Privacy Policy

1. Who we are and what this policy covers

PALM SOUQ PRIVATE LIMITED ("PALM SOUQ", "we", "us") is a private limited company incorporated in India (CIN U46309TN2026PTC193667) with its registered office at Old No. 65, New No. 135/7, Govindappa Naicken Street, Tondiarpet, Fort St George, Chennai, Tamil Nadu 600001, India. PALM SOUQ operates an LLM gateway and cost governance platform that meters token usage per tenant, enforces budgets and rate limits, and stops runaway agent loops in the request path.

This Privacy Policy explains how we handle personal data when you visit palmsouqltd.com, create an account, use the PALM SOUQ dashboard, APIs, SDKs and gateway (together, the "Service"), contact us, or apply for a job. It applies to PALM SOUQ acting as a controller (a "data fiduciary" under India's Digital Personal Data Protection Act, 2023).

When our customers route their own end users' requests through the gateway, the customer is the controller of that data and PALM SOUQ acts as a processor (a "data processor" under the DPDP Act). That processing is governed by our Data Processing Addendum and the customer's own privacy notice, not by this policy. If you are an end user of one of our customers, please contact that company directly.

2. Zero Payload Retention

The gateway is designed so that we never need to keep the content of your AI traffic. Request prompts, system messages, tool arguments and model completions stream through gateway memory to and from the model provider. They are not written to disk, not stored in logs, not included in metrics or traces, and not retained after the request completes. We call this Zero Payload Retention.

To count tokens and evaluate loop heuristics, the gateway inspects payloads in memory while the request is in flight. Loop detection relies on derived signals such as token counts per second, tool names and call sequences, step depth and short-lived similarity fingerprints that cannot be reversed into the original text. These signals are held in memory for the duration of the detection window and then discarded.

What we do store for each request is metadata: the timestamp, gateway region, the tenant, tier, feature and user identifiers you choose to send in the X-PalmSouq-Tenant, X-PalmSouq-Tier, X-PalmSouq-Feature and X-PalmSouq-User headers, the model and provider, input, output, cached and cache write token counts, computed cost, latency, HTTP status and any breaker or quota decision. We recommend that you send opaque identifiers in these headers rather than names or email addresses.

3. Personal data we collect

• Account data: name, work email, company, role, password hash or single sign-on identifier, and team membership.
• Billing data: billing contact, billing address, tax identifiers such as GSTIN where applicable, and payment status. Card details are collected and stored by our payment processor, Stripe; we never see or store full card numbers.
• Gateway metadata: the request metadata described in section 2, including any identifiers you place in PALM SOUQ headers.
• Provider credentials: the API keys you store with us for model providers. They are encrypted with keys held in hardware security modules and are never exposed to the browser after you save them.
• Usage and device data: dashboard activity, IP address, browser type, and pages viewed on palmsouqltd.com, collected through strictly necessary cookies and our own first-party analytics.
• Communications: messages you send to sales, support, security or press, call notes, and survey responses.
• Recruiting data: your CV, application answers, interview feedback and references, when you apply for a role.

4. How we use personal data and our legal bases

We use personal data only for the purposes below. Under the GDPR, we rely on the legal basis noted for each purpose. Under the DPDP Act, we rely on your consent or on the legitimate uses permitted by section 7 of the Act, such as the performance of a contract you have requested.

5. What we do not do

• We do not sell personal data, and we do not share it for cross-context behavioral advertising.
• We do not use prompts, completions or gateway metadata to train machine learning models, ours or anyone else's.
• We do not use advertising cookies or third-party ad trackers on palmsouqltd.com.
• We do not make decisions that produce legal or similarly significant effects about you based solely on automated processing. Breaker and quota decisions apply to API traffic according to rules the customer configures.

6. Sharing and subprocessors

We share personal data with service providers that help us operate the Service, under written contracts that require them to protect it and use it only on our instructions. The current list, with each provider's purpose and location, is published at palmsouqltd.com/legal/subprocessors, and we give customers at least 30 days' notice before adding a new subprocessor.

