Privacy Policy

Effective Date: [November 20, 2025]

This Privacy Policy explains how Avenirtek Digital Private Limited (“Avenirtek”, “we”, “our”, or “us”) collects, uses, stores, shares, and protects your personal data when you use our websites, mobile applications, digital platforms, or other services (together, the “Services”). By using our Services or sharing your information with us, you agree to this Privacy Policy and any supplementary notices we provide.

1. Scope and Application

This Privacy Policy applies to all individuals (“you”, “your”) who visit Avenirtek websites, use our products or Services, or interact with us in any manner—whether as customers, content partners, artists, vendors, contractors, or website visitors. This Policy does not apply to third-party websites, links, or applications not owned or controlled by Avenirtek. Where our Services link to third parties, their privacy terms govern their handling of your data.

2. Categories of Personal Data We Collect

We may collect and process the following categories of personal data (as defined under the Digital Personal Data Protection Act, 2023 (“DPDP Act”)):

1. Identification and Contact Information: name, postal address, email address, phone number, or other contact details.
2. Account and Transaction Data: usernames, passwords, order details, invoices, billing details, and limited payment information processed via secure third-party gateways (we do not store full payment instrument details).
3. Usage and Device Information: IP address, device identifiers, browser type, operating system, session data, log files, analytics, cookies, and similar technologies.
4. Marketing and Preference Data: communication preferences, interests, demographic information (where provided), and opt-in/opt-out choices.
5. Media and Submissions: audio, images, videos, artwork, metadata, liner notes, track information, and related content provided by artists or customers for digital distribution, production, monetization, or marketing.
6. Other Data: social media profile information (when you link or authorize), survey responses, feedback, support tickets, and information from publicly available sources.

Sensitive personal data (such as financial credentials, health data, or biometric identifiers) will be collected only where strictly necessary for a specific Service and only with explicit consent or as otherwise permitted by law.

3. How We Collect Personal Data

We collect personal data:

• Directly from you (e.g., account creation, service registration, uploads, purchases, support queries, or surveys).
• Automatically through your use of the Services (e.g., cookies, SDKs, analytics, device logs).
• From third parties where you have authorized sharing (e.g., social media integrations, distribution partners, payment processors) or from publicly available sources consistent with law.
• Through business collaborations, channel partners, and marketing or distribution programs.

4. Purposes of Processing

We use personal data for the following purposes:

• To provide and operate the Services, including account setup, order processing, artist content ingestion, distribution, and technical support.
• To communicate with you regarding transactions, updates, security alerts, policy changes, or marketing (where permitted).
• To manage digital distribution, publishing, monetization, rights management, and reporting to relevant platforms or partners.
• To personalize and improve the Services, perform analytics, debug issues, and enhance user experience.
• To prevent, detect, and investigate fraud, abuse, security incidents, and violations of our terms.
• To comply with applicable legal obligations, respond to lawful requests, and enforce our agreements. Where processing is based on consent, you may withdraw consent at any time using the methods described in Section 10 or by contacting us (see Section 13). Withdrawal will not affect prior processing already performed.

5. Legal Bases for Processing

We process personal data under one or more of the following legal bases:

• Consent: you have given consent for specific purposes.
• Contractual Necessity: processing is necessary to perform a contract with you or to take steps at your request before entering a contract.
• Legal Obligation: processing is necessary to comply with applicable laws, regulatory requirements, or lawful requests.
• Legitimate Interests: processing is necessary for our legitimate interests in operating, securing, and improving the Services, preventing fraud, and supporting business operations, provided these interests are not overridden by your rights and expectations.

6. Cookies and Similar Technologies

We use cookies, pixels, SDKs, and similar technologies for authentication, remembering preferences, analytics, performance measurement, and marketing (where permitted). You can manage cookie settings via your browser and, where available, our cookie banner or preference centre. Disabling certain cookies may affect Service functionality.

7. Information Sharing and Disclosure

We may share personal data in accordance with law and only as necessary:

• Intra-Group: with our subsidiaries, affiliates, and group companies for purposes consistent with this Policy.
• Service Providers: with trusted vendors for hosting, cloud services, analytics, customer support, payment processing, email/SMS delivery, fraud prevention, and security.
• Business Partners: in connection with distribution, publishing, royalty reporting, marketing collaborations, or co-branded initiatives (where you have consented, if required).
• Legal and Compliance: to comply with applicable laws, lawful requests, governmental or regulatory inquiries, to enforce our terms, protect our rights, security, users, or the public, or to prevent fraud or security incidents.
• Corporate Transactions: in connection with mergers, acquisitions, reorganizations, financing, or sale of assets, subject to appropriate safeguards and continued protection of your data. We do not sell or rent personal data to unaffiliated third parties.

