GROWTH PAGE AGENCY

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Privacy Policy

Last Updated: January 1, 2026

Effective Date: January 1, 2026

Data Fiduciary: Growth Page Agency (A unit of Adhikary Group)

Location: Jalpaiguri, West Bengal, India

1. INTRODUCTION

1.1. Purpose

Growth Page Agency (“We,” “Us,” “Our,” or the “Agency”), a unit of Adhikary Group, is committed to protecting the privacy and security of your personal data. This Privacy Policy (“Policy”) outlines how we collect, use, process, store, share, and protect information obtained from our clients, website visitors, and users (“You,” “Your,” or the “Data Principal”) through our website (www.growthpageagency.com) and our digital marketing services.

1.2. Legal Compliance

This Policy is drafted in compliance with the laws of India, including but not limited to:

  • The Digital Personal Data Protection Act, 2023 (DPDPA).
  • The Information Technology Act, 2000 (as amended).
  • The Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (“IT Rules”).
  • The Consumer Protection Act, 2019 (E-Commerce Rules).

1.3. Consent

By accessing our website, engaging our services (including SEO, Social Media Management, Paid Ads, Website Development, etc.), or voluntarily providing your information, you explicitly consent to the collection, processing, and storage of your data as described in this Policy.

1.4. Definitions

  • “Personal Data”: Any data about an individual who is identifiable by or in relation to such data (e.g., name, email address).
  • “Data Fiduciary”: Any person who alone or in conjunction with other persons determines the purpose and means of processing of personal data (here, Growth Page Agency).
  • “Data Principal”: The individual to whom the personal data relates.

2. INFORMATION WE COLLECT

We practice Data Minimization, meaning we only collect information that is strictly necessary for the delivery of our services and business operations.

2.1. Information You Provide Directly

We collect information when you fill out contact forms, sign service agreements, subscribe to newsletters, or communicate with us via email/WhatsApp. This includes:

  • Identity Data: Name, username, or similar identifier.
  • Contact Data: Billing address, delivery address, email address, and telephone numbers.
  • Business Data: Company name, job title, website URL, branding assets, and marketing goals.
  • Financial Data: Bank account or payment card details (processed securely via third-party payment gateways; we do not store raw credit card numbers).

2.2. Automatically Collected Information

When you interact with our website, we may automatically collect technical data using cookies and similar technologies:

  • Technical Data: Internet Protocol (IP) address, browser type and version, time zone setting, browser plug-in types, operating system, and platform.
  • Usage Data: Information about how you use our website, services, and which pages you visit.

2.3. Sensitive Personal Data

We generally do not collect “Sensitive Personal Data” (as defined under IT Rules, 2011, such as health data, biometric information, or caste) unless strictly required for a specific campaign or legal compliance. If such collection is necessary, we will obtain your explicit, written consent prior to collection.

2.4. Information from Third Parties

We may receive data about you from third parties, such as:

  • Social Media Platforms: If you interact with our ads on Facebook, Instagram, or LinkedIn.
  • Analytics Providers: Aggregated data from Google Analytics.
  • Public Sources: Information available in the public domain (e.g., your business website or LinkedIn profile).

3. HOW WE USE YOUR INFORMATION

We process your Personal Data only for lawful purposes (“Lawful Uses”) as defined under the DPDPA.

3.1. Purpose of Processing

We use your data to:

  • Service Delivery: Create, manage, and optimize digital marketing campaigns (SEO, PPC, Social Media) tailored to your business.
  • Communication: Respond to your inquiries, send proposals, invoices, and project updates.
  • Contractual Obligations: Fulfill our obligations under the Service Agreement signed with you.
  • Marketing: Send you newsletters, case studies, or offers related to our services (only with your consent, which you can withdraw at any time).
  • Legal Compliance: Comply with tax laws (GST filing), legal processes, or government requests.
  • Analytics: Improve our website functionality and user experience.

3.2. Lawful Bases

  • Consent: Where you have given clear consent for us to process your personal data for a specific purpose.
  • Legitimate Uses: For the performance of a contract to which you are a party or taking steps at your request before entering into a contract.
  • Legal Obligation: Where processing is necessary for compliance with a legal obligation (e.g., maintaining financial records for tax authorities).

4. SHARING AND DISCLOSURE OF INFORMATION

Growth Page Agency is not in the business of selling your data. We only share information when necessary to provide our services or when required by law.

4.1. Third-Party Service Providers (Data Processors)

We may share data with trusted third-party service providers who assist us in operating our business. These providers are bound by Data Processing Agreements to ensure confidentiality and security. They include:

  • Cloud Hosting: (e.g., AWS, Google Cloud, Hostinger) to host our website and client data.
  • Marketing Tools: (e.g., Mailchimp, HubSpot, Meta Business Suite, Google Ads) to run campaigns.
  • Analytics: (e.g., Google Analytics) to understand website traffic.
  • Payment Processors: (e.g., Razorpay, Stripe) to process payments securely.

4.2. Business Transfers

If Adhikary Group or Growth Page Agency is involved in a merger, acquisition, or sale of assets, your personal data may be transferred as part of that business asset. We will notify you via email and/or a prominent notice on our website of any change in ownership.

