logo

Arrowhead

Privacy policy

1. Scope

Arrowhead (AH Live Private Limited, "Arrowhead," "we," "our," or "us") is a Software-as-a-Service(SaaS) provider that delivers AI-powered voice automation, productivity analytics, and knowledge-management solutions (collectively, the "Services").

This Privacy Statement describes how we collect, use, disclose, and protect Personal Data relating to:

Employees & Contractors

anyone engaged by Arrowhead inside or outside India, including current and former employees, directors, interns, and third-party workers (collectively "Employees").

End-Customers & End-Users

natural persons who interact with our Services through our enterprise clients (collectively "Customers").

Where required, additional notices or contractual data-processing agreements (DPAs) may supplement this Statement

2. Definitions

Personal Data

Any information that identifies or can reasonably be linked to an individual.

Sensitive Personal Data

Personal Data that is subject to heightened protection under law (e.g., financial information, health data, biometric identifiers, government IDs)

Processing

Any operation performed on Personal Data (collection, storage, use, disclosure, deletion, etc.).

Controller / Processor

For Employee data, Arrowhead acts as Controller. For Customer data, Arrowhead typically acts as Processor on behalf of our enterprise client, who is the Controller.

3. Categories of Personal Data We Collect

3.1. Employee & Contractor Data

Identifiers

Name, email, phone, emergency contact, address, date of birth, gender, citizenship, government IDs, photographs.

Employment Information

Job title, department, employee ID, supervisor, start/end dates, contract type, compensation & benefits, leave records, training records, performance evaluations, disciplinary records.

Financial Data

Salary details, bank account number, tax identifiers, reimbursement records.

Health & Safety

Occupational health declarations, disability accommodations, workplace incident reports, CCTV footage, access-badge logs.

IT & Usage Data

Corporate device IDs, log-in credentials, access logs, email/communication metadata, IP addresses

3.2.Customer Data Collected Through the Services

Identifiers

Name (if provided in conversation), mobile phone number (stored only when provided or fetched via secure on-demand API from the client) and other identifiers as needed based on usecase.

Interaction Content

Call audio recordings, transcripts, tool-invocation parameters, user selections (e.g., preferred slot, product, or service).

Transactional & Device Metadata

Call timestamps, duration, routing information, bot/agent IDs, browser or telephony headers, IP address, device type.

We collect only the minimum data required to fulfill the purposes set out below.

4. Legal Bases for Processing

Employees

Performance of employment contract; compliance with labour, tax, and social-security law; Arrowhead's legitimate interests (e.g., network security); and, where required, consent (e.g., use of photos for marketing)

Customers

Performance of our client contract (service delivery); compliance with legal obligations; Arrowhead's legitimate interests in service quality, fraud prevention, and security; consent where required by law (e.g., voice recording notices)

5. Purposes of Collection & Use

5.1 Employee & Contractor Purposes (non-exhaustive)

Workforce administration (hiring, onboarding, payroll, benefits, performance, promotion, termination).

Corporate governance, budgeting, and financial reporting.

IT account provisioning, authentication, and security monitoring.

Health & safety, access-control, and premises security (including CCTV).

Compliance with statutory obligations (tax, social security, immigration, ESOP, whistle-blower investigations).

Investigation of misconduct, fraud, or legal claims.

5.2 Customer Purposes (non-exhaustive)

Delivering the contracted voice AI or automation workflow (e.g., scheduling a call, completing a purchase, routing to a human agent).

Generating and storing audio & transcript logs to enable quality assurance, dispute resolution, and regulatory compliance

Arrowhead does not sell Customer Personal Data or use it for marketing unrelated to the contracted Services.

6. Disclosure Practices

Internal Functions

HR, Finance, IT, Legal, Security teams with role-based access.

Enterprise Clients (Controllers)

Access to Customer interaction data generated through their own end-users, via secure dashboards or APIs.

Service Providers/ Sub-processors

Cloud hosting, telephony platforms, payroll vendors, benefits administrators, email & collaboration tools—each bound by confidentiality and data-processing agreements.

Regulators & Authorities

Responding to lawful requests, audits, or court orders

Corporate Transactions

Mergers, acquisitions, or asset transfers, subject to non-disclosure and continuation of protections.

Sensitive Personal Data is shared only on a strict need-to-know basis and, where mandated, with additional safeguards or contractual clauses.

7. Security Measures

Arrowhead maintains a layered security program aligned with ISO 27001 and the Indian Digital Personal Data Protection Act (DPDP 2023):

Encryption

AES-256 at rest, TLS 1.2+ in transit; customer name and phone numbers and PII data are encrypted at application level additional using AES-GCM.

Access Control

SSO (mandatory for all internal Arrowhead systems; customer-facing SSO available as an opt-in), MFA, least-privilege IAM roles, segregation of duties, and quarterly access reviews

Network & Infrastructure Security

AWS Guard Duty, Inspector, and Macie; Web Application Firewall (WAF) on public endpoints; VPC segmentation.

