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COMPLIANCE DIRECTIVE
DPDP / GDPR / CCPALast Updated: September 2026

Privacy Policy

LEGAL COMPLIANCE NOTICE // 14 PENDING STATUTORY PLACEHOLDERS

This document is a governance draft structured under the DPDP Act 2023 (India), EU/UK GDPR, and US CCPA/CPRA frameworks. In compliance with internal engineering safety rules, unresolved statutory fields are highlighted explicitly in amber badges below. They must be reviewed and populated with registered corporate records prior to formal legal filing.

1. Who this policy covers

This Privacy Policy explains how [AxonVortex Legal Entity Name] (“AxonVortex,” “we,” “us,” “our”), a company registered in India (CIN: [Your CIN], registered office: [Your registered address]), collects, uses, shares and protects personal data when:

  • You visit axonvortex.com (or its current domain) or any linked page;
  • You submit a contact form, request a Growth Audit, or otherwise enquire about our services;
  • You subscribe to updates or content from us;
  • You become a client, and we handle data on your behalf or on behalf of your business.

This policy applies regardless of where you're located. Because AxonVortex works with clients and visitors outside India, we've written this to meet India's Digital Personal Data Protection Act, 2023 (DPDP Act), the EU/UK General Data Protection Regulation (GDPR), and, where relevant, the California Consumer Privacy Act (CCPA/CPRA) — the three most likely regimes to apply to our visitors and clients. Where these laws differ, we generally apply whichever gives you stronger protection.

2. What data we collect

Information you give us directly

WhereWhat we collect
Contact / Growth Audit formName, business name, email address, phone number, website URL, and anything you tell us in the message field
Email or direct enquiryWhatever you choose to share with us
Becoming a clientBusiness information, billing details, access credentials to ad accounts/social accounts/website (where you grant them), and any content, data, or materials you provide for us to work with

Information collected automatically

SourceWhat it collectsWhy we use it
Google AnalyticsIP address (truncated where possible), device/browser type, pages visited, time on site, referring site, approximate location (city/country level)Understand how visitors use the site and improve it
Meta Pixel / Google Ads remarketing tagsDevice identifiers, browsing behaviour on our site, cookie-based identifiersMeasure ad performance and show relevant ads to past visitors on Meta and Google's networks
CookiesAs described in Section 4 belowSite functionality, analytics, and advertising

Information from our email marketing tool

If you subscribe to updates (via [Mailchimp/your email tool] or a similar provider), we collect your email address and, depending on the tool's settings, engagement data such as opens and clicks, so we can send relevant content and stop emailing you if you unsubscribe.

We do not knowingly collect sensitive personal data (health, financial account numbers, government IDs, etc.) through the website. If you send us sensitive information unprompted, we'll handle it with the same security measures described in Section 8, but we ask that you avoid sharing anything you don't need to.

3. Why we use your data (legal basis)

Depending on where you're located, we rely on one or more of the following:

  • Consent — for cookies, tracking pixels, and email marketing, where required. You can withdraw consent at any time (see Sections 4 and 9).
  • Contract necessity — to respond to your enquiry, deliver a service you've requested, or fulfil a client agreement.
  • Legitimate interest — to understand and improve how our site performs, and to communicate with prospective clients who've enquired, balanced against your right to privacy.
  • Legal obligation — where we're required to retain or disclose data (e.g. billing/tax records).

Under the DPDP Act, we act as a Data Fiduciary for the personal data we collect, and process it only for the purpose for which you provided it, based on your consent or another ground recognised under the Act.

4. Cookies and tracking

Our site uses cookies and similar technologies in three categories:

  • Strictly necessary — required for the site to function (e.g. remembering your cookie preference). These don't require consent.
  • Analytics — Google Analytics, to understand site usage. Requires your consent in the EU/UK and under DPDP where the data can identify you.
  • Advertising — Meta Pixel and Google Ads remarketing, to measure and target ads. Requires your consent in the EU/UK and under DPDP.
Interactive Cookie Controls: You can manage or revoke your consent preferences at any time by opening our .

