PRIVACY · POLICY · v1.0 DPDPA · GDPR · UK GDPR · CCPA/CPRA GOVERNING LAW: REPUBLIC OF INDIA
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DATA PROTECTION · PRIVACY COMMITMENT
Privacy Policy
NARION RESEARCH TECHNOLOGIES · QUANTITATIVE MARKET INTELLIGENCE PLATFORM
DOCUMENT VERSION
1.0
EFFECTIVE DATE
April 16, 2026
LAST REVIEWED
April 16, 2026
GOVERNING LAW
Republic of India
REGULATORY COMPLIANCE: DPDPA 2023 (India) IT Act 2000 · SPDI Rules 2011 GDPR (EU) 2016/679 UK GDPR · DPA 2018 CCPA / CPRA (California)
PRIVACY POLICY SUMMARY — AT A GLANCE

The following summary is provided for convenience. It does not replace the full Policy. In the event of any inconsistency, the full text prevails.

DATA WE COLLECT
Account info, authentication data, billing references, usage logs, support communications. We never collect biometric, health, political, or payment card data.
HOW WE USE IT
Service delivery, security monitoring, payment processing, platform improvement (anonymized only), legal compliance, and service notifications.
YOUR RIGHTS
Access, correction, erasure, restriction, portability, objection, and withdrawal of consent. Contact privacy@narionresearch.com to exercise any right.
DO WE SELL DATA
No. Never. Narion categorically prohibits the sale, rent, or commercial transfer of personal data to any third party, without exception.
DATA RETENTION
Retained only as long as necessary for each purpose or as required by law. Account data deleted within 90 days of account closure.
CONTACT
privacy@narionresearch.com · legal@narionresearch.com · www.narionresearch.com
BINDING PRIVACY NOTICE — READ CAREFULLY This Privacy Policy governs in full the manner in which Narion collects, receives, stores, processes, uses, shares, transfers, discloses, protects, and otherwise handles personal data obtained in connection with Users' access to and use of the Platform. Narion is firmly committed to the principle that all data handling activities shall be conducted lawfully, fairly, transparently, and with full respect for the dignity, autonomy, and fundamental privacy rights of every individual.

THE USER IS STRONGLY ADVISED TO READ THIS POLICY CAREFULLY AND IN ITS ENTIRETY BEFORE ACCESSING OR USING THE PLATFORM. BY ACCESSING, REGISTERING FOR, SUBSCRIBING TO, OR USING THE PLATFORM IN ANY MANNER, THE USER EXPRESSLY ACKNOWLEDGES HAVING READ, UNDERSTOOD, AND ACCEPTED THE DATA PRACTICES DESCRIBED IN THIS POLICY. IF THE USER DOES NOT ACCEPT THIS POLICY, THE USER MUST IMMEDIATELY CEASE ALL USE OF THE PLATFORM.

This Policy is incorporated by reference into and forms an integral, inseparable part of Narion's Terms of Service.
ARTICLE I
§1
ART. IIntroduction and Identity of the Data Controller
1.1 Identity of the Data Controller / Data Fiduciary

For the purposes of applicable data protection legislation, the data fiduciary (under the DPDPA) and data controller (under the GDPR and UK GDPR) in respect of all personal data collected and processed through the Platform is Narion Research Technologies. All references to "Narion," "we," "us," or "our" in this Policy refer to the individual Proprietor operating under the trade name "Narion Research Technologies." Narion is not a company, corporation, or registered legal entity, and all data protection obligations described in this Policy are the direct obligations of the individual Proprietor in their personal capacity.

BUSINESS NAME
Narion Research Technologies
BUSINESS TYPE
Individual sole proprietorship, Republic of India
PLATFORM
Quantitative Market Intelligence and Analytics Platform
GENERAL EMAIL
support@narionresearch.com
PRIVACY EMAIL
privacy@narionresearch.com
LEGAL EMAIL
legal@narionresearch.com
WEBSITE
www.narionresearch.com
GRIEVANCE OFFICER
Shashank Kumar Sinha - grievance@narionresearch.com
1.2 Scope of This Policy

This Policy applies to all personal data and related information collected, received, or generated in connection with:

  • Access to and use of the Platform through web-based, mobile-based, or API-based interfaces;
  • Account registration, subscription activation, and account management;
  • Communications between the User and Narion, including support requests, feedback, inquiries, and automated notifications;
  • Use of third-party integrations or external services accessed through the Platform;
  • Participation in research, beta programs, surveys, or other Platform-related activities conducted or facilitated by Narion.

This Policy does not apply to third-party websites, applications, or services that may be linked to from the Platform. Narion exercises no control over the data practices of such third parties, and Users are encouraged to review their policies independently.

1.3 Relationship to Terms of Service

This Policy is an integral part of and must be read alongside Narion's Terms of Service. In the event of any conflict between this Policy and the Terms of Service regarding data protection or privacy matters, this Policy shall govern to the extent of such conflict.

