Effective date: 3 September 2026
Last updated: 8 October 2026
1. Who we are
Truffl is a brand operated by Oravio AI Private Limited ("Truffl", "Oravio", "we", "us" or "our").
Registered office:
Flat No. 024, B-Block, No. 97/2, DS Max Signature,
Devinagar Main Road, Near LKR Nagar, RMV Stage 2,
Bengaluru, Karnataka - 560094, India
GSTIN: 29AAFCO2667R1ZJ
Privacy and grievance contact: as@trufflinnovations.in
Telephone: +91 63614 21009
This Privacy Policy explains how we collect, use, disclose, retain and protect personal data when you:
- visit our website or interact with our online content;
- contact us, request access, schedule a meeting or communicate with us;
- use a Truffl workspace, studio, API, SDK, integration or other service made available by us;
- participate in a call or other interaction powered by Truffl; or
- otherwise engage with Truffl as a customer, prospect, developer, partner, supplier or authorised user.
This policy also applies to personal data processed through Truffl's Facebook/Meta application and WhatsApp Business integrations, where the relevant features are enabled and authorised.
2. The roles of Truffl and its customers
Truffl processes personal data in different roles depending on the context.
2.1 When Truffl determines the purpose
Truffl generally acts as the data fiduciary or controller for personal data relating to:
- website visitors;
- access applicants and sales enquiries;
- customer account administrators and authorised workspace users;
- billing, contracting and business contacts;
- security, service integrity and legal compliance; and
- Truffl's own communications and marketing.
2.2 When an enterprise customer determines the purpose
When a Truffl customer uses the Services to operate a voice agent, customer-support workflow, revenue-recovery workflow, embedded application experience or other interaction, that customer generally determines why the end user's personal data is processed. In that context:
- the customer acts as the data fiduciary or controller; and
- Truffl acts as the customer's data processor or service provider and processes the data on documented instructions, subject to the applicable agreement.
The customer's privacy notice and choices govern its collection and use of end-user data. Questions or requests concerning a customer-operated interaction should normally be directed to that customer. We will assist the customer as required by law and our agreement.
If Truffl and a customer determine purposes jointly in a particular deployment, the applicable contract should allocate the parties' responsibilities.
3. Personal data we collect
Depending on how you interact with Truffl, we may collect the following categories.
3.1 Information you provide directly
- name, work email address, telephone number, company, role and location;
- access-request, contact-form and meeting-scheduling information;
- pricing-calculator inputs, selected models, generated quotes, timestamps and a browser identifier used to maintain quote records;
- account credentials and authentication information;
- communications, support requests, feedback and survey responses;
- contracting, billing and transaction information;
- configuration information, prompts, workflows, evaluation criteria and instructions submitted to the Services; and
- any other information you choose to provide.
3.2 Voice and interaction data
Where enabled by a customer deployment, the Services may process:
- live audio and voice recordings;
- transcripts and conversation summaries;
- caller and business telephone numbers, where available;
- speaker turns, timestamps, interruptions and other interaction events;
- detected intent, language, sentiment or other model-generated attributes;
- identifiers supplied by the customer, such as customer, order, account, ticket or session identifiers;
- contextual information retrieved from connected systems;
- tool calls, actions, approvals, fallbacks, transfers and outcomes;
- provider requests and responses retained for authorised diagnostics, including relevant instructions, conversation text, tool results and technical metadata;
- quality reviews, evaluation scores, annotations and reviewer comments; and
- technical metadata such as call status, duration, routing, latency and provider events.
Whether a call is recorded, and what notice or consent is required, depends on the customer's configuration and applicable law. Customers are responsible for providing legally required notices and obtaining legally required permissions before using Truffl to place, receive, record or analyse communications.
3.3 Workspace and integration data
- workspace membership, roles and permissions;
- agent versions, deployment settings and operational history;
- data exchanged with integrations selected by the customer;
- API requests, SDK events, webhook payloads and associated metadata;
- audit trails and administrative actions; and
- usage information relating to features and service performance.
