Privacy Policy

1 Introduction

This Privacy Policy (“Policy”) describes how Tirth Enterprise (“the Company”, “we”, “us”, or “our”), a sole proprietorship carrying on business at Rajkot, Gujarat, India, and being the developer and operator of the mobile application “Invo – The Invoice Maker” (“the Application”), handles information in connection with a user’s (“you”, “your”, or “User”) use of the Application.

The Application is designed to operate on a local-first basis. The business, customer and invoice records that you create are stored on your own device and are neither transmitted to, nor accessible by, the Company, save for the limited exceptions expressly identified in this Policy. This Policy is to be read together with the Terms of Service applicable to the Application, where such terms exist, and forms an integral part thereof.

By downloading, installing, accessing, or using the Application, you signify that you have read, understood, and agree to the handling of your information as described in this Policy. If you do not agree with this Policy, you must refrain from using the Application.

2 Definitions

“Personal Information” means any information that relates to a natural person which, either directly or indirectly, in combination with other information, is capable of identifying such person.

“Sensitive Personal Data or Information” (“SPDI”) shall, for the purposes of this Policy, include financial information such as bank account details, in accordance with the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (the “SPDI Rules”).

“Data Fiduciary” means Tirth Enterprise, being the entity that determines the purpose and means of Processing of Personal Information under this Policy, as such term is used in the Digital Personal Data Protection Act, 2023 (the “DPDP Act”).

“Data Principal” means the individual User to whom the Personal Information relates, as such term is used in the DPDP Act.

“Device” means the mobile device on which you have installed the Application. “Local Storage” means the private, application-sandboxed storage area of the Device that is accessible only to the Application. “Processing” means any operation performed on Personal Information, including collection, storage, use, disclosure, and erasure.

3 No Account Registration; Local-First Operation

The Application does not require a User to register an account, and does not require the submission of an email address, password, or any other login credential as a condition of use. The Application does not employ any form of user authentication (including anonymous authentication) and does not assign to the User any server-side account.

All business, customer and invoice records created through the Application are written to, and retained in, the Local Storage of the Device. Such records are not, in the ordinary course of operation, transmitted to the Company or to any third party, and the Company has no means of accessing them. The narrow and specific exceptions to this position — namely the free-tier usage counter, advertising, optional backup, and subscription payment — are set out in Clause 4 below.

4 Information Handled by the Application

4.1 Information you enter, stored on your Device

The following information, to the extent you choose to enter it, is stored in the Local Storage of your Device and is not received by the Company:

• your business name, tagline, contact person’s name, telephone number, and electronic mail address;
• your bank account information, including account number, IFSC code, and bank/branch name (constituting SPDI; see Clause 6 as to the additional safeguards applied to this category of information), together with your Unified Payments Interface (“UPI”) identifier;
• your Goods and Services Tax Identification Number (“GSTIN”) and state of registration;
• the name, telephone number, PAN, billing address, and GSTIN (where applicable) of your customers, as entered by you;
• the particulars of goods or services supplied, including description, quantity, unit price, applicable Harmonized System of Nomenclature (“HSN”) or Services Accounting Code (“SAC”), taxes, and any notes appended to an invoice;
• any business logo or signature image you add, which is stored as a file within Local Storage and is not uploaded to the Company.

4.2 The free-tier usage counter (the Company’s only server-side Processing)

To fairly enforce the monthly invoice limitation applicable to the free tier, and to prevent its circumvention by means of uninstallation and reinstallation, the Application records, against a device identifier, the number of invoices created in the current calendar month. This record is stored using Google Cloud Firestore, a service provided by Google LLC, under the Company’s project. It contains only the said identifier and a count, and contains no invoice content, no customer information, and no other Personal Information. This is the only information the Application transmits to, and stores on, infrastructure controlled by the Company.

