Legal · Privacy
Privacy policy
What we collect about the people who visit this site, the agencies we work for and the businesses we email, and how each of you stays in control.
- Effective
- Version
- 1.0
- Applies to
- Website visitors, clients, and businesses we contact
The short version
- 01We run email outreach for agencies. If a business replies with interest, we pass its contact details and reply to the agency that hired us. That is the service.
- 02Website analytics only run if you say yes. No ads, and we never sell website or client data.
- 03Every outreach email can be stopped with one reply, and a stop is permanent.
- 04Ask us to see, fix or delete your data and you'll get an answer within 30 days.
A summary to help you find your way. The numbered sections below are the full version.
01Who we are
Global Digital Projects (“GDP”, “we”, “us”) is a sole proprietorship registered in India (Udyam UDYAM-UP-58-0083342) at 555, Street No. 19, Laddhawala, Muzaffarnagar, Uttar Pradesh 251002, India. We write and send cold email outreach for SEO and web design agencies, and deliver the local businesses that reply with interest to those agencies as leads.
We decide why and how the personal data in this policy is used, so we are its “data controller” under the EU and UK GDPR and its “data fiduciary” under India's Digital Personal Data Protection Act, 2023 (DPDP Act). For anything about your data, write to our grievance officer, Mohd Asif, at asif@globaldigitalprojects.com.
02Whose data this covers
Three groups of people, and we treat each differently:
- Visitors to globaldigitalprojects.com.
- Clients and enquirers: agency owners and staff who ask about, order or pay for leads.
- Businesses we contact during outreach, and the people who work at them.
03What we collect, why, and on what basis
Where the GDPR applies, each use needs a lawful basis. We list it so you can see why we think we're allowed to do each thing.
| Group | What we collect | Why | Lawful basis |
|---|---|---|---|
| Visitors | IP address, browser and device type, pages requested and the time, in our host's server logs. | To serve the site and keep it secure. | Legitimate interests |
| Visitors who allow analytics | The site or campaign you came from, pages and sections viewed, how far you scroll, which contact buttons you press, rough location from your IP, and (in Microsoft Clarity) replays of clicks and scrolling with typed text hidden. | To learn which pages help agencies decide, and fix the ones that don't. | Consent, which you can withdraw at any time |
| Clients and enquirers | Name, business name, email, phone or WhatsApp number, messages and call notes, your ideal client profile, orders, invoices and payment confirmations. | To answer you, quote, deliver leads, bill and keep records. | Contract (or steps before one), legal obligation for tax records, legitimate interests for service updates |
| People who download our swipe file | Your email address, your agency's website, the page you signed up on and the time. We get an email alert for each one, sent through our email host. | To take you to the download and follow up about leads for your agency. Ask us to stop or delete them at any time. | Consent, given when you send the form |
| Businesses we contact | Business name, contact person's name, business email and phone, website, city, country and industry. If you reply: your reply and its date. | To send a small number of relevant business emails for our agency clients, and pass on the replies that show interest. | Legitimate interests (business-to-business outreach) |
Personal data by group
- Group
- Visitors
- What we collect
- IP address, browser and device type, pages requested and the time, in our host's server logs.
- Why
- To serve the site and keep it secure.
- Lawful basis
- Legitimate interests
- Group
- Visitors who allow analytics
- What we collect
- The site or campaign you came from, pages and sections viewed, how far you scroll, which contact buttons you press, rough location from your IP, and (in Microsoft Clarity) replays of clicks and scrolling with typed text hidden.
- Why
- To learn which pages help agencies decide, and fix the ones that don't.
- Lawful basis
- Consent, which you can withdraw at any time
- Group
- Clients and enquirers
- What we collect
- Name, business name, email, phone or WhatsApp number, messages and call notes, your ideal client profile, orders, invoices and payment confirmations.
- Why
- To answer you, quote, deliver leads, bill and keep records.
- Lawful basis
- Contract (or steps before one), legal obligation for tax records, legitimate interests for service updates
- Group
- People who download our swipe file
- What we collect
- Your email address, your agency's website, the page you signed up on and the time. We get an email alert for each one, sent through our email host.
- Why
- To take you to the download and follow up about leads for your agency. Ask us to stop or delete them at any time.
- Lawful basis
- Consent, given when you send the form
- Group
- Businesses we contact
- What we collect
- Business name, contact person's name, business email and phone, website, city, country and industry. If you reply: your reply and its date.
- Why
- To send a small number of relevant business emails for our agency clients, and pass on the replies that show interest.
- Lawful basis
- Legitimate interests (business-to-business outreach)
We never ask for, and don't want, sensitive data such as health, religion or financial account details. We don't make automated decisions about people that have legal or similar effects.
04If we emailed your business
We find local businesses that could use an agency's services, using publicly available business sources such as company websites, online business directories and map listings. We only collect business contact details, not home addresses or personal social profiles.
What happens when you reply
- You ask for a price, details or a call: we pass your name, business, email, phone, website, country and your reply to one agency client that sells that service, so they can answer you. From then on that agency is responsible for how it uses your details.
