Privacy Policy

1About This Policy and Who We Are

1.1Our Commitment

Vizry Group is committed to protecting your privacy and handling your personal data lawfully, fairly, and transparently. This Privacy Policy explains what personal data we collect, why we collect it, how we use and protect it, and the rights you have over it.

1.2Who We Are

Vizry Group is a group of companies operating an AI-native strategy execution ecosystem, a consulting and advisory practice, and a children's publishing business. This policy applies to the Vizry Group companies, associates, partnerships, and future group entities described in Section 2.

1.3A Note on This Version

This is a first published version of our group-wide privacy framework, written to align with the India Digital Personal Data Protection Act, 2023 and its Rules, and with the EU General Data Protection Regulation, ahead of their respective compliance timelines.

2Scope and the Entities We Cover

2.1The Entities

This policy covers the following Vizry Group entities, each of which may act as the Data Fiduciary (India) or Controller (EU) for the personal data it determines the purpose and means of processing:

2.2Associates, Partnerships, and Future Entities

Where we work with associates, joint ventures, or partnerships, or where we establish new group entities in the future, this policy applies to their processing of personal data under the Vizry Group umbrella unless a separate notice is provided to you at the point of collection.

2.3What This Policy Covers

This policy covers personal data collected through the vizry.com website, our products and services, our business relationships, and our recruitment activities. Some products carry additional product-specific terms noted in the relevant sections below.

3Key Terms

We use terms from both the Indian and the EU data protection frameworks. Where they differ, both are given so the meaning is clear regardless of where you are.

3.1The People

• Data Principal (India) or Data Subject (EU): you, the individual whose personal data is processed.
• Data Fiduciary (India) or Controller (EU): the Vizry Group entity that decides why and how your data is processed.
• Data Processor: a third party that processes data on our instructions.

3.2The Data

• Personal data: any information relating to an identified or identifiable individual.
• Processing: any operation performed on personal data, including collection, storage, use, sharing, and deletion.

4Personal Data We Collect

We collect different data depending on your relationship with us. We collect only what we need for the purposes described in Section 5.

4.1Website Visitors

• Information you submit through forms (name, email, company, phone, message)
• Technical data (IP address, browser type, device information)
• Usage data (pages viewed, time on site, referring source)
• When you open or download a publication from our website (a report, paper or policy paper served at vizry.com/insights/...): the date and time, your IP address, browser, operating system and device type, the page that referred you, your browser's language setting, and whether the file was fully delivered. We may derive an approximate location (country, region, city) and network from the IP address, using a location database held on our own systems
• Cookie and analytics data (see Section 7)

4.2Consulting and Advisory Clients (Vizry Services)

• Business contact details and professional role
• Engagement information necessary to deliver our services
• Correspondence and meeting records
• Billing and payment information

4.3Intalyst Platform Users (Vizry Technologies)

• Account and profile information
• Data you or your organisation input into the platform
• Usage, configuration, and log data
• Billing and subscription information

4.4Vaani Storybooks Customers and Readers (Vizry Publishing)

• Order and delivery information
• Parent or guardian contact details
• Minimal information relating to children, handled under Section 8
• Preferences and communication choices

4.5Job Applicants

• Application materials (name, contact details, CV, work history)
• Information provided during interviews and assessments

4.6Data We Do Not Seek

We do not intentionally collect special-category or sensitive personal data unless it is necessary for a specific, lawful purpose and you have been informed. Please do not share sensitive data with us unless we have asked for it.

5Why We Process Your Data and Our Legal Basis

We process personal data only where we have a valid legal basis. Because we serve individuals in India, the EU, and other markets, we set out both frameworks.

5.1Our Purposes

• To provide and improve our services, products, and website
• To respond to your enquiries and communicate with you
• To fulfil orders, process payments, and deliver products
• To operate the Intalyst platform and support its users
• To meet legal, regulatory, and contractual obligations
• To protect our rights, users, and systems from misuse
• To understand which publications are read, by which audiences and from where, to protect our publications from automated abuse, and to plan our research

5.2Legal Basis Under Indian Law (DPDP Act)

Under the DPDP Act, we process personal data on the basis of your consent, or for certain legitimate uses permitted by the Act. Where we rely on consent, you may withdraw it at any time as easily as you gave it (see Section 13).

5.3Legal Basis Under EU Law (GDPR)

Where the GDPR applies, we rely on one or more of: your consent; performance of a contract with you; compliance with a legal obligation; or our legitimate interests, provided these are not overridden by your rights.

6Artificial Intelligence and Automated Processing

We are transparent about our use of artificial intelligence. This section applies across the group.

6.1How We Use AI

We use a combination of open-source and commercially licensed AI and large language model tools to support our work, including analysis, drafting, content creation, and platform features. AI supports our teams; it does not replace human judgment.

6.2Human Oversight

Meaningful decisions that affect you are made by our people, not by an automated system alone. AI assists with speed and scale; the final judgment stays human.

6.3Your Data and AI Training

We do not use your personal data to train third-party foundation models, and we do not permit our AI tool providers to use your data to train their models beyond what is necessary to provide the service to us. Should our practices change in the future, we will update this policy and, where required, seek your consent.

