Data protection roles

India's Digital Personal Data Protection Act, 2023 (DPDP Act) names two roles. A Data Fiduciary decides why and how personal data is processed. A Data Processor processes it on a Data Fiduciary's behalf. Hopwire holds a different role for different data.

Messaging data

This is the personal data customers send through Hopwire: recipient numbers, message content, contact records and consent records. The customer decides why and how it is processed, so the customer is the Data Fiduciary. Hopwire, operated by Round Robin, is a Data Processor and acts on the customer's instructions.

Hopwire's own data

This is the data of Hopwire's own account holders and team members, billing records, invoices, and security and audit logs. Round Robin decides why and how it is processed, so it is the Data Fiduciary for that data.

Rights requests

Requests to access, correct or erase personal data, and grievances, about messaging data go to the customer who sent the message. Hopwire gives customers tools to answer them: contact export, contact erasure and consent history. If Hopwire receives a request about messaging data, it passes it on to the customer.

Requests about Hopwire's own account data go to Hopwire directly. Reply to any email from us or write through the early access form.

Personal data breaches

For messaging data, Hopwire tells the affected customer so they can meet their own obligations. For its own data, Hopwire handles notification as the Data Fiduciary.

About this page

This page describes roles. It is not a contract or legal advice.

A data processing agreement (DPA) is planned and does not exist yet. If you need one, contact us through the early access form.

Last reviewed 6 October 2026.