1. Who Is Responsible for Your Data (the "Controller")

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 with us, or otherwise interact with us in connection with our custom software and product configurator services for European manufacturers.

We wrote this policy to comply with the EU General Data Protection Regulation (GDPR) and to reflect what European visitors reasonably expect from a company processing their data, even though Abhinav DCS itself is established in India.

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 | Phone: +91 93560 89589

EU Representative (Art. 27 GDPR)

Because we are not established in the EU but offer our services to, and monitor the behaviour of, individuals in the EU, GDPR requires us to name a representative established in the Union who EU data subjects and supervisory authorities can contact instead of, or as well as, us directly. This policy will be updated with the representative's name, postal address, and email as soon as the appointment is finalised.

Data Protection Officer

We have not appointed a statutory Data Protection Officer, as our processing activities do not meet the GDPR thresholds that require one (Art. 37 GDPR). Any privacy query can be sent to europe@abhinavdcs.com and will be handled by our management team.

2. What Personal Data We Collect

We collect the following categories of personal data:

• Contact & enquiry data — name, work email, phone number, company name, job title, country, and the content of your form or emails to us.
• Meeting booking data — name, email, time zone, selected time slot, and any notes you add when booking a call via our Calendly booking widget.
• Business & project data — details you choose to share about your product logic, quoting process, ERP/CRM systems, or sample quotes, including during NDA-covered discussions.
• Communications — records of emails, calls, and messages exchanged with us (including via WhatsApp, where you initiate contact that way).
• Technical & usage data — IP address, browser type and version, device type, pages visited, referring URL, and approximate location derived from IP, collected via server logs and any analytics tool in use.

We do not knowingly collect any special categories of data (e.g. health, religion, political opinions) through this Website, and we ask that you do not include such information in any form or message you send us.

3. Why We Process Your Data and Our Legal Basis

We process personal data for the following purposes and on the following legal bases under Art. 6(1) GDPR:

• Responding to enquiries you send via the contact form or email — necessary steps prior to entering into a contract, or responding to your request (Art. 6(1)(b)).
• Scheduling and conducting demo/discovery calls — pre-contractual steps at your request (Art. 6(1)(b)).
• Delivering and managing a project you engage us for (NDA, proposals, contracts, invoicing) — performance of a contract (Art. 6(1)(b)).
• Maintaining business records, running our business and communicating with prospective and existing clients — our legitimate interest (Art. 6(1)(f)), balanced against your rights.
• Website security, fraud prevention, and diagnosing technical issues — our legitimate interest in keeping the Website secure and functioning (Art. 6(1)(f)).
• Non-essential cookies, analytics, or marketing communications — your consent (Art. 6(1)(a)), which you can withdraw at any time.
• Complying with legal, tax, or regulatory obligations (e.g. contract and invoice retention) — compliance with a legal obligation (Art. 6(1)(c)).

We never sell your personal data, and we do not use it for automated decision-making or profiling that produces legal or similarly significant effects on you.

4. Who We Share Your Data With

We disclose personal data only where necessary, and always under appropriate safeguards:

• CSpace — hosting infrastructure for client systems and data. CSpace is headquartered in Tallinn, Estonia (EU) and operates its own EU dark fibre ring connecting Europe to India. For EU client engagements, data is hosted exclusively in CSpace's EU/EEA data centres (Tallinn, Amsterdam, Stockholm). CSpace also operates data centres in Dallas, USA and Mumbai, India as part of its wider global network; these are not used to host EU client data except where a specific client agreement provides for it.
• Calendly — meeting scheduling. Calendly, Inc. is based in the United States; where your data is transferred there, it is done under Calendly's Standard Contractual Clauses or equivalent safeguards.
• Google — for Google Meet (calls), the Google Maps embed on our contact page, and Google Analytics (see Section 8). Data collected via Google Analytics is processed by Google LLC in the United States under the EU-U.S. Data Privacy Framework and/or Standard Contractual Clauses.
• Email, communication, and IT infrastructure providers who support our day-to-day operations.
• Professional advisors (lawyers, accountants) where necessary.
• Public authorities or regulators, where we are legally required to disclose data (e.g. in response to a lawful request).
• A successor entity, in the unlikely event of a merger, acquisition, or restructuring of our business — subject to the same protections described here.

We do not share your personal data with third parties for their own marketing purposes.

5. International Data Transfers

Abhinav DCS is headquartered in India. Some personal data you provide to us (for example, via the contact form or email) may be accessible to our team in India for the purpose of responding to you and managing the relationship.

For EU client engagements, project data and hosted systems are pinned to CSpace's EU/EEA data centres (Tallinn, Estonia; Amsterdam, Netherlands; Stockholm, Sweden), and this hosting does not itself involve a transfer of personal data outside the EU/EEA.

Where personal data is otherwise transferred outside the EEA — including access by our team in India, or to sub-processors such as Calendly or Google in the United States — we rely on appropriate safeguards recognised under GDPR, in particular the European Commission's Standard Contractual Clauses (SCCs), supplemented as needed by additional technical and organisational measures. You can request a copy of the relevant safeguard by writing to europe@abhinavdcs.com.

