
Privacy Policy
Last Updated: 10th September, 2026
This Privacy Policy explains how Abhinav DigiCompSoft Services Pvt. Ltd.
("Abhinav DCS", "we", "us", "our") collects, uses, shares and protects personal
data when you visit eu.abhinavdcs.com (the "Website"), contact us, book a call,
or otherwise interact with us in connection with our custom software and
product configurator services for European manufacturers.
We are established in India. This policy is written to comply with the EU General Data
Protection Regulation (GDPR), which applies to us because we offer services to
individuals in the EU and monitor their behaviour on this Website.
1. Who is responsible for your data Controller (Art. 4(7) GDPR):
Abhinav DigiCompSoft Services Pvt. Ltd. Head office: 915, Satyaniwas, near Raut Baug, Dhankawadi, Pune 411043, Maharashtra, India Branch office: Floor 4, Snehangan Building, Katraj–Dehu Road Bypass, Ambegaon Budruk, Pune 411046, Maharashtra, India Represented by: Dr. Deepika Jagtap, Managing Director Corporate Identity Number (CIN): U72900PN2012PTC142358
Contact for privacy matters: europe@abhinavdcs.com Telephone: +91 93560 89589
Data Protection Officer. We have not appointed a statutory Data Protection Officer, as our processing does not meet the thresholds in Art. 37 GDPR. Privacy queries go to europe@abhinavdcs.com.Controller and processor. We act as controller for data about Website visitors, enquiries and business relationships — that is what this policy covers. Where we build, host or support a system for a client, we act as processor on that client's instructions, governed by the Data Processing Agreement with them, not by this policy.
2. What personal data we collect We do not knowingly collect special categories of personal data (Art. 9 GDPR) and ask that you do not send them to us.
Providing your data is voluntary. You are under no statutory or contractual obligation to give us personal data. We cannot respond to an enquiry or enter a contract without at least a name and a means of reply (Art. 13(2)(e) GDPR).
Category Examples Source Contact & enquiry data
Name, work email, phone, company, job title, country, content of your message
You, via contact form or email
Meeting booking data
Name, email, time zone, selected slot, booking notes
You, via our scheduling tool
Business & project data
What you tell us about your product logic, quoting process, ERP/CRM systems, sample quotes, including under NDA
You, directly
Communications
Records of emails, calls and messages, including WhatsApp where you initiate contact that way
You, directly
Technical & usage data
IP address, browser type and version, device type, pages visited, referring URL, approximate location derived from IP
Automatically, from your browser
Cookie data
See section 8
Automatically, where consented
3. Why we process it, and our legal basis We do not sell personal data. We do not use it for automated decision-making or profiling producing legal or similarly significant effects (Art. 22 GDPR).
Purpose Legal basis (Art. 6(1) GDPR) Responding to enquiries sent via the contact form or email
(b) - steps prior to a contract, taken at your request
Scheduling and holding demo or discovery calls
(b) - pre-contractual steps at your request
Delivering and managing a project (NDA, proposals, contracts, invoicing)
(b) - performance of a contract
Business records, correspondence and relationship management
(f) - our legitimate interest in running our business and communicating with prospective and existing clients, balanced against your rights
Website security, fraud prevention, diagnosing technical faults
(f) - our legitimate interest in a secure, functioning Website
Analytics, non-essential cookies, third-party embeds, marketing emails
(a) - your consent, withdrawable at any time
Meeting legal, tax and regulatory obligations
(c) - compliance with a legal obligation
Establishing, exercising or defending legal claims
(f) - our legitimate interest in protecting our legal position
4. Who we share it with Processors acting on our documented instructions under Art. 28 GDPR contracts:
We also disclose data to professional advisers (lawyers, accountants) under confidentiality obligations; to public authorities where legally required; and to a successor entity in the event of a merger or acquisition, subject to equivalent protection.
We do not share personal data with third parties for their own marketing purposes.Processor Function Location and transfer basis CSpace
Hosting of this Website, and of client systems and project data
Headquartered in Tallinn, Estonia (EU). Hosted in EU/EEA data centres — Tallinn, Amsterdam, Stockholm. See section 5.
Google Ireland Ltd. / Google LLC
Business email (Google Workspace), Google Meet, Google Maps embed, Google Analytics
Google Workspace under Google's Cloud Data Processing Addendum. Transfers to the United States under the EU–U.S. Data Privacy Framework.
Calendly, LLC
Meeting scheduling
United States, under the EU–U.S. Data Privacy Framework. Calendly's Data Processing Addendum additionally incorporates the Standard Contractual Clauses (Module 2, controller-to-processor). Calendly does not offer EU data residency; booking data is hosted in the United States.
5. International data transfers We are established in India, which is not covered by an adequacy decision under Art. 45 GDPR.