4.3 Device identifier

The identifier used for the purpose described in Clause 4.2 is the Android ID — a per-application, per-device identifier that does not constitute the device’s IMEI, serial number, or any identifier of comparable specificity. It is processed solely for the said purpose, and is not used for advertising, cross-application tracking, or analytics. The Company does not use the device’s advertising identifier for the counter; advertising is addressed separately at Clause 4.4.

4.4 Advertising (free tier)

The free tier of the Application is supported by advertising served by Google AdMob, a service provided by Google LLC. A User may be shown a banner advertisement within the Application and, occasionally, a full-screen advertisement upon opening the Application. In connection with the selection, delivery, and measurement of such advertisements, Google (through the AdMob software incorporated in the Application) may collect and process information from the Device, which may include the device’s advertising identifier, IP address, coarse location inferred therefrom, and information as to the Device and the User’s interaction with the advertisement. Google acts in respect of such information as an independent controller under the Google Privacy Policy and Google’s advertising terms; the Company does not receive such ad-targeting information and does not use it to profile any User. Advertising is not shown to Users subscribed to a paid tier of the Application. Reference is made to Google’s disclosures at policies.google.com/technologies/ads.

4.5 Optional backup to your Google Drive

The Application provides an optional facility by which a User may create a backup of the User’s data for the purpose of restoring it on a new device or following reinstallation. Where a User elects to use this facility, the backup is written to that User’s own Google Drive account, within a folder associated with the Application, pursuant to the authorisation granted by the User through Google’s standard authorisation interface. The data backup is encrypted on the Device, prior to transmission, using a password chosen by the User; such password is not transmitted to, or stored by, the Company or Google, and a backup so encrypted cannot be recovered in the event the password is lost. The Company does not read, list, or retrieve the contents of any User’s Google Drive.

4.6 Payment information

All subscription payments are processed exclusively through Google Play Billing. The Company does not collect, view, transmit, or store any payment card, UPI, or bank credential submitted by a User in connection with the purchase of a subscription; such information is processed entirely by Google. The Company receives only the User’s entitlement status (the plan held and its expiry) for the purpose of enabling the corresponding features.

4.7 Information not collected

For the avoidance of doubt, the Application does not access or collect precise or approximate geolocation data; does not access the Device’s contacts, camera, or microphone; and does not collect the User’s name, email address, or any login credential, no account registration being required. The only permissions the Application requests are Internet access and network-state access, each required for the functions described in this Clause 4.

5 Purpose of Processing

Information handled through the Application is used solely for the following purposes:

• to generate, store, retrieve, and display invoices and business profile records on the Device, at the User’s direction;
• to generate PDF renderings of invoices and to facilitate the sharing thereof by the User, at the User’s own direction;
• to fairly enforce the usage limitation applicable to the free tier (Clause 4.2);
• to display advertising to Users of the free tier, and to process subscription payments for Users of a paid tier, as applicable (Clauses 4.4 and 4.6);
• to create and restore optional backups at the User’s request (Clause 4.5); and
• to respond to support or grievance communications initiated by the User.

The Company does not sell, rent, or trade Personal Information to any third party for any consideration.

6 Data Security and Storage

As set out in Clause 3, the substantial majority of the information handled by the Application resides only in the Local Storage of the Device and is not transmitted to the Company. In respect of such information as does leave the Device, and of the information stored locally, the Company applies the following measures:

• your bank account number and IFSC code, being SPDI, are encrypted on the Device using the Android Keystore hardware-backed cryptographic facility (where the Device supports it), prior to being stored, and are not stored or accessible in plain, unencrypted form, including to the Company;
• the optional data backup described in Clause 4.5 is encrypted on the Device, using a password known only to the User, before it is written to the User’s Google Drive;
• the free-tier counter described in Clause 4.2 is transmitted over connections secured by Transport Layer Security (TLS);
• the Application does not permit clear-text (unencrypted) network traffic, and does not allow its private data to be extracted through device backup mechanisms of the operating system.