ARTICLE II
§2
ART. IIRegulatory and Legal Compliance Framework
2.1 Applicable Data Protection Legislation

Narion is committed to the lawful, fair, and transparent processing of personal data in compliance with all applicable data protection and privacy laws. The regulatory framework governing Narion's data processing activities includes:

LEGISLATIONJURISDICTIONAPPLICABILITY
Digital Personal Data Protection Act, 2023 (DPDPA)IndiaPrimary framework — all Indian data principals. Imposes obligations on data fiduciaries including lawful consent, purpose limitation, data minimization, accuracy, storage limitation, security safeguards, and rights of data principals.
IT Act 2000 & SPDI Rules 2011IndiaGoverning collection and handling of sensitive personal data by bodies corporate, including written consent, accuracy, and reasonable security practices.
GDPR (EU) 2016/679European Economic AreaApplicable where Narion processes personal data of EEA data subjects in connection with offering services to them or monitoring their behavior within the EEA.
UK GDPR & Data Protection Act 2018United KingdomApplicable to processing of personal data of UK data subjects in analogous circumstances.
CCPA / CPRACalifornia, USAApplicable to the processing of personal information of California residents who qualify as consumers under those statutes.
2.2 Hierarchy of Applicable Standards

Where the requirements of two or more applicable data protection frameworks differ in respect of a particular processing activity, Narion shall apply the more stringent standard unless doing so would conflict with a mandatory provision of higher-priority applicable law. This commitment reflects Narion's policy of universal respect for individuals' fundamental privacy rights, irrespective of jurisdiction.

2.3 Narion's Role: Data Fiduciary and Data Controller

Under the DPDPA, Narion acts as a "Data Fiduciary" in respect of personal data of Indian data principals. Under the GDPR and UK GDPR, Narion acts as a "Data Controller." In either capacity, Narion determines the purposes and means of processing personal data. Where Narion engages third-party service providers to process personal data on its behalf, such providers act as Data Processors, and Narion shall ensure through appropriate contractual arrangements that they process data only in accordance with Narion's documented instructions, applicable law, and the commitments set out in this Policy.

2.4 Data Protection by Design and Default

In accordance with applicable data protection principles, Narion has embedded data protection considerations into the design, architecture, and operational procedures of the Platform. By default, only personal data strictly necessary for each specific processing purpose is collected, processed, stored, and retained. Narion continually reviews its data collection practices to identify and eliminate any collection of personal data that exceeds what is necessary for defined and legitimate purposes.

ARTICLE III
§3
ART. IIIDefinitions and Interpretive Provisions
3.1 Defined Terms

For the purposes of this Policy, defined terms include: "Personal Data" meaning any information that identifies or can identify a natural person; "Data Principal" / "Data Subject" meaning the individual to whom personal data relates; "Processing" meaning any operation performed on personal data; "Data Fiduciary" / "Data Controller" meaning the entity that determines the purposes and means of processing; "Data Processor" meaning a party processing data on the Data Controller's behalf; "Data Breach" meaning a security incident resulting in unauthorized access, disclosure, alteration, or loss of personal data; "Consent" meaning freely given, specific, informed, and unambiguous agreement to processing; and "Sensitive Personal Data" meaning personal data designated as requiring heightened protection under applicable law.

3.2 Rules of Interpretation

In this Policy: (a) references to the singular include the plural and vice versa; (b) references to any statute include any subsequent amendment or re-enactment; (c) headings are for convenience only; (d) "including" means "including without limitation"; (e) "days" means calendar days unless specified as "business days"; and (f) references to writing include electronic communications where appropriate.

ARTICLE IV
§4
ART. IVCategories of Personal Data Collected
4.1 Principle of Data Minimization

Narion collects only such personal data as is adequate, relevant, and strictly limited to what is necessary in relation to each specified purpose of processing. Narion does not collect personal data speculatively, in anticipation of possible future uses, or beyond what is demonstrably required for defined, legitimate, and disclosed purposes.

4.2 Account Registration and Identity Data

When a User registers for an account, Narion collects:

  • Full name or professional name as provided during registration;
  • Primary email address, serving as the principal account identifier and communication channel;
  • Organisation or company name, where the User represents an enterprise subscriber;
  • Country or region of residence or operation, as provided during registration or inferred from billing or usage data;
  • Preferred language and regional settings relevant to service delivery.

Narion does not require, and Users should not voluntarily provide, any government-issued identification numbers, national identity numbers, social security numbers, or similar official identification documents during standard registration.

4.3 Authentication and Security Credentials

To enable secure account access, Narion collects and maintains:

  • Password hash only: Narion stores only a cryptographically hashed and salted version of the User's password, computed using a memory-hard hashing algorithm (bcrypt or Argon2). Narion never stores passwords in plaintext;
  • API keys and authentication tokens issued for programmatic access;
  • Multi-factor authentication enrollment data and device trust records, where activated;
  • Login timestamps, session identifiers, and IP addresses associated with authentication events, retained for security audit and anomaly detection.
4.4 Billing and Subscription Data

In connection with subscription management, Narion collects subscription tier, billing cycle, billing address, transaction identifiers, payment reference numbers, and records of payment outcomes. Narion expressly does not collect or store full payment card numbers, CVV/CVC, bank account numbers, or any other primary financial credentials. All sensitive payment data is processed exclusively by third-party payment processors under PCI DSS compliance. Narion receives only tokenized payment references and transaction status data.

