Privacy Notice

1. Who we are and how to contact us

For the personal data described in this notice, Shlokcent Technologies Private Limited is the Data Fiduciary (the "controller" under the GDPR and UK GDPR).

Privacy contact, for questions about this notice and for requests to exercise your rights: info@cybersoldiers.in.

Grievance Officer: Saurabh Agrawal, email info@cybersoldiers.in, telephone +91 78143 21156, Paras Hermitage, Hoshangabad Road, Bhopal, Madhya Pradesh 462026, India.

Technical support questions go to support@cybersoldiers.in. Please send privacy requests to the privacy contact or the Grievance Officer so that they are recorded and tracked.

2. Personal data we collect

We collect only what is needed for the purposes in Section 3.

• Data you give us: your name, work email address, telephone number, organisation, role, the content of your message and the page or form it came from, when you fill in a contact, demonstration, partnership or download form, or when you write to us.
• Correspondence: the emails and messages we exchange with you, and notes of calls and meetings with you.
• Technical data collected automatically: IP address, browser and device type, operating system, the pages visited, the time of visits and the page that referred you. This is held in our hosting and server logs.
• Analytics data: if you allow analytics cookies, Google Analytics records how you use the website (pages viewed, approximate location, interactions such as scrolling and outbound clicks). See Section 5 and our Cookie Policy.
• Your cookie choice: a record of the preference you set in our cookie banner, kept in your browser.

We do not ask for, and ask you not to send us through the website, payment card details, government identity numbers, health data or other sensitive personal data.

3. Why we use it, and our legal basis

For processing governed by Indian law, we rely on your consent under section 6 of the Digital Personal Data Protection Act, 2023 (the "DPDP Act"), or on a legitimate use under section 7, in particular section 7(a), where you voluntarily give us your details for a stated purpose. Until the relevant provisions of that Act are in force, we also act in line with the Information Technology Act, 2000 and the rules made under it. Where the GDPR, UK GDPR or Swiss law applies, the bases are those named below.

• Responding to enquiries, demonstration requests and partnership requests, and keeping a record of them. India: section 7(a). GDPR: steps taken at your request before a contract (Article 6(1)(b)) or our legitimate interest in responding to enquiries from organisations (Article 6(1)(f)).
• Sending you information about our services that you have not asked for as part of an enquiry. India: your consent. GDPR: your consent (Article 6(1)(a)) or, where the law of your country permits business-to-business communications, our legitimate interest in informing business contacts (Article 6(1)(f)). Every such message has a way to stop receiving it.
• Keeping the website secure and working, including detecting misuse. India: section 7(a) and reasonable security practices. GDPR: our legitimate interest in the security of the website (Article 6(1)(f)).
• Understanding how the website is used so that we can improve it, through Google Analytics, only if you allow analytics cookies. India: your consent. GDPR: your consent (Article 6(1)(a)).
• Complying with law and with lawful requests of public authorities, and establishing, exercising or defending legal claims. India: sections 7(d) and 7(e) and section 17 where it applies. GDPR: legal obligation or our legitimate interest in complying with the laws that apply to us (Articles 6(1)(c) and 6(1)(f)).

We do not sell personal data. We do not use personal data from the website for advertising or for profiling. If we want to use your data for a purpose not described here, we will give you a fresh notice and, where the law requires it, ask for your consent first.

4. Consent and withdrawing it

Where we rely on consent, it is given by a clear action, such as ticking a box on a form or choosing "Accept all" or saving your choices in the cookie banner. You may withdraw it at any time, as easily as you gave it.

• Cookies: use "Cookie settings" in the footer of any page and switch analytics off, or choose "Reject all".
• Marketing messages: use the unsubscribe link in the message, or write to info@cybersoldiers.in.
• Anything else: write to info@cybersoldiers.in from the address you used.

Withdrawal does not affect processing that took place before it. We will stop the processing the consent related to, within a reasonable time, unless the law requires or allows us to continue.

5. Cookies and analytics

The website uses cookies only as set out in our Cookie Policy. Strictly necessary storage is used without consent. Analytics cookies are off until you allow them, and you can change your choice at any time. We do not use advertising cookies.

We use Google Analytics, a service of Google LLC, to measure use of the website. Google acts as our service provider for this purpose. If you decline analytics, no analytics script is loaded.

