Privacy Policy

This Privacy Policy explains how FlickerBytes Private Limited ("FlickerBytes", "we", "us") handles personal data when you visit flickerbytes.com or contact us. It covers this marketing website only. The Niyam product has its own privacy terms, which apply once you create an account.

For the personal data you give us through this website, FlickerBytes is a Data Fiduciary under India's Digital Personal Data Protection Act, 2023 ("DPDP Act"), and a controller under the UK and EU General Data Protection Regulation where that applies to you.

What we collect

We do not use analytics, advertising, profiling or tracking technologies on this website, and we do not build behavioural profiles of visitors.

Cookies, and what we actually use instead

To be precise, because this is the kind of claim we ask our own customers to get right: this website sets no cookies at all.

What it does use is a single browser local storage entry:

Neither entry is used to track you across other websites, and neither is shared with anyone. We choose your region from your browser's timezone setting rather than by looking up your IP address with a geolocation service, so nothing about your location is sent to a third party.

This identifier is created by the consent mechanism itself, which is why it is classed as strictly necessary: without an identifier there is nothing to attach a consent decision to, and no way to honour a later withdrawal. If we introduce any non-essential storage in future, it will be placed behind consent and added to this table before it goes live.

Managing and withdrawing consent

Consent on this site is collected and managed through Niyam's own Consent & Preferences widget, which appears on every page. You can reopen it at any time to review your choices, change a category, or withdraw consent entirely. Withdrawing consent is as straightforward as giving it and takes effect immediately; you do not need to email us to do it.

Withdrawal does not affect the lawfulness of anything we did before you withdrew.

Why we are allowed to process it

Under the DPDP Act we rely on one of two bases, and no others:

The DPDP Act does not contain a general "legitimate interests" basis, and we do not claim one. Where the UK or EU GDPR applies to you, our corresponding bases are your consent (Article 6(1)(a)) and our legitimate interests in responding to a business enquiry and in securing the site (Article 6(1)(f)).

What we use it for

We do not sell personal data, we do not share it for anyone else's marketing, and we do not use it for advertising or behavioural targeting.

Who else processes it, and where

We use a small number of processors. Each acts on our instructions under contract. These are the only third parties that receive personal data from this website:

We host our website fonts ourselves rather than loading them from a third-party font service, so visiting this site does not disclose your IP address to a font provider.

Transfers outside India

Because of the processors above, personal data you submit may be processed outside India. We transfer personal data only to countries not restricted under section 16 of the DPDP Act, and we place contractual protections on each processor. Where the UK or EU GDPR applies, transfers outside the UK or EEA are made under the UK International Data Transfer Addendum or the European Commission's Standard Contractual Clauses, together with any additional measures those require.

How long we keep it

We erase personal data when you withdraw consent, or when the purpose it was collected for is no longer being served, unless we are required to retain it to comply with a legal obligation, as section 8(7) of the DPDP Act requires.

Your rights

As a Data Principal under the DPDP Act you have the right to:

To exercise any of these, contact Compliance1@flickerbytes.com.

You can also complain to the Data Protection Board of India. You are not required to come to us first, though we would rather have the chance to put something right. The Board's complaint procedure is published by the Board itself.

If you are in the UK or the European Economic Area

We offer our products in the UK and the EEA, including pricing in local currency, so the UK and EU GDPR may apply to you. In that case you additionally have the rights of access, rectification, erasure, restriction, portability and objection, and the right to complain to your national supervisory authority.

We have not yet appointed a representative in the Union or the UK for the purposes of Article 27 GDPR; we are in the process of doing so. Until we have, EU and UK data subjects can exercise any right under this policy by contacting us directly using the details above or in the Contact section below.

Children

This website and our products are intended for businesses and the people who work in them. They are not directed at children, and we do not knowingly collect the personal data of anyone under 18. We do not track, profile or direct advertising at children. If we learn that we have collected a child's personal data without verifiable parental consent, we will erase it. If you believe a child has given us personal data, contact Compliance1@flickerbytes.com and we will act on it.

Security

We apply reasonable technical and organisational safeguards, including encryption in transit and at rest, role-based access control and logging. Our current security posture, including which standards we are certified against and which we are still working toward, is set out honestly on our Security & Trust page.

If something goes wrong

If a personal data breach occurs, we will notify the Data Protection Board of India and each affected Data Principal in the form and within the timeframes required by the DPDP Act and the DPDP Rules, and we will tell you what happened, what it affects and what we are doing about it. Where the UK or EU GDPR applies, we will also notify the relevant supervisory authority as those regulations require.

Language

This notice is published in English. You may request it in any language listed in the Eighth Schedule to the Constitution of India, as section 5(3) of the DPDP Act provides. Contact Compliance1@flickerbytes.com and we will provide it.

Changes to this policy

We update this policy when our processing changes - including whenever we add or remove a third-party script or processor on this website. The "last updated" date above always reflects the current version.

Contact and grievances

For any privacy question, rights request or grievance, contact our Grievance Officer, Richa Goyal, at Compliance1@flickerbytes.com or call +91 96723 70157. For sales enquiries, use sales.niyam@flickerbytes.com.