The SmartAqua App requests only permissions that are functionally required:
5.1 Location (approximate): to match you to service technicians and confirm service coverage.
5.2 Bluetooth: to locate and pair with your purifier during initial setup and local diagnostics.
5.3 Notifications: to alert you about payment, service, or device events.
5.4 Camera (optional): only when you scan the device QR code during onboarding or upload a complaint photo.
You can revoke any permission at any time through your device settings. Revoking required permissions may affect some functionality.
6.1 Our website uses strictly necessary cookies for session management and functional cookies for preference storage.
6.2 We may use basic analytics (page views, referring source) to understand how our website is used. These are aggregated and do not identify you personally.
6.3 We do not use third-party advertising cookies and do not sell any website behaviour data.
6.4 You can disable cookies through your browser settings.
We share your personal data only in these limited scenarios:
7.1 Service providers (Data Processors): payment gateways, SMS providers, cloud infrastructure, and certified installation technicians — all bound by data-processing agreements.
7.2 Legal requirements: in response to a lawful request from a court, regulator, or law-enforcement authority under Indian law.
7.3 Business transfer: in the event of a merger, acquisition, or asset sale, customer data may be transferred to the acquiring entity subject to the same privacy protections.
7.4 We do not sell personal data to third parties for advertising, marketing, or data-broker purposes.
8.1 Active subscriber data is retained for the duration of your subscription plus 7 years thereafter, as required by Indian tax and consumer protection laws.
8.2 KYC documents (Aadhaar reference, address proof) are retained for the legally mandated period.
8.3 Device telemetry beyond 24 months is aggregated and de-identified — individual device identifiers are removed.
8.4 You can request earlier deletion of your personal data (see Section 10) subject to our legal retention obligations.
9.1 All data transmitted between your device, our app, our cloud, and our servers is encrypted using TLS 1.2+.
9.2 At-rest data is encrypted using AES-256.
9.3 Access to personal data within our organisation is role-based and logged for audit.
9.4 We conduct periodic security reviews and maintain incident-response procedures.
9.5 In the unlikely event of a data breach affecting you, we will notify you and the Data Protection Board of India as required under the DPDP Act.
As a Data Principal under the DPDP Act, you have the following rights:
10.1 Right to Access: request a summary of personal data we hold about you.
10.2 Right to Correction: ask us to correct inaccurate or out-of-date personal data.
10.3 Right to Erasure: request deletion of personal data no longer needed for the original purpose (subject to legal retention obligations).
10.4 Right to Grievance Redressal: raise a concern about our handling of your data — we will respond within 30 days.
10.5 Right to Withdraw Consent: opt out of marketing communications at any time using the unsubscribe link or by contacting us.
10.6 Right to Nominate: nominate another person to exercise your rights in case of death or incapacity.
To exercise any of these rights, email support@smartaquapurifiers.com with "DPDP Request" in the subject line.
11.1 Our Services are intended for individuals aged 18 and above. We do not knowingly collect personal data directly from children.
11.2 If a subscription is held by a household with minors, the account holder (a consenting adult) is responsible for controlling app access.
11.3 If you believe we have inadvertently collected personal data from a minor, contact us immediately for deletion.
12.1 We may update this Privacy Policy from time to time to reflect changes in our practices or the law.
12.2 Material changes will be notified to you via the SmartAqua App, email, or SMS at least 15 days before they take effect.
12.3 Continued use of our Services after the effective date of an updated policy means you accept the updated policy.
For privacy questions, data requests, or grievance redressal, reach our Data Protection Officer:
Email: support@smartaquapurifiers.com
Phone: +91 99999 99999
WhatsApp: Message our team
You also have the right to lodge a complaint with the Data Protection Board of India if you believe we have not handled your personal data in compliance with the DPDP Act 2023.