Privacy policy

What this platform records about the people who use it, and about the domains it scans.

This is the wording in force. It took effect on .

Who this notice is from

This notice explains what Cloudheal Solutions (India) Private Limited does with personal data in Cloudheal, the exposure management platform at easm.cloudheal.com.

Cloudheal Solutions (India) Private Limited is a company incorporated in India, with its registered office at Unit 101/B-1, First Floor, Raheja Plaza-1, LBS Marg, Ghatkopar West, Mumbai - 400086. In this notice it is called "we", "us" and "our".

We act as the Data Fiduciary in respect of personal data for which we determine the purpose and means of processing, including account administration, authentication, platform security, billing and audit records.

Where we process personal data contained in findings, assets, scans and exposure information solely on behalf of a customer organisation and in accordance with its instructions, the customer organisation acts as the Data Fiduciary and we act as its Data Processor.

Who this notice covers

It covers three groups, and the third is the one such a notice usually forgets.

For the third group we hold only what a public register or a breach source already published, we do not use it to contact them, and we do not enrich it. A person in that group may ask us what we hold about them and ask us to erase it, using the contact details at the end of this notice, and we will do so unless keeping it is required by law.

Customer organisations must use personal data relating to third parties only for legitimate cybersecurity, incident response and remediation purposes and in accordance with applicable law. Such information must not be used for marketing, profiling, surveillance, credential exploitation or to obtain unauthorised access to any account, system or infrastructure.

What the platform holds

Account and sign-in records

For every person given access we hold a name, an email address, whether that address has been verified, and the date the account was created. A password is set by the person through a one-time link and is stored only as a hash. We do not hold the password itself.

For every active session we hold the originating IP address, the browser and operating system reported by that browser, and the time the session was last used. Sessions expire after eight hours of inactivity by default.

An administrator of an organisation can see the sessions of other members of that same organisation, including their IP addresses and the browsers they signed in from. This lets an administrator find and end a session they do not recognise.

Domain and asset information

When an organisation adds a domain, the platform records what is publicly discoverable about it. This includes registration records published by the domain registry, which carry the name, organisation, email address, telephone number and postal address of up to three contacts. That information is published by the registry rather than uncovered by the scan, and it is held with the rest of the inventory.

Two modules report on domains the organisation does not own: lookalike domains, and domains associated with the organisation's own. Where a registry publishes a registrant name or email address for one of those, the platform records it.

Dark web exposure

The dark web module reports exposures connected to an organisation's domains. What it holds is narrower than the phrase suggests, and the difference matters:

If a record cannot be masked safely it is discarded rather than stored. If an organisation has no usable encryption key, ingestion fails rather than storing anything in the clear.

Records of what people did

The platform keeps an audit record of actions taken in it: domains added and removed, scans started and stopped, credits granted and adjusted, roles changed, people invited and disabled, settings changed, reports exported, and every request to reveal a dark web value. Each entry records who acted, what they acted on and when.

Requests to reveal a dark web value are recorded separately, with the reason given, in a record linked by digest to the one before it so that a single entry cannot be altered without the rest showing it.

Reading a finding is not recorded. The audit record covers changes and reveals rather than every view of a screen.

Why the platform holds it

Personal data is held for these purposes and no others:

What the platform does not do

The platform carries no analytics, no advertising technology, no tracking pixels and no profiling. Nothing about how a person uses the screens is sent anywhere. Personal data is not used to train machine learning models, and it is not sold, rented or shared for marketing.

Cloudheal currently uses only cookies that are necessary for authentication, operation and user preferences. If non-essential cookies or similar technologies are introduced, we will provide any notice or choice as required by applicable law.

Where the data is held

The platform and its database run in Mumbai, in the asia-south1 region of Google Cloud. Backups are held in Delhi, in asia-south2, for thirty five days. Both are in India, and the configuration refuses a multi-region setting that would move backups out of the country.

Two things leave India, and both are stated here rather than left to be discovered:

Who else processes the data

We use a limited number of service providers and processors to operate and support the platform. A current list, naming each one and what it does, is available to customers on request under confidentiality. By function they are:

We may be required to transfer, store, or otherwise process your personal data outside India where necessary for the purposes described in this Privacy Notice, including where we engage service providers, affiliates, or other third parties located outside India. Any such transfer or processing will be undertaken in accordance with the applicable laws, as applicable. We will comply with any restrictions, requirements, or safeguards prescribed by the Central Government in relation to the transfer of personal data outside India.

The platform sends three kinds of email and no others: an invitation, a password reset, and an address verification. Each carries the recipient's address, the product name and a one-time link. None carries a name, a role, an organisation or any finding. A copy of each message is retained in the sending mailbox, which we administer.

How long data is kept

Dark web records are disposed of three hundred and sixty five days after this platform received them, which an administrator may set between thirty and three thousand six hundred and fifty days. The clock runs from the date the platform took custody rather than the date of the breach. Disposal destroys the encrypted values and leaves a record that the disposal happened.

The record of who revealed a dark web value is deliberately not disposed of with it, so that the account of who saw what survives the disposal of the thing they saw.

Other data is kept as follows:

Notwithstanding the retention periods stated above, we may retain personal data or records for a longer period where retention is required or permitted by applicable law, regulatory direction, legal proceedings, investigation or applicable cybersecurity requirements.

Removing data, and erasure

Removing a domain, a scan or an organisation hides it. The customer stops seeing it and everything beneath it, and the audit record, the credit ledger and the record of dark web reveals are untouched and remain readable by the people who audit them. Nothing is erased by that act.

This is deliberate. Records of who accessed leaked credentials are retained rather than deleted, so that the account of who saw what survives the disposal of the thing they saw.

Where a person asks us to erase personal data and we are not required to keep it, we will do so within thirty days. Two limits apply and we state them rather than discovering them with you:

One act erases immediately. We can destroy an organisation's dark web encryption key, which makes every dark web value held for that organisation permanently unreadable. It does not touch findings, assets, registration contacts, the audit record or the ledger, and it cannot reach a backup taken before it ran.

How the data is protected

If something goes wrong

Where a personal data breach occurs, we will notify the Data Protection Board of India and each affected person without undue delay, and in any event within seventy two hours of becoming aware of it. The notice will describe what happened, what data was affected, what we are doing about it, and what the person can do.

Where the people affected are not reachable through the platform, we will notify them by email, or where that is not possible, by public notice.

Rights

A person whose personal data we hold may:

We will respond within thirty days. There is no charge. We may ask for enough information to establish who is asking, and we will ask for no more than that.

Where a request concerns personal data findings or exposure information that we process on behalf of a customer organisation, we will refer the request to the relevant customer organisation and provide reasonable assistance in responding to the request, as the customer organisation acts as the Data Fiduciary in respect of that processing.

Contact

Write to Pooja Gupta, at grievance@cloudheal.com, or at Unit 101/B-1, First Floor, Raheja Plaza-1, LBS Marg, Ghatkopar West, Mumbai - 400086. We will acknowledge within seven working days and respond within thirty.

Changes to this notice

This notice is version V1.1, issued on 10 October 2026. Earlier versions are available on request. Where a change materially affects how personal data is used, we will tell affected customer organisations at least thirty days before it takes effect.