4.5 Usage Data and Interaction Logs

When the User interacts with the Platform, Narion automatically collects:

  • IP address and derived approximate geolocation data (country or city level), used for security, fraud prevention, and regional service configuration;
  • Device information: device type, hardware model, operating system name and version, browser type and version;
  • Session data: URLs of pages visited, referrer URL, session start and end timestamps, session duration, pages viewed, and navigation sequence;
  • User interaction data: clicks, scrolls, in-Platform search queries, and feature utilization patterns;
  • API access logs: endpoint accessed, request timestamps, request volumes, HTTP response codes, and error messages;
  • System performance metrics: page load times, API response latencies, and error rates.
4.6 Communication and Support Data

When the User communicates with Narion, Narion collects the full content of all communications, contact information provided, support ticket identifiers and case notes, and recordings or transcripts of live support sessions where such functionality is offered and the User has been notified.

4.7 Derived and Analytical Data

Narion may generate data derived or inferred from primary collected data, including aggregated usage statistics, behavioral pattern analyses, and platform performance benchmarks, all processed exclusively in anonymized or aggregated form. Derived data is not used to make individualized decisions about any User.

4.8 Data Narion Does Not Collect

For the avoidance of doubt, Narion does not collect, and has no legitimate purpose for collecting, any of the following:

  • Genetic or biometric data;
  • Health, medical, or clinical information;
  • Religious beliefs, political opinions, or trade union membership;
  • Criminal conviction or offence history;
  • Racial or ethnic origin (except as incidentally reflected in regional settings);
  • Full government-issued identification documents, except where specifically required for identity verification under institutional subscription arrangements.

If a User inadvertently submits data in any of the above categories, Narion will delete such data promptly upon identification and will not process it for any purpose.

ARTICLE V
§5
ART. VPurposes and Legal Bases for Data Processing
5.1 Principle of Purpose Limitation

Narion processes personal data strictly for specified, explicit, and legitimate purposes and does not process personal data in a manner incompatible with those purposes. Each processing activity is associated with a defined and independently justifiable legal basis.

5.2 Service Provision and Account Management
PURPOSE
To deliver the Platform's contracted functionalities, including account creation and maintenance, subscription activation, API provisioning, analytics delivery, and technical support.
DATA
Identity data, authentication credentials, billing data, usage data.
LEGAL BASIS
Contractual necessity (GDPR Art. 6(1)(b)); performance of a lawful contract (DPDPA); legitimate use in connection with contracted service delivery.
5.3 Security, Fraud Prevention, and Integrity Monitoring
PURPOSE
To protect the Platform, its Users, and Narion's infrastructure against unauthorized access, data breaches, fraudulent activity, and security incidents, including intrusion detection, anomaly monitoring, rate-limiting, and security incident investigation.
DATA
Authentication logs, IP addresses, session data, API access records, device identifiers.
LEGAL BASIS
Legitimate interests of Narion in maintaining security (GDPR Art. 6(1)(f)); legal obligation to implement reasonable security practices under the SPDI Rules and DPDPA.
5.4 Payment Processing and Financial Administration
PURPOSE
To process subscription payments, issue invoices, manage billing disputes, comply with financial recordkeeping and tax obligations, and prevent payment fraud.
DATA
Billing details, transaction identifiers, subscription records, payment outcomes.
LEGAL BASIS
Contractual necessity; legal obligation under the Income Tax Act, 1961 (India) and applicable GST legislation.
5.5 Platform Improvement and Product Development
PURPOSE
To analyze Platform usage patterns, identify areas for improvement, develop new features, and conduct internal research. Conducted exclusively on anonymized and aggregated data.
DATA
Anonymized and aggregated usage data only. No personal data is used for this purpose without prior effective anonymization.
LEGAL BASIS
Legitimate interests (GDPR Art. 6(1)(f)). Processing conducted exclusively on anonymized data poses no risk to individual Users' rights or interests.
5.6 Legal and Regulatory Compliance
PURPOSE
To comply with applicable laws, regulations, court orders, and regulatory directives.
DATA
Any personal data necessary to fulfill a specific legal obligation, retained for the minimum period required.
LEGAL BASIS
Legal obligation (GDPR Art. 6(1)(c)); lawful obligation under applicable Indian and international law.
5.7 Service Communications and Notifications
PURPOSE
To send essential service-related communications including account confirmations, password resets, subscription renewal notices, security alerts, service interruption notices, and policy update notifications. The User may not opt out of essential service communications while maintaining an active subscription.
DATA
Email address, notification preferences, communication history.
LEGAL BASIS
Contractual necessity for transactional communications; legitimate interests for communications reasonably expected by Users.
5.8 Marketing Communications (Consent-Based and Optional)
PURPOSE
Where the User has expressly opted in, to send promotional communications, product announcements, research newsletters, or other marketing materials relating to Narion's Platform. Narion does not send unsolicited marketing communications.
DATA
Email address, communication preferences.
LEGAL BASIS
Consent (GDPR Art. 6(1)(a); DPDPA). The User may withdraw consent at any time by following the unsubscribe link or contacting privacy@narionresearch.com. Withdrawal does not affect service access or essential communications.
5.9 Dispute Resolution and Legal Claims

Purpose: To establish, exercise, or defend legal rights and claims, including pre-litigation dispute management, legal proceedings, and compliance audits. Legal basis: Legitimate interests in asserting and defending legal rights (GDPR Art. 6(1)(f)); legal obligation where required by applicable law.

