Your Privacy,
Our Responsibility
All Products, Services & Stakeholders Worldwide — the single authoritative privacy framework governing everything Ksham Innovation does.
Effective Date
15 August 2024
Last Updated
24 March 2026
Jurisdiction
DPDPA 2023 · GDPR
Introduction
Welcome to Ksham Innovation. This document constitutes the Master Privacy Policy of Ksham Innovation ("we," "our," or "us") and is the single, authoritative privacy framework governing all products, services, platforms, and interactions offered or facilitated by Ksham Innovation — whether now in existence or introduced in the future.
This policy explains how we collect, use, store, share, and protect personal information of all individuals who interact with us in any capacity, including but not limited to:
- Members of the general public visiting our website or using our products
- End users of the Able Assistant App and Able Glasses
- Individuals with hearing impairment or other disabilities using our assistive services
- Registered Healthcare Professionals including RCI-certified audiologists
- Job applicants and career enquirers
- Primary and secondary stockholders, investors, and business partners
- Newsletter and blog subscribers
- Any other natural or legal persons engaging with Ksham Innovation globally
Products & Services Covered
Our products and services covered under this Master Policy include, but are not limited to:
- The Ksham Innovation Website (www.kshaminnovation.in) — including the Contact Us, Career, Audiologist Partnership, Blog, Newsletter, About Us, and Home pages
- The Able Assistant Mobile Application ("Able Assistant App")
- Able Glasses and associated hardware products
- Any future products, services, or platforms introduced by Ksham Innovation
We are committed to protecting your privacy and handling your data responsibly, transparently, and in full compliance with the Digital Personal Data Protection Act, 2023 (DPDPA) of India, the General Data Protection Regulation (GDPR) for users in the European Economic Area, and other applicable international privacy frameworks.
Who We Are — Data Controller
Ksham Innovation is the Data Controller (or Data Fiduciary under DPDPA) responsible for your personal data.
Organisation
Ksham Innovation
Location
Maharashtra, India, 444801
Privacy Email
team@kshaminnovation.in
Website
www.kshaminnovation.in
Scope of This Master Policy
This Master Privacy Policy is universal in application. It applies globally, without geographic limitation, to every individual or entity that interacts with Ksham Innovation in any capacity, including:
- General Public: Any person who visits our website, reads our blog, or subscribes to our newsletter
- App Users: All individuals who download, install, or use the Able Assistant App, regardless of geography
- Hearing-Impaired and Disabled Individuals: Persons using our assistive products and services including Able Glasses and the Able Assistant hearing support features
- Healthcare Professionals: RCI-certified audiologists and other hearing care professionals who partner with or are listed on our platform
- Job Applicants: Individuals who submit applications or resumes for employment or internship opportunities
- Primary Stockholders: Founders, directors, board members, and major equity holders of Ksham Innovation
- Secondary Stockholders: Minority investors, angel investors, venture capital partners, and other financial stakeholders
- Business Partners and Vendors: Third-party companies, contractors, or service providers who enter into agreements with Ksham Innovation
- Regulators and Authorities: As required by applicable law or regulatory obligation
This policy covers all current and future products and services offered by Ksham Innovation. When a new product or service is launched, it shall automatically fall under the scope of this Master Policy unless a separate, supplementary policy is explicitly issued and communicated.
Note: This policy does NOT apply to third-party websites, apps, or services that we may link to. We encourage you to review the privacy policies of any third-party services you access through our platforms.
Confidentiality Agreements: For stockholders and business partners, certain categories of information such as financial records, board communications, or due diligence materials may also be subject to separate Non-Disclosure Agreements (NDAs) or shareholder agreements. This Master Policy governs personal data only.
Information We Collect
We collect different categories of information depending on how you interact with our products and services.
4.1 — Website: Contact Us Page
When you submit an enquiry through our Contact Us form, we collect:
- Full Name
- Email Address
- Contact / Phone Number
- Message / Enquiry Content
4.2 — Website: Career / Job Applications
When you apply for a position at Ksham Innovation, we collect:
- Full Name
- Email Address
- Contact / Phone Number
- Resume / CV (including educational qualifications, work experience, and any personal information voluntarily included in the document)
- Any additional information provided in the application form
Resumes may contain sensitive personal information such as date of birth, photograph, or other details. We advise applicants to share only what is necessary. by sharing your resume you are willing to provide the mentioned information and provide a full authority to analyze, evaluate the CV/ Resume.
4.3 — Website: Audiologist Partnership Page
Audiologists who wish to partner with Ksham Innovation and obtain a Verified Badge on the Able Assistant App submit:
- Full Name
- Professional Photograph
- Email Address and Contact Number
- Clinic / Practice Address and Location
- RCI (Rehabilitation Council of India) Registration ID — mandatory for audiologists practising in India
- Any other professional information submitted via the partnership form
This information is reviewed manually by our team for the purpose of verification. Upon successful verification, the audiologist's professional profile (name, location, contact details, and RCI ID status) will be displayed within the Able Assistant App to help users find certified audiologists near them. RCI ID and professional photographs constitute sensitive professional data. By submitting this form, audiologists consent to their professional profile being displayed on the Able Assistant App.
