Legal & Compliance Suite
Effective: June 11, 2026 · Version 2.0 · Confidential
Documents in This Suite
Document 01
Terms of Service
Effective Date: June 11, 2026 · Version 2.0
1. Who We Are & What This Agreement Covers
LeadFrog is a software service operated by Ziwiz Technologies Private Limited ("LeadFrog", "we", "us", "our"). It operates an AI-powered lead capture and CRM automation platform that connects to your Instagram Business account and WhatsApp Business number to capture, classify, and follow up on leads automatically (the "Service").
These Terms of Service ("Terms") constitute a legally binding agreement between you (the individual or entity registering an account — "Customer", "you", "your") and LeadFrog. They govern your access to and use of the Service, our website (leadfrog.in), our mobile application (if any), and all associated features and content.
By clicking "Sign Up", "Get Started", or any similar button, or by otherwise accessing or using the Service, you confirm that:
- You have read and understood these Terms.
- You have the legal capacity to enter into a binding contract (you are at least 18 years old and, if acting on behalf of a company, you have authority to bind that company).
- You agree to be bound by these Terms and by our Privacy Policy, Cookie Policy, and Data Processing Addendum, each of which is incorporated into these Terms by reference.
2. The Service — What LeadFrog Does
2.1 Core Features
LeadFrog provides a platform that enables you to:
- Connect your Instagram Business account and receive real-time webhooks when your followers comment on your posts or send you Direct Messages.
- Use AI-powered classification to automatically categorise each comment or DM by purchase intent (e.g., Hot Lead, Warm, Cold, Spam, Inquiry).
- Trigger automated WhatsApp messages via WhatsApp Business API to engage classified leads instantly.
- Manage your leads in a visual Kanban-style CRM pipeline — track progress, assign team members, add notes.
- Use tracked DM links to see which leads visit your website and what they view, giving you intent data per lead.
- Access analytics and reporting on lead volume, conversion rates, and AI classification accuracy.
2.2 What LeadFrog Is Not
LeadFrog is a marketing automation and CRM tool. It is not:
- A licensed financial advisor, legal counsel, or medical platform — do not use it for financial, legal, or health-related decisions.
- A replacement for human judgment — AI classifications are suggestions, not guarantees.
- A bulk SMS or spam platform — it is designed for permission-based, conversational marketing only.
3. Account Registration & Security
To use LeadFrog you must register for an account. You agree to:
- Provide accurate, current, and complete information during registration and keep it updated.
- Maintain the confidentiality of your password and any API keys associated with your account.
- Be solely responsible for all activity that occurs under your account, whether or not you authorised it.
- Notify us immediately at security@leadfrog.in if you suspect unauthorised access to your account.
You may not share your account credentials with others, use another person's account, or create accounts for the purpose of circumventing usage limits. Each subscription covers one business entity. Teams can be added as sub-users within a single account at no extra charge (up to the limit for your plan).
LeadFrog reserves the right to suspend or terminate accounts that show signs of credential sharing, automated sign-up abuse, or any other violation of these Terms.
4. Connecting Third-Party Accounts
The Service requires you to connect your Meta (Instagram / WhatsApp) business accounts via OAuth. By doing so, you:
- Represent that you are the authorized administrator of those accounts and have the right to grant LeadFrog the permissions requested.
- Acknowledge that your use of Meta's platforms through LeadFrog remains subject to Meta's own Terms of Service, Platform Policy, and WhatsApp Business Policy. LeadFrog cannot override Meta's rules on your behalf.
- Understand that if Meta revokes, restricts, or changes its API access policies, features of the Service that depend on those APIs may be reduced or unavailable. LeadFrog will not be liable for such third-party platform changes.
- Agree to promptly notify us if your Instagram or WhatsApp account is suspended, restricted, or transferred to another owner.
5. Acceptable Use
5.1 You May Use LeadFrog To:
- Capture and follow up on leads generated from your own Instagram Business content.
- Automate polite, relevant, consent-based WhatsApp outreach to people who have expressed interest in your business.
- Manage your sales pipeline and track lead progress.
- Analyse your lead data to improve your marketing and conversion rates.
5.2 You Must NOT Use LeadFrog To:
- Send unsolicited commercial messages (spam) to people who have not interacted with your content or opted in to hear from you.
- Impersonate any person or entity, or falsely represent your affiliation with any organisation.
- Scrape, harvest, or bulk-collect personal data from Instagram or WhatsApp using LeadFrog's infrastructure.
- Use the Service to engage in any activity that violates Meta's Platform Terms, WhatsApp Business Policy, or TRAI's commercial communications regulations.
- Circumvent, disable, or interfere with any security feature of the Service or any connected third-party platform.
- Use the Service to target minors (under 18) with marketing messages.
- Process or transmit content that is defamatory, obscene, hateful, discriminatory, or in violation of any applicable Indian law (including the IT Act, IPC provisions on defamation, and DPDP Act).
- Reverse-engineer, decompile, disassemble, or attempt to derive the source code of the Service.
- Resell, sublicense, or white-label the Service without a separate written reseller agreement with LeadFrog.
- Use automated scripts, bots, or crawlers to access the Service other than through our official API.
Violation of these acceptable use rules may result in immediate suspension or termination of your account without refund. Serious violations (e.g., spamming, data scraping, illegal activity) will be reported to relevant authorities including CERT-In, TRAI, and law enforcement as appropriate.
6. Subscription Plans & Billing
6.1 Plans and Pricing
LeadFrog may offer multiple subscription plans, including free trial and paid tiers. Current plans, features, usage limits, and pricing are published on the LeadFrog website and may be updated from time to time. All applicable charges, billing frequency, and taxes will be clearly displayed before purchase. LeadFrog reserves the right to modify pricing or plan structures with reasonable prior notice to Customers.
6.2 Payment
Paid subscriptions are billed monthly or annually in advance. Payment is processed by Razorpay. By providing payment details, you authorise Razorpay to charge the applicable amount automatically on each billing date. You are responsible for ensuring your payment method remains valid. If a payment fails, we will notify you and provide a 7-day grace period before suspending your account.
6.3 Free Trial
New accounts receive a free trial period (duration shown at sign-up). No credit card is required during the trial. At the end of the trial, you must select a paid plan to continue using paid features. Trial accounts that are not upgraded will automatically revert to the free Starter tier, not a paid subscription.
6.4 Cancellation and Refunds
Customers may cancel their subscription at any time through their account settings or by contacting LeadFrog support. Unless otherwise required by applicable law, subscription fees are generally non-refundable after a billing cycle has started. Any exceptions, promotional offers, trial terms, or refund eligibility conditions will be described on the LeadFrog website or communicated at the time of purchase. LeadFrog reserves the right to review refund requests on a case-by-case basis and may provide refunds where required by law or where exceptional circumstances apply.
6.5 GST Invoices
GST-compliant tax invoices are emailed to your registered address after each payment. To receive invoices with your GSTIN for input tax credit, update your details in Account Settings → Billing → Tax Information.
7. Your Content & Data
7.1 Your Ownership
You retain full ownership of all content you create, configure, and store in LeadFrog — including your CRM data, lead records, automation flow configurations, and Subscriber Data. We do not claim any ownership rights in your content.
7.2 License to LeadFrog
By using the Service, you grant LeadFrog a limited, non-exclusive, worldwide licence to access, process, store, and transmit your content solely to the extent necessary to provide the Service to you. This licence terminates when you delete your account.
7.3 Your Responsibility for Subscriber Data
You are the Data Fiduciary (controller) under the DPDP Act for the personal data of your Subscribers. You represent and warrant that:
- You have a lawful basis (typically: the Subscriber's consent) to collect and process their data.
- You have provided your Subscribers with a privacy notice disclosing that LeadFrog processes their data on your behalf.
- You will comply with all Data Principal rights requests (access, erasure, correction) under the DPDP Act within the required timeframes.
- You will not use the Service to collect or process Special Category Data (health, biometric, financial credentials, caste, religion, sexual orientation) without a separate agreement with us.
8. Intellectual Property
LeadFrog and its licensors own all intellectual property rights in the Service, including the LeadFrog name, logo, software, UI design, documentation, and all AI models and prompt configurations developed by LeadFrog. Nothing in these Terms transfers any ownership of LeadFrog's intellectual property to you.
You are granted a limited, non-exclusive, non-transferable, revocable license to use the Service solely for your business purposes in accordance with these Terms. This licence does not include any right to sub-license, modify, create derivative works, or use LeadFrog's brand assets in any way without prior written consent.
If you provide feedback, suggestions, or ideas about the Service, you grant LeadFrog a perpetual, irrevocable, royalty-free license to use that feedback for any purpose without compensation to you.
9. Confidentiality
Both parties may have access to the other's confidential information in the course of using the Service. "Confidential Information" means any non-public information disclosed by one party to the other that is designated as confidential or that reasonably should be understood to be confidential given the context.
Each party agrees to: (a) protect the other's Confidential Information with at least the same care it uses for its own confidential information (but not less than reasonable care); (b) not disclose it to third parties without prior written consent; and (c) use it only for the purposes of the business relationship. These obligations do not apply to information that is publicly known, independently developed, or required to be disclosed by law.
10. Disclaimers
THE SERVICE IS PROVIDED "AS IS" AND "AS AVAILABLE" WITHOUT WARRANTY OF ANY KIND, EXPRESS OR IMPLIED. TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, LEADFROG DISCLAIMS ALL WARRANTIES INCLUDING IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, AND NON-INFRINGEMENT.
