Privacy policy
Effective from 9 November 2026
This policy explains how Stemphor Techlabs LLP (“Stemphor”, “we”, “us”) collects, uses, shares and protects personal data. It covers this website and Stem Commerce, including the Stem Merchant app on Android, iOS and the web, and the WhatsApp shopping experience that Stem Commerce provides for businesses. We process personal data in line with the Digital Personal Data Protection Act, 2023 and other applicable Indian law.
1. Who is responsible for your data
- Website visitors and merchants. When you use this website, or when you or your business use Stem Commerce, we decide how your personal data is used. We are the data fiduciary for that data.
- Customers of a merchant. When you shop with a business on WhatsApp through Stem Commerce, that business decides how your personal data is used and is the data fiduciary. We process your data on the business’s behalf, as its data processor. For most requests about your data, contact the business first. You can also contact us, and we will help or pass your request to the business.
2. What we collect
When you visit this website
- Contact form: your name, email address, phone number and message. The form is delivered to us by email through EmailJS.
- Technical data: our hosting provider (Cloudflare) and our font provider (Google Fonts) receive your IP address and browser details when your browser loads the site. This website does not use analytics or advertising cookies.
When your business uses Stem Commerce
- Account data: the mobile number you sign in with (verified by a one-time code), your name, your role, and the details of the team members you invite.
- Business data: your business name, store names and addresses, tax details such as GST rates, your WhatsApp Business Account and phone number, and your product catalogue, prices, stock, coupons and message templates.
- App data: the app version and environment, which help us support you.
When you shop with a business on WhatsApp
- Contact details: your WhatsApp phone number and profile name.
- Messages: the messages you exchange with the business, including text, voice notes and their transcripts, and any translations the business asks for.
- Orders: your cart, orders, delivery address, coupons used, order history and payment method (cash on delivery).
- Preferences: whether you have opted out of marketing messages, and tags or groups the business assigns to you.
- Advertising data: if you reached the business from a click-to-WhatsApp ad, an identifier for that ad click.
3. How we use it
- To provide Stem Commerce: show the catalogue, run the cart and checkout in WhatsApp, record orders, and deliver messages between businesses and their customers.
- To sign you in, keep accounts secure and prevent misuse.
- To provide AI features for businesses (section 4).
- To tell a business’s ad platform that an ad led to a purchase, when the business uses click-to-WhatsApp ads (section 5).
- To answer enquiries, give support, and improve our products and services.
- To meet our legal obligations.
We do not sell personal data. We do not use a business’s customer data for our own marketing.
4. AI features and voice notes
Stem Commerce uses AI services from outside providers to help businesses:
- Replies and understanding messages. Customer messages are sent to an AI model to understand what the customer wants and to suggest or send short replies. Answers are based on the business’s own catalogue.
- Voice-note transcription. When a customer sends a voice note, the audio is sent to a speech-to-text service, which returns a written transcript and the detected language.
- Translation. When a business taps to translate a message, its text is sent to an AI model.
We reach these models through OpenRouter, which routes each request to a model provider such as OpenAI, Google or ElevenLabs. These services process data outside India. Each provider handles the data under its own terms and privacy policy, which may allow it to keep the data for a period of time.
5. Who we share it with
We share personal data only with service providers that help us run our services, and only as much as they need:
- Meta (WhatsApp Business Platform): sends and receives WhatsApp messages and runs WhatsApp Flows.
- Google Cloud: hosts our servers, database and file storage in the Mumbai region (asia-south1).
- Google Firebase Authentication: verifies the mobile number that merchants sign in with.
- OpenRouter and the AI model providers it routes to, including ElevenLabs for voice notes: the AI features in section 4.
- Cloudflare: serves this website and protects our services.
- EmailJS: delivers messages from this website’s contact form.
- Meta Conversions API, Google Ads and Google Analytics: only when a business runs click-to-WhatsApp ads. We send the ad-click identifier and purchase details. Phone numbers are hashed before they are sent.
We may also disclose personal data when the law requires it, to protect rights and safety, or as part of a merger or sale of our business. Businesses using Stem Commerce can see the data of their own customers. They are responsible for how they use it.
During the pilot, Stem Commerce does not process online payments or book couriers. We will update this policy before we add payment or delivery partners.
6. Transfers outside India
Our main servers and database are in India. Some service providers, including Meta, Firebase, OpenRouter, the AI model providers and ElevenLabs, process data in other countries. We only transfer personal data to countries that Indian law does not restrict.
7. How long we keep it
- Merchant account and business data: while the account is open, and for one month after it is closed, unless the law requires us to keep it longer.
- Customer data: for as long as the business uses Stem Commerce, or until the business deletes it or asks us to delete it.
- Voice-note audio: 30 days, then deleted automatically. The transcript is kept with the message, like a text message.
- Contact form messages: as long as we need them to answer and follow up on your enquiry.
8. How we protect it
We use encryption in transit, encrypted data exchange for WhatsApp Flows, signature checks on every message we receive from WhatsApp, access controls that keep each business’s data separate, and secrets stored in a managed secret store. No system is perfectly secure. If a personal data breach affects you, we will notify you and the Data Protection Board of India as the law requires.
9. Your rights
Under the Digital Personal Data Protection Act, 2023, you can:
- ask for a summary of your personal data and how it is processed;
- ask us to correct, complete, update or erase your personal data;
- withdraw consent where we rely on it (this does not affect processing that already happened);
- nominate someone to exercise your rights if you die or become unable to; and
- raise a grievance with us, and then with the Data Protection Board of India.
To stop marketing messages from a business, use the opt-out option in its WhatsApp message or ask the business. If you are a customer of a business, you can also ask that business directly. To make a request to us, write to our Grievance Officer (section 11). We may need to verify your identity first.
10. Children
Our services are not meant for anyone under 18, and we do not knowingly collect their personal data. If you believe a child has given us personal data, contact us and we will delete it.
11. Grievance Officer and contact
Grievance Officer: Girish Vengasseri
Email: [email protected]
Address: Stemphor Techlabs LLP, 10th Floor, Building 4, North Wing, NESCO IT Park, Western Express Highway, NESCO, Goregaon East, Mumbai, Maharashtra 400063, India
We will acknowledge your grievance and aim to resolve it within the time the law sets. For anything else, write to [email protected].
12. Changes to this policy
We will update this page when our practices change and change the date at the top. If a change is significant, we will also tell merchants in the Stem Merchant app or by message.
