Introduction & Details of Data Fiduciary
This Privacy Notice is issued in compliance with Section 5 of the Digital Personal Data Protection Act, 2023 (DPDP Act). It informs visitors and clients ("Data Principals") about how their digital personal data is collected, processed, stored, protected, and what rights they hold.
Data Fiduciary Information:
- Name / Practice: CS Manjunath S (Practicing Company Secretary)
- Membership: Institute of Company Secretaries of India (ICSI)
- Insolvency Registration: Registered Insolvency Professional (IBBI)
- Registered Office: #21/F4 1st Floor, Kalidasa Road, Jayalakshmi Puram, Mysore 570002, Karnataka, India
- Official Email: manjuacs87@gmail.com / csmanjunaths@gmail.com
- Telephone: +91 9964307595
Categories of Personal Data Collected
We believe in strict data minimization (Section 8(7)). We collect only the personal data strictly required to deliver our professional services:
| Data Category | Specific Data Points | Method of Collection | Statutory Purpose |
|---|---|---|---|
| Contact & Identification Data | Full Name, Mobile Number, Email Address, Business Name | WhatsApp Quick Enquiry Modal, direct WhatsApp chats, email, or telephone enquiries. | Responding to client inquiries, scheduling consultations, providing professional secretarial proposals. |
| Statutory Corporate Data | Director Identification Number (DIN), PAN, Corporate Identity Number (CIN), registered entity details | Directly provided by client during professional engagements. | Filing ROC forms, MCA event-based compliance, secretarial audits, IBC proceedings as mandated by Companies Act, 2013 and IBC, 2016. |
| Technical & Analytics Data | Anonymized IP address, device type, browser, pages visited, referral source | Google Analytics (GA4 - Consent Mode v2) & CounterAPI (only activated upon affirmative consent). | Website security, performance optimization, detecting errors, analyzing aggregate visitor traffic. |
Lawful Basis & Purposes for Processing
Under Section 4 of the DPDP Act, personal data is processed strictly under the following lawful grounds:
- Informed Consent (Section 6): You provide clear, unambiguous, affirmative consent when submitting an enquiry through our WhatsApp modal, contacting us via email, or accepting non-essential analytics cookies.
- Performance of Professional Engagement: Processing corporate documents to perform agreed secretarial, ROC, corporate legal, and IBC advisory services requested by you.
- Legal & Regulatory Obligations: Complying with statutory reporting requirements under the Companies Act, 2013, Insolvency and Bankruptcy Code, 2016, SEBI regulations, and ICSI Professional Code of Conduct.
Your Rights as a Data Principal
Under Chapter III of the DPDP Act, 2023, you hold comprehensive rights over your personal data:
1. Right to Access (Section 11)
You can request a summary of personal data being processed by us, identities of any third-party processors, and processing details.
2. Right to Correction & Erasure (Section 12)
You can request correction of inaccurate data, completion of incomplete data, updating of data, or erasure of personal data no longer necessary for the purpose it was collected.
3. Right to Withdraw Consent (Section 6(4))
You may withdraw your consent at any time as easily as it was given, with no impact on the legality of prior processing. You can adjust cookie preferences via the link in the footer.
4. Right of Grievance Redressal (Section 13)
You have the right to register grievances with our designated Grievance Officer regarding the processing of your personal data.
5. Right to Nominate (Section 14)
You may nominate an individual who, in the event of death or incapacity, will exercise your data principal rights.
Cookies & Digital Identifiers Policy
We implement Google Consent Mode v2 to ensure full privacy compliance:
- Essential Website Storage: Required for fundamental site functions, such as recording your cookie consent preferences. These cannot be disabled.
- Performance / Analytics Cookies (Google Analytics 4): Measures aggregate visitor volume, referral sources, and page interaction. These are set to DENIED by default and are only loaded if you click "Accept All" on our DPDP Consent Banner.
- Managing Preferences: You can review, modify, or revoke your cookie choices at any time using the Cookie & Privacy Settings button in the footer.
Data Retention & Security Safeguards
Under Section 8(4) and 8(7) of the DPDP Act:
- Security Safeguards: We employ industry-standard technical measures (HTTPS encryption, restricted access, secure devices) to prevent unauthorized access, alteration, or data breach.
- Retention Period: Enquiry details from prospective clients are retained only as long as necessary to answer your queries (typically up to 180 days). Formal client engagement records are maintained in accordance with statutory retention mandates under the Companies Act, 2013 (e.g. 8 years for secretarial registers).
Designated Grievance Officer & Complaints Mechanism
In accordance with Section 8(9) and Section 13 of the DPDP Act, 2023, the following officer has been designated to address questions, requests, or grievances regarding personal data processing:
CS Manjunath S
Designated Grievance Officer & Data Fiduciary
Office: #21/F4 1st Floor, Kalidasa Road, Jayalakshmi Puram, Mysore 570002, Karnataka
Email: manjuacs87@gmail.com / csmanjunaths@gmail.com
Phone: +91 9964307595
Turnaround Time: All grievances will be acknowledged within 48 hours and resolved within 30 days.
Complaint to the Data Protection Board of India (DPBI)
Under Section 13(3) and Section 18 of the DPDP Act, if you do not receive a resolution from our Grievance Officer within 30 days, or are dissatisfied with the response, you have the statutory right to file a complaint with the Data Protection Board of India (DPBI) via its designated digital portal or official mechanism as notified by the Government of India.