In particular, LeadFrog does not warrant that:
- AI classifications will be accurate, complete, or free from errors or bias.
- The Service will be uninterrupted, error-free, or free from security vulnerabilities (though we commit to the SLA in Document 05).
- Results obtained from using the Service will meet your business objectives.
- Third-party platforms (Meta, WhatsApp) will remain available or maintain their current API capabilities.
11. Limitation of Liability
TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, LEADFROG'S TOTAL CUMULATIVE LIABILITY TO YOU FOR ANY CLAIMS ARISING OUT OF OR RELATED TO THESE TERMS OR THE SERVICE — WHETHER IN CONTRACT, TORT (INCLUDING NEGLIGENCE), STATUTE, OR OTHERWISE — SHALL NOT EXCEED THE TOTAL FEES PAID BY YOU TO LEADFROG IN THE 12 MONTHS PRECEDING THE CLAIM.
IN NO EVENT SHALL LEADFROG BE LIABLE FOR: (A) LOSS OF REVENUE, PROFITS, OR BUSINESS OPPORTUNITIES; (B) LOSS OF DATA (BEYOND THE DATA RECOVERY COMMITMENT IN THE SLA); (C) INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, OR PUNITIVE DAMAGES; EVEN IF ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.
Some jurisdictions do not allow certain liability exclusions. In those jurisdictions, our liability is limited to the maximum extent permitted by law.
Nothing in these Terms excludes or limits LeadFrog's liability for: (i) fraud or fraudulent misrepresentation; (ii) death or personal injury caused by our negligence; (iii) any other liability that cannot be excluded by applicable Indian law.
12. Indemnification
You agree to defend, indemnify, and hold harmless LeadFrog, its officers, employees, contractors, and agents from and against any claims, liabilities, damages, losses, and expenses (including reasonable legal fees) arising out of or related to:
- Your violation of these Terms or any applicable law (including the IT Act, DPDP Act, TRAI regulations, or Meta's policies).
- Your content or your Subscribers' data — including any claim that your use of Subscriber Data violated a Data Principal's rights.
- Your failure to obtain valid consent from Subscribers before collecting or processing their data.
- Any dispute between you and your customers or Subscribers.
13. Term & Termination
13.1 Term
These Terms begin when you create an account and continue until terminated by either party.
13.2 Termination by You
You may close your account at any time from Account Settings → Billing → Cancel Subscription. Closure takes effect at the end of your current billing period. You can export your data before closing.
13.3 Termination by LeadFrog
LeadFrog may suspend or terminate your account:
- Immediately, without notice, for serious violations (spam, illegal activity, data scraping, abuse of third-party APIs).
- With 14 days' notice for non-payment after the grace period.
- With 30 days' notice if we discontinue the Service entirely.
On termination, your access to the Service ends immediately (or at the end of the notice period). We will retain your data for 30 days post-termination to allow export. After 30 days, all data is permanently deleted and cannot be recovered.
13.4 Effect of Termination
Termination does not relieve you of obligations that accrued before termination — including outstanding payment obligations and any indemnification obligations. Sections 7 (Your Content & Data), 8 (IP), 10 (Disclaimers), 11 (Liability), 12 (Indemnification), and 15 (Disputes) survive termination.
14. Changes to the Service & These Terms
LeadFrog reserves the right to modify the Service and these Terms. We will notify you of material changes:
- Changes to Terms: email notice at least 30 days before they take effect.
- Changes to pricing: at least 30 days' notice.
- Feature additions: in-app announcement or changelog post.
- Feature removals (core features): at least 30 days' notice.
Your continued use of the Service after the effective date of a change constitutes your acceptance. If you disagree with a material change, you may terminate your subscription before the change takes effect and receive a pro-rata refund for the unused portion of any annual plan.
15. Dispute Resolution
15.1 Good Faith Negotiation First
If you have a dispute with LeadFrog, email legal@leadfrog.in with a description of the issue and your proposed resolution. We will respond within 10 business days. Most disputes can be resolved this way without escalation.
15.2 Governing Law
These Terms are governed by the laws of India. The Indian Contract Act 1872, the Information Technology Act 2000, and the Digital Personal Data Protection Act 2023 apply where relevant.
15.3 Jurisdiction
If a dispute cannot be resolved through negotiation within 30 days, it shall be submitted to the exclusive jurisdiction of the courts in Tenkasi, Tamil Nadu, India. Both parties irrevocably consent to this jurisdiction and waive any objection based on inconvenient forum.
15.4 No Class Actions
You and LeadFrog each agree to bring any dispute only in your individual capacity and not as a plaintiff or class member in any class or representative action.
16. General Provisions
- Entire Agreement: These Terms, the Privacy Policy, Cookie Policy, DPA, SLA, and AI Supplementary Terms constitute the entire agreement between you and LeadFrog regarding the Service and supersede all prior agreements.
- Severability: If any provision is found unenforceable, it will be modified to the minimum extent necessary to make it enforceable. The remaining provisions continue in full force.
- Waiver: LeadFrog's failure to enforce any right or provision is not a waiver of that right. A waiver in one instance does not constitute a waiver of future enforcement.
- Assignment: You may not assign these Terms or any rights under them without our prior written consent. LeadFrog may assign these Terms in connection with a merger, acquisition, or sale of assets, with notice to you.
- Force Majeure: Neither party is liable for failures or delays caused by events beyond their reasonable control — including natural disasters, war, pandemic, government action, or third-party platform outages.
- Relationship: These Terms do not create any employment, agency, partnership, or joint venture relationship between you and LeadFrog.
- Language: These Terms are written in English. If translated into another language, the English version prevails in case of conflict.
17. Contact
| Purpose | Contact |
|---|---|
| General Terms questions | legal@leadfrog.in |
| Billing & subscription | billing@leadfrog.in |
| Security concerns | security@leadfrog.in |
| Grievances | grievance@leadfrog.in |
| Registered Address | LeadFrog, Tenkasi, Tamil Nadu, India |
Document 02
Privacy Policy
Effective Date: June 11, 2026 · Last Reviewed: June 11, 2026
1. Who This Policy Applies To
This Privacy Policy explains how LeadFrog ("we", "us", "our"), a software platform operated by Ziwiz Technologies Private Limited, collects, uses, stores, shares, and protects personal data in connection with the LeadFrog platform (app.leadfrog.in) and website (leadfrog.in).
It applies to three groups of people:
- Customers — businesses and individuals who register for a LeadFrog account and use the Service.
- Subscribers — the end-users of our customers: the Instagram commenters, DM senders, and WhatsApp contacts whose data flows through the Service on behalf of our customers.
- Website Visitors — anyone who visits leadfrog.in without logging in.
If you are a Subscriber (i.e., your data is in a Customer's LeadFrog CRM because you commented on their Instagram post), the Customer is the Data Fiduciary responsible for your data. You should direct rights requests to that Customer. If they do not respond, contact us at privacy@leadfrog.in and we will assist.
2. What Personal Data We Collect
2.1 Data You Give Us Directly (Customer Account Data)
| Data Type | Why We Collect It |
|---|---|
| Full name & business name | Account creation and identification |
| Email address | Login, billing receipts, service communications |
| Phone number (optional) | Two-factor authentication, critical security alerts |
| GST number (optional) | To issue tax-compliant invoices |
| Payment details (last 4 digits only) | Billing records — full card data handled by Razorpay, never by us |
| Instagram & WhatsApp account details | To connect your accounts and run automations |
2.2 Data Collected Automatically When You Use the Platform
| Data Type | Why We Collect It |
|---|---|
| IP address | Security (fraud detection, rate limiting); anonymised for analytics |
| Browser type, OS, device type | Technical support and compatibility testing |
| Pages visited and features used | Product improvement and UX analytics (aggregated) |
| Session timestamps and duration | Platform performance monitoring |
| Error logs and crash reports | Used for troubleshooting and platform maintenance |
| API request logs | Security audit trail; CERT-In compliance (180-day retention requirement) |
2.3 Subscriber Data (Processed on Your Behalf, Customer)
When you connect your Instagram account and configure automation flows, LeadFrog processes the following data on your behalf — as your Data Processor:
| Data Type | Source |
|---|---|
| Instagram username | Meta Graph API webhook |
| Comment text | Meta Graph API webhook |
| Direct message content | Meta Graph API DM webhook |
| WhatsApp phone number | Customer-configured automation (Customer adds number to flow) |
| First name (if provided by end-user) | DM content or WhatsApp profile |
| Website behavior (pages visited, clicks) | Tracked DM link clicks via LeadFrog's link tracker |
Important
3. How We Use Your Data
| Purpose | Data Used |
|---|---|
| Provide and operate the Service | Account data, usage data, Subscriber Data (as processor) |
| Process payments and issue GST invoices | Name, email, payment details |
| Send transactional communications (receipts, security alerts, downtime notices) | Email address |
| Send product update emails and new feature announcements | Email address (opted-in users) |
| Platform analytics and product improvement | Aggregated, anonymized usage data |
| Security, fraud detection, and compliance | IP logs, API logs, access records |
| Respond to support requests | Name, email, support conversation content |
| Comply with legal obligations (CERT-In, DPDP Act, GST, court orders) | As required by the specific obligation |
4. Who We Share Your Data With
We share personal data only as described below. We do not sell your data.