6.4Intalyst Platform

The Intalyst platform uses AI to support strategy execution intelligence. Where the platform processes data you or your organisation provide, it does so to deliver the service to you, under the terms of your platform agreement.

6.5Vaani Content Creation

Vaani Storybooks content is created with substantial human creative direction, supported by licensed AI tools, with final creative decisions made by our team. We do not use customer or reader personal data for content generation.

7Cookies and Similar Technologies

7.1What Cookies We Use

We use cookies and similar technologies to operate the website, remember your preferences, and understand how the site is used.

7.2Managing Cookies

Where consent is required, we ask for it through our cookie banner. You can change your choices at any time through the cookie settings on our website or through your browser settings. Disabling some cookies may affect how the site works.

8Children's Data

8.1Age Standards

Under the India DPDP Act, a child is anyone under 18, and processing their data requires verifiable consent from a parent or lawful guardian. Under COPPA in the United States, additional protections apply to children under 13. We apply the protection appropriate to each user.

8.2Verifiable Parental Consent

Where we process a child's personal data, we require verifiable consent from a parent or guardian before doing so, using methods permitted by applicable law.

8.3What We Do Not Do

We do not track, profile, or carry out behavioural monitoring of children, and we do not direct targeted advertising at children.

8.4Parental Controls

Parents and guardians may review the personal data we hold about their child, request its correction or deletion, and manage communication preferences by contacting us (see Section 15).

9How We Share Data and Our Third Parties

9.1We Do Not Sell Your Data

We do not sell your personal data.

9.2Who We Share With

We share personal data only as needed, with:

• Service providers who process data on our instructions (hosting, analytics, email, payment processing)
• AI and large language model providers, under contracts that restrict their use of the data
• Distribution and platform partners for Vaani products (for example, print and retail partners)
• Professional advisers, where necessary
• Authorities, where required by law

Publication open records are held on our own hosting and are not shared with analytics providers, advertisers or location-lookup services.

9.3Processor Obligations

Where a third party processes data on our behalf, we require appropriate contractual and security safeguards, consistent with the DPDP Rules and the GDPR.

10International Data Transfers

10.1Where We Operate

We operate across India, the UAE, Saudi Arabia, and other markets, and some of our service providers are located outside your country.

10.2Safeguards

Where we transfer personal data across borders, we do so in accordance with applicable law and put appropriate safeguards in place to protect it.

11How Long We Keep Your Data

11.1Retention Principle

We keep personal data only for as long as necessary for the purposes described in this policy, or as required by law. When it is no longer needed, we erase or anonymise it.

Publication open records: the full IP address is kept for 12 months from the open; after that it is shortened (the last part removed) and the rest of the record is kept for research on our readership.

11.2Erasure on Request

You may request erasure of your personal data (see Section 13). Where a request applies, we act on it within the timeframes set by applicable law, including passing the request to our processors where relevant.

12How We Protect Your Data

12.1Security Safeguards

We implement reasonable technical and organisational security measures to protect personal data, including access controls, encryption where appropriate, and periodic review of our safeguards.

12.2Your Role

No system is perfectly secure. Please help protect your data by keeping your account credentials confidential and contacting us if you suspect any unauthorised use.

13Your Rights and How to Exercise Them

You have rights over your personal data. We set out both frameworks so your rights are clear wherever you are.

13.1Your Rights Under Indian Law (DPDP Act)

• The right to access a summary of your personal data and how it is processed
• The right to correction and erasure of your personal data
• The right to grievance redressal
• The right to nominate another individual to exercise your rights in the event of death or incapacity

13.2Your Rights Under EU Law (GDPR)

• Access, rectification, and erasure
• Restriction of processing and objection to processing
• Data portability
• The right to withdraw consent
• The right to lodge a complaint with a supervisory authority

13.3How to Make a Request

To exercise any of these rights, contact us using the details in Section 15. We may need to verify your identity before acting on a request. We will respond within the timeframes required by applicable law.

14Data Breach Notification

In the event of a personal data breach, we will act promptly to contain and assess it, and we will notify the relevant authority and affected individuals where required, within the timeframes set by applicable law.

15Grievance Officer and Data Protection Contact

15.1Contact for Data Matters

For any question, concern, or request about your personal data, or to raise a grievance, contact:

Vizry Group, Data Protection Contact Email: legal@vizry.com

15.2Escalation

If you are not satisfied with our response, you may have the right to escalate to the relevant data protection authority in your jurisdiction, including the Data Protection Board of India or your EU supervisory authority.

16Changes to This Policy

We may update this policy from time to time. When we make material changes, we will update the version and effective date above and, where appropriate, notify you. Your continued use of our website and services after an update means you accept the revised policy.

Version history. 1.0, January 1, 2026: first published version. 1.1, November 4, 2026: publication open records added (Sections 4.1, 5.1, 9.2 and 11.1).

17Contact Information

Vizry Group Email: hello@vizry.com Legal and data protection: legal@vizry.com

For entity-specific correspondence, please state which product or service your enquiry relates to so we can route it correctly.