3.4 Automatically collected website and device data
- IP address, device and browser type, operating system and approximate location;
- pages viewed, referring URLs, timestamps, clicks and navigation events;
- cookie identifiers, advertising identifiers and campaign attribution data;
- login, authentication and security events; and
- diagnostic, crash, performance and fraud-prevention data.
Our use of cookies and similar technologies is described in the Cookie Notice.
3.5 Data obtained from third parties
We may receive personal data from:
- the organisation that provides you access to Truffl;
- customers that configure Truffl interactions;
- identity, authentication and security providers;
- telephony, speech, language-model, hosting, analytics, advertising and scheduling providers;
- connected applications and data sources selected by a customer;
- referral partners and publicly available professional sources; and
- regulators, law-enforcement bodies or other parties where permitted by law.
3.6 Meta and WhatsApp Business data
Where a customer authorises a Meta or WhatsApp Business integration, we may process the information needed to operate the enabled features, within the permissions granted to Truffl:
- business, WhatsApp Business Account and connected phone-number identifiers;
- authorised administrator or account information made available through the granted permissions;
- recipient telephone numbers and WhatsApp identifiers;
- message content and attachments exchanged through the integration;
- message templates, template status, message identifiers, timestamps, delivery status and related webhook events; and
- integration permissions, access tokens and connection-status information.
We use this information to connect the authorised business account, operate the requested business communications, deliver and receive messages, record outcomes and support the integration. We do not obtain access to all of a person's Facebook activity or private conversations merely because a business account is connected.
Authorising a business-account connection is separate from any notice, consent or opt-in required to communicate with its customers. Meta Platform Data is used only for the authorised purposes described in this policy and permitted by the applicable Meta and WhatsApp terms.
4. How we use personal data
We may use personal data to:
- provide, configure, operate, maintain and support the Services;
- authenticate users and administer workspaces, roles and permissions;
- process conversations, context, tool calls, actions and outcomes at a customer's direction;
- connect the Services to customer-selected systems and providers;
- monitor availability, quality, latency, security and operational performance;
- troubleshoot incidents, prevent abuse and protect users, customers and the Services;
- evaluate and improve prompts, workflows, routing, interfaces and product functionality;
- respond to enquiries, review access requests and schedule meetings;
- manage customer relationships, contracts, payments and business operations;
- send service notices and, where permitted, product or marketing communications;
- measure website use, attribute campaigns and deliver or measure advertising, subject to required consent and opt-out rights;
- comply with legal obligations, enforce agreements and establish or defend legal claims; and
- create aggregated or de-identified information that does not reasonably identify an individual.
5. Legal grounds
We process personal data only where permitted under applicable law. Depending on the jurisdiction and context, the basis may include:
- your free, specific, informed and unambiguous consent;
- processing necessary to provide a service you requested or to take steps at your request;
- certain legitimate uses recognised by applicable law;
- our legitimate interests, where applicable and not overridden by your rights, including operating and securing the Services, responding to business enquiries and improving product performance;
- performance of a contract;
- compliance with a legal obligation; or
- establishment, exercise or defence of legal claims.
Where we rely on consent, you may withdraw it using the method presented at collection, through cookie settings where relevant, or by contacting us. Withdrawal does not affect processing already lawfully completed and may limit features that depend on the relevant data.
6. AI and automated processing
Truffl uses automated systems and third-party models to interpret interactions, generate responses, select workflows, evaluate quality and support actions. These systems can make mistakes.
Customers configure the permitted scope of their agents, connected tools, approval requirements, fallbacks and human handoffs. Customers must not use Truffl as the sole basis for decisions that produce legal or similarly significant effects on individuals unless the use is lawful, appropriately governed and expressly supported by the applicable agreement.
Customer Content and model training: Truffl does not use a customer's recordings, transcripts, messages or other Customer Content to train models for other customers by default. Such use may occur only after documented tenancy and data-governance policies have been established, the customer has provided separate, explicit, informed consent, and any additional permissions required from the individuals concerned have been obtained.
A separate training notice will identify the data used, purpose, intended model use, recipients, retention period, safeguards and withdrawal process, including how models already trained will be treated. Declining training consent does not prevent use of the core service. Consent does not authorise uses prohibited by applicable law or Meta, WhatsApp or other provider terms.
