Privacy Policy
In short
- This website doesn’t use cookies, analytics or tracking pixels, and it doesn’t load anything from other companies’ servers.
- We only receive personal data when you contact us or become a client.
- We use it to reply, to do the work you hire us for and to keep the records the law requires. We don’t sell it or use it for advertising.
- You can ask to see, correct or delete your data at any time by writing to contact@troiken.com.
1. Who we are
Troiken is a brand name used by Darshan, a sole proprietor based in Chennai, Tamil Nadu, India (“Troiken”, “we”, “us”). We decide why and how your personal data is used. That makes us the data fiduciary under India’s Digital Personal Data Protection Act, 2023 (DPDP Act), and the controller under the EU and UK General Data Protection Regulation (GDPR).
- contact@troiken.com
- Phone
- +91 95662 02542
- Location
- Chennai, Tamil Nadu, India
2. What this website collects
- No cookies, analytics or tracking. The site doesn’t set cookies or use any tracking technology. See the Cookie Policy.
- No third-party requests. All files, including fonts, are served from troiken.com, so visiting doesn’t send your details to font services, advertising networks or social media companies.
- The “Tell us about your business” chat sends us your answers, only when you press Send. Nothing is sent while you’re answering. When you send, your answers go to our web host, Hostinger, which emails them to us; they aren’t saved in a database on the website. You can see exactly what’s sent in section 3. If you choose “Use my email app instead”, your own email app sends it.
- The five-question quiz doesn’t send anything. It works out its suggestions in your browser. If you then open the chat, your quiz results come with you and are sent only if you press Send.
- Spam protection. To stop automated spam, the website counts how many messages are sent from each connection and from each email address or WhatsApp number. It doesn’t store your IP address, email address or number for this: it keeps scrambled codes that can’t be turned back into them. The code for your connection changes every day and is deleted within two hours; the code for your email address or number is deleted within 25 hours.
- Server logs. Like every website, ours is delivered by a hosting provider that records standard technical logs: IP address, browser type, the page requested, the referring page and the time. These are used to deliver the site and protect it from attacks. We don’t use them to identify visitors or build profiles.
3. When you contact or work with us
| What | Why | Legal basis |
|---|---|---|
| What you send through the chat: your name; your email address, your WhatsApp number or both; if you give it, your website or Instagram link; your answers about your business, the help you want, what matters most to you and your ad budget; and anything else you write. Or your phone number and messages if you call or message us | To reply to your enquiry, and to prepare a free audit or proposal if you ask for one | India: your consent, or data you have given us voluntarily for this purpose (DPDP Act, sections 6 and 7(a)). EU and UK: steps you ask us to take before a contract, and our legitimate interest in replying (GDPR Article 6(1)(b) and (f)) |
| Information about your business and marketing that you share for an audit | To review it and give you recommendations | As above |
| Contact, billing and payment details of clients | To deliver our services, send invoices and receive payment | Our agreement with you, and our obligations under tax and accounting law |
| Access to your ad accounts, analytics, CRM or messaging tools | To do the work you have hired us for | Our agreement with you. See section 4 |
We only ask for what we need. Please don’t send passwords, payment card details or other sensitive information by email or through the chat. If we need access to your accounts, we’ll ask you to grant it through the platform’s own access tools.
4. Data we handle for clients
When we run campaigns, chat automations or CRMs for a client, we may handle personal data about that client’s customers, such as leads, messages and contact details. In that work we act on the client’s instructions, as their data processor, and the client’s own privacy policy applies to those people.
We use that data only for the client’s work, keep it confidential, and return or delete it when the work ends, unless the law requires us to keep it. If you are a customer of one of our clients, please contact that business first. We will help them respond to you.
5. Who we share data with
We don’t sell personal data, and we don’t share it with advertisers. We share it only with:
- service providers that help us run the business, such as our email, file storage, phone and messaging providers and our web host, Hostinger, which also delivers the chat’s messages to us. They may use it only to provide their service to us;
- Facebook, Instagram (both run by Meta) or LinkedIn, if you choose to contact us through them. Their own privacy policies apply to what you send there;
- professional advisers, such as accountants and lawyers, who must keep it confidential;
- courts, regulators or other authorities, when the law requires it.
6. Where your data is stored
We are based in India, so your data is processed in India. Some of our service providers store data in other countries. India doesn’t currently have an adequacy decision from the European Commission or the UK government. If you are in the EU or UK and the law requires safeguards for these transfers, we use providers that offer them, such as standard contractual clauses.
7. How long we keep it
- Enquiries that don’t lead to work: up to 12 months after our last message, then deleted.
- Client records: for the length of our work together, then for as long as Indian tax and accounting law requires (currently up to eight years), then deleted.
- Server logs: for the period set by our hosting provider.
- Spam-protection codes (see section 2): deleted within two hours (connection) or 25 hours (email address or number).
If you ask us to delete your data sooner, we will, unless the law requires us to keep it.
8. Your rights
Wherever you are, you can ask us to:
- tell you what personal data we hold about you, how we use it and who we have shared it with;
- correct, complete or update it;
- delete it;
- stop using it where we rely on your consent. This doesn’t affect anything we did before you withdrew it;
- let someone you nominate exercise these rights for you if you die or become unable to (DPDP Act, section 14).
In India, once you have used our grievance process (section 9), you can also complain to the Data Protection Board of India.
In the EU or UK, you also have the right to restrict or object to how we use your data, to receive it in a portable format, and to complain to your data protection authority. In the UK, that’s the Information Commissioner’s Office.
To use any of these rights, email contact@troiken.com. We may ask you to confirm your identity. We will respond within one month.
9. Grievance officer
If you have a concern about how we handle your data, contact our grievance officer:
- Name
- Darshan
- contact@troiken.com
- Phone
- +91 95662 02542
We will respond within 48 hours of receiving your message, and resolve it within one month at most.
10. Security
We protect personal data with reasonable safeguards, such as limiting access to the people who need it and securing the accounts we use. This website is served over an encrypted (HTTPS) connection. No way of storing or sending data is perfectly secure. If a breach affects your personal data, we will tell you, and the authorities, where the law requires it.
11. Children
Our services are for businesses. We don’t knowingly collect personal data from anyone under 18. If you think a child has sent us personal data, contact us and we will delete it.
12. Cookies and Do Not Track
This website doesn’t use cookies or tracking technologies. Because we don’t track you, Do Not Track and Global Privacy Control signals don’t change how the site behaves. Details are in the Cookie Policy.
13. Other websites
This site links to Facebook, Instagram and LinkedIn. Those links are plain links: nothing from those services is embedded here. Once you follow one, that service’s privacy policy applies.
14. Changes to this policy
When this policy changes, we update this page and the date at the top. If we start collecting data in a new way, such as adding analytics, we will update this policy first, and ask for your consent where the law requires it.