5.10 No Secondary or Incompatible Use

Narion does not use personal data for any purpose incompatible with the purposes described in this Article. Where Narion intends to process personal data for a new purpose not listed herein, Narion shall assess compatibility, identify a lawful basis, and notify Users through the Policy update process in Article XV before such processing commences.

ARTICLE VI
§6
ART. VISensitive Personal Data and Heightened Protection
6.1 Categories of Sensitive Personal Data

Under the SPDI Rules, 2011, the following categories of personal data are designated as "Sensitive Personal Data or Information" and are subject to heightened collection, processing, and protection standards: financial information including bank and card credentials; passwords and authentication secrets; biometric data; health or medical information; sexual orientation; and any other category so designated by applicable legislation. Narion processes two of these categories in limited circumstances: (a) hashed authentication credentials; and (b) billing reference data received from third-party payment processors.

6.2 Heightened Obligations for Sensitive Data

In respect of any sensitive personal data processed by Narion, the following heightened obligations apply:

  • Collection only with explicit, informed, prior consent of the User, except where required by law;
  • Use solely for the purpose for which it was collected, without secondary use or disclosure except as required by law or with fresh explicit consent;
  • No disclosure to third parties without explicit consent, save for payment processors under binding confidentiality and security agreements;
  • Provision to the User of clear information about the type of sensitive data collected, the purpose, and the intended recipients before collection;
  • Implementation of security practices as prescribed under the SPDI Rules, including adherence to ISO/IEC 27001 or equivalent security standards.
6.3 Special Categories Under GDPR

Narion does not process any special categories of personal data as defined in Article 9 of the GDPR (including health data, genetic data, biometric data used for unique identification, data concerning racial or ethnic origin, political opinions, religious beliefs, trade union membership, or sexual orientation) in connection with the Platform. Where any such data is inadvertently received, Narion will delete it promptly without further processing.

ARTICLE VII
§7
ART. VIIData Sharing, Disclosure, and Third-Party Transfers
7.1 Absolute Prohibition on Sale of Personal Data

Narion does not, and shall never, sell, rent, exchange, license, or otherwise transfer personal data to any third party for commercial consideration or for the purposes of that third party's own marketing, profiling, or commercial activities. This prohibition is absolute, without exception, and applies regardless of the commercial value that the data in question might represent. Narion is not a data brokerage, advertising network, or data marketplace.

7.2 Disclosure to Third-Party Service Providers (Processors)

Narion may disclose personal data to carefully selected third-party service providers engaged to perform specific functions necessary for the Platform's operation:

  • Cloud Infrastructure Providers: Providers of server hosting, data storage, content delivery, and related infrastructure. Contractually prohibited from accessing or using the data for any other purpose;
  • Payment Processors: Including Razorpay, Stripe, Lemon Squeezy, PayU, and Cashfree. Receive billing details and transaction data strictly under their own terms, privacy policies, and PCI DSS obligations;
  • Analytics and Monitoring Providers: Providers of application performance monitoring tools, who receive anonymized or pseudonymized technical usage data only;
  • Email and Communication Service Providers: Providers of transactional email delivery services used to route service notifications and support communications;
  • Security Service Providers: Providers of security scanning, vulnerability assessment, and threat intelligence services.

Narion shall ensure through appropriate data processing agreements that all Processors: (a) process personal data only on Narion's documented instructions; (b) implement appropriate technical and organisational security measures; (c) do not engage sub-processors without Narion's prior written authorisation; (d) cooperate with Narion in fulfilling Data Principal rights obligations; and (e) delete or return personal data at the end of the engagement.

7.3 Disclosure to Legal and Regulatory Authorities

Narion may disclose personal data to governmental authorities, law enforcement, regulatory bodies, or courts where legally required, including compliance with applicable laws, response to a valid court order or subpoena, response to a lawful request by a regulatory authority, or protection of the rights, property, or safety of Narion, its Users, or the public. To the extent permitted by law, Narion will endeavor to notify affected Users of any such disclosure request before complying. Narion will disclose the minimum amount of personal data strictly necessary to fulfill the legal obligation.

7.4 Business Transfers

In the event of a transfer of Narion's business, trade name, or assets to a successor, personal data may form part of the transferred assets. Narion shall provide Users with advance notice of any such transfer, ensure the transferee is bound by equivalent data protection obligations, and, where required by applicable law, seek Users' consent prior to transfer. Users who object may request deletion of their personal data before the transfer takes effect.