Aggregated or de-identified service information may be used to improve reliability, safety and performance where it cannot reasonably identify a person or customer and the use is otherwise permitted. A redacted label alone does not establish that information is anonymous.
7. How we disclose personal data
We may disclose personal data to:
7.1 Customer-authorised recipients
The customer that controls a workspace and its authorised users may access data processed within that workspace according to assigned permissions.
7.2 Service providers and subprocessors
We use vendors to provide infrastructure, hosting, storage, telephony, speech processing, language models, communications, authentication, monitoring, analytics, advertising, scheduling, customer support and professional services. They may process personal data only for authorised purposes and subject to contractual safeguards appropriate to their role.
A current list of material subprocessors, their processing purposes and relevant processing locations is available to customers on request. Where required by an applicable agreement, we will provide notice of material changes to that list.
Information needed to send or receive authorised WhatsApp communications is exchanged with Meta/WhatsApp. Their own privacy notices and applicable business terms govern their processing. Relevant audio, text or business context may also be sent to the speech and language-model providers used for a Truffl interaction.
7.3 Business and professional advisers
We may disclose information to auditors, insurers, banks, lawyers, accountants and other professional advisers where reasonably necessary.
7.4 Legal, safety and compliance recipients
We may disclose information where reasonably necessary to comply with law or legal process, respond to lawful requests, protect rights or safety, investigate fraud or security incidents, or enforce agreements.
7.5 Corporate transactions
Information may be disclosed in connection with a financing, merger, acquisition, reorganisation, sale of assets or similar transaction, subject to appropriate confidentiality and legal safeguards.
7.6 Advertising and analytics partners
If you consent where required, website identifiers and activity may be disclosed to analytics and advertising partners for measurement, attribution, personalisation or cross-context behavioural advertising. Depending on applicable law, this may be considered a "sale," "sharing" or targeted advertising even where no money changes hands. You may reject non-essential cookies or change your preferences at any time. Where required, we will honour recognised opt-out preference signals.
We do not knowingly sell voice recordings, transcripts or Customer Content for monetary consideration.
8. International processing and transfers
Truffl and its providers may process personal data in India and other countries where they operate. Those countries may have different data-protection laws.
Where applicable law requires transfer safeguards, we will use appropriate contractual or legal mechanisms. For EEA, UK or Swiss data, these may include adequacy decisions, approved standard contractual clauses and supplementary measures. Transfers from India will remain subject to restrictions or requirements notified under applicable Indian law and any sector-specific localisation obligations that apply to the customer.
Customers requiring a specific processing region or data-residency arrangement must ensure it is stated in the applicable Order Form or Data Processing Addendum.
9. Retention and deletion
Retention depends on the purpose of processing, the applicable customer agreement, supported retention settings and legal obligations. There is currently no single automatic expiry period that applies to all Truffl recordings, transcripts and Customer Content. These records may remain stored until deletion is arranged, subject to applicable legal requirements. Customers may contact us to establish the retention and deletion arrangements applicable to their deployment.
Certain diagnostic records have separate retention settings. Those settings do not determine the retention of an entire call, its recordings or other copies. Account, enquiry and support information is retained for the associated service or business purpose; accounting, security and other legally required records follow the applicable statutory requirements.
For Meta Platform Data, we apply the deletion requirements of the applicable Meta terms, including when it is no longer needed for an authorised purpose, a valid deletion request is received, or the relevant customer relationship ends, unless retention is legally required. A business-account disconnection stops access through that connection but does not necessarily delete information already stored. You may request deletion separately using the instructions in section 11.
Backup and archival copies may follow different deletion procedures from active systems. Removing an active record does not immediately remove every backup or object version; recording archives may require separate deletion. We consider these copies when handling deletion requests and applicable retention obligations. Deletion by Truffl does not automatically delete independent copies held by a customer, Meta/WhatsApp, a carrier or another provider.