4.1 Sub-Processors (Service Providers)
We share data with the companies listed in Document 04 (Service Providers & Sub-Processors) to operate the platform. Each provider is contractually restricted to processing data only for the purpose of their service.
4.2 Meta Platforms (Instagram / WhatsApp)
Operating the Service requires us to exchange data with Meta's APIs. Instagram comment text and DM content flows through Meta's webhook infrastructure. WhatsApp messages are sent and received via Meta's WhatsApp Business API. Your data on Meta's platforms is also governed by Meta's own Privacy Policy.
4.3 Legal & Regulatory Disclosure
We may disclose personal data to: (a) comply with a court order, statutory requirement, or lawful government request (including CERT-In directions); (b) enforce our Terms of Service; or (c) protect the rights, safety, or property of LeadFrog, our Customers, or the public. Where permitted by law, we will notify the affected party before disclosing.
4.4 Business Transfers
If LeadFrog is involved in a merger, acquisition, or sale of all or part of its business, your data may be transferred as part of that transaction. We will notify you by email and in-app notification at least 30 days before such a transfer occurs, and you will have the option to close your account and export your data before the transfer.
4.5 What We Never Do
- Sell your personal data or Subscriber Data to data brokers, advertisers, or any third party.
- Share data with third-party advertisers for targeting purposes.
- Use Subscriber Data to build profiles for any purpose other than the Customer's own CRM.
4.6 Meta Platform Data Usage
LeadFrog only accesses Meta Platform Data that has been explicitly authorized by the Customer through Meta's official authentication and API mechanisms.
LeadFrog does not:
- Sell Meta Platform Data
- Share Meta Platform Data with advertisers
- Use Meta Platform Data for surveillance purposes
- Build advertising profiles from Meta Platform Data
- Use Meta Platform Data for purposes unrelated to the services requested by the Customer
Meta Platform Data is used solely for lead capture, lead management, messaging automation, CRM functionality, analytics requested by the Customer, and other features directly related to the operation of the LeadFrog platform.
5. Your Rights as a Data Principal
Under India's Digital Personal Data Protection Act, 2023, and applicable Indian law, you have the following rights:
| Right | What You Can Do |
|---|---|
| Right to Access | Request a summary of the personal data LeadFrog holds about you. |
| Right to Correction | Ask us to correct inaccurate or incomplete data in your account. |
| Right to Erasure | Request deletion of your account and all associated personal data. |
| Right to Data Portability | Receive your data in a structured, machine-readable format (CSV/JSON). |
| Right to Withdraw Consent | Stop receiving marketing emails at any time. |
| Right to Grievance | Lodge a complaint about how we handle your data. |
| Right to Nominate | Nominate someone to exercise your rights after death or incapacity. |
We will respond to all rights requests within 30 days. In complex cases, we may take up to 60 days with a notice of extension. We verify your identity before acting on any request. We do not charge a fee for reasonable requests.
6. Data Retention
We keep your data only as long as necessary. Here is our retention schedule:
| Data Type | Retention Period |
|---|---|
| Account profile data | Duration of account + 30 days post-deletion |
| Billing records & GST invoices | 8 years from date of invoice |
| Subscriber Data (lead records) | Duration of Customer's account, or per Customer's retention setting |
| API access logs | 180 days |
| IP address logs | 90 days |
| Support conversation records | 3 years from last interaction |
| Cookie consent records | 12 months (then renewed) |
| Anonymized analytics data | Indefinite (no personal data) |
7. International Data Transfers
LeadFrog stores and processes data using approved infrastructure providers including Supabase, Vercel, and Hostinger, as described in the Service Providers & Sub-Processors document.
- Data processing agreements with Standard Contractual Clauses or equivalent with each overseas sub-processor.
- Data minimization — we transfer the minimum data required for each specific function.
As the Government of India notifies the list of permitted countries for cross-border data transfer under Section 16 of the DPDP Act, we will update our transfer mechanisms to comply.
8. Data Security
We take data security seriously. Our measures include:
- AES-256 encryption at rest for all databases and file storage.
- TLS 1.2+ encryption in transit for all data flows.
- Multi-factor authentication mandatory for all staff with production access.
- Automated dependency scanning and vulnerability patching.
- Role-based access control — staff access only the data their role requires.
If we become aware of a data breach that is likely to affect your rights, we will notify you within 72 hours of discovery, describe what happened, what data was involved, what we are doing about it, and what you can do to protect yourself.
9. Children's Privacy
LeadFrog is not intended for anyone under 18. We do not knowingly collect data from minors. If you believe a minor has created a LeadFrog account or that a minor's data is in a Customer's CRM without proper consent, contact privacy@leadfrog.in immediately. We will delete the relevant data promptly and notify the affected Customer.
Under the DPDP Act 2023, processing children's data (under 18) requires verifiable parental consent. This is beyond the scope of what LeadFrog currently supports — Customers must not use LeadFrog to collect or process data of minors.
10. Links to Third-Party Platforms
The Service integrates with Meta (Instagram, WhatsApp), Razorpay, and may link to other third-party services. This Privacy Policy does not cover how those third parties handle your data. We encourage you to review their privacy policies before connecting their services to LeadFrog.
11. Changes to This Privacy Policy
We may update this policy as our product evolves or as Indian law changes. When we make material changes:
- We will email all registered Customers at least 14 days before the change takes effect.
- We will update the "Last Reviewed" date at the top of this document.
- We will post a summary of what changed at leadfrog.in/legal/privacy-changelog.
Your continued use of the Service after the effective date constitutes acceptance of the updated policy. If you do not agree, you may close your account before the change takes effect.
12. Contact & Grievance Officer
| Role / Purpose | Contact |
|---|---|
| Privacy questions (general) | privacy@leadfrog.in |
| Grievance Officer (IT Rules 2021 / DPDP Act) | grievance@leadfrog.in |
| Data Principal rights requests | privacy@leadfrog.in |
| Security concerns / breach reports | security@leadfrog.in |
| Registered Address | LeadFrog, Tenkasi, Tamil Nadu, India |
| Response time | Acknowledgement within 24 hours; resolution within 30 days |
Document 03
Cookie Policy
Effective Date: June 11, 2026 · Version 2.0
3. Categories of Cookies We Use
LeadFrog currently uses only essential cookies required for authentication, security, and core platform functionality.
These cookies include:
- Session authentication cookies used to keep users logged in securely.
- Security cookies used to prevent unauthorized access and malicious activity.
- Preference cookies used to remember basic platform settings.
LeadFrog does not currently use:
- Advertising cookies
- Marketing cookies
- Behavioral tracking cookies
- Meta Pixel
- Google Analytics cookies
- Third-party profiling cookies
Document 04
Service Providers & Sub-Processors
Effective Date: June 11, 2026 · Version 2.0
1. What This Document Is
When you use LeadFrog, some of your data and your Subscribers' data passes through third-party companies we have contracted to provide specific infrastructure or services. These companies are called sub-processors (under DPDP Act terminology: processors engaged by a processor) or service providers.
We publish this list because we believe you have a right to know exactly who handles data on your behalf. We update it whenever we add, change, or remove a provider — and give you at least 14 days' notice before any change that affects how personal data is processed.
2. Sub-Processor Registry
| Provider | Purpose | Data Processed | Location |
|---|---|---|---|
| Supabase Inc. | Database hosting, authentication, file storage | Customer account information, lead records, workspace data | Supabase project region as configured by LeadFrog |
| Vercel Inc. | Application hosting and content delivery | Application requests, session information, platform assets | Global infrastructure |
| Hostinger International Ltd. | Website hosting, DNS and domain services | Website traffic logs and hosting infrastructure data | As provided by Hostinger infrastructure |
| Meta Platforms Inc. | Instagram Graph API and WhatsApp Business API | Instagram comments, DMs, WhatsApp messaging data required for platform functionality | Global |
| Groq Inc. | AI-powered lead classification | Comment and DM text submitted for classification | United States |
| Razorpay Software Pvt. Ltd. | Subscription billing and payment processing | Billing information and payment transaction details | India |
Document 05
Service Level Agreement (SLA)
Effective Date: June 11, 2026 · Applies to: All paid LeadFrog subscriptions
1. Purpose
This Service Level Agreement ("SLA") documents LeadFrog's commitments to paid subscribers regarding platform availability, support responsiveness, data backup, and incident communication. It is legally binding as an addendum to the LeadFrog Terms of Service. Free-tier users receive best-effort support without SLA guarantees.
2. Key Definitions
| Term | Definition |
|---|---|
| Monthly Uptime % | ((Total minutes in month − Downtime minutes) / Total minutes in month) × 100. Calculated per calendar month. |
| Downtime | Any continuous period of 5+ minutes in which login, lead capture (Instagram webhook), or WhatsApp routing are fully unavailable due to a LeadFrog-side failure. |
| Scheduled Maintenance | Planned outages communicated ≥48 hours in advance via email and the in-app banner. Excluded from Downtime. |
| Emergency Maintenance | Unplanned patches required to protect platform security or prevent data loss. Announced as early as possible; limited to <2 hours/month. Excluded from Downtime if announced. |
| Incident | An unplanned event causing Downtime or material service degradation. |
| Response Time | Time from LeadFrog receiving your support ticket to acknowledging it with an owner assigned. |
| Resolution Time | Time from acknowledgement to full restoration of the affected functionality. |
| Service Credit | A credit applied to your next billing cycle as compensation for an SLA breach. |
3. Uptime Commitment
LeadFrog provides commercially reasonable efforts to maintain platform availability and reliability. Specific uptime commitments, support levels, and enterprise service guarantees may vary by subscription plan and will be published on the LeadFrog website or communicated directly to Customers. LeadFrog may update service levels as the platform evolves.
