Privacy Policy.

Praesidio Care Private Limited ("VAYU," "we," "us," or "our"), a company incorporated under the Companies Act, 2013 with its registered office in Bengaluru, Karnataka, India, operates the VAYU smart glasses platform, companion mobile applications, the website at vayuglasses.in, and all related information, content, features, tools, products, and services (collectively, the "Services"). VAYU is backed by Praesidio Care Private Limited, which enables us to provide the Services to you.

This Privacy Policy describes how we collect, use, and disclose your personal information when you visit, use, or make a purchase or other transaction using the Services or otherwise communicate with us. If there is a conflict between our Terms of Use and this Privacy Policy, this Privacy Policy controls with respect to the collection, processing, and disclosure of your personal information.

Please read this Privacy Policy carefully. By using and accessing any of the Services, you acknowledge that you have read this Privacy Policy and understand the collection, use, and disclosure of your information as described in this Privacy Policy.

Personal Information We Collect

When we use the term "personal information," we are referring to information that identifies or can reasonably be linked to you or another person. Personal information does not include information that is collected anonymously or that has been de-identified so that it cannot identify or be reasonably linked to you. We may collect or process the following categories of personal information, depending on how you interact with the Services and as permitted or required by applicable Indian law:

Contact details

• Your name, shipping address, billing address, phone number (with country code), and email address

Financial information

• Credit card, debit card, UPI, and net banking information; payment details; transaction records; form of payment; and payment confirmation
• Financial information is processed securely through RBI-compliant third-party payment processors (such as Razorpay or Stripe). We do not store full card numbers on our servers

Account information

• Your username, password, security questions, preferences, and settings on the VAYU companion app and website

Order & transaction information

• Items you view, add to your cart, add to your wishlist, or purchase, return, exchange, or cancel, and your past transaction history
• Pre-order and waitlist registration details, including your profession, reason for purchase, prescription lens requirements, and selected edition

Device data (from VAYU smart glasses)

• Voice commands and audio: Processed on-device in real time and deleted immediately after processing unless you explicitly choose to save a recording. We do not retain raw audio on our servers
• Camera and visual data: Images and video are processed in real time for AI features (translation, object recognition, contextual assistance). They are not stored or transmitted unless you explicitly capture and save content
• Location data: Used for contextual AI features such as weather, navigation, and local recommendations. Location services can be disabled in the companion app at any time
• Device telemetry: Battery status, firmware version, connectivity status, sensor diagnostics, and crash reports to maintain and improve device performance
• Usage patterns: Anonymised feature usage frequency to improve the Services. This data cannot be linked back to you individually

Communications with us

• Information you include in customer support enquiries, feedback forms, emails, and any other correspondence with our team

Automatically collected information

• Log data: IP address, browser type and version, referring URLs, device identifiers, operating system
• Cookies and similar technologies: For website functionality, analytics, and to remember your preferences
• Usage information: How and when you interact with or navigate the Services, pages viewed, links clicked, and time spent

Sources of Information

We may collect personal information from the following sources:

• Directly from you: When you create an account, place a pre-order, join the waitlist, visit or use the Services, communicate with us, or otherwise provide us with your personal information
• Automatically through the Services: From your device (including the VAYU smart glasses and companion app) when you use our products or visit our website, through cookies and similar technologies
• From our service providers: When we engage third parties to enable certain technology or when they collect or process your personal information on our behalf (e.g. payment processors, shipping partners, analytics providers)
• From our partners or other third parties: Business partners, marketing partners, or publicly available sources, where permitted by applicable law

How We Use Your Information

To provide, tailor, and improve the services

We use your personal information to provide you with the Services, including to perform our contract with you, to process your payments through RBI-compliant gateways, to fulfil your orders, to remember your preferences, to send notifications related to your account, to process purchases, returns, exchanges, or other transactions, to create and manage your account, to arrange for shipping within India and internationally, to facilitate returns and exchanges, and to create a customised experience. For VAYU device users, this includes delivering AI-powered features such as real-time translation, contextual assistance, and memory recall.

Marketing and advertising

We use your personal information for marketing and promotional purposes, such as to send marketing communications by email, SMS, or WhatsApp (where you have opted in), and to show you relevant advertisements. You may opt out of marketing communications at any time using the unsubscribe link in our emails or by contacting us.

Security and fraud prevention

We use your personal information to authenticate your account, provide a secure payment experience, detect and investigate possible fraudulent, illegal, or malicious activity, and to protect public safety. If you register an account, you are responsible for keeping your account credentials safe.

Customer support

We use your personal information to provide customer support, respond to your enquiries, troubleshoot device issues (including remote diagnostics for warranty claims), and maintain our business relationship with you.

