Privacy Policy

1. Who we are

XCOGNiSAAS and MasterFunnelSystem are run by FABEMINDS COUNSELLING PRIVATE LIMITED (CIN U80902MH2022PTC389429), registered office E-38, 03, Gulmohar Colony, N5, Aurangabad, Maharashtra 431003 ("Fabeminds", "we", "us").

This policy applies to our website, our app and the funnels, pages and documents we generate for you. It forms part of our Terms of Service. If the two ever conflict, the Terms of Service apply.

2. Words used in this policy

• You means the person or business that signs up, buys a plan or uses the platform.
• Platform means our website, app, AI features, templates and frameworks.
• Your content means anything you give us: business details, offers, answers to our questions, brand files and any AI key you connect.
• Output means what the platform creates for you: pages, scripts, ad angles, messages, playbooks and reports.
• Your leads means your own customers, prospects or clients, and your clients' customers.

3. What we collect

• Account details: your name, email address, phone number, business name and login details.
• Billing details: your plan, invoices and payment records. Card and bank details are entered on our payment partner's secure page. We do not see or store full card numbers.
• Your content: the information you type or upload so the platform can build your funnels, including what you enter on our website before signing up.
• Assessment answers: only if you choose to take an assessment we offer, such as WINGS or B.I.A.S.
• Technical data: device and browser type, IP address, log-in times, pages used, error reports and records of the choices and consents you give.
• Messages: what you send us by email, WhatsApp or phone when you contact us.

4. Why we use it

We use your data only to:

• create and manage your account and give you the platform;
• generate, store for a limited time and deliver your Output;
• take payments, issue invoices and meet tax and accounting duties;
• answer your questions and give support;
• keep the platform secure, prevent fraud and misuse, and fix problems;
• improve our platform, using information that no longer identifies you wherever possible;
• send you service messages about your account, billing and changes to our terms;
• send product updates and offers, only if you have opted in;
• comply with the law, respond to lawful requests, and establish or defend legal claims.

We process your data with your consent, or where the law allows us to without it, for example when you voluntarily give us data for a clear purpose, or when we must comply with the law. We do not sell your personal data.

5. Your leads' data is your responsibility

MasterFunnelSystem creates funnels and hands them to you. You host, publish and run them. Any data your pages, forms, ads or messages collect from your leads is collected by you, for your own purposes. You are responsible for giving your leads the right notices, getting their consent where needed and handling their data lawfully.

Do not upload your leads' personal data to the platform unless we have agreed in writing to process it for you under a data processing agreement.

6. AI processing and your own AI key

To create your Output, your content is sent to the AI model providers we use. They process it to return results to us, under contract.

If you connect your own AI key, your requests go to the AI provider you chose, under your own account with them and their terms. That provider's handling of your data is between you and them.

Please do not put sensitive information into the platform, such as health details, passwords, card numbers or other people's personal data.

7. Who we share it with

• Service providers who help us run the platform, such as hosting, AI, payment, email, messaging and support providers. They may use your data only to provide their service to us.
• Professional advisers such as our lawyers, auditors and accountants.
• Authorities when the law requires it, or to protect our rights, our users or the public.
• A buyer or successor if our business, or part of it, is merged, sold or restructured. They will be bound by this policy.

8. Where your data is processed

Some of our service providers store or process data outside India. We transfer data only as Indian law allows, and not to any country the Government of India has restricted.

9. How long we keep it

• Business inputs and drafts: deleted within 90 days after you close your account.
• Assessment answers: deleted within 12 months after your report is delivered, or within 30 days after you validly ask us to delete them.
• Security, access and consent records: kept for at least 1 year, or longer while a claim could be brought.
• Invoices, accounts and tax records: kept for as long as company and tax law requires.

We may keep data longer if the law requires it or if we need it to establish, exercise or defend a legal claim.

10. Security and keeping your own copies

We use reasonable security measures suited to the data we hold, and we will notify you and the authorities about a data breach where the law requires. No online service can be completely secure.

The platform is not a backup or storage service. We do not promise to keep backups of your content or Output, and data can be lost through outages, errors or attacks. Download your Output promptly and keep your own copies. Our responsibility for lost data is limited as set out in our Terms of Service, except where the law does not allow that limit.

11. Your rights and choices

Under Indian data protection law, you can ask us to:

• tell you what personal data we hold about you and how we use it;
• correct, complete or update it;
• erase it, unless we must keep it by law;
• withdraw a consent you gave;
• let someone you nominate exercise these rights if you die or become unable to.

Email support@fabeminds.com from your registered address. We may ask you to verify your identity first, and we reply within the time the law allows.

If you withdraw consent or ask us to erase data that the platform needs, we may no longer be able to provide some or all of the service. This does not entitle you to a refund except as set out in our Refund Policy. Withdrawing consent does not affect anything we did lawfully before.

Marketing: you can unsubscribe from product updates and offers at any time, using the link in our email or by replying STOP on WhatsApp. You will still receive service messages about your account.

12. Cookies

Our website and app use cookies and similar technologies that are needed to keep you signed in, remember your settings and keep the platform secure. If we add analytics or advertising cookies, we will tell you, and ask for your consent where the law requires.

13. Children

The platform is for people aged 18 and over. We do not knowingly collect data from children. If we learn that we have, we will delete it.

14. Changes to this policy

We may update this policy as our services or the law change. For a material change, we will tell you by email or in the app before it takes effect, in line with our Terms of Service. The date at the top shows when it was last updated.

15. Questions and complaints

Please contact our grievance officer first. We will acknowledge and resolve your complaint within the time the law requires. If you are not satisfied with our response, you may then approach the Data Protection Board of India.