Client systems and project data. For EU client engagements, data is hosted exclusively in CSpace's EU/EEA data centres - Tallinn (Estonia), Amsterdam (Netherlands) and Stockholm (Sweden) - pinned to the EU. CSpace is headquartered in Tallinn and operates its own EU fibre network. This hosting does not itself involve a transfer outside the EEA.
CSpace also operates data centres in Dallas (United States) and Mumbai (India) as part of its wider network. These are not used for EU client data unless a specific client agreement provides for it - for example a disaster-recovery configuration. Where it does, an appropriate transfer safeguard is put in place beforehand and disclosed in that client's Data Processing Agreement.
Support access from India. Where a client requests support or reports an issue, named personnel in India may access data in that client's system to diagnose and resolve it. This access is triggered by a client request rather than routine or continuous, limited to what the issue requires, restricted to authorised personnel, and logged.
Enquiry and relationship data. Personal data you send us directly - via the contact form, email or a booking is accessible to our team in India so that we can respond to you and manage the relationship.
Safeguards. Where personal data is transferred outside the EEA, we rely on the European Commission's Standard Contractual Clauses (Art. 46(2)(c) GDPR), supported by a transfer impact assessment and supplementary technical and organisational measures. For transfers to Google LLC we rely on the EU–U.S. Data Privacy Framework. You can request a copy of the relevant safeguard at europe@abhinavdcs.com.6. How long we keep it Once the purpose has ceased and no retention obligation applies, we delete or anonymise the data.
Data Retention Enquiries that do not lead to a project
24 months from last contact, then deleted or anonymised
Meeting booking data
Duration of the booking record, then deleted
Client and contract data
Duration of the engagement plus applicable tax and accounting retention periods
Website server logs
Up to 90 days, longer only where needed to investigate a specific incident
7. Your rights You have the right to:
• Access your personal data and receive a copy (Art. 15)
• Rectification of inaccurate or incomplete data (Art. 16)
• Erasure (Art. 17)
• Restriction of processing (Art. 18)
• Data portability (Art. 20)
• Object to processing based on legitimate interest, on grounds relating to your particular situation (Art. 21). Where we process your data for direct marketing, you may object at any time and we will stop, without giving reasons.
• Withdraw consent at any time where processing is based on it (Art. 7(3)), without affecting the lawfulness of processing before withdrawal
Contact europe@abhinavdcs.com. We respond within one month, extendable by two further months for complex requests, and will tell you if we need the extension.
Right to complain. You may lodge a complaint with a supervisory authority in your member state of residence, place of work, or the place of the alleged infringement (Art. 77 GDPR). A list is maintained by the EDPB at https://edpb.europa.eu/about-edpb/about-edpb/members_en8. Cookies and similar technologies Strictly necessary cookies are set without consent under Art. 6(1)(f) GDPR and § 25(2) TDDDG. These are limited to what is required to deliver the service you requested your session, your language and theme, security, and the record of your cookie choice itself.
Everything else requires your prior consent under Art. 6(1)(a) GDPR and § 25(1) TDDDG. Nothing non-essential loads before you choose.
Google Analytics. Collects your IP address (truncated where configured), device and browser information, and pages visited. Processed by Google LLC in the United States under the EU–U.S. Data Privacy Framework. Google acts as our processor. Their policy: https://policies.google.com/privacy. Google Analytics is not loaded until you consent.
Withdrawing consent. Use the cookie settings link in the Website footer at any time. Withdrawal is as easy as giving consent. You can also use Google's opt-out add-on at https://tools.google.com/dlpage/gaoptout or your browser's own controls.Category What it does Consent Strictly necessary
Session, language, theme, security, storing your cookie choice
Not required
Analytics
Google Analytics - which pages are read, which lead to an enquiry
Required
Functional embeds
Google Maps on the contact page, the Calendly booking widget, YouTube video - each sets its own cookies when loaded
Required
9. Security We apply technical and organisational measures appropriate to the risk (Art. 32 GDPR), including EU/EEA-pinned hosting for EU client systems under a signed Data Processing Agreement, role-based access control on a need-to-know basis, encrypted transmission (TLS), logging of support access, confidentiality obligations and NDAs for staff and contractors, source code escrow for client projects, and defined incident response procedures.
No system is entirely secure. We will notify affected individuals and the relevant supervisory authority of a personal data breach where required by law.10. Children Our Website and services are directed at business professionals and are not intended for anyone under 16. We do not knowingly collect personal data from children.
11. Changes to this policy We may update this policy to reflect changes in our practices or legal requirements. The current version is always published here with the date at the top. Where changes materially affect how we process your data, we will notify affected individuals directly where we hold contact details.
12. Contact Abhinav DigiCompSoft Services Pvt. Ltd. Email: europe@abhinavdcs.com Telephone: +91 93560 89589