7.5 Aggregated and Anonymized Data

Narion may share genuinely anonymized and aggregated data with third parties for academic research, industry analysis, or platform capability demonstration purposes, provided that such sharing cannot reasonably be used to re-identify any individual User, whether alone or in combination with other available data.

ARTICLE VIII
§8
ART. VIIIInternational Data Transfers and Cross-Border Processing
8.1 Nature of International Transfers

Narion operates from India and processes personal data primarily within India. However, the nature of the Platform's global infrastructure and service providers may require that personal data be transferred to, stored in, or accessed from jurisdictions outside India. Such transfers may arise where cloud infrastructure is hosted in overseas data centres, third-party service providers operate processing facilities outside India, or Users access the Platform from jurisdictions outside India.

8.2 Applicable Safeguards

Where personal data is transferred to a jurisdiction that does not provide equivalent data protection, Narion shall implement one or more of the following safeguards:

  • Standard Contractual Clauses (SCCs): Data processing agreements incorporating contractual clauses approved by the European Commission (for GDPR-covered transfers) or analogous instruments recognized under Indian law for cross-border transfers under the DPDPA;
  • Adequacy Determinations: Reliance on formal adequacy decisions by the Government of India or other relevant regulatory authorities recognizing a jurisdiction as providing adequate data protection;
  • Technical Safeguards: Application of end-to-end encryption, key management practices, and access controls ensuring that transferred data remains protected in transit and at rest;
  • Processor Agreements: Binding contractual obligations on overseas processors to process data only on Narion's instructions and in accordance with applicable law.
8.3 User Acknowledgement and Consent

By registering for and using the Platform, the User acknowledges and, where consent constitutes the applicable legal basis, consents to the international transfer and processing of their personal data as described in this Article, subject to the safeguards described herein. Users who do not wish their data to be transferred internationally should discontinue use of the Platform and request deletion of their data in accordance with Article XI.

8.4 GDPR-Compliant Transfers

Where Narion processes personal data of EEA data subjects and such data is transferred outside the EEA, Narion shall ensure compliance with Chapter V of the GDPR, relying on adequacy decisions, standard contractual clauses, or other valid transfer mechanisms as applicable. Narion shall maintain records of all such transfers and the safeguards applied, and make such records available to supervisory authorities upon request.

ARTICLE IX
§9
ART. IXData Retention, Storage Limitation, and Deletion
9.1 Principle of Storage Limitation

Narion retains personal data for no longer than is necessary for the purposes for which it was collected, or for such longer period as is required or permitted under applicable law. Retention periods are determined by reference to the purposes of processing, applicable legal obligations, and legitimate interests in maintaining records for audit and dispute resolution. Narion does not retain personal data on a speculative basis.

9.2 Retention Schedule
DATA CATEGORYSTANDARD RETENTION PERIODBASIS
Account & Identity DataDuration of account + 90 days post-closureContractual, then legal hold period
Authentication Logs90 days rollingSecurity monitoring and fraud prevention
Billing & Transaction Records7 yearsTax law obligations (IT Act 1961, GST)
Usage & Interaction Logs12 monthsPlatform improvement, security, and performance
Support Communications3 years from resolutionDispute resolution and service quality
Marketing Consent RecordsUntil withdrawal + 3 yearsProof of consent under applicable law
Legal Hold DataUntil hold is formally liftedLegal proceedings, regulatory investigations
9.3 Secure Deletion and Anonymization

Upon expiry of the applicable retention period, personal data shall be subject to secure deletion using industry-standard data destruction methods appropriate to the storage medium, or to effective anonymization rendering re-identification not reasonably practicable. Narion shall not retain personal data in identifiable form beyond the periods specified in this Article.

9.4 Legal Holds

Notwithstanding the above, Narion may retain personal data beyond standard periods where required for Legal Hold purposes, including: ongoing or anticipated legal proceedings or regulatory investigations; court orders or regulatory directions requiring preservation; or mandatory minimum retention periods under applicable law. Legal Hold data is preserved in its original form and is not subject to deletion or anonymization until the hold is formally lifted.

ARTICLE X
§10
ART. XData Security, Technical Safeguards, and Breach Response
10.1 Security Commitment and Framework

Narion implements a comprehensive set of technical, organisational, and procedural security measures designed to protect personal data against unauthorized access, disclosure, alteration, destruction, loss, and all other forms of unlawful or unauthorized processing. Narion's security practices are informed by internationally recognized standards including ISO/IEC 27001 and the security requirements prescribed under the SPDI Rules and the DPDPA.

