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Legal  ·  Data & Privacy

Privacy Policy

Effective: 13 March 2026  ·  Jurisdiction: India (DPDP Act 2023)
DOC-PRIV-2.1
01  ·  Overview

Who this policy covers

This Privacy Policy describes how Conduit Lead Intelligence Infrastructure ("Conduit", "we", "us") collects, processes, stores, and protects personal data in the course of operating the lead intake and qualification platform.

Conduit is a B2B infrastructure product. Clients are the businesses that deploy Conduit to manage their own lead pipelines. Data principals (referred to as "leads" within the platform) are the individuals whose personal information is submitted through lead capture forms, email, WhatsApp, or CSV import.

Important

Each Conduit deployment is operated by an independent client on their own infrastructure. That client is the primary data fiduciary under the India Digital Personal Data Protection Act 2023 (DPDP Act). Conduit provides the processing infrastructure; the client is responsible for obtaining lawful consent from their leads before their data enters the system.

02  ·  Data We Collect

What personal data is processed

The categories of personal data processed by Conduit depend on the client's configuration. For the reference travel deployment, the following data is collected:

Field Type Purpose
Full Name Identity Required for personalised outreach. Not used in lead scoring.
Phone Number Contact Primary channel for WhatsApp outreach and deduplication.
Email Address Contact Secondary channel, ingested via Gmail pipeline.
Travel Destination Qualifying signal Used in LSQA scoring (Intake Completeness Score).
Travel Date Qualifying signal Used in LSQA scoring (Temporal Urgency Index).
Budget Qualifying signal Used in LSQA scoring (Allocation Signal Density).
Conversation messages Behavioural WhatsApp conversation history used by AI qualification agent.
Lead source Metadata Used in LSQA scoring (Source Authority Index) and analytics.
Consent method & timestamp Compliance Records how and when the individual consented to be contacted.

Fields are defined per-client in their configuration file. The set of data collected for any deployment is limited to what the client configures.

03  ·  Collection Methods

How personal data enters the system

  • Meta Lead Ads Webhook: Real-time lead data submitted through Meta (Facebook/Instagram) lead generation forms. Webhook payloads are verified via HMAC-SHA256 signature before processing.
  • Gmail API: Lead notification emails from configured sender addresses are ingested and parsed using the Claude AI API. The Gmail integration uses OAuth 2.0 and is limited to reading emails from specified sender addresses only.
  • WhatsApp (Twilio): Inbound WhatsApp messages from leads are received via Twilio's webhook. All inbound messages are verified using Twilio's request signature before processing.
  • CSV Import: Clients may upload CSV files containing lead data via the dashboard. Clients are responsible for ensuring that all imported leads have provided appropriate consent.
04  ·  AI Processing

Automated processing and AI

Conduit uses the Claude AI API (provided by Anthropic, PBC) for two processing functions:

  • Email parsing: Incoming lead notification emails are sent to the Claude API to extract structured lead fields (name, phone, destination, travel date, budget). No human reviews this extraction.
  • Conversation qualification: The AI qualification agent ("Priya" in the reference deployment) responds to WhatsApp messages on behalf of the client. The agent extracts qualifying information from conversation turns, updates the lead's score, and determines escalation or disengagement.
AI Disclosure

The qualification agent is an AI system. If a lead directly asks whether they are speaking to a bot, robot, or AI, the system is required to honestly disclose that it is an AI assistant. This requirement is enforced in the agent's operating instructions and aligns with WhatsApp Business API policy and applicable transparency obligations.

Automated lead scoring (the LSQA model) assigns each lead a score between 0–100 and categorises them as HOT, WARM, COLD, or JUNK. This scoring directly affects the outreach sequence the lead receives. Leads may be manually re-scored or have their stage overridden by the client through the dashboard.

05  ·  Third-Party Processors

Who else processes the data

Personal data flows through the following third-party sub-processors as part of normal system operation:

Processor Role Data Transferred DPA / Agreement
Supabase Database (PostgreSQL) All lead PII, conversation history, scoring records DPA available. India deployments must use Singapore or Mumbai region.
Twilio WhatsApp messaging Phone number, message content DPA required. Sign via Twilio Console → Legal before go-live.
Anthropic (Claude API) AI email parsing & conversation agent Email content, conversation messages, lead fields Subject to Anthropic Usage Policy. DPA recommended for EU deployments.
Meta (Facebook) Lead Ads webhook source Form submission data Governed by Meta Business Terms & WhatsApp Business API policy.
Google Gmail API (OAuth) Email content from configured sender addresses only Governed by Google API Services User Data Policy.
Railway / Render Hosting platform Application logs (no persistent PII storage) Per-platform DPA / data processing addendum.

