Skip to content
arpr
Book an audit

Data protection

How we handle your data

Performance marketing runs on personal data. Most agencies have not worked out what that now means. This page sets out exactly how we handle yours, including the parts the industry prefers not to discuss.

Last updated 12 October 2026 · Written against the Digital Personal Data Protection Act, 2023 and the DPDP Rules, 2025

The short version

  • On your work, you are the Data Fiduciary and we are your Data Processor. We act on your instructions, nothing more.
  • We sign a data processing agreement before we touch anything, and we bring the draft.
  • Named logins only. No shared accounts, no credentials over email or chat, access revoked the day someone leaves.
  • We will not upload a customer list to an ad platform until you confirm in writing that you have a lawful basis for it.
  • We publish our subprocessors, and we tell you before we add one.

1. Who is responsible for what

The Act divides everyone into two roles, and the division decides who carries the liability. It is worth being precise about it, because a vague answer here is the first sign an agency has not done the work.

Roles on a typical engagement
ContextYouUs
Your customers' data, in your CRM, site, ad accounts and analyticsData Fiduciary — you decide why and howData Processor — we act on your documented instructions
Enquiries you send us, and your team's contact detailsData PrincipalData Fiduciary
Advertising platforms you ask us to runData FiduciaryWe configure; the platform processes under your platform terms

Because Section 8(5) makes you responsible for the security of data processed on your behalf, our job is to make that responsibility easy for you to discharge and easy to evidence. Every control below exists for that reason.

2. Before we touch your data

Four things happen before anyone on our team opens one of your platforms.

  1. A data processing agreement is signed. We bring the draft. It names the processing activities, the categories of data, the subprocessors, the security measures, the retention position and what happens at the end. If you have your own paper, we will work to it.
  2. Scope is written down. Which systems, which data, which people. Anything outside that list is a change request, not an assumption.
  3. Access is granted natively and individually. Each person gets their own account on your platform, with multi-factor authentication. We will decline a shared login even when it is offered, because it destroys your audit trail as well as ours.
  4. The lawful basis is confirmed for anything we will share onward. Covered in §4.

3. The controls we run

Rule 6 of the DPDP Rules names what reasonable security safeguards look like. This is our implementation of it.

Safeguards, mapped to Rule 6
SafeguardHow we run it
EncryptionTLS in transit everywhere. At rest wherever the platform supports it. No client data on personal devices without disk encryption
Masking and obfuscationSession recording and heatmap tools configured with input masking on by default. Customer-level exports reduced to the fields the analysis actually needs
Access controlNamed accounts, multi-factor authentication, least privilege. Nobody holds standing access to a system their current work does not require
Access logsPlatform-native logging left on and not cleared. Our own access grants and revocations recorded with dates
RevocationRuns on two triggers — a person leaves the team, or an engagement ends. Completed within 2 business days and confirmed to you in writing
Credential handlingPlatform-native access grants, or a password manager. Never email, chat, WhatsApp or a shared document
Retention on our sideExports, raw files and screenshots deleted on a schedule and at the end of the engagement, with the deletion recorded
ConfidentialityWritten obligations on everyone who works with us, employees and contractors alike

4. The marketing-specific risks

This is the section that matters, and it is the one most agencies skip. Running paid media moves personal data in ways that are easy to miss, because the platforms make them one click deep.

Hashing is not anonymisation

A hashed email address in a Customer Match or Custom Audience upload is pseudonymised, not anonymous. It is still personal data, and sharing it with an advertising platform is still processing that needs a basis. Any agency that tells you hashing removes the obligation has told you something convenient rather than something true.