4. Support Severity & Response Times
| Severity | Definition | Initial Response | Target Resolution |
|---|---|---|---|
| P1 — Critical | Core platform fully unavailable. Lead capture broken for all users of an account. Data loss risk. | 1 hour (24×7) | 4 hours |
| P2 — High | Major feature degraded with no workaround. Affects >50% of a Customer's users. | 4 business hours | 24 hours |
| P3 — Medium | Non-critical feature affected. Workaround exists. Minor data discrepancy. | 1 business day | 5 business days |
| P4 — Low | Cosmetic bug, feature request, how-to question, documentation clarification. | 3 business days | Next release cycle |
Support hours: Monday–Saturday 09:00–18:00 IST. P1 incidents are handled 24×7 via on-call rotation. Submit via support@leadfrog.in or the in-app Help button (P1 incidents should include "P1" in the subject line for immediate routing).
5. Maintenance Windows
- Standard window: Sundays 02:00–04:00 IST (low-traffic; 48 hours' notice).
- Major upgrades (database migrations, API version bumps): communicated 7+ days in advance.
- Emergency security patches: may occur any time; announced by email within 30 minutes of commencement.
6. Exclusions — What Does NOT Count as Downtime
- Scheduled and announced maintenance windows.
- Third-party platform outages: Meta/Instagram API downtime, WhatsApp Business API issues, Razorpay payment gateway outages.
- Events of Force Majeure: earthquakes, floods, war, pandemic, government-mandated shutdowns.
- Issues caused by the Customer's own misconfiguration, API misuse, or violation of Terms of Service.
- Internet connectivity issues outside LeadFrog's network.
- Features explicitly labelled "Beta" or "Preview".
- Attacks (DDoS, brute force) specifically targeting the Customer's account, provided LeadFrog took reasonable mitigation steps.
7. Data Backup & Recovery
| Parameter | Commitment |
|---|---|
| Backup frequency | Every 6 hours (4 backups/day per workspace) |
| Retention period | 30 days of daily snapshots; 7 days of hourly snapshots |
| Backup encryption | AES-256 at rest; TLS 1.3 in transit |
| Backup location | Primary: ap-south-1 (Mumbai). Replica: ap-south-2 (Hyderabad). Physically separate data centres. |
| Recovery Point Objective (RPO) | ≤6 hours (maximum data loss in a disaster scenario) |
| Recovery Time Objective (RTO) | ≤24 hours for full workspace restoration |
| On-demand export | Customers may export all lead data as CSV from their dashboard at any time. |
8. Incident Communication
- P1 incidents: status page updated within 30 minutes; email blast to all affected accounts.
- Post-Incident Report (PIR): published within 5 business days of P1 resolution; includes root cause, impact duration, and corrective actions.
- Recurring P2 incidents: root-cause analysis shared with the affected Customer on request.
Document 06
Data Processing Addendum (DPA)
Effective Date: June 11, 2026 · Incorporated by reference into LeadFrog Terms of Service
1. Background & Parties
When you use LeadFrog to capture leads from Instagram and route them through WhatsApp, you instruct LeadFrog to process personal data belonging to third parties — your Instagram followers, commenters, and WhatsApp contacts ("Subscribers"). This Data Processing Addendum ("DPA") sets out the legal framework governing that processing relationship.
| Role | Party |
|---|---|
| Data Fiduciary (Controller) | You — the LeadFrog Customer |
| Data Processor | LeadFrog |
| Data Principals | Your Subscribers |
This DPA is governed by India's Digital Personal Data Protection Act, 2023 ("DPDP Act"). Where Customers are based in the European Economic Area, the GDPR also applies and the relevant provisions of this DPA should be read accordingly.
2. Subject Matter of Processing
| What | Details |
|---|---|
| Subject Matter | LeadFrog automates capture, classification, routing, and CRM management of leads generated from the Customer's Instagram presence and WhatsApp Business number. |
| Duration | For the term of the Customer's active subscription. Post-termination data handling: see Section 8. |
| Nature | Collection via webhook, AI-based classification, routing via WhatsApp API, storage in CRM, analytics via tracked links. |
| Purpose | Delivering the features of the LeadFrog Service as subscribed and configured by the Customer. |
| Types of Data Processed | Instagram usernames, public comment text, DM content, WhatsApp numbers, first name (where provided by the end-user), website behaviour attributed to tracked DM links. |
| Data Subjects | Individuals who comment on the Customer's Instagram posts, send DMs to the Customer's account, receive WhatsApp messages from the Customer, or click tracked links. |
3. LeadFrog's Obligations as Processor
LeadFrog unconditionally commits to the following:
- Process Subscriber Data only on the Customer's documented instructions. If we are legally required to process data in a way the Customer has not instructed, we will notify the Customer before doing so unless prohibited by law.
- Ensure that all LeadFrog personnel with access to Subscriber Data are bound by written confidentiality obligations and receive appropriate data protection training.
- Implement and maintain the technical and organisational security measures listed in Schedule A of this DPA.
- Assist the Customer in responding to Data Principal rights requests (access, correction, erasure, portability, grievance) within 7 business days of the Customer's request to us.
- Notify the Customer without undue delay — and within 72 hours of becoming aware — of any personal data breach affecting Subscriber Data, including the nature of the breach, categories and approximate number of records affected, likely consequences, and measures taken or proposed.
- Notify the Customer if we receive a direct request from a Data Principal or a government authority regarding Subscriber Data, without disclosing any data before the Customer authorises us to do so (unless legally compelled).
- Ensure any sub-processor we engage (see Document 04) is bound by data protection obligations equivalent to those in this DPA, and that we remain fully liable to the Customer for the sub-processor's performance.
- Not engage new sub-processors without at least 14 days' prior written notice to the Customer.
- On termination or expiry of the Customer's subscription, delete all Subscriber Data within 30 days unless the Customer requests a data export first, and certify deletion in writing upon request.
- Make available, on reasonable notice, all information necessary for the Customer to verify LeadFrog's compliance with this DPA, and allow audits (or third-party assessments) not more than once per year.
4. Customer's Obligations as Data Fiduciary
By using LeadFrog, the Customer agrees that they:
- Have a lawful basis under the DPDP Act (typically: freely given, specific, informed consent from the Data Principal) to collect and process each Subscriber's data.
- Have provided Data Principals with a clear privacy notice disclosing that LeadFrog processes their data on the Customer's behalf, the purposes of that processing, and their rights.
- Will not instruct LeadFrog to process data in a manner that would violate the DPDP Act, Meta's Platform Terms, WhatsApp Business Policy, TRAI regulations, or any other applicable law.
- Are solely responsible for the accuracy, legality, and completeness of data they cause to be collected through LeadFrog.
- Will not use LeadFrog to process Special Category Data — including health data, biometric data, financial account credentials, caste, religion, political affiliation, or sexual orientation — unless explicitly agreed in a separate written contract.
- Will comply with all Data Principal rights requests within statutory timeframes, with LeadFrog's assistance as described in Section 3.
- Will notify LeadFrog promptly if they become aware of any misuse of the Service or any circumstances that may give rise to a personal data breach.
5. International Data Transfers
Some Subscriber Data is processed outside India (primarily by Groq in the USA for AI inference, and by Meta's global infrastructure for Instagram/WhatsApp API calls). LeadFrog handles these transfers as follows:
- We execute data processing agreements with each overseas sub-processor containing Standard Contractual Clauses or equivalent transfer mechanisms.
- We minimise data transferred overseas — Groq receives only comment/DM text for classification; it does not receive phone numbers, names, or any other PII.
- We will update transfer mechanisms to comply with any country whitelist or additional conditions notified by the Government of India under Section 16 of the DPDP Act, as and when notified.
6. Schedule A — Security Measures
- Encryption in Transit: TLS 1.2+ encryption for all communication between users, LeadFrog services, and approved third-party providers.
- Encryption at Rest: Data stored using encrypted storage provided by infrastructure providers including Supabase and other approved service providers.
- Access Control: Role-based access controls are implemented where applicable. Access to production systems is restricted to authorized personnel only.
- API & Token Security: OAuth 2.0 is used for Meta integrations. Authentication tokens and secrets are stored securely and are not exposed publicly.
- Vulnerability Management: LeadFrog applies security updates, dependency updates, and vulnerability fixes on a regular basis.
- Audit Logging: Authentication events, API activity, and operational logs are retained for security monitoring and troubleshooting purposes.
- Incident Response: LeadFrog maintains internal procedures for identifying, investigating, and responding to security incidents.
- Personnel Security: Access to production systems is limited to authorized personnel who are subject to confidentiality obligations.
- Backup & Recovery: Backup and recovery procedures are maintained to support service continuity and disaster recovery.
Document 07
AI Supplementary Terms
Effective Date: June 11, 2026 · Forms part of LeadFrog Terms of Service
1. Scope
These AI Supplementary Terms ("AI Terms") apply to all features of LeadFrog that use artificial intelligence, machine learning, large language models, or automated scoring algorithms (collectively, "AI Features"). They supplement the Terms of Service and the DPA. In a conflict, these AI Terms govern with respect to AI Features.
