Privacy Policy

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.

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).

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).

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.

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.

Once the purpose has ceased and no retention obligation applies, we delete or anonymise the data.

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_en

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.

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.

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.

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.

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