What we do about each
ActivityOur rule
Customer Match, Custom Audiences, lookalike seedsNo list goes to a platform until you confirm in writing that you have a lawful basis for sharing it. One email is enough. We keep that confirmation with the campaign record
Conversions API and server-side taggingConsent state is passed through to the server container. If a visitor refused advertising cookies, the server-side event does not fire for them either. This is the most commonly missed control in the entire stack
Offline conversion importsTreated exactly like an audience upload — same written confirmation, same record
Pixels on checkout and confirmation pagesBlocked until consent, like every other non-essential tag. Order value and identifiers are never sent ahead of it
Session recording and heatmapsInput masking on before the first recording, not after. Recordings start only after consent, and are excluded from pages where sensitive fields appear
Reporting and exportsAggregated by default. Customer-level data only where the analysis genuinely requires it, held for a stated period, then deleted
Audience and list expirySeeds and uploaded lists are refreshed and re-confirmed rather than left running indefinitely on a basis that may no longer hold

5. What we will not do

Stated plainly, because a list of commitments is only meaningful alongside the things we decline.

6. Subprocessors

We use third-party services to do the work. Which ones depends on your stack, and the list is agreed in the data processing agreement rather than assumed. The usual categories:

We tell you before we add a subprocessor that will handle your data, and you can object. A current named list for your engagement is available on request at any time.

7. If something goes wrong

You carry the notification obligation under the Act. We make it possible for you to meet it, which means our clock has to be faster than yours.

Our breach commitments
StepWhen
We tell youWithout delay, and in any event within 24 hours of becoming aware
First assessmentWhat happened, what data, how many people, what we have already contained
Full support packWithin 48 hours — the detail you need for your own report to the Data Protection Board, which is due within 72 hours
RemediationContainment first, then cause, then the change that stops it recurring, reported to you in writing

Our 24-hour and 48-hour commitments exist so your own 72-hour obligation to the Board is comfortable rather than tight. We would rather tell you about something that turns out to be nothing.

8. Requests from your customers

If one of your customers asks for access, correction or erasure, that request belongs to you — you are the Data Fiduciary and the decision is yours. What we do:

Under Rules 13 and 14 you have up to 90 days for grievances and erasure requests. Our turnaround is set to leave you most of that window.

9. What we need from you

Compliance here is genuinely shared, and three things from your side make the difference.

  1. A consent mechanism that actually blocks. If your banner fires tags before consent, nothing we do downstream can fix the basis. If it does not block today, we will tell you, and fixing it is work we can do.
  2. A clear answer on lawful basis for any list you want used. You do not need a legal memo. You need to be able to say how those customers were collected and what they were told.
  3. Notice of changes to your own privacy notice or stack. If you add a tool that collects personal data, or change what your notice says, the processing we run on your behalf may need to change with it.

10. Where we are

The Act's substantive obligations commence on 13 May 2027. We would rather show you our position than claim a finished one.

Our own readiness, honestly stated
ItemStatusTarget
Privacy notice meeting the Rule 3 content requirementsLiveDone
Named grievance contact publishedLive — Abhishek Mago, Founder & CEODone
Access control, named logins, revocation processOperatingDone
Rules on audience uploads and server-side consent stateOperatingDone
Our standard data processing agreementIn drafting, with counsel review to followDecember 2026
Consent banner with genuine tag-blocking on this siteIn buildDecember 2026
Full data map and documented retention schedulePlannedJune 2027

We are not a Significant Data Fiduciary and have not been designated as one, so the additional obligations under Section 10 — an India-based Data Protection Officer, an independent data auditor, annual impact assessments and algorithmic due diligence — do not currently apply to us. If that ever changes, this page will say so.

11. Contact

Data protection enquiries

Email
enquiry@arprconsulting.com
Grievance Officer
Abhishek Mago, Founder & CEO
Phone
+91 98734 42222
Acknowledgement
Within 2 business days

If you are running a vendor assessment and need this in your own questionnaire format, send it over. We answer them rather than asking you to accept a page.

This page describes our practices. It is not legal advice, and it does not replace the data processing agreement for your engagement — where the two differ, that agreement governs. See also our Privacy policy, Terms and conditions and Accessibility statement.