Privacy Policy

1. Who this policy covers

This policy explains how Abhisam Software Private Limited ("we", "us", "Abhisam") — the Data Fiduciary for the purposes of the Digital Personal Data Protection Act, 2023 ("DPDP Act") — handles personal data collected through dpdpatraining.in.

2. What personal data we collect

We collect personal data only in two clearly defined situations:

• Contact form submissions: your name, work email, company name, phone number (if provided), and the content of your message.
• Website analytics (only with your consent): aggregated page-view statistics, referrer URL, browser type, and approximate geography (country/region level). No name, email, or precise identifier is collected via analytics.

3. Purposes of processing

Each category of personal data is processed for specific, disclosed purposes:

• Contact form data — to respond to your enquiry, provide a quote, or follow up on a purchase discussion. We do not use this data for unsolicited marketing.
• Analytics data — to understand aggregate site usage patterns so we can improve content and navigation. No individual profiling or advertising use.

4. Basis for our processing

We process information in accordance with applicable law, and we are preparing our practices for the substantive provisions of the DPDP Act, which are scheduled to commence on 13 May 2027. On this site:

• Contact form submissions: when you submit an enquiry, we process the information you voluntarily provide for the specified purpose of responding to your enquiry, preparing a quotation, or discussing the service you have asked about. We do not add you to a general marketing list unless you separately opt in.
• Analytics tracking: we load StatCounter analytics only if you have opted in via the consent banner. If you decline or ignore the banner, no analytics load and no analytics identifiers are set.
• Spam prevention on the enquiry form: we use hCaptcha to protect the enquiry form from automated abuse and maintain the security and availability of the site. This processes information such as your IP address and browser characteristics for bot detection.

The exact statutory bases under Sections 6 and 7 of the DPDP Act (consent and certain legitimate uses) will apply from 13 May 2027. This policy will be updated to reference the applicable statutory bases when they commence. This site is not aimed at children.

5. Third-party processors and cross-border transfers

We use the following Data Processors to operate this site. Some of these processors are located outside India; their own transfer safeguards may include contractual clauses or other recognised mechanisms under the framework applicable to them (such as GDPR-related mechanisms for EU-based processors). We will also comply with any requirements or restrictions issued by the Central Government under Rule 15 of the DPDP Rules when those provisions become operative.

• Netlify, Inc. (United States) — hosting and Netlify Forms. Stores and forwards contact-form submissions.
• Intuition Machines, Inc. / hCaptcha (United States) — spam prevention on the contact form. Processes IP address, browser characteristics, and interaction patterns solely for bot detection.
• StatCounter International (Dublin, Ireland) — website analytics, only if you accept via the consent banner. Subject to GDPR as an EU processor.

Section 16 of the DPDP Act and Rule 15 of the DPDP Rules are scheduled to commence on 13 May 2027. Once operative, Section 16 will allow the Central Government to restrict the transfer of personal data by a Data Fiduciary to notified countries or territories outside India, while Rule 15 will allow the Central Government to specify additional requirements concerning the availability of transferred personal data to foreign States or entities under their control. Abhisam will comply with any such notifications or requirements when they take effect. As of the date of this policy, no country-specific restrictions or additional requirements apply to the transfers described above.

6. Data retention

• Contact form submissions: retained for 24 months from the date of your enquiry, unless we are actively engaged in a purchase, renewal, or support conversation with you, in which case retention extends for the duration of that engagement plus 24 months.
• Analytics data: retained by StatCounter under their retention policy — typically a rolling window not exceeding 12 months.

7. Children's data

This site is intended for adult professionals evaluating corporate training. We do not knowingly collect personal data from anyone under 18. If you believe we have inadvertently collected data from a minor, please contact our Grievance Officer (see Section 10) and we will delete it promptly.

8. Data security

We implement reasonable technical and organisational safeguards to protect the personal data we hold, including encryption in transit (HTTPS), access controls on our administrative systems, and vetted third-party processors. No system is perfectly secure, and we cannot guarantee absolute protection.

9. Data Principal rights and Abhisam's current practice

The DPDP Act provides Data Principals with rights of access, correction and erasure, grievance redressal, and nomination (Sections 11-14 of the Act). These statutory rights are scheduled to become operative on 13 May 2027.

In advance of that date, Abhisam voluntarily accepts equivalent privacy requests concerning personal data submitted through this site. Specifically:

• Access — you may ask what personal data we hold about you.
• Correction — you may ask us to correct inaccurate or outdated data.
• Erasure — you may ask us to delete your personal data, subject to any applicable legal retention obligations.
• Grievance — you may raise a complaint about how your personal data is handled (see Section 10 below).
• Nomination — you may nominate another person to exercise these requests on your behalf if you are unable to do so.
• Withdraw analytics consent — you may withdraw analytics tracking consent at any time using the reset consent preference link.

10. Grievance Officer

For any complaints, requests to exercise your rights, or questions about how we handle your personal data:

Grievance Officer
Email: privacy@abhisam.com
Response commitment: within 7 working days for acknowledgement; substantive resolution within timelines required by the DPDP Rules.

11. Data breach notification

In the event of a personal data breach affecting your information, we commit to notifying the Data Protection Board of India and affected Data Principals in accordance with Rule 7 of the DPDP Rules, 2025 — including within the timelines and format prescribed.

12. Escalation to the Data Protection Board

The DPDP Act provides for escalation of grievances to the Data Protection Board of India under Section 27. The statutory mechanism for a Data Principal to approach the Board under these provisions is scheduled to become operative on 13 May 2027. In advance of that date, if you are not satisfied with our response to a grievance, you may raise the matter through any complaint channels that the Ministry of Electronics and Information Technology and the Board make available.

13. Changes to this policy

We may update this policy from time to time. Material changes will be reflected in the "Last updated" date at the top. We recommend reviewing this page periodically.

14. Contact

General questions about this policy: privacy@abhisam.com. Grievances and rights requests should be directed to the Grievance Officer at the address in Section 10.