4.4 — Able Assistant App: User-Provided Information
When you use the Able Assistant App, we may collect:
- Basic Personal Information: Name, age, gender (provided during onboarding or profile setup)
- Health Information: Audiogram results generated by the in-app hearing screening test, self-reported hearing concerns, and responses to hearing-related questions
- Location Data: With your explicit permission, your approximate location is used to help you find nearby RCI-certified audiologists
- Microphone Access: Used solely to perform the audiometry screening test and to detect ambient noise levels, ensuring the test is conducted in a sufficiently quiet environment. Audio is processed locally and is NOT recorded, stored, or transmitted
- Language Preferences: Your preferred language for the Able Assistant feature
4.5 — Able Assistant App: LLM-Based Virtual Audiologist
Our Able Assistant feature uses a Large Language Model (LLM) to answer your hearing-related questions in your preferred language via text or audio. Please note:
- Conversations with Able Assistant are NOT stored or logged on our servers
- Queries are transmitted to our third-party LLM integration partner(s) for real-time processing. These partners operate under data processing agreements with us
- We strongly advise you not to share identifying personal information (such as full name, phone number, or Aadhaar number) within the chat interface
4.6 — Able Glasses
Able Glasses are designed to complement your hearing care journey. Depending on the features you use, Able Glasses may collect:
- Audio environmental data (processed on-device for hearing assistance purposes)
- Usage data (device interactions, feature usage patterns) to improve product performance
This section will be updated as Able Glasses features are further developed. We will notify you of any material changes via an updated Privacy Policy.
4.7 — Automatically Collected Data
When you visit our website or use the app, we may automatically collect:
- Device Information: Device type, operating system, browser type and version
- Usage Data: Pages visited, features used, session duration, app interaction patterns
- Log Data: IP address, access times, referring URLs
- Cookies and Tracking Technologies: Used on our website for analytics (see Section 8)
4.8 — Newsletter and Blog Subscriptions
If you subscribe to our newsletter or blog updates, we collect your email address and, optionally, your name to personalise communications.
How We Use Your Information
We use the information we collect for the following purposes:
5.1 — Providing & Improving Our Services
- To operate and deliver the Able Assistant App features, including the audiometry screening test, audiologist finder, and Able Assistant virtual support
- To process and respond to enquiries submitted via the Contact Us page
- To evaluate job applications and conduct the recruitment process
- To verify audiologist credentials and display verified professional profiles within the app
- To improve the functionality, performance, and user experience of our products
5.2 — Health and Hearing Care
- To generate and display your audiogram report and WHO hearing grade
- To store your audiogram results (on our servers and/or your device) so you can track your hearing health over time
- To provide personalised guidance through the Able Assistant feature
5.3 — Communication
- To send you transactional communications (e.g., confirmation of enquiry receipt, application status updates)
- To send newsletters, blog updates, and hearing health awareness content — only where you have opted in
- To respond to your support or service requests
5.4 — Analytics and Product Development
- To analyse usage patterns and app performance using third-party analytics tools (Google Analytics, Firebase) to improve our services
- Analytical data is aggregated and anonymised wherever possible
5.5 — Legal and Compliance
- To comply with applicable laws and regulatory obligations
- To detect, prevent, and address fraud, security breaches, or misuse of our services
Legal Basis for Processing
We process your personal data on the following legal grounds:
Consent
For health information (audiogram data), location access, microphone access, newsletter subscriptions, and sharing your data with audiologists. You may withdraw consent at any time without affecting the lawfulness of prior processing.
Contractual Necessity
To process your job application or to fulfil our obligations to audiologist partners.
Legitimate Interests
For analytics, product improvement, fraud prevention, and security, where our interests do not override your rights.
Legal Obligation
Where processing is required to comply with applicable laws.
For users in the European Union or EEA, we process data in accordance with GDPR Article 6 (lawful bases) and Article 9 (special category data, which includes health information).
Data Retention
We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by law:
| Data Type | Retention Period |
|---|---|
| Contact Us Enquiries | Retained for up to 2 years |
| Job Applications (unsuccessful) | Retained for up to 6 months after the recruitment process concludes, then securely deleted |
| Job Applications (successful) | Retained as part of the employee record for the duration of employment and thereafter per applicable employment law |
| Audiologist Partnership Data | Retained for the duration of the partnership and up to 3 years thereafter |
| Audiogram / Health Data | Retained on our servers for as long as your account is active, plus a period of 2 years after account deletion |
| Newsletter Subscriptions | Retained until you unsubscribe |
| Analytics Data | Typically retained for up to 26 months (as per Google Analytics defaults) |
You may request deletion of your data at any time (see Section 11 — Your Rights).