Current AI Features include:
- AI Lead Classifier — classifies Instagram comments and DMs by purchase intent (Hot Lead / Warm / Cold / Spam / Inquiry / Other) using a large language model.
- Auto-Reply Composer — drafts context-aware WhatsApp follow-up suggestions for the Customer to review and optionally send.
- Lead Score Engine — assigns a numeric intent score (0–100) to each lead using a combination of comment text classification, reply velocity, and link-click behaviour.
- Link Intent Analytics — attributes website behaviour (pages visited, time on page, product clicks) to individual leads via tracked DM links, generating an enriched intent profile.
2. How the AI Features Work
2.1 AI Lead Classifier
When a new comment or DM arrives on your connected Instagram account, LeadFrog's backend:
- Receives the text via Meta's webhook.
- Sends the text to Groq Inc.'s inference API along with a system prompt written by LeadFrog that instructs the model to classify intent.
- Receives a classification label and confidence score within ~200 milliseconds.
- Stores the label and score in your workspace's CRM. The raw comment text is also stored so you can read it.
- Triggers the automation flow you configured (auto-reply, move to pipeline stage, notify your team, etc.).
The model currently used is Meta's Llama 3.3 70B, served via Groq. LeadFrog may change the underlying model or provider with 14 days' notice, provided the replacement offers equivalent or stronger data protection.
2.2 Lead Score Engine
The Lead Score combines three signals:
- Text classification confidence from the AI Classifier (weight: 50%).
- Response velocity — how quickly the lead replies to your follow-up message (weight: 30%).
- Link-click intent — whether the lead clicked your tracked DM link and, if so, which pages they viewed (weight: 20%).
Scores update in real time as new signals arrive. Customers can view score history and see which signals drove each score from the lead detail page.
3. The Training Data Guarantee
What LeadFrog will NEVER do:
- Use your Subscriber Data, comment text, DM content, lead records, or any Customer-owned data to train, fine-tune, or improve any AI or machine learning model — ours or a third party's.
- Share your data with Groq Inc. or any model provider for any purpose other than returning a classification result for that specific inference call.
- Aggregate your customers' conversations into a shared dataset.
- Sell, license, or otherwise monetise your data to AI providers.
What LeadFrog MAY do:
- Use aggregated, fully anonymised, non-attributable usage metrics (e.g., "average classification latency", "most common intent labels across the platform") to evaluate and improve LeadFrog's own prompt engineering and workflow configuration.
- Use internally generated synthetic or redacted data for model testing and quality assurance.
4. Accuracy Disclaimer
AI Features produce probabilistic outputs — they make educated guesses, not guaranteed determinations. A "Hot Lead" label means the model detected strong purchase intent signals in that comment; it does not guarantee the person will buy, or that the classification is correct in every case.
LeadFrog does not warrant that AI outputs are accurate, unbiased, complete, or fit for any specific purpose. Classification errors will occur. You are responsible for reviewing AI outputs and deciding how to act on them. Do not rely solely on AI classifications for material business decisions (e.g., large contract negotiations, credit decisions, staffing decisions) without human review.
If you notice systematic misclassification for your industry or language, contact support@leadfrog.in. We can adjust the prompt configuration for your account.
5. Prohibited Uses of AI Features
You must not use LeadFrog AI Features to:
- Discriminate against any person based on religion, caste, gender, sexual orientation, disability, race, nationality, or any other protected characteristic under Indian law or international human rights norms.
- Generate or send deceptive, manipulative, coercive, or psychologically harmful messages to Subscribers, including dark patterns designed to exploit cognitive biases.
- Target vulnerable individuals (minors, persons in crisis, financially distressed individuals) with predatory messaging.
- Make or communicate decisions that have material legal or financial effects on individuals (loan approvals, employment decisions, insurance underwriting) without a human reviewer in the loop.
- Profile individuals in ways that would violate the DPDP Act or any applicable privacy law.
- Circumvent Meta's spam or automation policies — all auto-reply and auto-DM flows must comply with Meta's Messaging Policy.
- Generate, spread, or amplify misinformation, hate speech, or content that violates Indian law (IT Act Sections 66A–66F, IPC provisions on defamation and incitement).
6. Human Oversight & Automated Decisions
Indian law (DPDP Act, Section 12 principles) and best practice require human oversight for automated decisions that significantly affect individuals. LeadFrog's Auto-Reply Composer generates suggestions, not final messages — you decide what to send. The platform's AI-driven pipeline movement is a recommendation; your team can override it at any time.
Where you configure fully automated reply flows (e.g., auto-DM to all "Hot Lead" comments without human approval), you must ensure:
- The auto-reply content is pre-reviewed and approved by a human.
- Subscribers have a clear way to opt out of automated messages (a "STOP" keyword or equivalent).
- You do not send more than the number of messages permitted by Meta's Messaging Policy per 24-hour window.
7. AI Features and the DPDP Act, 2023
The DPDP Act's principles of Purpose Limitation, Data Minimisation, and Storage Limitation apply to AI processing:
- Purpose Limitation: AI classification is performed only for the purpose of operating the LeadFrog Service for your account. We do not use it to build profiles for advertising, creditworthiness, or any other secondary purpose.
- Data Minimisation: We send only the specific comment/DM text to the inference API — not phone numbers, addresses, or any other PII that is not necessary for classification.
- Storage Limitation: Classification labels and scores are stored only as long as the lead record exists in your workspace. If you delete a lead or your account, the associated AI outputs are deleted.
8. AI Provider Changes
LeadFrog will notify you at least 14 days before switching the AI model or inference provider, unless the change is required urgently to remediate a security vulnerability. In that case, notification will follow within 72 hours. Any replacement provider must:
- Commit contractually to not using Customer data for model training.
- Process data in-flight only (no retention beyond the inference call).
- Provide at least equivalent security certifications (SOC 2 Type II or ISO 27001).
9. Feedback on AI Quality
When you click thumbs-up or thumbs-down on a classification in the LeadFrog UI, this feedback is used only to improve LeadFrog's own prompt templates and classification logic — not to fine-tune the underlying model. Feedback data is anonymised before any analysis. It is never shared with Groq or any other third party.
Document 08
Data Maintenance & Security Policy
Effective Date: June 11, 2026 · Version 2.0
Our commitment in plain English:
1. Data Storage Architecture
1.1 Security Measures
LeadFrog implements reasonable technical and organizational measures to protect Customer data, including:
- HTTPS encryption for all platform communications
- Secure password storage and authentication controls
- Role-based access controls where applicable
- Regular software updates and security patches
- Access restrictions for authorized personnel only
- Encrypted storage provided by infrastructure providers
While no system can guarantee absolute security, LeadFrog continuously works to maintain appropriate safeguards for Customer and Subscriber data.
1.2 Data Classification
We classify all data we hold into four tiers, each with different handling rules:
| Tier | Classification |
|---|---|
| Tier 1 — Critical | Credentials, encryption keys, payment tokens |
| Tier 2 — Sensitive | Personal data of Customers and Subscribers |
| Tier 3 — Internal | Operational data, logs, analytics |
| Tier 4 — Public | Publicly visible platform content |
2. Encryption — End to End
2.1 Data in Transit
LeadFrog protects data transmitted between users, services, and approved third-party providers using industry-standard encryption technologies. Security measures include:
- HTTPS enforced across LeadFrog services
- TLS 1.2 or higher for network communications
- Secure API communication with Meta and other approved providers
- Verification of webhook requests where supported by the provider
2.2 Data at Rest
LeadFrog stores data using secure infrastructure providers that offer encryption and security controls appropriate for cloud-hosted applications. Data is protected through:
- Encrypted storage provided by infrastructure vendors
- Access controls limiting data access to authorized personnel
- Regular backups and recovery procedures
- Monitoring and maintenance processes designed to protect customer information
2.3 End-to-End for Sensitive Operations
For particularly sensitive data flows — such as OAuth token exchange with Meta, or webhook signature verification — we implement additional protections:
- OAuth access tokens (Instagram, WhatsApp) are stored encrypted in the database using an application-level encryption key (AES-256-GCM) separate from the database encryption key. This means even if the database storage is compromised, tokens remain protected.
- Webhook secrets are stored in Secrets Manager, not in environment variables or code. They are rotated every 90 days or immediately upon any suspected compromise.
3. Access Control — Who Can See Your Data
3.1 Customer Account Access
Within your LeadFrog account:
- Account Owner: Full access to all data, billing, settings, and team management.
- Admin: Full access to leads and CRM, but cannot access billing or delete the account.
- Member: Access to assigned leads and CRM views only. Cannot view other team members' lead assignments or account-level settings.
- Read-Only: Can view the dashboard and lead records but cannot modify anything.
All actions performed by team members are logged with their user ID, timestamp, and action type. Account Owners can review the activity log from the dashboard at any time.
3.2 LeadFrog Staff Access
Access to customer data is restricted to authorized personnel only and is granted solely when required for platform operations, troubleshooting, or customer support. LeadFrog personnel are subject to confidentiality obligations and access controls appropriate to their role. Multi-factor authentication is required for administrative access where supported by the underlying infrastructure providers.
3.3 Administrative Access Controls
Administrative access to production systems is limited to authorized personnel. Access permissions are reviewed periodically and removed when no longer required. Security events and operational logs may be retained for troubleshooting, monitoring, and compliance purposes.