5. Who we share data with

We don't sell your personal data. We share it only with:

  • Service providers who process it on our behalf, currently: Google (Analytics, Ads), Meta (Pixel/Ads), [Mailchimp/your email tool], [Vercel or your hosting provider], and [any CRM/portal tool you use once your portal is live]. Each is bound by its own data processing terms with us.
  • Professional advisors (accountants, lawyers) where necessary to run our business.
  • Law enforcement or regulators, only where legally required.
  • A successor business, if AxonVortex is ever sold or restructured — you'd be notified.

We do not share client business data (ad accounts, analytics, content) with anyone outside the specific tools needed to deliver the agreed service, without your permission.

6. International data transfers

AxonVortex is based in India. If you're contacting us or working with us from outside India, your data will be transferred to and processed in India, and possibly in other countries where our service providers operate (e.g. the US, where Google and Meta process data).

  • Under the DPDP Act, India permits cross-border transfer of personal data to any country except those the Indian government specifically restricts by notification. As of this writing, no such restricted list has been issued.
  • Under GDPR, transferring personal data from the EU/UK to India requires an approved safeguard — we rely on Standard Contractual Clauses (SCCs) with our processors, and apply the same data-handling standards to EU/UK personal data regardless of where it's processed.
  • Under CCPA, California residents' data is protected regardless of where it's processed, per the rights in Section 9.

7. How long we keep data

  • Enquiries that don't become clients: up to 24 months from your last contact, then deleted, unless you ask us to delete it sooner.
  • Client data: for the duration of our engagement, plus [X years — check your local requirement; India generally requires financial records for 8 years] to meet tax, accounting and legal obligations.
  • Analytics data: per Google Analytics' default retention settings, or as configured to the shortest practical period.
  • Marketing list data: until you unsubscribe or ask us to delete it.

8. How we protect your data

We take reasonable technical and organisational measures to protect personal data, including restricting access to data on a need-to-know basis, using reputable, security-vetted third-party providers (Google, Meta, Mailchimp, Vercel, etc.), and using encrypted connections (HTTPS) for the site and forms. As a small, single-operator business, we don't claim enterprise-grade certifications (e.g. ISO 27001, SOC 2) — if a prospective client requires those for their own compliance, please raise it during scoping so we can be upfront about what we can and can't meet.

If a data breach occurs that's likely to affect you, we'll notify affected individuals and, where legally required, the Data Protection Board of India and/or relevant supervisory authorities, without undue delay.

9. Your rights

If you're in India (under the DPDP Act), you have the right to:
  • Obtain a summary of the personal data we hold about you and how it's processed
  • Request correction, completion, or updating of your personal data
  • Request erasure of your personal data (unless we need to keep it for a legal purpose)
  • Withdraw consent at any time, as easily as you gave it
  • Nominate another individual to exercise these rights on your behalf in the event of death or incapacity
  • Register a grievance with us, and escalate to the Data Protection Board of India if unresolved
If you're in the EU/UK (under GDPR), you additionally have the right to:
  • Access a copy of your data
  • Restrict or object to certain processing
  • Receive your data in a portable format
  • Lodge a complaint with your local data protection authority
If you're a California resident (under CCPA/CPRA), you have the right to:
  • Know what personal data we've collected and why
  • Delete your personal data
  • Opt out of the “sale” or “sharing” of personal data for cross-context behavioural advertising
  • Not be discriminated against for exercising these rights

To exercise any of these rights, email [grievance/privacy email — e.g. privacy@axonvortex.com] or info@axonvortex.com. We will respond within 30 days.

10. Grievance Officer

In accordance with the DPDP Act 2023, our Grievance Officer details are:

NAME:[Grievance Officer Name]
EMAIL:[grievance email] / info@axonvortex.com
REGISTERED ADDRESS:[registered address]

If you have a concern about how your data has been handled, contact the Grievance Officer first. If it isn't resolved to your satisfaction, you may escalate the matter to the Data Protection Board of India.

11. Children's privacy

AxonVortex's services and website are directed at businesses and business decision-makers, not individuals under 18. We don't knowingly collect personal data from anyone under 18. If you believe a minor has provided us data, contact us and we'll delete it.

12. Changes to this policy

We may update this policy as our tools, services, or the law change. We'll update the “Last updated” date above, and for material changes, we'll make a reasonable effort to flag it on the site.

13. Contact us

[AxonVortex Legal Entity Name][Registered Address]