Each client deployment uses their own accounts with these third-party services. Client data is not co-mingled across deployments. Row-Level Security (RLS) is enforced on all Supabase tables, with client_id as the isolation key.

06  ·  Retention

How long data is kept

The default data retention period is 365 days from the date of lead creation, configured via the compliance.data_retention_days field in each client's configuration file. Clients may set a shorter retention period appropriate for their jurisdiction and regulatory obligations.

Conversation history, scoring records, outreach logs, and follow-up records are all subject to the same retention period as the parent lead record. After the retention period expires, all associated records are eligible for deletion.

07  ·  Data Principal Rights

Your rights under the DPDP Act 2023

Under the India Digital Personal Data Protection Act 2023, you have the following rights with respect to your personal data:

  • Right to Access: You may request a summary of the personal data held about you and the purposes for which it is being processed.
  • Right to Correction: You may request that inaccurate or incomplete personal data be corrected or updated.
  • Right to Erasure: You may request deletion of your personal data. The system supports full erasure: upon request, all records are deleted in dependency order across all tables (conversations, scoring history, follow-ups, outreach logs, and the lead record itself).
  • Right to Grievance Redressal: You may raise a grievance with the data fiduciary (the client operating the deployment) or, if unresolved, escalate to the Data Protection Board of India.
  • Right to Withdraw Consent: You may withdraw consent at any time. To opt out of all future WhatsApp communications, send the message STOP to the WhatsApp number you were contacted from. Upon receipt, all outreach is immediately halted, the lead record is archived, and all scheduled follow-ups are cancelled. The system will not send any further messages.

To exercise any of these rights, contact the client (the business that collected your information). The client is the data fiduciary and is responsible for responding to your request within the timeframes prescribed by the DPDP Act.

08  ·  Consent

How consent is collected and recorded

Consent is required before any lead data enters the system. The method of consent collection depends on the ingestion source:

  • Meta Lead Ads: Consent is captured via the Meta lead form at the time of submission. Each form must include an explicit WhatsApp opt-in checkbox. The consent method is recorded as meta_form.
  • Website / Gmail: Consent is captured via the website contact form. Forms must include explicit WhatsApp opt-in language. The consent method is recorded as website_form.
  • CSV Import: Clients uploading CSV data are responsible for confirming that all imported leads have provided valid prior consent. The consent method is recorded as csv_import.

The system records a consent_given_at timestamp and consent_method field on every lead record at the time of ingestion.

09  ·  Opt-Out

How to stop receiving messages

To immediately opt out of all WhatsApp communications, send any of the following messages to the WhatsApp number you were contacted from:

  • STOP
  • UNSUBSCRIBE
  • REMOVE ME

The system processes opt-out requests in real time. Upon detection, the lead record is archived and all pending follow-up messages are cancelled. No further messages will be sent from the system. This opt-out is permanent for that phone number within the deployment.

Compliance Note

Messaging a lead after they have sent a STOP request is a violation of the WhatsApp Business API Messaging Policy and may result in suspension of the client's WhatsApp Business Account. The Conduit opt-out mechanism is enforced at the infrastructure level and cannot be bypassed.

10  ·  Security

How data is protected

  • Database isolation: Row-Level Security (RLS) is enforced on all tables. Each client's data is isolated by client_id. Cross-client data access is architecturally prevented.
  • Webhook verification: All inbound webhooks (Meta, Twilio) are verified using cryptographic signatures before processing. Invalid requests are rejected with a 403 response.
  • Credential storage: API keys, tokens, and credentials are stored in environment variables only. No secrets are committed to the codebase. Dashboard authentication uses Argon2id password hashing.
  • TLS in transit: All external communication uses HTTPS/TLS. WhatsApp messages are encrypted in transit by the Twilio and Meta infrastructure.
  • Idempotent processing: Webhook events are deduplicated using a unique idempotency key, preventing duplicate lead creation from repeated deliveries.
11  ·  Policy Changes

Updates to this policy

This policy may be updated to reflect changes in Conduit's data processing practices, applicable law, or platform capabilities. Material changes will be reflected in the effective date at the top of this document. Continued use of the platform following an update constitutes acceptance of the revised policy.

12  ·  Contact

Reach us

For privacy-related inquiries, data principal rights requests, or to report a concern, contact the client operating the deployment you interacted with. For infrastructure-level inquiries regarding Conduit, use the contact form at conduit.infrastructure.

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