This Privacy Policy (“Policy”) is issued by Vermmillion Communication Private Limited (“Company,” “we,” “us,” “our”), a data fiduciary under the Digital Personal Data Protection Act, 2023 (“DPDPA”). This Policy outlines the manner in which we collect, process, use, disclose, and protect digital personal data as defined under Section 2(j) of DPDPA, in compliance with Indian law and applicable statutory guidelines.
1. Definitions and Scope
- Personal Data: Any data relating to an identifiable individual (“Data Principal”), including name, phone number, email address, and digital identifiers such as IP address.
- Processing: Includes collection, recording, organization, storage, alteration, retrieval, and utilization of personal data, whether automated or manual.
- Applicability: This Policy applies to all visitors (“Users”) to [insert website URL], and to all individuals who submit personal information via our platforms.
2. Data Collection and Purpose
- Voluntary Collection: Contact information including but not limited to name, phone number, email is obtained exclusively through forms or direct inquiries made by the User. Submission is recognized as informed and specific consent for the stated purposes.
- Automatic Data Gathering: Technical details including but not limited to IP address, device, browser type, pages visited are passively collected through cookies or similar technology for Website performance, security, analytics, and fraud prevention.
Purpose of Processing:
- To establish communication and respond to queries or requests for information regarding our services.
- To provide follow-ups or relevant updates as permitted by applicable law.
- To improve website security, usability, and content based on analytics.
- To maintain compliance with statutory or regulatory obligations.
3. Consent Framework
- Explicit Consent: By submitting contact details, the User provides free, informed, and specific consent for collection and processing in accordance with DPDPA. Consent is revocable and withdrawal mechanisms are provided (Section 6 DPDP Rules 2025).
- Privacy Notice: At the time of data collection, Users are presented with a concise notice identifying categories of personal data, intended purpose, retention period, User rights, grievance redressal process, and the mechanism for withdrawal of consent. Except for the categories of personal data, all other information shall be provided in the Privacy Policy.
4. Legal Basis for Processing
- Lawful Purposes: Data is processed only for purposes authorized under Section 4 of DPDPA, including User consent and other legitimate uses as specified by law.
- Data Minimization: Only data strictly necessary for stated purposes is collected; no additional profiling, tracking, or behavioral monitoring is performed.
5. Data Retention & Security
- Retention: Personal data is retained only as long as necessary for the declared purpose or as mandated by law. Upon expiry or withdrawal of consent, data is securely deleted or anonymized.
- Security Measures: Reasonable technical and organizational safeguards are implemented (e.g., encryption, access controls) to protect against unauthorized access, alteration, or loss. In the event of a data breach, notification will be provided to the Data Protection Board of India and the affected User as per statutory norms.
6. User Rights under DPDPA
Users (“Data Principals”) have the right to:
- Access their personal data and obtain a copy.
- Seek correction, completion, or updation of any data found inaccurate.
- Withdraw consent for further processing, with mechanisms as simple as those for providing consent.
- Request deletion of personal data, subject to statutory retention requirements.
- Lodge complaints with the Company’s designated grievance officer, and if unsatisfied, with the Data Protection Board of India.
- Contact for Rights Exercise: info@vermmillion.net.in
7. Cookies & Third-Party Links
- Cookies: The Website utilizes cookies for site optimization and analytics. Users can accept or refuse cookies through browser settings.
- External Links: Our Website may link to third-party sites. We are not responsible for their privacy practices. Users are advised to review their respective policies separately.
8. Grievance Redressal and Dispute Resolution
- Users may contact the designated Grievance Officer, Name: Savyasaachi Wable; Email: legal@vermmillion.net.in, for privacy complaints, requests, or escalation.
- Disputes will be resolved primarily through negotiation; if unresolved, Users may escalate the matter to the Data Protection Board of India or appropriate legal forum.
9. Cross-Border Data Transfers
- Personal data will not be transferred outside India except in accordance with government notifications or statutory guidelines. Transfers to jurisdictions on a negative list, as notified by the Government of India, are strictly prohibited.
10. Policy Updates
- This Policy may be updated periodically to reflect changes in law or our processing activities. Users will be notified only via this page by checking the last updated date.
Contact Information
Vermmillion Communication Private Limited
11th Floor, Vipul Business Park, Sohna Road
Sector 48, Gurgaon – 122018
Email: info@vermmillion.net.in
Phone: 0124-4642000