This is a draft, not legal advice
Prepared as a working template and not reviewed by a qualified lawyer or data protection specialist. Bracketed fields must be completed and the document reviewed — particularly the lawful-basis, transfer and processor sections — before you rely on it.
1. In short
We collect the minimum needed to run an account and bill it. Your source code, your cryptographic keys and your software payloads are never sent to us — packaging and encryption happen on your own machine. Product telemetry is off unless you turn it on.
This policy explains what Aitele Research LLP (“we”) does with personal data when you use the Pramaan service.
2. What we collect
| Account data | Name, email, organisation, password hash, and the plan you are on. |
| Contact details you share | If you confirm your contact details in Pramaan and choose to share them with us: your name, email (confirmed with a code we email you), phone number and postal address, so we can reach you about your sales, payments and disputes. Off unless you confirm them; you can stop sharing at any time. |
| Messages to Pramaan | What you write to Pramaan's mediator in an escrow conversation, or to Pramaan directly, decrypted only on our own computer. |
| Billing data | Billing address and tax identifiers if you give them, and for each plan payment: the wallet address that paid, the transaction on the blockchain, the plan, the amount and the currency. Plans are paid in crypto only (USDC or USDT), so we never see or store card or bank details. |
| Usage metadata | Counts needed for billing: projects and active entitlements. Counts and identifiers, not content. |
| Support data | Whatever you choose to send us in a support request, including any logs you attach. |
| Technical logs | IP address, user agent and timestamps for requests to the hosted console, kept for security and abuse prevention. |
| Optional telemetry | Anonymous feature and error counts, only if you opt in. Off by default. |
3. What we never collect
- Your source code or binaries. Packaging runs locally; the payload never leaves your machine.
- Your signing keys, content encryption keys or watermark master key. Generated locally, stored locally. We cannot recover them, by design.
- Your Tardos bias vector. The secret that makes fingerprinting collusion-resistant is never transmitted, and the console does not serve it to a browser.
- Your customers' files. We have no relationship with your Licensees and receive nothing from their devices.
4. Why we process it, and on what basis
| To provide the Service | Performance of a contract |
| To bill you and meet tax obligations | Contract; legal obligation |
| To secure the Service and prevent abuse | Legitimate interests |
| To answer support requests | Contract; legitimate interests |
| To send service notices | Contract; legitimate interests |
| To send marketing email | Consent — withdrawable at any time |
| Optional product telemetry | Consent — opt-in only |
We are established in India, so the Digital Personal Data Protection Act, 2023 (“DPDP Act”) is our primary regime — under it we are the Data Fiduciary and you are the Data Principal. Where we serve customers in the UK or EEA we additionally apply the UK and EU GDPR, and the bases in the table above are stated in GDPR terms. Under the DPDP Act, processing rests on your consent or on legitimate uses recognised by that Act.
5. Data written to a blockchain
Blockchain records are public and permanent. They cannot be edited or erased — by us, or by you. Please consider this before writing anything on chain.
What the Service writes on chain is deliberately minimal: cryptographic digests, wallet addresses, version strings, storage pointers, Merkle roots, timestamps and revocation records. It does not include names, emails or software payloads.
A wallet address may nonetheless be personal data where it can be linked to an individual. Because the ledger is immutable, a request to erase such data cannot be fulfilled on chain; we can erase associated records held in our own systems. Where you deploy to your own private network, you control that ledger entirely.
6. Fingerprints and device identifiers
The Service produces two kinds of identifier worth calling out:
- Device IDs — a hash of a public key held in a Licensee's TPM. It identifies a machine, not a person, and it is generated and used on the Publisher's side. We do not collect Licensee device IDs.
- Watermark codewords — a per-entitlement fingerprint stored in your local publisher state so you can trace a leak. It stays on your machine.
If, as a Publisher, you link these to identifiable customers, you are the controller of that data and responsible for handling it lawfully — including telling your customers that copies are individually marked.
7. Pramaan Marketplace
The Marketplace has no Pramaan server in the middle, so most of what happens there is between you, the publisher's computer and a public blockchain. Here is who sees what.