6. How Long We Keep Your Data

We keep personal data only for as long as necessary for the purpose it was collected:

• Enquiries that do not lead to a project: up to 24 months from your last contact with us, so we can follow up and maintain accurate records, after which it is deleted or anonymised.
• Meeting booking data: retained for as long as it remains in our scheduling tool plus a reasonable period afterward, then deleted.
• Client and contract data: for the duration of the engagement plus any period required by applicable contractual, tax, or accounting obligations (commonly 6–10 years, depending on jurisdiction and document type).
• Website server logs: typically retained for a short period (e.g. up to 90 days) for security and diagnostic purposes, unless needed longer to investigate a specific incident.

Where we no longer need personal data for the purposes above, we delete or anonymise it.

7. Your Rights Under GDPR

If you are located in the EEA (or otherwise protected by GDPR), you have the right to:

• Access the personal data we hold about you and receive a copy of it.
• Rectify inaccurate or incomplete data.
• Erasure ("right to be forgotten") of your data, subject to certain exceptions.
• Restrict our processing of your data in certain circumstances.
• Data portability — receive your data in a structured, commonly used, machine-readable format, or have it transmitted to another controller, where technically feasible.
• Object to processing based on our legitimate interests, including profiling.
• Withdraw consent at any time, where processing is based on consent, without affecting the lawfulness of processing carried out before withdrawal.
• Lodge a complaint with a supervisory authority in your EU member state of residence, place of work, or place of the alleged infringement. A list of EU data protection authorities is available at: https://edpb.europa.eu/about-edpb/about-edpb/members_en

To exercise any of these rights, contact us at europe@abhinavdcs.com. We will respond within one month, as required by GDPR (extendable by a further two months for complex requests, in which case we will tell you why).

8. Cookies and Similar Technologies

Our Website uses cookies and similar technologies in the following categories:

• Strictly necessary cookies — required for the Website to work and to remember the choices you make about it: the language you selected, whether you chose the light or dark theme, and the record of this cookie choice itself. The consent record is stored under the name abhinav_cookie_consent, as a first-party cookie that expires after 12 months and in your browser’s local storage. It holds only whether you allowed analytics and the date you decided — no identifier, and nothing that is sent to a third party. These do not require consent under GDPR/ePrivacy rules and cannot be switched off through our cookie banner.
• Analytics cookies — Google Analytics. We use Google Analytics to understand how visitors use this Website (e.g. which pages are viewed, how long visitors stay, and which pages led to an enquiry), so we can improve it. Google Analytics sets cookies on your device and collects data including your (truncated/anonymised, where configured) IP address, device and browser information, and pages visited. This data is processed by Google LLC, and may be transferred to and processed in the United States under the EU-U.S. Data Privacy Framework and/or Standard Contractual Clauses as an appropriate safeguard. Google acts as our processor for this purpose; further detail is available in Google’s own privacy policy at https://policies.google.com/privacy.
• Legal basis: your consent (Art. 6(1)(a) GDPR), given via our cookie banner. Google Analytics is not merely inactive before you consent — it is not on the page at all. No Google script is requested and no analytics cookie is set until you choose “Accept all”, or switch Analytics on in the cookie preferences. We additionally send Google’s consent signal for analytics storage as denied by default and update it to granted only after your choice, and we send the advertising signals as denied at all times, because we run no advertising tags.
• Retention: analytics data is retained in accordance with our Google Analytics account settings (currently set to 14 months), after which it is automatically deleted by Google.
• Withdrawing consent: you can withdraw your consent at any time through the “Cookie preferences” link in the Website footer. Withdrawing takes effect immediately — we send Google a denial signal, delete the _ga and _gid cookies from your browser, and load no analytics script on any page you visit afterwards. You can also use a browser setting or extension that blocks Google Analytics, such as Google’s own opt-out add-on at https://tools.google.com/dlpage/gaoptout.
• Third-party embed cookies — a few pages embed content from other providers: the Calendly booking widget, Google Maps, and YouTube. These load only on the pages that carry them, and when they load they may set their own cookies, governed by those providers’ own cookie and privacy policies. They are not currently behind a separate switch in our cookie banner; if you would prefer they were not loaded, avoid those pages or block third-party cookies in your browser.
• No advertising or profiling cookies — we set none. We do not use cookies to build profiles, to retarget you elsewhere, or to share anything about you with an advertising network.

We ask for your consent through a cookie banner before any non-essential cookie is set, and you can change or withdraw that choice at any time through the “Cookie preferences” link in the Website footer. Declining is recorded in the same way as accepting, so you are not asked again on every page. You can also control or delete cookies through your browser settings.

9. Security

We use appropriate technical and organisational measures to protect personal data against unauthorised access, loss, misuse, or alteration, including hosting client systems and data with CSpace on EU/EEA-pinned infrastructure for EU clients under a signed Data Processing Agreement, restricted access controls, and encrypted transmission where applicable. No system is completely secure, but we work to keep your data appropriately protected and will notify affected individuals and the relevant supervisory authority of any personal data breach where required by law.

10. Children's Privacy

Our Website and services are directed at business professionals and are not intended for individuals under the age of 16. We do not knowingly collect personal data from children.

11. Changes to This Policy

We may update this Privacy Policy from time to time, for example to reflect changes in our practices or legal requirements. We will post the updated version on this page with a revised "Last updated" date. We encourage you to review this page periodically.

12. Contact Us

If you have questions about this Privacy Policy or how we handle your personal data, contact us at:

Abhinav DigiCompSoft Services Pvt. Ltd. Email: europe@abhinavdcs.com Phone: +91 93560 89589