Privacy Policy
Last updated 6 September 2026 · Varnan Digital (OPC) Private Limited · CIN U62090KL2025OPC096808
This policy explains what personal data Varnan Digital (OPC) Private Limited collects, why we collect it, who we share it with, and the control you have over it. It covers this website, our marketing and sales activity, and the services we deliver to clients.
The short version. We collect what you give us on a form or in a conversation, plus basic analytics if you allow it. We do not sell personal data and we never have. Analytics, advertising and embedded third-party features stay switched off until you turn them on. You can ask us for a copy of your data, or ask us to delete it, at [email protected].
1. Who we are
Varnan Digital (OPC) Private Limited is a digital marketing and AI services company incorporated in India on 1 September 2025.
- Legal entity: Varnan Digital (OPC) Private Limited
- Corporate Identity Number: U62090KL2025OPC096808
- Registered office: 446, Kaivalliam, Vakkom, Chirayinkeezhu, Thiruvananthapuram, Kerala 695308, India
- Contact for privacy matters: [email protected]
For the personal data described in this policy, Varnan is the data fiduciary under India’s Digital Personal Data Protection Act, 2023, and the data controller under the UK and EU General Data Protection Regulation where that law applies. When we process personal data on behalf of a client as part of a paid engagement, we act as a data processor instead. Those arrangements are governed by our Data Processing Addendum.
2. Who this policy is about
We hold personal data about four groups of people:
- Website visitors — anyone who loads a page on varnandigital.com.
- Enquirers and prospects — people who submit a form, book a call, reply to outreach, or otherwise start a conversation with us.
- Clients and their staff — the people we work with day to day at companies that engage us.
- Our client’s own contacts — leads, customers and audiences whose data passes through campaigns and systems we run. We handle that data as a processor, on our client’s instructions.
3. What we collect and why
| Category | What it includes | Why we hold it | Lawful basis |
|---|---|---|---|
| Enquiry details | Name, work email, phone number, company website, the bottleneck you selected, your message, the page you submitted from, and the date and time. | To reply to you, assess fit, and prepare a proposal. | Consent, and our legitimate interest in responding to a business enquiry. Under the DPDP Act, the consent you give when submitting the form. |
| Scheduling data | Name, email, chosen time slot, time zone and any answers you give when booking, held in Calendly and Google Calendar. | To hold a strategy call at a time that works for you. | Consent, and performance of steps taken at your request before entering a contract. |
| Meeting records | Call recordings, transcripts and AI-generated summaries produced by Fireflies.ai for calls we host. | To capture what was agreed without taking notes during the call. | Consent. Recording is announced at the start of the call and you may ask us to stop or delete it. |
| Client relationship data | Contact details of your team, contracts, briefs, project tasks, invoices and payment records. | To deliver the services and meet our tax, accounting and company-law obligations. | Performance of a contract, and legal obligation. |
| Site analytics | Pages viewed, referring source, approximate location derived from IP, device and browser type, and interaction events. Microsoft Clarity additionally records anonymised session replays and heatmaps. | To understand which content works and where the site fails people. | Consent only. Nothing is collected unless you switch Analytics on. |
| Advertising data | Ad interaction and conversion signals from Google AdSense and ad platform tags. | To measure advertising and, where enabled, show relevant ads. | Consent only. Off by default. |
| Server and security logs | IP address, request URL, user agent, timestamps and blocked-request records held by our host, Cloudflare and Wordfence. | To keep the site online and to detect and block attacks. | Legitimate interest in the security and availability of our systems. These are strictly necessary and cannot be switched off. |
| Outreach data | Business contact details sourced from public professional profiles, company websites and directories, plus a record of what we sent and how you replied. | To contact businesses that fit our service profile. | Legitimate interest in business-to-business marketing, subject to the safeguards in our Communications Policy. |
We do not knowingly collect sensitive categories of data such as health, biometric, financial account, caste, religion or political data, and you should not send them to us. We do not knowingly collect data from children under 18. If you believe a child has given us personal data, write to us and we will delete it.
4. What we do not do
- We do not sell personal data, and we do not share it with data brokers.
- We do not load analytics, advertising or third-party embeds before you consent.
- We do not use your personal data or your company’s confidential material to train third-party AI models. See our AI Usage Policy.
- We do not make decisions producing legal or similarly significant effects about you by automated means alone.
5. Cookies and tracking
varnandigital.com uses a consent gate. Until you make a choice, only strictly necessary cookies are set, and the code for Google Analytics, Google AdSense, Microsoft Clarity, Calendly and Sign in with Google is prevented from executing at all. Choosing Reject all keeps it that way and clears the non-essential cookies we can reach from your browser.