Legal compliance

We use your personal information to comply with applicable Indian law (including the Information Technology Act, 2000 and the Digital Personal Data Protection Act, 2023, as applicable), to respond to valid legal process including requests from law enforcement or government agencies, to investigate potential violations of our terms, and to protect our legal rights.

How We Disclose Information

In certain circumstances, we may disclose your personal information to third parties for legitimate purposes subject to this Privacy Policy:

• Service providers: Vendors and third parties who perform services on our behalf, including IT management, payment processing (Razorpay, Stripe, etc.), data analytics, customer support, cloud storage (AWS, Google Cloud), fulfilment, and shipping partners (Delhivery, Blue Dart, India Post, etc.)
• Business and marketing partners: To provide marketing services and deliver relevant advertisements, in accordance with their own privacy notices
• With your consent: When you direct, request, or otherwise consent to disclosure, such as to ship your products
• Within our corporate group: With Praesidio Care Private Limited and other affiliates within our corporate group
• Business transactions: In connection with a merger, acquisition, reorganisation, or bankruptcy
• Legal obligations: To comply with applicable legal obligations, respond to court orders, subpoenas, or government requests under Indian law

Data Security & Encryption

• End-to-end encryption for all data transmitted between your VAYU device, companion app, and our servers
• AES-256 encryption for data at rest on our servers
• On-device processing for sensitive audio and visual data: audio is processed locally and deleted after use unless you choose to save
• HIPAA-compliant infrastructure for VAYU MedPro, ensuring healthcare data meets international standards
• Client-attorney privilege encryption for VAYU LegalEdge, with additional security layers for legal professionals
• Regular security audits and penetration testing by independent third-party firms
• RBI-compliant payment processing through certified payment gateways

Please be aware that no security measures are perfect or impenetrable, and we cannot guarantee "perfect security." We recommend that you do not use unsecure channels to communicate sensitive or confidential information to us.

Data Retention

• Audio and visual data processed on-device is deleted immediately after processing unless you explicitly save it
• Account data is retained for the duration of your account and for a period of 3 years thereafter for legal and business purposes
• Transaction data is retained for a minimum of 8 years as required under the Indian Income Tax Act, 1961 and GST regulations
• Device telemetry is retained in anonymised form for up to 2 years for product improvement
• Marketing preferences are retained until you opt out or delete your account

Your Rights & Choices

Under applicable Indian data protection law, including the Digital Personal Data Protection Act, 2023 (DPDP Act) where applicable, and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, you have the following rights:

• Right to Access: You may request access to the personal information we hold about you
• Right to Correction: You may request that we correct inaccurate or incomplete personal information
• Right to Erasure: You may request deletion of personal information we maintain about you, subject to legal retention requirements
• Right to Withdraw Consent: Where we rely on consent to process your personal information, you have the right to withdraw this consent at any time. Withdrawal will not affect the lawfulness of any processing based on your consent before its withdrawal
• Right to Grievance Redressal: You have the right to register a complaint with our Grievance Officer if you are dissatisfied with our handling of your personal information
• Right to Nominate: You have the right to nominate another individual to exercise your rights on your behalf in the event of your death or incapacity, as provided under the DPDP Act

Managing communication preferences

You may opt out of promotional emails using the unsubscribe link, reply STOP to SMS messages, or contact us directly. We may still send non-promotional communications about your account, orders, shipping, or warranty.

You may exercise any of these rights by contacting us at the details below. We will respond within 30 days. We may need to verify your identity before processing your request.

Children's Data

The Services are not intended to be used by children, and we do not knowingly collect personal information about children under the age of 18. If you are the parent or guardian of a child who has provided us with their personal information, you may contact us to request deletion. As of the effective date of this Privacy Policy, we do not have actual knowledge that we process personal information of individuals under 18 years of age.

Third-Party Websites & Links

The Services may provide links to websites or online platforms operated by third parties. If you follow links to sites not affiliated or controlled by us, you should review their privacy and security policies. We do not guarantee and are not responsible for the privacy or security of such sites. Our inclusion of such links does not imply endorsement of the content on such platforms.

International Transfers

Your personal information may be transferred to, stored, and processed in countries other than India, including countries where our cloud infrastructure providers (such as AWS and Google Cloud) maintain servers. Where such transfers occur, we ensure appropriate safeguards are in place consistent with applicable Indian data protection laws. By using the Services, you consent to such transfers.

Changes to This Policy

We may update this Privacy Policy from time to time, including to reflect changes to our practices or for legal or regulatory reasons. We will post the revised Privacy Policy on our website and update the "Last updated" date. Your continued use of the Services after any changes constitutes acceptance of the updated Privacy Policy.

Grievance Officer & Contact

In accordance with the Information Technology Act, 2000 and the rules made thereunder, the name and contact details of the Grievance Officer are provided below:

For the purpose of applicable data protection laws, Praesidio Care Private Limited is the data controller / data fiduciary of your personal information.