Monitoring & Logging

Centralised SIEM, immutable audit logs, anomaly detection, 24×7 alerting.

Secure Development Lifecycle

Code reviews, dependency scanning, container image hardening, staged rollouts.

Business Continuity & DR

Automated backups, point-in-time RDS snapshots, cross-region replication, validated recovery playbooks.

Vendor Management

Third-party risk assessments, contractual security requirements, and right-to-audit clauses.

Dedicated Single-Tenant Deployments

For customers requiring complete isolation, Arrowhead provisions and operates a dedicated AWS account exclusively for the client. Arrowhead maintains administrative control while granting the customer read-only auditor access for transparency. This option may be subject to additional costs depending on the contractual arrangement.

8. International Data Transfers

Default Storage Region

Unless otherwise specified, all customer data is stored in AWS us‑east‑1 (Virginia). This region offers the best latency for our global customer base and is protected by the controls described in Section 5.3.

India Data Residency

Customers that require data to remain in-country may opt for storage exclusively in AWS ap-south-1 (Mumbai/BOM). All primary and backup copies stay within Indian territory.

Singapore/Malaysia Data Residency

For customers based in Malaysia and Singapore who require local data residency, Arrowhead offers storage in AWS Asia Pacific regions – either Singapore (ap-southeast-1) or Kuala Lumpur (ap-southeast-5), based on customer preference or regulatory requirements. All data, backups, and metadata remain within the selected region.

Employee Data

Employee data is normally stored in India. Limited cross-border transfer (e.g., into global HR SaaS tools) is subject to adequacy findings or SCCs plus encryption.

Transfer Mechanisms

Any cross-border transfers rely on:

Adequacy decisions under applicable privacy laws; or

Contractual safeguards such as Standard Contractual Clauses (SCCs) augmented by end-to-end encryption.

9. Data Subject Rights

Subject to local law, Employees and Customers may have rights to:

  • Access, correct, or delete Personal Data
  • Restrict or object to certain Processing
  • Port data to another service provider
  • Withdraw consent at any time (where consent is the legal basis); and
  • Lodge a complaint with a supervisory authority.
  • Requests should be sent to privacy@arrowhead.team. We respond within one month, or two months for complex cases.
  • 10. Data Retention

    Employee records

    7 years after termination (or longer if required by labour or tax law).

    Customer call recordings & transcripts

    Till contract term, configurable per client contract. Post contract termination data is deleted upon customer request or per compliance.

    Security & access logs

    12 months for operational logs; up to 7 years for forensic or legal hold.

    When retention expires, data is securely deleted or irreversibly anonymised.

    11. Withdrawal of Consent

    Where processing of Personal Data is based on consent, a Data Principal has the right to withdraw such consent at any time by writing to the Company at dpo@yourcompany.com or through any other mechanism made available by the Company.

    Upon receipt of a valid request for withdrawal of consent, the Company shall cease processing the relevant Personal Data, except where such processing is required under applicable law or is necessary for the performance of contractual or legal obligations.

    12. Consequences of Withdrawal

    Withdrawal of consent may result in the inability of the Company to provide certain services or functionalities that depend on such Personal Data. The Company shall not be liable for any consequences arising from such limitation or discontinuation of services resulting from the withdrawal of consent.

    The withdrawal of consent shall not affect the lawfulness of processing carried out prior to such withdrawal.

    13. Data Principal Rights & Grievance Redressal

    In accordance with applicable data protection laws, including the Digital Personal Data Protection Act, 2023, individuals whose personal data is processed by the Company (“Data Principals”) have the right to:

  • Access information relating to the processing of their Personal Data;
  • Request correction or erasure of inaccurate, incomplete, or no longer required Personal Data, subject to applicable law;
  • Withdraw consent at any time where processing is based on consent, without affecting the lawfulness of prior processing (noting that such withdrawal may impact service availability);
  • Seek grievance redressal in relation to the processing of Personal Data; and
  • Nominate an individual to exercise their rights in the event of death or incapacity.
  • 14. Data Protection and Grievance Redressal

    The Company is committed to protecting the privacy and personal data of individuals. Pursuant to the provisions of the Digital Personal Data Protection Act, 2023, the Company has designated a Data Protection Officer / Grievance Officer to handle queries, requests, and grievances in relation to personal data.

    Any data principal may contact the Grievance Officer using the details below:

    Designation: Data Protection Officer / Grievance Officer

    Email: dpo@arrowhead.com

    Address: No.882, 11th Main, 3rd Cross, HAL II Stage, Indiranagar, Bangalore - 560038, India

    15. Updates to This Statement

    We review this Statement annually or whenever material changes occur to our Processing activities or applicable law. We will notify Employees and Clients of significant updates via email.