INDIAN JURISDICTION // DPDP ACT 2023 & IT ACT 2000

PRIVACY POLICY

This Privacy Policy governs the collection, processing, storage, and transfer of digital personal data and confidential commercial telemetry by VISUAL SHADOW in strict accordance with the Digital Personal Data Protection Act, 2023 (DPDP Act 2023), Section 43A of the Information Technology Act, 2000, and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (SPDI Rules).

STATUTORY JURISDICTION: REPUBLIC OF INDIASEAT OF GOVERNANCE: KOLKATA, WEST BENGALCOMPLIANCE: DPDP ACT 2023 CERTIFIED

FIDUCIARY PRIVACY COVENANT

VISUAL SHADOW acts as a responsible Data Fiduciary. We do not sell, rent, monetize, or disclose client sales volumes, gross merchandise value (GMV), ad budgets, or commercial catalog blueprints to third parties or data brokers. All client communications and audits are protected under binding Indian legal confidentiality.

01Identity of the Data Fiduciary

Under the Digital Personal Data Protection Act, 2023, the Data Fiduciary determining the purposes and means of processing personal data is:

VISUAL SHADOW

E-Commerce Consultancy • Brand Building • AI Solutions • Technology

Registered Office: 6, J K Paul Road, Kolkata, 700038

State / Jurisdiction: West Bengal, Pin Code: 700038, India

Direct Consultation Helpline: +91 9073995531

Official Statutory Email: contact@visualshadow.com

02Statutory Grounds for Processing (DPDP Act, 2023)

In accordance with Section 4, Section 6, and Section 7 of the DPDP Act, 2023, VISUAL SHADOW processes personal data strictly on the basis of:

A. Free, Specific, Informed and Unconditional Consent (Section 6):Obtained when a Data Principal voluntarily submits inquiries, project briefs, or consultation requests via our web platform, telephone line, or WhatsApp concierge.
B. Legitimate Uses & Contractual Performance (Section 7):Processing necessary to perform agreed e-commerce consultancy services, marketplace management, custom technology architecture, brand identity design, and billing under executed Statements of Work (SOW).
C. Compliance with Indian Statutory Mandates:Fulfilling obligations under the Central Goods and Services Tax Act, 2017 (CGST Act), the Income Tax Act, 1961, and legal directives issued by Indian regulatory or law enforcement authorities.

03Categories of Personal & Commercial Data Collected

1. Contact & Inquiry Information

Name, corporate designation, email address, WhatsApp/mobile number, brand name, store URLs, and strategic project requirements.

2. Marketplace & Storefront Credentials

Under mutual Non-Disclosure Agreements, delegated sub-user permissions for Amazon Seller Central, Shopify, Flipkart, or Meta ad managers solely to conduct audits.

3. Invoicing & Tax Identifiers

Corporate PAN (Permanent Account Number), GSTIN (Goods and Services Tax Identification Number), registered legal address for statutory invoicing.

4. Technical & Device Telemetry

IP addresses, browser characteristics, session timestamps collected for cybersecurity firewall filtering and CERT-In compliance.

04AI Model Training & Commercial Data Segregation

In deploying artificial intelligence solutions, virtual brand ambassadors, and workflow agents, VISUAL SHADOW guarantees:

Strict Zero-Training Rule: Proprietary client commercial data, sales figures, margin spreadsheets, and unpublished product roadmaps are never used to train public multi-tenant foundation models.
Isolated Tenant Inference: AI inference calls run inside sandboxed enterprise API containers where client inputs and outputs are discarded post-computation with zero data retention.
Clearance of Synthetic Ambassadors: All virtual models and synthetic visual assets created for clients are commercially cleared under Indian copyright and advertising guidelines.

05Statutory Rights of Data Principals (DPDP Act, 2023)

As a Data Principal residing in India or transacting with our Indian consultancy, you possess enforceable statutory rights under Sections 11, 12, 13, and 14 of the DPDP Act:

Section 11: Right to Access Summary of Personal Data

Section 12: Right to Correction, Updating & Erasure

Section 13: Right of Grievance Redressal

Section 14: Right to Nominate Authorized Representative

To exercise these statutory rights, send a verified request to our Resident Grievance Officer. All requests are acknowledged within 48 hours and processed within 30 statutory days.

06Data Retention, Storage & Cross-Border Transfers

All digital personal data is retained only for the duration necessary to accomplish the specified purpose or satisfy statutory tax and corporate audit periods in India (typically 8 financial years under Section 44AA of the Income Tax Act, 1961). Cross-border transfers of personal data for cloud hosting or analytics comply with the negative list restrictions notified by the Central Government under Section 16 of the DPDP Act, 2023.

07Statutory Grievance Redressal Mechanism (India)

Pursuant to Section 5(9) of the SPDI Rules, 2011 and Section 13 of the DPDP Act, 2023, the contact details of our Resident Grievance Officer are set forth below:

GRIEVANCE & DATA PROTECTION OFFICERSTATUTORY APPOINTMENT

Entity: VISUAL SHADOW

Physical Address: 6, J K Paul Road, Kolkata, 700038, Kolkata, West Bengal, 700038, India

Grievance Helpline: +91 9073995531 (Mon–Sat, 10:00 AM – 6:00 PM IST)

Designated Email: contact@visualshadow.com

Statutory Resolution Timeline: Maximum 30 days from date of receipt

If your grievance remains unaddressed after 30 days, you have the statutory right to escalate the matter before the Data Protection Board of India (DPBI).