6. Who we share personal data with

We share personal data only where needed for the purposes above:

• Cloud hosting providers, such as Microsoft Azure and Amazon Web Services: hosting of the website and of the systems that receive form submissions.
• Microsoft 365 and Google Workspace: email, so that we can receive and answer your messages.
• Google (Google Analytics): analytics data, only if you allow analytics cookies.
• Professional advisers such as lawyers, chartered accountants and auditors, under duties of confidentiality.
• Courts, regulators, CERT-IN, the Data Protection Board of India and law enforcement agencies, where we are required by law or a lawful order.
• A successor entity, if our business or part of it is transferred, which will be bound to protect your data no less than this notice does.

We bind each service provider by written contract to process personal data only on our instructions and to protect it.

7. Transfers outside India

Some of the providers above process data outside India, for example Google for analytics and Microsoft or Google for email. Under section 16 of the DPDP Act, personal data may be transferred outside India except to a country or territory the Central Government has restricted. We do not transfer personal data to any such restricted territory.

Where the GDPR, UK GDPR or Swiss law applies to a transfer to a country without an adequacy decision, we rely on the standard contractual clauses adopted by the European Commission (and the UK Addendum where relevant), or another mechanism that those laws recognise. You may ask us for a copy of the relevant safeguards at info@cybersoldiers.in.

8. How long we keep personal data

We keep personal data only as long as needed for the purpose it was collected for, or longer only where a law requires it. After that we erase it or make it anonymous.

• Enquiries, demonstration requests and correspondence: for as long as needed to respond and to maintain the resulting commercial relationship, and afterwards for no longer than the applicable limitation period.
• Marketing contact details: until you withdraw consent, after which we keep only a record of the withdrawal so that it is respected.
• Website server logs: for a limited period, and for at least 180 days where the CERT-IN Directions of 28 April 2022 require it, kept within Indian jurisdiction.
• Analytics data: for the limited period set in our Google Analytics account.
• Records of rights requests and grievances: for the period within which a related claim may be brought.

9. Security

We take reasonable security safeguards to protect personal data, including encryption in transit, access limited to authorised people, and logging. No method of transmission or storage is completely secure. If a personal data breach affects you, we will tell you and the authorities as the law requires, including reporting cyber security incidents to CERT-IN within six hours of noticing them.

10. Your rights

Your rights depend on the law that applies to you.

• India (DPDP Act, as it comes into force): to obtain a summary of the personal data we process and the other parties we have shared it with; to correction, completion, updating and erasure; to grievance redressal; to nominate another person to exercise your rights if you die or are unable to; and to withdraw consent.
• European Economic Area, United Kingdom and Switzerland: access, rectification, erasure, restriction, portability, objection (including to direct marketing), withdrawal of consent, and the right to complain to your supervisory authority. We do not make decisions about you based solely on automated processing.
• California: to know, delete and correct personal information, and not to be discriminated against for exercising these rights. We do not sell or share personal information for cross-context behavioural advertising.
• United Arab Emirates and other places: the rights your local law gives you, which we will honour as that law requires.

To exercise a right, write to info@cybersoldiers.in from the email address you used with us, saying what you want. We verify your identity before acting, and we do not charge a fee unless the law allows one for manifestly excessive requests. We respond within 30 days (and in any case as the applicable law requires).

Under section 15 of the DPDP Act you must give only verifiably authentic information, must not impersonate anyone, and must not make false or frivolous complaints.

11. Grievances and complaints

If you have a grievance about our processing of your personal data, contact the Grievance Officer (Saurabh Agrawal, info@cybersoldiers.in, +91 78143 21156). We acknowledge within 24 hours and resolve within 30 days of receipt.

If you are not satisfied, you may complain to the Data Protection Board of India, once that mechanism is in force and after you have used the process above. You may also complain to a supervisory authority in your country, such as the Information Commissioner's Office in the United Kingdom.

12. Children

The website is intended for organisations and their staff. It is not directed at anyone under 18, and we do not knowingly collect personal data from children. If you believe a child has given us personal data, write to info@cybersoldiers.in and we will erase it.

13. Changes to this notice

We may update this notice as the law, the website or our processing changes. We publish the updated version on this page with a new version number and effective date. Where a change needs your consent, we will ask for it before the change applies to you.

14. Governing law

This notice is governed by the laws of India, without prejudice to any mandatory rights you have under the data protection law of the place where you are located.