- You say no, or ask us to stop: we add your email address to our do-not-contact list and don't email you again, for any client.
- You don't reply: your details are not passed to anyone.
06WhatsApp, email and calls
When you message us on WhatsApp, WhatsApp (Meta) carries the message under its own terms and privacy policy. We use your number and messages to reply, send quotes, delivery notices and payment details, and we may manage these conversations through the WhatsApp Business Platform.
- We only send you marketing messages on WhatsApp if you have agreed to receive them from Global Digital Projects.
- Reply STOP at any time and we won't send further marketing messages.
- Booking a call through Calendly shares the details you enter there with us.
08International transfers
We work from India, our clients are mostly in the United States, Canada, the United Kingdom and Australia, and our providers store data in several countries. Where the GDPR or UK GDPR applies to a transfer, we rely on the European Commission's standard contractual clauses (with the UK addendum) or another safeguard the law allows. Indian law permits transfers except to countries the Government of India restricts.
09How long we keep it
| Data | Kept for | Why that long |
|---|---|---|
| Server and security logs | At least 1 year | Security, and Indian rules on keeping logs |
| Google Analytics data | 14 months | Year-on-year comparisons |
| Clarity recordings and heatmaps | Recordings about 30 days, heatmaps up to 13 months | Clarity's own limits |
| Enquiries that didn't become orders | 12 months after last contact | In case you come back |
| Client records | While we work together, plus 3 years | Questions and disputes |
| Invoices and payment records | As Indian tax law requires, generally 8 years | Legal obligation |
| Outreach contact data | Up to 24 months after the last email | Campaigns for the same market |
| Delivered lead records | 3 years | Replacements, and never delivering the same lead twice |
| Do-not-contact list | Kept indefinitely, email address only | So a stop stays a stop |
Retention
- Data
- Server and security logs
- Kept for
- At least 1 year
- Why that long
- Security, and Indian rules on keeping logs
- Data
- Google Analytics data
- Kept for
- 14 months
- Why that long
- Year-on-year comparisons
- Data
- Clarity recordings and heatmaps
- Kept for
- Recordings about 30 days, heatmaps up to 13 months
- Why that long
- Clarity's own limits
- Data
- Enquiries that didn't become orders
- Kept for
- 12 months after last contact
- Why that long
- In case you come back
- Data
- Client records
- Kept for
- While we work together, plus 3 years
- Why that long
- Questions and disputes
- Data
- Invoices and payment records
- Kept for
- As Indian tax law requires, generally 8 years
- Why that long
- Legal obligation
- Data
- Outreach contact data
- Kept for
- Up to 24 months after the last email
- Why that long
- Campaigns for the same market
- Data
- Delivered lead records
- Kept for
- 3 years
- Why that long
- Replacements, and never delivering the same lead twice
- Data
- Do-not-contact list
- Kept for
- Kept indefinitely, email address only
- Why that long
- So a stop stays a stop
After that, we delete the data or strip it of anything that identifies a person.
10How we protect it
The site runs over HTTPS, access to lead and client data is limited to the people who need it, and we follow reasonable security practices as Indian law requires. If a breach affects your data, we'll tell you and the regulators where the law requires, including the Data Protection Board of India and, under the GDPR, the supervisory authority within 72 hours.
11Your rights
Depending on where you live, you can ask us to:
- tell you what personal data we hold about you and who we've shared it with;
- correct, complete or update it;
- delete it;
- withdraw a consent you gave, which is as easy as giving it;
- stop using it for outreach or direct marketing (always honoured), or object to other uses;
- limit how we use it, or send it to you or someone else in a portable format (GDPR);
- act through someone you nominate if you die or can't act yourself (DPDP Act).
Start on your privacy choices page or email asif@globaldigitalprojects.com. It's free. We may ask you to confirm who you are, and we answer within 30 days.
12Extra rights for US residents
California and several other US states give residents the right to know, delete and correct personal information, to opt out of its sale or sharing, and not to be treated differently for using these rights. You can also act through an authorised agent.
In the last 12 months we collected identifiers (name, email, phone), professional information (business, role), your reply to our emails, commercial information from orders, and, with consent, internet activity on this site. Passing an interested business's details to an agency client for a fee can count as a “sale” under some state laws. To opt out, use Do not sell or share my personal information.
13Children
Our service is for businesses. We don't knowingly collect data about anyone under 18. If you think we have, tell us and we'll delete it.
14Grievance officer and complaints
- Grievance officer
- Mohd Asif
- Founder and Grievance Officer
- Contact
- asif@globaldigitalprojects.com
- +91 6396 535 600 · 555, Street No. 19, Laddhawala, Muzaffarnagar, Uttar Pradesh 251002, India
We acknowledge complaints promptly and resolve them within 30 days. If you're not satisfied, you can go to the Data Protection Board of India once you've used our process, the UK Information Commissioner's Office, the data protection authority where you live in the EU, or your state attorney general in the US.
15Changes to this policy
When we change this policy we update the date and version at the top. If a change affects how we use your data in a meaningful way, we'll tell clients by email or WhatsApp before it takes effect. Questions go to sales@globaldigitalprojects.com.