Notwithstanding the foregoing, no method of electronic transmission or storage is entirely secure, and the Company cannot guarantee the absolute security of information handled through the Application.

7 Disclosure to Third-Party Processors

The Company engages the following third-party service providers, each of which processes information solely to the extent necessary to provide the respective service described, and in accordance with such providers’ own applicable privacy policies:

The Company may further disclose information where required to do so by applicable law, regulation, legal process, or governmental request, or where necessary to establish, exercise, or defend a legal claim, or to protect the rights, property, or safety of the Company, its Users, or the public.

8 Cross-Border Transfer of Information

The third-party service providers identified in Clause 7 may process and store information on servers located outside India. By using the Application, the User acknowledges and consents to the transfer of information to jurisdictions outside India for the purposes described in this Policy, subject to such providers’ contractual and technical safeguards.

9 Data Retention and Erasure

As the substantial majority of your information resides only on your Device, you control its retention directly. You may edit or delete any invoice, customer, or business record within the Application at any time. The “Delete account” function provided within the Application’s Account section permanently and irreversibly erases your business profile, all associated invoice records, and all files stored by the Application from the Device; such deletion takes effect immediately and cannot subsequently be reversed or recovered by the Company. Uninstalling the Application likewise removes its Local Storage from the Device, and a backup may be deleted by the User from the User’s Google Drive.

The free-tier counter described in Clause 4.2 resets each calendar month. To have the counter record associated with your Device erased, you may contact the Company using the particulars in Clause 13, and the Company shall delete it.

10 GST Invoicing Feature — Scope and Limitation

The Application incorporates a feature intended to assist Users in the preparation of invoices compliant with the Goods and Services Tax framework, and in the generation of summary exports in a format suitable for use in the preparation of GSTR-1 returns. The Company does not itself file any return with the Goods and Services Tax Network or any governmental authority on behalf of any User; such filing may lawfully be undertaken only through providers duly authorised in that behalf. The reference data (HSN/SAC codes and postal-index-number-to-state mapping) used by this feature is packaged within the Application itself and does not involve the transmission of User data to any external lookup service.

11 Children’s Privacy

The Application is designed for use by business proprietors of the age of majority and is not directed to, nor knowingly used to collect Personal Information from, children under the age of 18 years. Should the Company become aware that it has inadvertently collected Personal Information from a child, it shall take reasonable steps to delete such information promptly.

12 Rights of the Data Principal

Subject to applicable law, a User (Data Principal) has the following rights in respect of their Personal Information:

• Right to access and correction: all business and invoice records entered by a User remain visible to, and directly editable by, that User at all times within the Application.
• Right to erasure: as set out in Clause 9.
• Right in respect of advertising: a User may reset or limit advertising-identifier-based personalisation through the Device’s settings (on most devices, under Settings › Google › Ads), or may eliminate advertising entirely by subscribing to a paid tier.
• Right to grievance redressal: as set out in Clause 13.

13 Grievance Redressal

In accordance with the requirements of applicable Indian law, the Company has designated the following Grievance Officer to address any complaint or concern regarding the Processing of Personal Information under this Policy:

The Grievance Officer shall acknowledge receipt of any complaint and shall endeavour to redress the same within the timelines prescribed under applicable law.

14 Amendment of this Policy

The Company reserves the right to amend, modify, or update this Policy at its sole discretion, at any time, to reflect changes in the Application’s functionality or in applicable law. Any such amendment shall be reflected by an updated “Last revised” date at the head of this document, and the amended Policy shall be published at this address. Continued use of the Application following any such amendment shall constitute the User’s acceptance of the Policy as so amended.

15 Governing Law and Jurisdiction

This Policy shall be governed by, and construed in accordance with, the laws of India. Any dispute arising out of or in connection with this Policy shall be subject to the exclusive jurisdiction of the competent courts at Rajkot, Gujarat, India.

16 Contact Information

For any query, clarification, or concern regarding this Policy or the Company’s data practices, the User may contact: