Compliant with the IT Act 2000, IT (Amendment) Rules 2011, and the Digital Personal Data Protection Act 2023 (DPDP Act).
1. Data Controller Identity
AdBaBa (Palm Technologies Private Limited) is the data fiduciary as defined under the Digital Personal Data Protection Act 2023. We determine the purpose and means of processing your personal data.
For any data-related queries: legal@adbaba.in
Data Protection Officer: Sunil Punamchand Anecha · privacy@adbaba.in · +91-9422086166
2. What Data We Collect
A. From Advertisers
- Full name, company name, email address, phone number
- GST number and billing address
- Payment information — processed by our payment gateway; we do not store card or bank credentials
- Advertisement creatives uploaded to the Platform
- Campaign history, booking records, and usage logs
B. From Screen Owners
- Name, company name, email address, phone number
- GST number and registered business address
- Screen location data, pricing inputs, and availability settings
- Bank account details for payout processing (stored with AES-256 encryption)
- Device IDs for SYNC-capable screens and associated technical data
C. From Political Campaign Accounts
- Party registration number issued by the Election Commission of India
- Candidate identification documents (Aadhaar / PAN / Voter ID as applicable)
- Authorized signatory details and declaration
- All campaign data, creative files, and playback logs — retained for a minimum of 7 years for ECI compliance
D. Automatically Collected Data
- IP address, browser type and version, device type and operating system
- Pages visited, time spent on pages, links clicked
- Session data and authentication tokens
- Cookie data (see Section 8)
3. How We Use Your Data
- Delivering advertising campaign services booked on the Platform
- Processing payments, issuing GST-compliant invoices, and managing refunds
- Calculating and distributing Screen Owner payouts
- Sending transactional communications (booking confirmations, receipts, campaign reports)
- Operating the SYNC Engine and delivering synchronized campaign signals to enrolled screens
- Improving Platform services, the pricing engine, and the fairness rotation algorithm
- Complying with legal obligations including ECI reporting requirements for political campaigns
- Detecting and preventing fraud, abuse, and security threats
- Responding to legal process, court orders, or government authority requests
4. Data Sharing
We share your personal data only in the following circumstances:
- Payment gateway providers (Razorpay / PayU): for secure payment processing. They are bound by their own privacy policies and PCI-DSS compliance obligations.
- Screen Owners: we share only the campaign creative file and scheduled play time. Advertiser identity is never disclosed to Screen Owners.
- Government authorities: when required by a court order, statutory obligation, or valid request from a law enforcement authority or the Election Commission of India.
- Professional advisors: lawyers, auditors, and accountants bound by confidentiality obligations.
We do not:
- Sell, rent, or trade personal data to any third party for commercial purposes
- Disclose Advertiser identity to Screen Owners
- Disclose Screen Owner pricing to Advertisers
- Use ad creatives for any purpose other than delivering the booked campaign
5. Data Retention
| Data Category | Retention Period | Basis |
|---|---|---|
| Advertiser campaign data | 3 years from campaign completion | Business records |
| Political campaign data | 7 years minimum | ECI compliance requirement |
| Payment and invoice records | 8 years | Income Tax Act 1961 |
| Account data | Duration of account + 1 year after closure | Dispute resolution |
| Server and access logs | 90 days | Security monitoring |
6. Your Rights Under the DPDP Act 2023
As a data principal under the Digital Personal Data Protection Act 2023, you have the following rights:
- Right to Access: obtain a summary of your personal data held by AdBaBa and the purposes for which it is being processed.
- Right to Correction: request correction of inaccurate or incomplete personal data.
- Right to Erasure: request deletion of your personal data, subject to legal retention requirements.
- Right to Withdraw Consent: withdraw consent for non-essential data processing at any time. Withdrawal does not affect the lawfulness of processing prior to withdrawal.
- Right of Nomination: nominate another individual to exercise your rights in the event of your death or incapacity.
- Right to Grievance Redressal: file a complaint with AdBaBa's Grievance Officer. All data-related complaints are resolved within 30 days.
To exercise any of these rights, email legal@adbaba.in with your registered email address and a description of your request. We may require identity verification before processing your request.
7. Data Security
- All data is transmitted over HTTPS with TLS 1.2 or higher encryption.
- Bank account details and sensitive financial data are stored with AES-256 encryption at rest.
- Access to personal data is restricted to authorised AdBaBa personnel on a need-to-know basis.
- We conduct regular security reviews and vulnerability assessments of our Platform.
- In the event of a data breach that is likely to affect your rights or interests, we will notify you and the relevant authority within 72 hours of becoming aware of the breach, as required by applicable law.
8. Cookies
We use two categories of cookies:
- Essential cookies: required for Platform login, session management, and security. These cannot be disabled without breaking Platform functionality.
- Analytics cookies: used to understand how users interact with the Platform so we can improve it. These are activated only after your explicit consent.
We do not use advertising cookies or third-party tracking pixels. You can manage your cookie preferences at any time via our Cookie Policy page. You can also manage cookies through your browser settings, though disabling essential cookies will affect Platform functionality.
9. Children's Data
The AdBaBa Platform and its services are not directed at or intended for use by persons under 18 years of age. We do not knowingly collect personal data from minors. If we become aware that personal data of a minor has been submitted to the Platform, we will delete such data promptly. If you believe we may have inadvertently collected data from a minor, please contact us at legal@adbaba.in.
10. Changes to This Policy
We may update this Privacy Policy periodically. Any changes will be posted on this page with an updated effective date, and registered users will be notified by email. Your continued use of the Platform after the effective date constitutes acceptance of the updated policy. For material changes, we will provide a prominent notice on the Platform in addition to the email notification.