10.2 Technical Security Measures
  • Encryption in Transit: All personal data transmitted between the User's device and the Platform is encrypted using Transport Layer Security (TLS) protocol version 1.2 or higher, protecting against interception and man-in-the-middle attacks;
  • Encryption at Rest: Personal data stored in Narion's databases and storage systems is encrypted using industry-standard symmetric encryption (AES-256 or equivalent);
  • Password Security: User passwords are stored exclusively as salted cryptographic hashes computed using a memory-hard hashing algorithm (bcrypt, Argon2, or equivalent). Narion never stores plaintext passwords;
  • Role-Based Access Controls: Access to personal data and production systems is governed by least-privilege principles. Privileged access requires multi-factor authentication;
  • Audit Logging: Comprehensive audit logs of access to personal data and production systems are maintained, enabling detection and investigation of unauthorized access or anomalous behavior;
  • Vulnerability Management: Regular vulnerability assessments and security reviews of the Platform's infrastructure and codebase, with timely remediation of identified vulnerabilities;
  • Intrusion Detection and Prevention: Automated systems to identify and respond to potential security threats in real time;
  • Data Isolation: User data is logically segregated within Narion's infrastructure to prevent unauthorized cross-user access.
10.3 Organisational Security Measures
  • Access governance on a strict need-to-know basis, reviewed periodically and revoked promptly upon change of role or termination of engagement;
  • Third-party processor due diligence, including contractual data protection obligations and, where appropriate, security audits;
  • Documented internal security policies and procedures governing data handling, access management, incident response, and acceptable use.
10.4 Inherent Risks and Limitation of Guarantee

No information security system is impenetrable, and the transmission of data over the internet carries inherent and unavoidable risks. Narion does not guarantee absolute security of personal data and cannot warrant that unauthorized third parties will never succeed in defeating Narion's security measures.

10.5 Data Breach Detection, Notification, and Remediation

In the event that Narion becomes aware of a Data Breach affecting Users' personal data, Narion shall:

  • Containment: Immediately take steps to contain the breach, prevent further unauthorized access, and preserve forensic evidence for investigation;
  • Investigation: Conduct a prompt internal investigation to determine the nature, scope, cause, and impact of the breach;
  • Regulatory Notification: Where applicable law requires notification of a supervisory authority (including under the DPDPA implementing regulations or GDPR Article 33), submit the required notification within the prescribed timeframe (72 hours under GDPR);
  • User Notification: Where a breach poses a significant risk to affected Users, notify such Users in a timely manner, describing the breach, the data affected, the likely consequences, and the measures Narion is taking to address it;
  • Remediation: Implement appropriate measures to prevent recurrence and review security practices in light of the incident.

Users who suspect their account or personal data may have been compromised should contact Narion immediately at privacy@narionresearch.com.

ARTICLE XI
§11
ART. XIRights of Data Principals and How to Exercise Them
11.1 Overview and Non-Discrimination Commitment

Depending on the User's jurisdiction, the User may be entitled to exercise one or more of the rights described in this Article in respect of their personal data processed by Narion. Narion is committed to facilitating the exercise of these rights in a transparent, timely, and non-discriminatory manner. Narion shall not penalise, disadvantage, or treat unfavorably any User solely because they have exercised a right to which they are entitled under applicable law.

11.2 Right of Access

The User has the right to request confirmation as to whether personal data concerning them is being processed by Narion and, where it is, to receive a copy of that data together with the purposes of processing, the categories of data involved, the recipients or categories of recipients, the anticipated retention period, and any other information required under applicable law. Narion shall provide the requested information free of charge within thirty (30) days of receipt of a valid, verified request.

11.3 Right to Correction

The User has the right to request the correction of any inaccurate or incomplete personal data held by Narion. Certain categories of data may be corrected directly through the account management interface. For other categories, correction requests should be submitted to Narion through the contact details in Article XVI.

11.4 Right to Erasure

The User has the right to request deletion of their personal data where: the data is no longer necessary for its original purpose; the User withdraws consent and no other legal basis applies; the User objects and no overriding legitimate grounds exist; the data has been processed unlawfully; or erasure is required by applicable law. Where Narion cannot comply fully, Narion will notify the User and delete or restrict the data to the maximum extent lawfully permitted.

11.5 Right to Restriction of Processing

The User may request that Narion restrict processing of their personal data to storage only, pending resolution of a dispute, where: the accuracy of the data is contested; processing is unlawful but the User prefers restriction to erasure; Narion no longer requires the data but the User needs it for legal claims; or the User has objected and Narion's legitimate grounds assessment is pending.

11.6 Right to Data Portability

Where processing is based on consent or contractual necessity and is carried out by automated means, the User has the right to receive the personal data they have provided to Narion in a structured, commonly used, machine-readable format (such as JSON or CSV), and to transmit it to another controller where technically feasible. This right applies to data actively provided by the User and does not extend to derived or inferred data generated by Narion's systems.

11.7 Right to Object

The User has the right to object, at any time, to the processing of their personal data where such processing is based on Narion's legitimate interests. The User's right to object to processing for direct marketing purposes is absolute and unconditional: upon such objection, Narion shall immediately cease all direct marketing processing.

11.8 Right to Withdraw Consent

Where processing is based on the User's consent, the User may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing that occurred before withdrawal. Narion shall implement the withdrawal promptly and ensure it is reflected in all subsequent processing.