Where information must be preserved for legal compliance, an investigation or a legal claim, its continued use is restricted to that purpose. Required preservation does not authorise unrelated marketing or shared model training. Separately consented training data follows the retention and withdrawal terms disclosed in the relevant training notice. Aggregated or de-identified information may be retained where it no longer identifies an individual and the use is otherwise permitted.
10. Security
We use administrative, organisational and technical safeguards designed to protect personal data against unauthorised access, acquisition, disclosure, alteration, loss or destruction. Measures may include access controls, authentication, encryption in transit and where appropriate at rest, tenant separation, logging, monitoring, vulnerability management, backups, incident response and vendor review.
No service is completely secure. Customers are responsible for protecting credentials, configuring permissions, reviewing authorised integrations and notifying us promptly of suspected compromise.
We will notify affected customers or individuals and relevant authorities of qualifying personal-data breaches as required by applicable law and contract.
11. Your rights and choices
Subject to applicable law and exceptions, you may have rights to:
- obtain information about personal data processed and processing activities;
- access a summary or copy of personal data;
- correct, complete or update inaccurate or incomplete data;
- request erasure or deletion;
- withdraw consent;
- object to or restrict certain processing;
- receive portable data where applicable;
- opt out of marketing, targeted advertising, sale or sharing where applicable;
- nominate another person to exercise rights where applicable; and
- seek grievance redressal or complain to the competent regulator.
To exercise a right relating to data controlled directly by Truffl, email as@trufflinnovations.in with the subject Privacy Request. We may verify your identity and authority before acting. We will respond within the period required by applicable law.
For data processed on behalf of a Truffl customer, contact that customer first. If you contact us, we may forward the request to the relevant customer and assist it in responding.
Data deletion requests, including Meta/WhatsApp data
To request deletion of personal data held by Truffl, including information obtained through Truffl's Meta application or WhatsApp integration, email as@trufflinnovations.in with the subject Data Deletion Request. This request method is available even if you do not have an active Truffl account.
Provide a contact address for our response, the relevant business or workspace if known, and enough information to identify the account or interaction and the data you want deleted. Do not send passwords, access tokens or unnecessary sensitive documents. We may request proportionate information to verify your identity or authority and may coordinate with the customer responsible for the interaction.
We will respond within the period required by applicable law and explain any applicable retention exception where permitted. Removing an integration is not a substitute for a deletion request concerning data already stored.
Marketing choices
You may unsubscribe through the link in a marketing email or contact us. You may still receive necessary service, security and account communications.
Cookie and advertising choices
Use Cookie Settings in the website footer to reject or withdraw consent for non-essential technologies. Where applicable, we will also recognise legally required browser-based opt-out signals. See the Cookie Notice for details.
12. Children
The website and Services are intended for businesses and authorised adult users, not for children. We do not knowingly collect personal data directly from children for account creation or marketing.
Customers must not configure Truffl to process children's personal data unless the deployment has been expressly approved in writing, the customer has established a lawful basis, required verifiable parental or guardian consent has been obtained, and all additional safeguards required by law are implemented.
If you believe a child has provided personal data directly to Truffl without appropriate authorisation, contact us.
13. Third-party services
The Services may link to or integrate with third-party services. Their privacy practices are governed by their own notices. A customer's decision to connect a third-party service authorises Truffl to exchange data with it as needed to provide the integration, subject to the customer's agreement and configuration.
14. Changes to this Privacy Policy
We may update this Privacy Policy to reflect changes in our Services, data practices or legal obligations. We will post the updated version with a revised date. If a change materially affects how we use personal data, we will provide additional notice or obtain consent where required.
15. Contact and grievance redressal
Questions, complaints and rights requests may be sent to:
Privacy and Grievance Contact
Oravio AI Private Limited (Truffl)
Flat No. 024, B-Block, No. 97/2, DS Max Signature,
Devinagar Main Road, Near LKR Nagar, RMV Stage 2,
Bengaluru, Karnataka - 560094, India
Email: as@trufflinnovations.in
Telephone: +91 63614 21009
If you are not satisfied with our response, you may escalate the matter to the competent data-protection or other regulatory authority after using our grievance-redressal process where applicable.