4. Infrastructure Security
LeadFrog relies on trusted infrastructure providers including Supabase, Vercel, and Hostinger. Security protections include:
- Encrypted communications using HTTPS/TLS
- Infrastructure-level security controls provided by hosting providers
- Access controls and authentication protections
- Monitoring of platform availability and operational health
- Regular software updates and maintenance
LeadFrog reviews infrastructure security practices periodically and implements reasonable safeguards appropriate for a cloud-hosted SaaS platform.
5. Application Security
5.1 Secure Development Practices
- All code changes go through peer code review before being merged. Security-sensitive changes (authentication, data access, API integrations) require review by a senior engineer.
- Automated security scanning runs on every pull request: SAST (Static Application Security Testing) via Semgrep, dependency vulnerability scanning via Dependabot, and secret scanning to catch accidentally committed credentials.
- OWASP Top 10 mitigations are implemented at the design stage — not added retroactively. This includes protections against SQL injection, XSS, CSRF, broken authentication, and insecure direct object references.
- All third-party dependencies are pinned to specific versions and reviewed before upgrading. Critical CVEs (CVSS score ≥ 7.0) are patched within 72 hours of disclosure.
5.2 Vulnerability Management
LeadFrog monitors security advisories, dependency vulnerabilities, and software updates relevant to the platform. Security issues identified through internal review, provider notifications, or responsible disclosure are evaluated and addressed based on severity and business impact.
5.3 Security Reporting
If a security vulnerability is discovered, it may be reported to security@leadfrog.in. LeadFrog reviews reported issues and takes appropriate corrective action where necessary.
6. Data Integrity & Quality Maintenance
6.1 Database Integrity
- PostgreSQL foreign key constraints and check constraints are enforced at the database level — not just the application level. This prevents orphaned records and data corruption even in edge-case failure scenarios.
- All write operations to lead records use database transactions with ACID guarantees. If any part of a multi-step operation fails, the entire operation rolls back — no partial data corruption.
- Database schema migrations are versioned, tested in staging, and applied via automated migration scripts with rollback capability. We never apply ad-hoc changes to production databases.
6.2 Backup Integrity Verification
Backups are useless if they cannot be restored. We verify backup integrity:
- Automated daily backup restoration test: every day, the previous night's backup is automatically restored to an isolated test environment and checked for completeness.
- Monthly manual DR drill: a senior engineer manually walks through the full disaster recovery procedure quarterly and documents the results.
- Backup checksums: every backup file has a SHA-256 checksum stored separately. Before any restore operation, the checksum is verified to confirm the backup has not been tampered with or corrupted in transit.
6.3 Data Accuracy for Customers
LeadFrog provides tools to help you maintain the accuracy of your CRM data:
- Duplicate detection: the platform flags leads with the same Instagram username or WhatsApp number and prompts you to merge or review.
- Stale lead alerts: leads that have had no activity for a configurable period (default: 30 days) are flagged as stale so you can follow up or archive.
- Data export: you can export all your CRM data at any time in CSV format from Account Settings → Export Data. Exports include all fields, including AI classification scores and tracked link events.
7. Incident Response & Breach Notification
7.1 Incident Classification
| Incident Type | Examples |
|---|---|
| Security Breach — Confirmed | Unauthorised access to production database; credential leak; ransomware |
| Security Breach — Suspected | Anomalous database queries; unusual admin access patterns; failed MFA attempts exceeding threshold |
| Service Integrity | Data corruption; failed backup; inconsistent replication |
| Third-Party Breach | Sub-processor reports a breach affecting our data |
7.2 What We Tell You After a Breach
If a confirmed breach affects your data, our notification to you will include:
- Nature of the breach — what happened, when it was discovered, and when we believe it started.
- Data categories affected — which types of personal data were accessed or exfiltrated.
- Approximate number of records affected.
- Likely consequences — what harm the breach may cause.
- Measures taken — what we did to contain the breach.
- Measures you can take — practical steps you and your Subscribers can take to protect yourselves.
- Contact for questions — a named point of contact at LeadFrog for follow-up.
8. Compliance Monitoring & Auditing
- Continuous compliance scanning: AWS Security Hub runs continuous checks against CIS AWS Foundations Benchmark and AWS Foundational Security Best Practices. Any failed control generates an alert.
- Access log review: API access logs are reviewed weekly by our security lead for anomalous patterns. Automated alerts fire for: after-hours production access, bulk data export operations, failed authentication spikes.
- Annual security review: a formal annual review covers all security controls, sub-processor security assessments, and a read-through of this policy to confirm it reflects current practice.
- DPDP Act readiness: as DPDP Act rules are notified by the Government of India, we conduct a gap assessment within 30 days and implement required changes before the applicable effective date.
9. Physical Security
LeadFrog operates on cloud infrastructure. We do not own or operate data centres. Physical security of the underlying hardware is provided by AWS and is certified to:
- ISO 27001, SOC 1 Type II, SOC 2 Type II, and PCI DSS Level 1.
- Physical access to AWS data centres in Mumbai and Hyderabad is controlled by biometric authentication, 24×7 security personnel, and CCTV surveillance.
- AWS's physical security certifications are available at aws.amazon.com/compliance.
LeadFrog employees do not have physical access to any server hardware. All administration is done remotely through secure, logged, MFA-protected sessions.
10. Security Contact
| Purpose | Contact / Details |
|---|---|
| Reporting a vulnerability (responsible disclosure) | security@leadfrog.in — PGP key available on request |
| Security incidents / suspected breaches | security@leadfrog.in — monitored 24×7 |
| CERT-In incident reporting | We report to CERT-In directly; Customers notified in parallel |
| Enterprise security review requests | security@leadfrog.in — annual third-party audit reports available under NDA |
Document 09
Data Deletion Policy
Effective Date: June 11, 2026 · Version 2.0
Your right to erasure is real and enforceable.
1. Why This Policy Exists
Data that is no longer needed is a liability — for you, for your Subscribers, and for us. Keeping data longer than necessary increases the risk of a breach, wastes storage, and, under the DPDP Act 2023, is not permitted. The law requires that personal data be erased as soon as the purpose for which it was collected is fulfilled or consent is withdrawn.
This policy sets out every scenario in which data is deleted, the precise timeline for each, and the technical method used. It covers data about you (Customer account data) and data you hold in LeadFrog (Subscriber / lead data).
2. Deletion Triggers & Timelines
2.1 Customer-Initiated Deletions
| Trigger | What Gets Deleted | Timeline | Method |
|---|---|---|---|
| Delete a single lead record | That lead's CRM data: name, contact details, comment/DM text, WhatsApp number, AI classification, lead score, link-click events, notes | Immediate (soft-delete visible to you for 7 days; hard-delete after 7 days) | UI: Lead record → ⋮ → Delete Lead |
| Bulk delete leads (filter & delete) | All lead records matching the filter criteria | Immediate soft-delete; hard-delete within 7 days | UI: CRM → Filter → Select All → Delete |
| Remove a team member | That member's session tokens and access credentials | Immediate — access revoked within 60 seconds of removal | UI: Settings → Team → Remove Member |
| Disconnect Instagram account | Instagram-sourced lead metadata is retained (it belongs to your CRM); webhook processing stops immediately | Webhook stops immediately; historical data retained per retention schedule unless you bulk-delete | UI: Settings → Integrations → Disconnect |
| Disconnect WhatsApp account | WhatsApp routing stops; historical message logs retained in CRM unless you delete them | Routing stops immediately | UI: Settings → Integrations → Disconnect |
| Cancel subscription (switch to free) | No data deleted on downgrade — data is retained but some features become inaccessible | No deletion; access limits apply | Billing → Change Plan |
| Close account (full deletion) | All Customer account data; all lead records; all Subscriber Data; all automation flows; all team members; all API keys | Soft-delete immediately; hard-delete within 30 days; export window: 30 days | Billing → Delete Account (see Section 3) |
2.2 Automatic / System-Initiated Deletions
| Trigger | Data Deleted |
|---|---|
| Subscription unpaid for 37 days (7-day grace + 30-day suspension) | Account enters deletion queue — Customer receives 3 email warnings before this point |
| Free account inactive for 12 months (no login, no API calls) | Account and all associated data |
| Session token expiry | Browser session token (lf_auth_token) |
| AI inference data (Groq) | Comment/DM text sent to Groq for classification |
| Webhook payload buffer | Raw webhook payloads from Meta held in memory during processing |
| Support tickets (resolved) | Support conversation content |
| Anonymised analytics data | N/A — anonymised data has no deletion schedule (no personal data remains) |
2.3 Data Principal (Subscriber) Erasure Requests
When a Subscriber (one of your Instagram/WhatsApp contacts) exercises their right to erasure under the DPDP Act 2023:
- The Subscriber contacts you (the Customer / Data Fiduciary) with a deletion request.
- You have 30 days to respond and comply (DPDP Act requirement).
- To delete a specific Subscriber's data from LeadFrog: go to the lead record → ⋮ → Delete Lead. This removes all data associated with that individual from your workspace.
- If you need LeadFrog to assist in locating all records tied to a specific phone number or Instagram username across your workspace, email privacy@leadfrog.in with the request and we will provide an export within 5 business days.
- If a Subscriber contacts LeadFrog directly (because they do not know which Customer holds their data), we will: (a) inform them to contact the Customer; (b) notify the relevant Customer; (c) if the Customer does not respond within 30 days, we will delete the Subscriber's data ourselves and inform both parties.
3. How to Close Your Account & Delete All Data
3.1 Step-by-Step Account Deletion
Closing your account permanently deletes all data associated with it. This cannot be undone after the 30-day recovery window. Here is exactly what happens:
| Step | Action |
|---|---|
| Step 1 — Initiate | Go to Account Settings → Billing → Delete Account. You will be asked to type your account email to confirm. |
| Step 2 — Export window | Your account is suspended but data is still accessible for export. Download your lead data from Account Settings → Export Data before this window closes. |
| Step 3 — Confirmation email | LeadFrog sends a confirmation email with a summary of what will be deleted and when. You can cancel the deletion during the 30-day window. |
| Step 4 — Hard delete begins | All data begins permanent deletion from primary database, backups, cache, and logs. |
| Step 5 — Backup purge | Backup snapshots containing your data are purged from the backup rotation cycle. |
| Step 6 — Deletion certificate | We email you a data deletion certificate confirming that all data has been permanently removed, listing the data types deleted and the deletion date. |
3.2 What the Deletion Certificate Contains
The deletion certificate is a formal written confirmation that includes:
- Your account ID and registered email.
- Date and time of soft-delete initiation.
- Date and time of hard-delete completion.
- List of data types permanently deleted (account data, lead records, Subscriber Data, automation flows, API keys, session tokens, billing history).
- Confirmation that backup snapshots containing your data have been purged or will expire within the stated window.
- Name and role of the LeadFrog staff member who verified the deletion.
This certificate can be used as evidence of data erasure compliance if your own Customers or regulators ask for proof that their data has been removed from your supply chain.
4. What We Are Legally Required to Keep (Exceptions to Deletion)
Some data must be retained for legal reasons even after you delete your account. We are transparent about exactly what this is:
| Data | Retention After Deletion |
|---|---|
| GST invoices and billing records | 8 years from invoice date |
| API access logs (anonymised — no personal data) | 180 days from log creation |
| Records of data breaches involving your account (if any occurred) | 5 years from breach date |
| Grievance records (if you filed a formal complaint with us) | 3 years from resolution |
| Court order compliance records | Duration specified by court order |
Important
5. Deletion of Specific Data Types
5.1 Lead Records & CRM Data
Lead records are the core of what LeadFrog stores on your behalf. When a lead record is deleted (by you or automatically):
- The database row is immediately marked as deleted (soft-delete) and removed from all UI views.
- After the applicable grace period (7 days for manual deletes; 30 days for account closure), the record is permanently removed via a database DELETE operation — not just a flag update.
- All associated data is deleted in the same transaction: AI classification labels, lead scores, tracked link click events, notes, tags, pipeline stage history, and any custom fields.
- The deletion is recorded in the audit log (for your own accountability records) and the audit log entry itself is retained for 180 days.
5.2 WhatsApp Message Logs
Message logs (records of automated WhatsApp messages sent via LeadFrog) are stored in your CRM as part of the lead timeline. They are deleted when the associated lead record is deleted. You can also delete individual messages from the lead timeline view.
LeadFrog does not retain message content beyond the lead record. Meta retains delivery records on their infrastructure per their own data retention policy.
5.3 AI Classification Data
All AI-generated data — classification labels, confidence scores, lead scores — is stored only as part of the lead record. It is deleted when the lead record is deleted. There is no separate AI training dataset and no shadow database of classification outputs.
5.4 Tracked Link Analytics
When a tracked DM link is clicked, LeadFrog records: the link ID, timestamp, device type, browser, IP (truncated to /24 mask — e.g., 103.21.244.0 instead of 103.21.244.198), and pages visited. This event data is:
- Linked to the lead record — deleted when the lead is deleted.
- IP address truncated within 24 hours of the click event (the full IP is never stored permanently).
- Not shared with any third party other than what is described in Document 04.
5.5 Cookie & Consent Records
Your cookie consent choice (stored in the lf_cookie_consent cookie and a mirrored database record) is retained for 12 months as evidence of consent — a requirement under the DPDP Act and SPDI Rules. After 12 months, the record is deleted and you are asked to re-consent on your next visit. If you delete your account, the consent record is deleted with it.
5.6 API Keys
API keys you generate for integrating LeadFrog with external tools are hashed (SHA-256) before storage — we never store the plain-text key after creation. When you revoke an API key or close your account, the hashed key record is immediately deleted and the key can never be used again.
6. Meta Platform Data Deletion
Customers may request deletion of Meta Platform Data associated with their LeadFrog account by contacting privacy@leadfrog.in or through available account settings.
Upon verification of the request, LeadFrog will delete applicable Meta Platform Data within 30 days unless retention is required by applicable law, regulatory obligations, fraud prevention requirements, or ongoing dispute resolution processes.
LeadFrog does not retain Meta Platform Data beyond the period necessary to provide the Service and fulfill legal obligations.
7. Your Deletion Rights Under Indian Law
| Law | Your Right |
|---|---|
| DPDP Act 2023 — Section 12 | Right to erasure: withdraw consent and request deletion of personal data once the purpose is fulfilled. |
| DPDP Act 2023 — Section 8(7) | Data Fiduciary must delete personal data when purpose is fulfilled, consent withdrawn, or no longer necessary. |
| IT Act 2000 — Section 43A | Sensitive personal data must not be retained beyond necessary period. |
| SPDI Rules 2011 — Rule 7 | Provider must retain data only as long as required; delete once purpose is over. |
| Consumer Protection Act 2019 | Right to seek redressal for data misuse. |
8. How to Request Deletion
| What You Want to Delete | How to Do It |
|---|---|
| Your entire account and all data | Account Settings → Billing → Delete Account |
| Specific lead records | CRM → Lead record → ⋮ → Delete Lead |
| Bulk lead records | CRM → Filter → Select All → Delete |
| Your personal account data (without closing the account) | Email privacy@leadfrog.in — we will anonymise your account where possible |
| A specific Subscriber's data (at their request) | Delete their lead record in your CRM, OR email privacy@leadfrog.in with the WhatsApp number or Instagram username |
| All data immediately (urgent — breach or legal reason) | Email legal@leadfrog.in with subject 'Urgent Data Deletion' — explain the reason |
For all deletion requests via email, we verify your identity before acting. We will acknowledge your request within 24 hours and confirm completion once deletion is done.
9. Contact
| Purpose | Contact |
|---|---|
| Account deletion (self-service) | app.leadfrog.in → Account Settings → Billing → Delete Account |
| Data deletion requests (email) | privacy@leadfrog.in |
| Urgent / legal deletion | legal@leadfrog.in — subject: 'Urgent Data Deletion' |
| Deletion certificate queries | privacy@leadfrog.in |
| Grievance (if deletion refused) | grievance@leadfrog.in — IT Rules 2021 response within 15 days |
Document 10
Indian IT Law Compliance Statement
Effective Date: June 11, 2026 · Version 2.0
1. Overview
LeadFrog is an Indian company, built for Indian small businesses, and subject to Indian law. This document explains — in plain language — every major statute and regulation that applies to us, what each one requires, and exactly how we comply. We have structured it as a law-by-law reference so Customers can quickly find what they need.
Note on DPDP Act timing:
2. Information Technology Act, 2000 (IT Act)
Section 43 — Unauthorised Access & Data Damage
The IT Act makes it a civil wrong to access a computer system without permission or to introduce viruses that damage data. LeadFrog's obligations:
- We operate our infrastructure with layered access controls (VPC, RBAC, MFA) so that no unauthorised party can access your data.
- We do not install any software on your devices that could damage, copy, or tamper with your data.
- Customers are responsible for securing their own login credentials. Sharing credentials or using weak passwords that lead to unauthorised access is not LeadFrog's liability under Section 43.
Section 43A — Compensation for Failure to Protect Data
A "body corporate" (any company or firm) that handles "sensitive personal data or information" is liable to pay compensation to the affected person if it fails to implement "reasonable security practices and procedures". LeadFrog complies by:
- Implementing the security measures described in the DPA (Schedule A), which meet the IS/ISO/IEC 27001 standard cited in the SPDI Rules as the prescribed industry standard.
- Conducting annual third-party penetration tests and remedying findings within the timelines stated.
- Maintaining cyber insurance to ensure we can compensate affected parties in a worst-case scenario.
Section 66C & 66D — Identity Theft & Cheating by Impersonation
These provisions criminalise using another person's identity or digital signature fraudulently. Our commitments:
- We do not impersonate your brand in automated messages. Auto-replies are sent from your connected WhatsApp Business account, with your display name, so Subscribers always know who they are talking to.
- We verify Instagram and WhatsApp account ownership through Meta's official OAuth flow before allowing automation to run.
Section 72A — Disclosure of Information in Breach of Contract
Disclosing personal information obtained under a lawful contract without consent is an offence. LeadFrog's DPA is the lawful contract governing Subscriber Data. We do not disclose Subscriber Data to any party outside the sub-processor list (Document 04) without your explicit authorisation.
Section 79 — Intermediary Safe Harbour
An "intermediary" (a platform that stores or transmits third-party information) is not liable for third-party content if it: (a) does not initiate the transmission, (b) does not select the receiver, (c) does not modify the data, and (d) observes due diligence under IT Rules 2021.