The full inventory of cookies, their purpose and their lifetime is in the Cookie Policy. You can change your choice at any time using the Cookie preferences link in the footer.
Our web fonts are served from our own domain, not from a third-party font service, so no data is sent to a font provider when you load a page.
6. Who we share data with
We share personal data with service providers who process it on our instructions, and only as far as they need it. Every provider we currently use, what it receives and where it processes data is listed in the Third-Party Policy. In summary, they fall into these groups:
- Infrastructure — website hosting, Cloudflare for DNS and content delivery, and Wordfence for security filtering.
- Communication and productivity — Google Workspace, Calendly, ClickUp, Notion, Fireflies.ai and WhatsApp Business.
- Measurement — Google Analytics 4, Google Search Console, Microsoft Clarity and Microsoft Bing Webmaster Tools, subject to your consent.
- Advertising platforms — Google Ads, Meta, LinkedIn and Microsoft Advertising, used to run campaigns for clients.
- AI providers — Anthropic, and where a client chooses it, OpenAI. Both are used under API terms that do not permit training on our inputs.
We also disclose data where we are legally required to, to our professional advisers under a duty of confidence, and to a buyer or successor if the business is ever sold. We will tell clients before any such transfer takes effect.
7. Where your data goes
Our website is hosted on infrastructure located in India. Several of the providers above are based outside India and will process data in the United States, the European Union and other countries. Where personal data protected by UK or EU law is transferred outside those regions, we rely on the provider’s Standard Contractual Clauses or an adequacy decision. Under the DPDP Act, we transfer personal data outside India only to countries not restricted by the Central Government.
8. How long we keep it
| Data | Retention |
|---|---|
| Enquiries that do not become clients | 24 months from last contact, then deleted. |
| Client records and correspondence | Duration of the engagement plus 3 years. |
| Contracts, invoices and tax records | 8 years, as required by Indian company and tax law. |
| Call recordings and transcripts | 12 months, or sooner on request. |
| Analytics data | Held by the provider under its own retention setting: up to 14 months in Google Analytics 4, and 30 days for Microsoft Clarity session recordings. |
| Server and security logs | Up to 12 months. |
| Your cookie choice | 180 days, after which we ask again. |
9. Your rights
Whatever law applies to you, we will honour these requests:
- Access — a copy of the personal data we hold about you and a summary of how it is processed.
- Correction — fix anything inaccurate, incomplete or out of date.
- Erasure — delete your data where we have no lasting legal reason to keep it.
- Withdraw consent — as easily as you gave it, including your cookie choice and consent to be contacted.
- Object or restrict — stop or pause processing based on legitimate interests, including direct marketing, which we will always stop on request.
- Portability — receive your data in a structured, machine-readable format.
- Nominate — under the DPDP Act, nominate someone to exercise these rights if you die or become incapacitated.
Write to [email protected] with the subject line “Data request”. We reply within 30 days and do not charge for a reasonable request. We may ask you to confirm your identity before releasing data.
10. Grievance officer and complaints
Our Grievance Officer under the DPDP Act is Amal Jandheer, Director, reachable at [email protected]. If you are not satisfied with our response, you may complain to the Data Protection Board of India. If you are in the UK or EU, you may complain to your national supervisory authority, such as the Information Commissioner’s Office in the UK.
11. How we protect data
The site runs over HTTPS with Cloudflare in front of the origin server. Administrative access uses strong, unique credentials and multi-factor authentication where the platform supports it. Form submissions are validated and checked with a nonce to block automated abuse, and the Wordfence firewall filters malicious traffic. Access to client data is limited to the people working on that engagement. No system is perfectly secure, and if a breach affects your personal data we will notify you and the relevant regulator as the law requires.
12. Changes to this policy
We review this policy at least once a year and whenever we add or remove a service provider. Material changes are announced on this page with a new “last updated” date, and where the change affects how we use your data we will ask for fresh consent rather than assume it.
Contact us about privacy
Varnan Digital (OPC) Private Limited
446, Kaivalliam, Vakkom, Chirayinkeezhu, Thiruvananthapuram, Kerala 695308, India
[email protected]
More legal documents
Legal centre · Privacy Policy · Cookie Policy · Consent Policy · Website Forms Policy · Third-Party Policy · Data Processing Addendum · Terms of Service · Acceptable Use Policy · Disclaimer · Accessibility Statement · Client Service Terms · Refund and Cancellation · AI Usage Policy · Communications Policy