1. Who we are
TODO for counsel
Identify the data controller — Pro Lifeset Overseas Pvt Ltd, CIN U52291PB2024PTC060508, registered office SCO 06, Bhupindra Road, Patiala. Grievance officer name/contact.
2. What personal data we collect
TODO for counsel
Name, email, phone, address, date of birth, country of interest, academic records, passport scans, financial proofs, visa refusal letters, CAIPS/GCMS notes. Source (submitted by client, collected via lead form, uploaded to portal).
3. Why we collect it (purposes)
TODO for counsel
To provide visa consultancy services; to submit visa applications on the client's behalf; to comply with PTA licence record-keeping obligations; to communicate case status via WhatsApp/SMS/email.
4. Legal basis (DPDP Act 2023 alignment)
TODO for counsel
Consent; necessary for performance of contract; legitimate interests. Map each purpose to a DPDP Act lawful basis.
5. Who we share it with
TODO for counsel
Visa posts (Canadian High Commission, etc.) via official channels; WhatsApp/Meta (MSG91), Resend, Razorpay, Supabase, Vercel, Sentry. Each needs a data processor agreement.
6. Retention
TODO for counsel
Case records retained for X years per PTA licence conditions and Indian tax records. Client has right to request deletion where legally permitted.
7. Rights of the data principal
TODO for counsel
Access, correction, erasure, grievance redressal, nomination (DPDP Act 2023). Process for exercising each right.
8. Children's data
TODO for counsel
We do not knowingly collect personal data from persons under 18 without a parent or guardian's consent (dependent visa applicants).
9. International transfers
TODO for counsel
Supabase (Singapore), Vercel (global), Resend (US), Sentry (US). Justify transfer mechanism under DPDP Act.
10. Security
TODO for counsel
Encryption at rest (Supabase), in transit (TLS), access controls (RLS + role-based), passwords (OTP/magic link, no shared passwords), secret key rotation policy.
11. Cookies & analytics
TODO for counsel
Session cookies (Supabase auth), analytics cookies (GA4, Microsoft Clarity, Vercel Analytics). Cookie consent banner scope and opt-out mechanism.
12. Grievance officer
TODO for counsel
Name, email, address, response time SLA (DPDP Act requires response within 30 days).
13. Updates to this policy
TODO for counsel
Effective date; how changes are communicated to existing clients.