11.9 Additional Rights Under the DPDPA (Indian Data Principals)
  • The right to receive a summary of personal data being processed and the processing activities;
  • The right to correction and erasure of inaccurate, incomplete, or no-longer-necessary personal data;
  • The right to obtain a summary of all third parties with whom personal data has been shared;
  • The right to grievance redressal through a defined complaints procedure with the Grievance Officer;
  • The right to nominate another individual to exercise these rights in the event of the data principal's death or incapacity.
11.10 Rights Under CCPA/CPRA (California Residents)
  • Right to know: To request disclosure of categories and specific pieces of personal information collected, sources, business purposes, and third-party recipients;
  • Right to deletion: To request deletion of personal information, subject to certain exceptions;
  • Right to correct: To request correction of inaccurate personal information;
  • Right to opt out of sale or sharing: Narion does not sell or share personal data; this right is therefore not triggered by Narion's practices;
  • Right to limit use of sensitive personal information: To the extent applicable to Narion's processing activities;
  • Right to non-discrimination: Narion shall not discriminate against Users for exercising their CCPA/CPRA rights.
11.11 How to Submit a Rights Request

To exercise any of the rights described in this Article, the User should submit a written request to:

  • Privacy Email: privacy@narionresearch.com (Subject line: "Data Rights Request — [Type of Right]");
  • Legal Email: legal@narionresearch.com (for complex or dispute-related requests);
  • Grievance Portal: as provided on Narion's website.

Narion shall respond to all valid rights requests within thirty (30) calendar days of receipt and verification of identity. For particularly complex requests, Narion may extend this period by a further two (2) months, providing written notice of the extension and its reasons within the initial thirty-day period. Narion will not charge a fee for rights requests except where requests are manifestly unfounded, repetitive, or excessive.

ARTICLE XII
§12
ART. XIICookies, Tracking Technologies, and Session Management
12.1 Overview

Cookies are small text files placed on a User's device by a website, enabling recognition of the device and storage of session, preference, or activity data. In addition to cookies, Narion may employ related tracking technologies including web beacons, local storage objects, and session tokens. All such technologies are subject to the principles and controls described in this Article.

12.2 Categories of Cookies Used
12.3 Cookies Narion Does Not Use

Narion does not use, and expressly prohibits on the Platform:

  • Advertising or targeting cookies used to serve personalized advertisements based on cross-site browsing behavior;
  • Third-party social media tracking pixels that report User activity to social media platforms;
  • Fingerprinting scripts or supercookies designed to re-identify Users who have cleared standard cookies.
12.4 Cookie Consent and User Control

Where applicable law requires prior consent before placing non-essential cookies, Narion shall present Users with a clear and informative consent interface on their first visit. Users may accept all categories, accept only strictly necessary cookies, or customize their preferences by category. Consent choices are recorded and honored in all subsequent sessions.

Users retain the ability to control cookies through browser settings, including refusing, deleting, or receiving notification of cookies. Narion respects browser-level "Do Not Track" signals where technically feasible and does not interpret browser-level cookie restrictions as consent to any specific cookie category.

12.5 Cookie Policy

A separate, detailed Cookie Policy governing Narion's use of cookies and tracking technologies, including a full list of cookies deployed, their specific purposes, duration, and third-party providers involved, is available on Narion's website. The Cookie Policy is incorporated into and forms part of this Privacy Policy.

ARTICLE XIII
§13
ART. XIIIChildren's Privacy and Protection of Minors
13.1 Platform Not Intended for Minors

The Platform is designed, developed, and intended exclusively for use by adults who have attained the age of majority in their jurisdiction, and in no event by persons under the age of eighteen (18) years. Narion does not direct the Platform's features, marketing, or outreach toward individuals under the age of eighteen, and the Platform does not contain content, tools, or functionalities designed to appeal to or be suitable for minors.

13.2 No Knowing Collection from Minors

Narion does not knowingly collect, solicit, process, store, or retain personal data from any individual under the age of eighteen (18) years. The account registration process includes a mandatory age confirmation step. Where Narion discovers or is notified that personal data has been collected from a minor without verifiable parental or guardian consent, Narion shall: (a) promptly delete the minor's personal data from all systems; (b) terminate the minor's account; and (c) investigate and implement measures to prevent recurrence.

13.3 Parental Notification and Contact

If a parent or guardian becomes aware that their minor child has provided personal data to Narion without proper authorization, they should contact Narion immediately at privacy@narionresearch.com with details of the account or data concerned. Narion shall treat such requests with priority and respond within five (5) business days.

ARTICLE XIV
§14
ART. XIVThird-Party Links, Integrations, and External Services
14.1 Third-Party Links

The Platform may contain hyperlinks to external websites, applications, or services operated by third parties not affiliated with Narion. Such links are provided for User convenience only. Narion has no control over the content, privacy practices, data processing activities, or security measures of any third-party website or service, and expressly disclaims all responsibility and liability for the privacy practices of such third parties. The inclusion of a hyperlink to a third-party website does not constitute Narion's endorsement of that website, its content, or its products and services. Users are strongly encouraged to review the privacy policy and terms of service of any third-party website they visit before providing personal data.

