Privacy policy
Last updated 13 October 2026
Draft, not yet in force. This page needs review by a lawyer, and the highlighted details filled in, before the site goes live.
This policy covers the Pathledge website at pathledge.com and its waitlist. It does not cover the Pathledge product, which will have its own terms and privacy policy before anyone outside the beta is given access.
1. Who we are
Pathledge is a product of Prymera Consulting Private Limited, a company incorporated in India (CIN U72900WB2020PTC238750). Our office is at WeWork Salarpuria Symbiosis, Arekere, Bannerghatta Rd, Bengaluru, Karnataka 560076, India. The company's registered office is at Unit No. 10, 16th Floor, Aurora Waterfront, GN-34/1, Salt Lake City, Sector V, Kolkata, West Bengal 700091, India. We decide why and how the personal data described here is used. In European and UK law that makes us the controller; in Indian law, the data fiduciary.
Contact for anything in this policy: vivek@truoco.com.
2. What we collect
| What | When | Why |
|---|---|---|
| Your email address | When you join the waitlist | To confirm your place, tell you about Pathledge's launch and invite you in |
| Optional answers: the tools you ship with, who you ship for, how many environments you look after, and a free-text note | If you choose to answer after joining | To decide the order of invitations and to understand who Pathledge is for |
| Sign-up details: date and time, the page you signed up on, the page that referred you, and your IP address | When you submit a form | To keep a record of your consent and to detect spam and abuse |
| Usage data: pages viewed, approximate location (country or city, derived from IP address), device and browser, and how you move through the page (clicks, scrolling, and session recordings with form fields masked) | Only if you accept analytics cookies | To understand how the site is used and improve it |
| Anything you send us by email | When you write to us | To reply and keep a record of the request |
We do not ask for your name, a password or payment details on this site, and we ask you not to put sensitive personal information in the free-text note.
3. Our legal grounds
- Consent: for waitlist emails, for the optional answers, and for analytics. You give it by submitting the form or accepting analytics cookies, and you can withdraw it at any time (section 8).
- Legitimate interests: for keeping the site secure, stopping spam sign-ups and keeping a record of consent. Under India's Digital Personal Data Protection Act we rely on your consent and on the legitimate uses that Act allows.
- Legal obligation: where a law requires us to keep or disclose a record.
4. Who we share it with
We do not sell personal data, and we do not share it for anyone else's advertising. We use a small number of service providers who process data on our instructions:
- our hosting and database provider, which stores the waitlist;
- our email delivery provider, which sends waitlist emails;
- Google (Google Analytics) and Microsoft (Microsoft Clarity), only if you accept analytics cookies. Both act under their own terms as well as ours, and Microsoft may use Clarity data to improve its own services. See our cookie policy.
We may also disclose data if the law requires it, or to a buyer if the Pathledge business is sold, in which case this policy continues to apply to data already collected.
5. Where it is processed
We are based in India, and our providers may process data in India, the European Economic Area, the United Kingdom, the United States and other countries where they operate. Where data covered by European or UK law leaves those regions, we rely on the safeguards those laws accept, such as the European Commission's standard contractual clauses and the UK addendum to them.
6. How long we keep it
- Waitlist details: until you leave the list or have been invited and have either joined or declined, and in any case no longer than 24 months after you signed up, unless you confirm you want to stay.
- Record of your consent and of any unsubscribe: for up to three years after it ends, so we can show what you agreed to and avoid emailing you again.
- Analytics data: up to 14 months in Google Analytics and up to 13 months in Microsoft Clarity, with session recordings kept for about 30 days.
- Emails you send us: for up to two years after the conversation ends.
7. How we protect it
Data is encrypted in transit, the waitlist is readable only by a small number of named people at Prymera Consulting Private Limited, and access is logged. No system is perfectly secure; if a breach affects your data we will tell you and the relevant authority as the law requires.
8. Your choices and rights
- Leave the waitlist: use the unsubscribe link in any email, or write to vivek@truoco.com.
- Change your analytics choice: use "Cookie settings" at the foot of any page.
- See, correct or delete your data, or get a copy of it: write to vivek@truoco.com. We reply within 30 days and may need to confirm the request comes from you.
Depending on where you live, you also have these rights:
- India: to a summary of your data and how it is processed, to correction and erasure, to have a complaint dealt with by our grievance officer (section 10), to nominate someone to exercise your rights if you die or lose capacity, and to complain to the Data Protection Board of India.
- European Economic Area and United Kingdom: to access, rectification, erasure, restriction, data portability and objection, to withdraw consent, and to complain to your local data protection authority or, in the UK, the Information Commissioner's Office.
- California and other US states: to know, delete and correct your data and not to be treated differently for asking. We do not sell personal information or share it for cross-context behavioural advertising. We treat a Global Privacy Control signal from your browser as a refusal of analytics cookies.
9. Children
This site is for people working in software. It is not directed at anyone under 18, and we do not knowingly collect their data. If you believe a child has signed up, tell us and we will delete the record.
10. Grievance officer
Vivek Sharma, Director, Prymera Consulting Private Limited, WeWork Salarpuria Symbiosis, Arekere, Bannerghatta Rd, Bengaluru, Karnataka 560076, India. Email: vivek@truoco.com. We acknowledge complaints within 48 hours and aim to resolve them within 30 days.
11. Changes to this policy
If we change this policy we will update this page and its date. If the change affects how we use data you have already given us, we will email the waitlist before it takes effect.