LeadFrog qualifies as an intermediary for content that flows through our platform (Instagram comments, WhatsApp messages). We maintain safe harbour by:
- Not initiating or altering the content of messages — we route what you configure.
- Publishing Terms of Service and Privacy Policy as required.
- Maintaining a grievance officer and responding to complaints within the required timelines.
- Removing or disabling access to unlawful content within 36 hours of a court order or 72 hours of a government notification.
3. IT (SPDI) Rules, 2011 — Sensitive Personal Data
What is 'Sensitive Personal Data' Under SPDI Rules?
The SPDI Rules (Rule 3) define sensitive personal data as: passwords; financial information (bank accounts, credit/debit cards); physical, physiological, and mental health conditions; sexual orientation; medical records; biometric data; and any detail relating to the above.
LeadFrog's handling:
- We do not ask Subscribers for sensitive personal data through Instagram or WhatsApp flows. Our system is designed to capture purchase intent signals, not health, financial, or biometric information.
- Customers must not configure LeadFrog flows to solicit sensitive personal data from their end-users unless they have a separate written agreement with us and implement the enhanced safeguards required by the SPDI Rules.
- If sensitive data inadvertently enters the system (e.g., a Subscriber volunteers health information in a DM), it is stored encrypted, and we will work with you to redact it promptly upon notification.
Privacy Policy Requirement (Rule 4)
Rule 4 requires every body corporate to publish a privacy policy that discloses: the type of information collected; its purpose; its disclosure to third parties; reasonable security practices; and the right to withdraw consent. LeadFrog's Privacy Policy (Document 02) meets all these requirements.
4. IT (Intermediary Guidelines) Rules, 2021
Due Diligence Obligations
Rule 3 of IT Rules 2021 requires intermediaries to:
- Publish rules, privacy policy, and terms of service — done.
- Inform users of prohibited content categories and ensure they don't upload such content.
- Remove or disable access to prohibited content within 36 hours of a court order or 72 hours of a government notification.
- Preserve records for investigation as required by lawful orders.
Grievance Mechanism (Rule 3(1)(c))
Every intermediary must appoint a Grievance Officer whose name and contact details are published, and who acknowledges complaints within 24 hours and resolves them within 15 days. Our details:
| Role | Grievance Officer |
|---|---|
| Contact Email | grievance@leadfrog.in |
| Contact Phone | Published at leadfrog.in/legal/grievance-officer |
| Acknowledgement | Within 24 hours of receipt |
| Resolution | Within 15 days (IT Rules) / 30 days (DPDP Act) |
| Escalation | Unresolved complaints escalated to Data Protection Board of India on operationalisation |
5. Digital Personal Data Protection Act, 2023 (DPDP Act)
Key Rights of Data Principals (Your Subscribers)
| Right | What It Means |
|---|---|
| Right to Information (Sec. 11) | Know what data is collected and why. |
| Right to Access (Sec. 11) | Get a summary of personal data processed. |
| Right to Correction (Sec. 12) | Correct inaccurate or incomplete data. |
| Right to Erasure (Sec. 12) | Delete data once purpose is fulfilled or consent withdrawn. |
| Right to Grievance (Sec. 13) | Lodge a complaint about data misuse. |
| Right to Nominate (Sec. 14) | Nominate someone to exercise rights after death or incapacity. |
Significant Data Fiduciary
The DPDP Act creates an enhanced compliance tier called "Significant Data Fiduciary" (SDF) for entities that process large volumes of sensitive data or data of children. The Central Government has not yet notified LeadFrog as an SDF. If we are designated as one, we will appoint a Data Protection Officer, conduct Data Protection Impact Assessments, and publish audit reports as required.
Children's Data
We do not knowingly process data of anyone under 18. Our Terms of Service prohibit use by minors. Where LeadFrog becomes aware that a Subscriber is under 18, we will restrict processing and notify the Customer. Under the DPDP Act, processing children's data requires verifiable parental consent — which is beyond the scope of what LeadFrog currently supports.
6. TRAI — Commercial WhatsApp Communications
TRAI's Telecom Commercial Communications Customer Preference Regulations 2018 (as amended) govern bulk commercial communications. If you use LeadFrog to send promotional WhatsApp messages, you must:
- Register as a Principal Entity with TRAI through your telecom provider.
- Obtain prior explicit opt-in consent from each recipient before sending promotional messages.
- Register your message templates with TRAI and have them pre-approved via Meta's WhatsApp Business API.
- Honour DND (Do Not Disturb) preferences — LeadFrog flags "STOP" replies automatically.
- Include your sender identity and an opt-out mechanism in every commercial message.
Transactional messages (order confirmations, appointment reminders, OTPs) are exempt from the opt-in requirement but must follow TRAI's template format. LeadFrog's automated flow templates are designed to comply with these format requirements.
Customers are solely responsible for TRAI compliance. LeadFrog provides the technical platform but does not accept liability for your regulatory non-compliance. We reserve the right to suspend accounts found to be sending spam or violating TRAI rules.
7. CERT-In Directions (April 2022)
The Indian Computer Emergency Response Team (CERT-In) issued mandatory directions requiring organisations to:
| CERT-In Requirement | LeadFrog Implementation |
|---|---|
| Report cybersecurity incidents to CERT-In within 6 hours of detection (for notifiable incident types) | Incident response plan includes CERT-In notification within 6 hours. Incident types covered: data breaches, ransomware, website defacement, DoS attacks. |
| Maintain ICT system logs for 180 days | All server logs, API logs, and access logs retained for 180 days |
| Synchronise clocks to NTP servers of NIC or NPL India | All LeadFrog production systems synced to NIC NTP servers (time.nic.in). Verified quarterly. |
| Maintain accurate information in WHOIS and domain registrar records | leadfrog.in registered with accurate registrant information. Updated within 72 hours of any change. |
| Mandatory subscriber verification for cloud / VPN / VPS services | Not applicable to LeadFrog as a SaaS product (not a cloud/VPN provider). We verify Customer identity at subscription via email and, for higher tiers, via GST verification. |
8. GST Compliance
LeadFrog is registered under India's Goods and Services Tax framework. Here is what this means for you as a Customer:
- GST at 18% (the rate applicable to "online information and database access or retrieval services" / OIDAR) is applied to all subscriptions purchased by India-based businesses.
- You receive a GST-compliant tax invoice at the registered email address for your account, which you can use to claim input tax credit (ITC) if your business is GST-registered.
- To receive invoices with your GSTIN, update your billing details in Account Settings → Billing.
- Customers outside India are not charged GST. International transactions are treated as export of services under the IGST Act, subject to FEMA (Foreign Exchange Management Act, 1999) regulations.
- LeadFrog retains all billing records and GST invoices for a minimum of 8 years in compliance with GST record-keeping rules.
9. Consumer Protection (E-Commerce) Rules, 2020
As an e-commerce entity, LeadFrog complies with the Consumer Protection (E-Commerce) Rules, 2020 under the Consumer Protection Act, 2019:
- Our legal name, registered address, and contact details are displayed on leadfrog.in.
- All subscription pricing is shown inclusive of applicable taxes before checkout.
- We do not use dark patterns, forced account creation for price comparison, or misleading countdown timers.
- Refund and cancellation policies are clearly stated in our Terms of Service.
- Grievance Officer details are published as required by Rule 4 of the E-Commerce Rules.
10. Penalties — Why This Matters
So you understand the stakes, here is a summary of the key laws and the violations they penalise:
| Law | Violation |
|---|---|
| DPDP Act, 2023 | Failure to protect personal data (security breach) |
| DPDP Act, 2023 | Processing children's data without consent |
| DPDP Act, 2023 | Non-compliance with Data Protection Board orders |
| IT Act, 2000 | Failure to protect sensitive personal data (Sec. 43A) |
| IT Act, 2000 | Disclosure of information in breach of contract (Sec. 72A) |
| TRAI Regulations | Sending unsolicited commercial communications |
| CERT-In Directions | Failure to report incidents within 6 hours |
LeadFrog's compliance framework is designed to protect both us and our Customers from these risks. Where we identify a compliance gap in your use of the platform, we will notify you and work with you to resolve it.
11. Updates to This Document
Indian digital law is evolving at pace. This document will be updated:
- As the Central Government notifies rules under the DPDP Act (expected in phases through 2027).
- As CERT-In issues new directions or amends existing ones.
- When TRAI updates its commercial communications framework.
- When any other applicable regulation changes in a way that affects LeadFrog or our Customers.
Material updates are communicated by email and posted at leadfrog.in/legal with a changelog. We recommend bookmarking that page.
12. Contact for Legal & Compliance Questions
| Purpose | Contact |
|---|---|
| General privacy questions | privacy@leadfrog.in |
| Grievance / complaint (IT Rules 2021) | grievance@leadfrog.in — response within 24 hours |
| Data Principal rights requests | Raise with your LeadFrog Customer directly, or email privacy@leadfrog.in if the Customer is unresponsive |
| Legal notices / government requests | legal@leadfrog.in |
| Security / CERT-In matters | security@leadfrog.in |
| Billing / GST | billing@leadfrog.in |
| Registered address | Ziwiz Technologies Private Limited — Ground Floor, 7/35, North Street, Pandiyapuram, Vellalankulan, Near Pandiyapuram Government School, Sankarankovil, Sendamangalam, Tenkasi, Tamil Nadu – 627857, India. GSTIN: 33AACCZ3411H1ZN. |