14.2 Third-Party Integrations

Where the Platform integrates with or connects to third-party platforms, data sources, or analytical tools, such integrations may involve the transfer of technical data (such as API authentication tokens or session identifiers) to the relevant third-party service. Privacy practices applicable to such integrations are governed by the third party's own privacy policies. The User is solely responsible for reviewing and accepting the terms and privacy policies of any third-party service they use in connection with the Platform.

ARTICLE XV
§15
ART. XVChanges to This Privacy Policy
15.1 Right to Modify

Narion reserves the right to amend, modify, supplement, or replace this Privacy Policy at any time, at its sole discretion, to reflect changes in applicable law, regulatory guidance, Platform functionalities, or Narion's data processing practices. All modifications shall be effective from the date of publication on Narion's official website, unless a later effective date is specified.

15.2 Notification of Material Changes

Where a proposed modification constitutes a material change to this Policy, Narion shall provide advance notice as follows:

  • Email notification to the registered account email address, sent not less than fourteen (14) calendar days before the modified Policy takes effect, describing the nature of the material changes in plain and accessible language;
  • Prominent notice on the Platform dashboard or home page, displayed throughout the notice period;
  • Where required by applicable law (including the DPDPA or GDPR), an affirmative opt-in or re-consent mechanism prior to continued processing under the modified Policy.
15.3 Continued Use Constitutes Acceptance

Where the User continues to access or use the Platform following publication of a modified Policy without objecting, such continued use constitutes acceptance of the modified Policy. Users who object to a material modification may exercise their right to request deletion of their personal data and terminate their account in accordance with Article XI and the Terms of Service.

15.4 Historical Policy Versions

Narion maintains an archive of previous versions of this Policy, available upon request to any User wishing to review the historical development of Narion's privacy practices. Requests should be directed to privacy@narionresearch.com.

ARTICLE XVI
§16
ART. XVIGrievance Redressal, Contact Details, and Supervisory Authorities
16.1 Grievance Officer (India — DPDPA and IT Act)

In accordance with the Information Technology Act, 2000, the SPDI Rules, 2011, and the Digital Personal Data Protection Act, 2023, Narion has designated a Grievance Officer responsible for receiving, addressing, and resolving all complaints, queries, and data-related concerns from Users. The Grievance Officer shall acknowledge all complaints within 48 hours and endeavor to resolve them within 30 days of receipt, in accordance with applicable statutory requirements. Details of the Grievance Officer are published on Narion's official website.

GRIEVANCE OFFICER
Shashank Kumar Sinha
DESIGNATION
Proprietor & Data Protection Officer
GRIEVANCE EMAIL
grievance@narionresearch.com
POSTAL ADDRESS
New Delhi, India
ACKNOWLEDGEMENT
Within 48 hours
RESOLUTION TIME
Within 30 days
16.2 General Privacy and Legal Contact
BUSINESS NAME
Narion Research Technologies
PRIVACY QUERIES
privacy@narionresearch.com
LEGAL NOTICES
legal@narionresearch.com
GENERAL SUPPORT
support@narionresearch.com
WEBSITE
www.narionresearch.com
REGISTERED ADDRESS
New Delhi, India
16.3 Right to Lodge a Complaint with Supervisory Authorities

Users who believe that Narion's processing of their personal data violates applicable data protection law retain the right to lodge a complaint with the competent supervisory authority in their jurisdiction. Narion encourages Users to contact Narion directly first. Relevant supervisory authorities include:

  • India (DPDPA): The Data Protection Board of India, once constituted pursuant to the DPDPA's implementing regulations. Until such time, Users may also raise complaints through the Grievance Officer described in Article 16.1, or through such consumer or regulatory forums as may have jurisdiction;
  • European Union (GDPR): The data protection supervisory authority of the EU member state in which the User resides, works, or in which the alleged infringement took place. Full list: https://edpb.europa.eu/about-edpb/about-edpb/members_en
  • United Kingdom (UK GDPR): The Information Commissioner's Office (ICO), at www.ico.org.uk
  • California, USA (CCPA/CPRA): The California Privacy Protection Agency (CPPA), at cppa.ca.gov
FINAL ACKNOWLEDGEMENT AND ACCEPTANCE

BY ACCESSING, REGISTERING FOR, OR USING THE PLATFORM IN ANY MANNER, THE USER IRREVOCABLY ACKNOWLEDGES AND CONFIRMS THAT:

  • The User has read this Privacy Policy in its entirety and has had a full and meaningful opportunity to seek independent legal or privacy counsel;
  • The User understands and accepts all data collection, processing, sharing, retention, and security practices described herein;
  • The User consents, where consent constitutes the applicable legal basis, to the international transfer of their personal data as described in Article VIII;
  • The User understands their rights as a Data Principal or Data Subject under applicable law and the mechanisms available to exercise those rights;
  • The User acknowledges that this Policy forms an integral part of the Terms of Service and that both documents are binding upon the User in their entirety.
— END OF PRIVACY POLICY —  ·  Narion Research Technologies  ·  privacy@narionresearch.com  ·  www.narionresearch.com