Data Security
We take the security of your personal data seriously and implement appropriate technical and organisational measures to protect it, including:
- Encryption of data in transit using TLS/SSL protocols
- Encryption of health data (audiogram results) at rest on our servers
- Access controls and authentication mechanisms to limit access to personal data to authorised personnel only
- Regular security assessments and vulnerability testing
- Data processing agreements with all third-party service providers
Your Rights
Depending on your jurisdiction, you have the following rights regarding your personal data:
Right to Access
Request a copy of the personal data we hold about you
Right to Correction
Request correction of inaccurate or incomplete data
Right to Erasure
("Right to be Forgotten"): Request deletion of your data, subject to legal obligations
Right to Withdraw Consent
Withdraw consent at any time for data processing based on consent (e.g., health data, newsletters, location)
Right to Data Portability
Receive your data in a structured, machine-readable format
Right to Object
Object to processing of your data for analytics or direct marketing
Right to Restrict Processing
Request restriction of processing in certain circumstances
Right to Grievance Redressal
Under the DPDPA 2023, you have the right to have your grievances addressed promptly
Exercise Your Rights
To exercise any of these rights, please contact us at: team@kshaminnovation.in
We will respond to all requests within 7 days. We may need to verify your identity before processing your request.
Children's Privacy
The Able Assistant App is intended for users aged 13 and above. We do not knowingly collect personal data from children under 13 years of age.
- If you are a parent or guardian and believe your child under 13 has provided us with personal information, please contact us at [team@kshaminnovation.in] and we will promptly delete such data
- For users aged 13–17, we recommend parental guidance when using health-related features of the app
- Audiogram results and health data for minors should ideally be reviewed with a parent or guardian
- Under the DPDPA 2023, processing of personal data of children requires verifiable parental consent
- We will implement appropriate age-verification and consent mechanisms to comply with this requirement
International Data Transfers
As Ksham Innovation serves users in India and internationally, your data may be transferred to and processed in countries other than your country of residence, including countries where our cloud infrastructure and third-party service providers are located (such as the United States or European Union).
Where such transfers occur, we ensure appropriate safeguards are in place, including:
- Standard Contractual Clauses (SCCs) approved by applicable data protection authorities
- Data processing agreements with third-party providers that require equivalent levels of data protection
By using our services, you acknowledge that your data may be transferred internationally in accordance with this policy.
Special Categories of Personal Data (Sensitive Information)
Certain data we collect is classified as sensitive personal data and requires heightened protection:
Health / Medical Data
Audiogram results and hearing grades are health data. We collect this only with your explicit consent and use it solely for the purpose of providing hearing care services through the Able Assistant App.
Biometric / Professional Credentials
Audiologist photographs and RCI ID numbers are collected exclusively for professional verification purposes and are not shared beyond what is necessary for display within the app.
You may withdraw consent for the collection and processing of sensitive personal data at any time by contacting us. However, note that withdrawal of consent for health data will limit your ability to use certain features of the Able Assistant App.
Third-Party Links and Integrations
Our website and app may contain links to third-party websites, and our services integrate with third-party platforms (including LLM providers and analytics tools). We are not responsible for the privacy practices of these third parties. We encourage you to read their privacy policies before providing any personal information.
Key third-party integrations include:
- Google Analytics / Firebase (Analytics)
- Cloud storage providers (AWS, Google Cloud, or Microsoft Azure)
- Email marketing service providers
- LLM API provider(s) for the Able Assistant conversational feature
Grievance
In accordance with the Information Technology Act, 2000, and the Digital Personal Data Protection Act, 2023, we have a Grievance resolution Department to address any concerns or complaints related to your personal data:
Grievance Email
grievance@kshaminnovation.in
Response Time
We will acknowledge your complaint within 24 hours and resolve it within 7 days.
If you are not satisfied with our resolution, you may approach the Data Protection Board of India (once constituted under the DPDPA 2023) or other applicable regulatory authorities.
Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make significant changes, we will:
- Update the “Last Updated” date at the top of this policy
- Notify registered app users via an in-app notification or email
- Post a prominent notice on our website
We encourage you to review this Privacy Policy periodically. Your continued use of our services after the effective date of the updated policy constitutes your acceptance of the changes.
Contact Us
If you have any questions, concerns, or requests related to this Privacy Policy or our data practices, please contact us at:
Organisation
Ksham Innovation
Team
Ksham Innovation Team
team@kshaminnovation.in
Website
www.kshaminnovation.in
We are committed to working with you to resolve any concerns about your privacy.
Thank you for trusting Ksham Innovation
with your hearing health journey.