8. Cross-Border Data Transfers

Some data may be processed or stored outside India. Where cross-border transfers occur, we implement adequate safeguards consistent with the DPDP Act and applicable rules, which may include contractual measures, certifications, or other legally recognized mechanisms. We will ensure that recipients provide a level of protection comparable to that under Indian law.

9. Data Security

We maintain technical and organizational measures designed to protect personal data against unauthorized access, alteration, disclosure, or destruction, including encryption in transit and at rest (where applicable), access controls, network security, secure development practices, and vendor due diligence. Despite these measures, no system is completely secure. You are responsible for maintaining strong passwords, enabling multi-factor authentication where available, and using secure networks.

10. Your Rights (Data Principal Rights)

Subject to the DPDP Act and applicable law, you may have the right to:

• Access your personal data and request a summary of processing.
• Correct or update inaccurate or incomplete personal data.
• Withdraw consent for processing based on consent.
• Request erasure of personal data no longer necessary for the stated purposes or where consent is withdrawn (subject to legal retention).
• Restrict or object to certain processing, including direct marketing.
• Request information about the processing and sharing of your personal data, including categories of third parties with whom data is shared.

You (or an authorized representative) may submit requests using the process in Section 14 or by contacting us at legal@avenirtek.in. We may request additional information to verify your identity and authority before acting on a request. If we decline a request as permitted by law (e.g., to protect the rights of others or comply with legal obligations), we will provide our reasons unless restricted by law.

11. Children’s Data

Our Services are not directed to individuals under the age of 18. We do not knowingly collect personal data from minors without the consent of a parent or legal guardian when required by law. If you believe a minor has provided personal data without appropriate consent, please contact us and we will take appropriate steps to delete or secure such data.

12. Data Retention

We retain personal data for as long as reasonably necessary to fulfil the purposes described in this Policy, to comply with legal or regulatory obligations, to resolve disputes, and to enforce our agreements. When data is no longer needed, we will delete or anonymize it in a secure manner, subject to backup and archival limitations and applicable retention laws.

13. Contact Information

Legal Department
Avenirtek Digital Private Limited
Registered Office: Door No. 3/747, Kuttippadam – Nedumthodu Road, Allapra PO, Kuttippadam Jn, Perumbavoor, Ernakulam, Kerala – 683556, India
Email: legal@avenirtek.in

14. Grievance Redressal and Data Principal Rights

In accordance with the DPDP Act, Avenirtek acknowledges your rights as a Data Principal and is committed to resolving privacy-related grievances promptly and transparently.

How to Raise a Grievance or Data Request
You may contact our Legal Department at legal@avenirtek.in with:

• Your full name and contact details.
• A clear description of your request or grievance.
• Any supporting documents or information.
• Proof of identity (and proof of authorization if acting on behalf of a Data Principal).

Acknowledgement and Resolution

• We will acknowledge your grievance or request within seven (7) days of receipt.
• We will aim to resolve your grievance or fulfill your request within thirty (30) days from the date of acknowledgement. If additional time is needed, we will inform you of the reasons and provide an estimated timeline.

Escalation
If your grievance is not resolved to your satisfaction, you may escalate the matter to the Data Protection Board of India in accordance with the DPDP Act and applicable rules.

15. Third-Party Services and Links

Our Services may include links to third-party sites or integrations with third-party platforms. We are not responsible for the privacy practices of such third parties. We encourage you to review their privacy policies before providing personal data.

16. Automated Decision-Making

We do not use solely automated decision-making that produces legal or similarly significant effects without appropriate human oversight. Where automated processing is used (e.g., fraud detection, content matching, or recommendations), we implement safeguards and allow you to contact us for clarification or to contest outcomes where required by law.

17. Changes to This Policy

We may update this Privacy Policy from time to time. The updated version and effective date will be posted on our website. Material changes will be notified via the Services or by email where feasible. Your continued use of the Services after the effective date signifies acceptance of the updated Policy.

18. Jurisdiction and Governing Law

This Privacy Policy is governed by the laws of India. Disputes will be subject to the exclusive jurisdiction of the courts at [Ernakulam, Kerala or other preferred forum], without prejudice to rights and remedies available under the DPDP Act and applicable rules.

19. Definitions

• “Personal data” means any data about an individual who is identifiable by or in relation to such data, consistent with the DPDP Act.
• “Processing” includes collection, storage, use, disclosure, or any operation performed on personal data.
• “Data Principal” means the individual to whom the personal data relates.
• “Data Fiduciary” means any person who, alone or in conjunction with others, determines the purpose and means of processing personal data.

Questions About This Privacy Policy

If you have questions or concerns regarding this Privacy Policy, please contact us:

• Avenirtek Digital Private Limited
  Door No. 3/747, Kuttippadam – Nedumthodu Road, Allapra PO, Kuttippadam Jn,
  Perumbavoor, Ernakulam, Kerala – 683556, India
• Email: legal@avenirtek.in
• For grievance redressal or Data Principal rights under the DPDP Act, please refer to Section 14 of this Policy.