| Browsing the Marketplace | The website reads app cards from the blockchain through a network node, and loads each listing and its artwork straight from the publisher's storefront on their own computer. Like any website, the node and the publisher's computer see your IP address and browser. Pages of this site also show two public counters from the chain (apps live and sales), and their history, read the same way by this website's server. |
| Getting an app | Your Pramaan sends your computer's public device key to the publisher's storefront, which seals your copy to it. The publisher keeps a record of the copies they issued (device key, time, release and, if they fingerprint, your copy's mark) on their computer. The publisher is responsible for that record; we do not receive it. |
| Free trials | The publisher's storefront remembers your device key and when your trial began, so each computer gets one trial. |
| Paying | Recorded on the blockchain, publicly and permanently: the app, your wallet address, a SHA-256 of your device key, the amount and the time. See section 5. |
| Your Pramaan Wallet | The wallet lives in Pramaan on your computer. Its key, passphrase and recovery phrase never leave it; we receive none of them. Its activity log is kept on your computer. Its address and the transactions it sends are public on the chain, like any wallet's. |
| Paying from the website | A Pramaan web page can ask your Pramaan, on your computer, to pay. The request goes from your browser to your own Pramaan, never through our servers, and shows you what will be paid before anything is sent. |
| Reselling a licence | Public on the chain, permanently: the seller's and buyer's wallet addresses, the price and royalty, and the public key of the computer the licence is resold to (and its SHA-256), so the publisher can seal it there. A public key can't open anything by itself, but it identifies a computer. A dispute is public too, with its reason, and counted against the buyer's address. |
| Conversations | Messages between buyers, sellers, publishers and Pramaan's mediator are encrypted on the sender's computer to each person in the conversation. Our relay carries them but can't read them: it sees only the sender's and recipients' wallet addresses, a random-looking conversation tag, the size and the time. It keeps each message for 120 days so a computer that was off can collect it, then deletes it. Each person's Pramaan keeps their own copy on their computer. |
| Contact details in a conversation | If you press Share contact in a conversation, everyone in it receives your confirmed name, email, phone and address, encrypted as above. They keep that copy; we can't take it back for you. |
| Paying for a plan in crypto | Public on the chain, permanently: your wallet address, the plan, the amount, the time, and your computer's ID, which your activation code is made for. We issue and send the code automatically through the relay. |
| Reporting an app | A report made on the app's page is public on the chain, with your wallet address and what you wrote. A report by email stays private between you and us. |
| Your Library | The list of apps you have lives in Pramaan on your computer. We see only what is public on the chain. |
| Reviewing apps | We receive review copies of publishers' software to check them for malware, not data about buyers. File hashes may be looked up in public malware databases; the files are not uploaded. |
Rules for publishers and buyers are in the Marketplace Terms.
8. Who we share with
We do not sell personal data. We share it only with processors acting on our instructions:
| Payment processing | [PROCESSOR] |
| Hosting & infrastructure | [PROVIDER, REGION] |
| Transactional email | [PROVIDER] |
| Support ticketing | [PROVIDER] |
| Error monitoring | [PROVIDER] |
We may also disclose data where legally required, or to protect our rights or the safety of others. If we are involved in a merger or acquisition, data may transfer as part of it, subject to this policy.
9. How long we keep it
| Account data | While your account is open, then [90] days |
| Invoices and tax records | [7] years, as required by law |
| Technical logs | [90] days |
| Support correspondence | [24] months |
| Messages on the relay | 120 days, encrypted, then deleted |
| Contact details shared with us | While you have sales, payments or a plan with us, then [24] months |
| On-chain records | Permanent — see section 5 |
10. Your rights
Depending on where you live, you may have the right to access, correct, delete, restrict or object to processing, to data portability, and to withdraw consent. Residents of California may request disclosure of data collected and opt out of “sale” or “sharing” — we do neither.
Under India's DPDP Act you may, as a Data Principal, seek access to and correction or erasure of your data, nominate another person to exercise your rights, and raise a grievance. Our Grievance Officer is [GRIEVANCE OFFICER NAME], reachable at hello@aiteleresearch.com.
To exercise any right, write to hello@aiteleresearch.com. We respond within [30] days. If unsatisfied you may escalate to the Data Protection Board of India, or to your local supervisory authority — in the UK, the ICO.
11. International transfers
We may process data in [COUNTRIES]. Where data leaves the UK or EEA we rely on adequacy decisions or Standard Contractual Clauses with appropriate safeguards. Details are available on request.
12. Cookies
The marketing site uses no tracking or advertising cookies. The hosted console uses a single strictly-necessary cookie to keep you signed in. If we ever add analytics that recognise you from one day to the next, or across other websites, we will ask first.
Counting visitors
The website shows how many people visit it, by hour and by day. It counts the way a turnstile does, without cookies and without storing anything on your device. When a page loads, the website's server combines your IP address and browser name with a random value that exists only in its memory and is replaced every day, and holds the result in memory until the day ends, only so that you are counted once that day. Neither your IP address nor that result is ever written down, and once the day's random value is gone the result can't be linked to you, or to your visits on other days. Only the totals are kept. Browsers that send Global Privacy Control or Do Not Track aren't counted at all, and neither are known crawlers. We count visitors to see whether the site is reaching people; the totals are public in the site's header.
13. Security
We use encryption in transit and at rest, least-privilege access, and audited administrative access. No system is perfectly secure; if a breach affects your personal data we will notify you and the relevant authority as required by law.
Report vulnerabilities to hello@aiteleresearch.com. We will not pursue legal action for good-faith research conducted under our disclosure policy.
14. Children
The Service is not directed at anyone under 18 and we do not knowingly collect their data. If you believe we have, contact us and we will delete it.
15. Changes
We will post updates here and, for material changes, give at least [30] days' notice by email.
16. Contact
Aitele Research LLP
Aitele Research LLP
Registered office: 105/104 Sandilya, Sardanagar Para, Sitamarhi, Bihar 843302, India
Head office: F-109, CRS Tower, Chattarpur, New Delhi 110074, India
GSTIN: 10ABUFA5977D1ZB
Privacy: hello@aiteleresearch.com
Data protection contact: [NAME / DPO IF APPOINTED]