Privacy notice: data collected, retention, and rights

Categories of personal data, in six lines

The editorial gateway processes personal data only for the editorial services it publishes. The processing is grounded in the Digital Personal Data Protection Act 2023 and the lawfulness basis the gateway publishes per category. The categories are account identifiers, contact details for readers who write in, device metadata for bot detection, aggregated analytics, marketing attribution, and support correspondence.

Three signals that gate every cookie

Before the editorial gateway sets a cookie, three signals are read: the cookie consent state from the consent record, the Global Privacy Control signal from the browser, and the implicit necessary-only mode when neither consent nor GPC is present. The three signals are checked on every page load.

Lawfulness basis, per category

The lawfulness basis for each category is published in the privacy table. Account data is processed under contract. Contact data is processed under consent. Device metadata is processed under legitimate interest. Analytics is processed under consent. Marketing is processed under consent. Support data is processed under consent.

What each lawfulness basis covers

Article 6(1)(b) GDPR (contract) covers account data: the reader has signed a contract by creating an account, and the editor needs the account data to operate the account. Article 6(1)(a) GDPR (consent) covers analytics, marketing, and support correspondence: the reader can withdraw consent at any time, and withdrawal triggers a purge within 7 days. Article 6(1)(f) GDPR (legitimate interest) covers device metadata: the editor has a legitimate interest in detecting bots and abusive traffic.

Retention windows, published in full

Account data is retained for 18 months after account closure to handle late disputes and to comply with the operator's published records window. Analytics is retained for 13 months in aggregated form. Marketing is retained for 30 days to bind the click attribution window. Support correspondence is retained for 24 months to handle delayed escalation. The retention windows are enforced through an automated purge job that runs monthly.

How the retention windows are enforced

The retention windows are enforced through an automated purge job that runs monthly. The job identifies records that have exceeded the retention window, exports the records for legal hold if any, and purges the records from the live tables. The audit log records every purge cycle with the row count and the timestamp.

Reader rights under the DPDP Act 2023

Readers have the right of access (a copy of the personal data the gateway holds), the right of correction (a correction of inaccurate data), the right of erasure (a deletion of data when the purpose is fulfilled), and the right to nominate (a nomination of another individual to exercise the rights on the reader's behalf). Rights are exercised through the privacy channel. The privacy desk responds within 30 days for full data requests.

How the DPDP rights flow works

A reader who exercises the right of access receives a copy of all personal data the editorial gateway holds within 30 days. A reader who exercises the right of correction receives a confirmation of the correction within 7 days. A reader who exercises the right of erasure receives a confirmation of the erasure within 7 days. A reader who nominates another individual receives a confirmation of the nomination within 7 days.

Published values, in one table

Categories of personal data processed by the editorial gateway

Where data is processed

Data is processed in India by the editorial gateway. Data may be processed outside India by analytics and marketing providers under a Data Processing Agreement with standard contractual clauses. The list of sub-processors is published on the privacy page. The editorial gateway requires sub-processors to honour the same retention windows the gateway publishes.

The sub-processor list

The editorial gateway publishes a sub-processor list on the privacy page. The list names every sub-processor, the data shared with the sub-processor, and the data-processing region. A reader who wants to opt out of a sub-processor category can use the contact channel; the editor will honour the opt-out within 7 days.

Children's data

The editorial gateway does not knowingly collect personal data from readers under the age of 18. The editorial gateway does not target children. The cookies the gateway sets are configured so that operators under 18 do not trigger analytics or marketing tracking. Where a parent or guardian believes the gateway has collected data on a child, the privacy desk will erase the data within 7 days of receipt of the request.

The children's data rule in detail

The editorial gateway does not target children. The cookies the gateway sets are configured so that operators under 18 do not trigger analytics or marketing tracking. A parent or guardian who believes the gateway has collected data on a child can use the privacy channel; the privacy desk will erase the data within 7 days of receipt of the request.

Editorial accountability and the DPDP rights

The privacy desk operates the DPDP Act 2023 rights requests on behalf of the editorial gateway. The accountability is logged: every request, the date, the right exercised, and the date of the response. The privacy desk responds within 7 days for cookie-specific requests and within 30 days for full data requests. A reader who wants to verify the accountability can navigate to the editorial log and find the case reference for the request.

How the editorial gateway runs the privacy audit

The editorial gateway runs the privacy audit on a quarterly cadence. The audit checks every category, every lawfulness basis, every retention window, and every reader right. The audit produces a published report that lists every category, every basis, every window, and every right. The audit report is published on the editorial responsibility page; the report carries the date of the audit and the date of the next audit. The audit report is the binding rule. A discrepancy between the audit report and the privacy notice triggers an update on the next refresh; the update is logged in the editorial log. A reader who wants to verify the privacy notice against the audit report can navigate to the editorial responsibility page.