We also forward your requests to the model providers you configure, such as OpenAI, Anthropic, Google or AWS. Those providers receive the request content because that is the purpose of the request; their handling of it is governed by your agreement with them. We may disclose personal data if required by law, to protect the rights and safety of our users or the public, or in connection with a merger or acquisition, in which case we will notify you before your data becomes subject to a different policy.

7. International transfers and data residency

PALM SOUQ operates regional control planes in US East, US West, EU Central, India South and Singapore. Customers on Growth and Scale plans can pin gateway metadata to the United States, the European Union or India. Account and billing data is processed in the United States and India.

Where personal data from the European Economic Area, the United Kingdom or Switzerland is transferred to a country without an adequacy decision, we use the European Commission's Standard Contractual Clauses and the UK International Data Transfer Addendum, together with supplementary measures such as encryption in transit and at rest. Transfers of personal data out of India follow the DPDP Act and any restrictions notified by the Government of India under section 16.

8. Retention

Payloads are not retained at all. Gateway metadata is kept for the retention period of your plan: 7 days on Starter, 13 months on Growth, and a contracted period on Scale, after which it is deleted or aggregated so it no longer identifies a person. Account data is kept while your account is active and for 90 days after closure. Billing records are kept for 8 years to meet Indian and US tax and accounting obligations. Recruiting data is kept for 12 months after a hiring decision unless you ask us to delete it sooner.

9. Security

We protect personal data with encryption in transit (TLS 1.2 or higher) and at rest (AES-256), hardware-backed key management for provider credentials, single sign-on and hardware keys for staff access, least-privilege access reviews, and continuous monitoring. Our controls are audited annually against the SOC 2 Type II criteria. More detail is available on our Security page and in the Trust Center. If we become aware of a personal data breach affecting you, we will notify you and the relevant authorities, including the Data Protection Board of India, within the time the law requires.

10. Your rights

Depending on where you live, you have some or all of the following rights. You can exercise them by writing to privacy@palmsouqltd.com. We will verify your identity, respond within 30 days, and not discriminate against you for exercising them.

• Access: obtain a summary or copy of the personal data we hold about you and how we use it.
• Correction and completion: ask us to fix inaccurate or incomplete data.
• Erasure: ask us to delete your personal data, subject to legal retention duties.
• Portability: receive your data in a structured, machine-readable format.
• Objection and restriction: object to processing based on legitimate interests, or ask us to restrict it.
• Withdraw consent: withdraw consent at any time, for example by unsubscribing from marketing email. Withdrawal does not affect processing that happened before it.
• Nominate (India): nominate another person to exercise your rights in the event of your death or incapacity, as provided by section 14 of the DPDP Act.
• Grievance redressal (India): raise a grievance with our Grievance Officer, and if unresolved, complain to the Data Protection Board of India.
• California: know, delete, correct, and opt out of sale or sharing (we do neither), and limit use of sensitive personal information (we use it only as permitted).
• Complain to a supervisory authority: in the EU or UK, you may lodge a complaint with your local data protection authority.

11. Children

The Service is built for businesses and is not directed at children. We do not knowingly collect personal data from anyone under 18. If you believe a child has provided us personal data, contact privacy@palmsouqltd.com and we will delete it.

12. Grievance Officer and contact

In accordance with the DPDP Act, 2023 and the Information Technology Act, 2000 and rules made under it, our Grievance Officer is Kabir Sethi, Head of Security and Compliance, PALM SOUQ PRIVATE LIMITED, Old No. 65, New No. 135/7, Govindappa Naicken Street, Tondiarpet, Fort St George, Chennai, Tamil Nadu 600001, India. Email: privacy@palmsouqltd.com. Phone: +91 (044) 4123-4040, Monday to Friday, 9:00 to 19:00 IST. We acknowledge grievances within 48 hours and resolve them within 30 days.

For all other privacy questions, write to privacy@palmsouqltd.com or legal@palmsouqltd.com.

13. Changes to this policy

We will post any changes on this page and update the effective date. If a change materially affects how we use personal data, we will notify account owners by email at least 30 days before it takes effect.