4.3. Legal Requirements

We may disclose your information if required to do so by law or in the good-faith belief that such action is necessary to:

  • Comply with a legal obligation, court order, or government request.
  • Protect and defend the rights or property of Growth Page Agency.
  • Prevent or investigate possible wrongdoing in connection with the Services.

5. DATA SECURITY AND RETENTION

5.1. Security Practices

We implement reasonable security practices and procedures as mandated by the IT Rules, 2011 and the DPDPA to protect your data from unauthorized access, loss, misuse, or alteration. These measures include:

  • Encryption: Using Secure Socket Layer (SSL) technology for data transmission.
  • Access Control: Restricting access to personal data to employees, agents, and contractors who have a strict “need to know.”
  • Regular Audits: Conducting periodic reviews of our data collection and storage practices.

5.2. Data Breach Notification

In the unlikely event of a personal data breach that poses a risk to your rights, we will notify the Data Protection Board of India and the affected Data Principals (You) within the timeline prescribed by the DPDPA or relevant regulations (typically without undue delay).

5.3. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

  • Client Records: Retained for 5-7 years after the end of the contract for tax and audit purposes.
  • Marketing Data: Retained until you withdraw consent (unsubscribe).
  • Anonymization: Upon expiration of the retention period, your data will be securely deleted or anonymized so that it can no longer be associated with you.

6. YOUR RIGHTS AND CHOICES

Under the Digital Personal Data Protection Act, 2023, you have specific rights regarding your personal data.

6.1. Right to Access and Information

You have the right to ask for a summary of the personal data we are processing and the identities of all other Data Fiduciaries and Data Processors with whom we have shared your data.

6.2. Right to Correction and Erasure

You have the right to request correction of inaccurate or misleading personal data, completion of incomplete data, and updating of your data. You also have the right to request the erasure of your personal data unless retention is necessary for a legal purpose.

6.3. Right to Withdraw Consent

Where we rely on your consent to process your data (e.g., marketing emails), you have the right to withdraw that consent at any time. You can do this by clicking the “unsubscribe” link in our emails or contacting us directly.

6.4. Right to Grievance Redressal

You have the right to have readily available means of grievance redressal. If you are unsatisfied with our response, you may approach the Data Protection Board of India.

6.5. Right to Nominate

You have the right to nominate any other individual who shall, in the event of your death or incapacity, exercise your rights under the DPDPA.

To exercise any of these rights, please contact our Data Protection Officer at support@growthpageagency.com. We will respond to legitimate requests within 30 days.

7. COOKIES AND TRACKING TECHNOLOGIES

7.1. What Are Cookies?

Cookies are small text files placed on your device to store data that can be recalled by a web server in the domain that placed the cookie.

7.2. How We Use Cookies

  • Essential Cookies: Necessary for the website to function (e.g., secure login).
  • Analytics Cookies: To help us understand how visitors interact with our website (e.g., Google Analytics).
  • Advertising Cookies: To show you relevant ads on third-party sites (e.g., Facebook Pixel, Google Ads Remarketing).

7.3. Managing Cookies

When you visit our website, you will be presented with a Cookie Banner allowing you to accept or reject non-essential cookies. You can also control cookies through your browser settings. Please note that disabling cookies may affect the functionality of our website.

8. INTERNATIONAL DATA TRANSFERS

While our primary operations are in India, we may use service providers (e.g., cloud servers) located outside India.

  • We ensure that any transfer of personal data to countries outside India complies with the restrictions imposed by the Government of India under the DPDPA.
  • We only transfer data to countries that offer a similar level of data protection or where we have put in place appropriate safeguards, such as standard contractual clauses.

9. CHILDREN’S PRIVACY

Our Services are not directed to individuals under the age of 18. We do not knowingly collect personal data from children. If we become aware that a child has provided us with personal data without verifiable parental consent, we will take steps to delete such information.

10. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements.

  • Notification: We will notify you of any material changes by posting the new Privacy Policy on this page and updating the “Last Updated” date. For significant changes, we may notify you via email.
  • Continued Use: Your continued use of the Service after the effective date of the revised Policy constitutes your acceptance of the terms.

11. GOVERNING LAW AND DISPUTE RESOLUTION

11.1. Jurisdiction

This Privacy Policy shall be governed by and construed in accordance with the laws of India. The courts in Jalpaiguri, West Bengal shall have exclusive jurisdiction over any disputes arising out of or relating to this Policy.

11.2. Dispute Resolution

Any dispute arising out of this Policy shall initially be attempted to be resolved amicably through the Grievance Redressal mechanism. If unresolved, the dispute may be referred to arbitration in accordance with the Arbitration and Conciliation Act, 1996, with the venue in Jalpaiguri.

12. CONTACT INFORMATION

If you have any questions about this Privacy Policy, or if you wish to exercise your rights or file a grievance, please contact our Data Protection Officer (DPO):

GROWTH PAGE AGENCY

(A unit of Adhikary Group)

Attention: Data Protection Officer

Address: Vivekananda Para, Jalpaiguri, 735101, West Bengal, India.

Email: support@growthpageagency.com

Phone: +91 62959 78290

Disclaimer: This document is provided as a template for informational purposes. While drafted to be compliant with current Indian laws (DPDPA 2023), it does not constitute legal advice. We strongly recommend having this policy reviewed by a qualified legal professional in India to ensure it meets your specific business requirements and any subsequent rules notified by the Government of India.