Privacy Policy
How Pragya Jain Ltd collects, uses, shares and protects personal information — on this website and in the campaigns we operate.
1. Who we are
Pragya Jain Ltd (“Pragya Jain Ltd”, “we”, “us”, “our”) is a private limited company registered in England and Wales, with its registered office at 22 Malvern Road, Handsworth, Birmingham, England B21 0AT, United Kingdom.
We are a performance marketing company. We operate this website, and we plan and run advertising campaigns on behalf of our clients and on our own account. This policy explains what we do with personal information in both of those roles.
For information collected through this website, Pragya Jain Ltd acts as a data controller. For information we process while running campaigns on behalf of a client, we generally act as a data processor on that client's instructions, and the client's own privacy policy will also apply.
2. Information we collect
2.1 Information you give us
When you submit our contact form, email us or call us, we collect the information you choose to provide, which typically includes:
- Name and job title
- Brand or company name and store URL
- Email address and telephone number
- Budget range and the details of your enquiry
- Any other information you include in your message
2.2 Information collected automatically
When you visit this website, we and our analytics providers may automatically collect:
- IP address (which may be truncated or anonymised)
- Browser type, operating system and device type
- Referring URL and pages viewed on this site
- Date, time and duration of your visit
- General geographic location inferred from IP address (typically city level)
- Cookie and similar identifiers, where you have consented to them
2.3 Information collected through campaigns
When we operate advertising campaigns, we may process information about people who interact with those campaigns, including click identifiers, advertising IDs, conversion and purchase events. Where this is done for a client store, that client determines the purposes of the processing and is the controller of that data, and we act as its processor.
3. How we use information
We use personal information to:
- Respond to your enquiry and communicate with you about it
- Provide, operate and improve our services
- Plan, run, measure and optimise advertising campaigns
- Attribute conversions and detect invalid, fraudulent or bot traffic
- Produce reporting for clients and for our own analysis
- Maintain security and prevent abuse of our systems
- Comply with legal, tax, accounting and regulatory obligations
- Enforce our Terms of Service and other agreements
We do not sell personal information, and we do not add enquiry contacts to marketing lists without their consent.
4. Legal bases for processing (GDPR)
Where the EU or UK General Data Protection Regulation applies, we rely on the following legal bases:
| Purpose | Legal basis |
|---|---|
| Responding to your enquiry | Legitimate interests, or steps prior to entering a contract |
| Providing services to clients | Performance of a contract |
| Analytics and advertising cookies | Consent |
| Security, fraud and abuse prevention | Legitimate interests |
| Legal, tax and accounting records | Compliance with a legal obligation |
Where we rely on legitimate interests, we have assessed that our interest in operating and marketing our business is not overridden by your rights and freedoms. You may object to this processing at any time (see section 9).
5. Cookies and similar technologies
Cookies are small files stored on your device. We use the following categories:
| Category | Purpose | Consent required |
|---|---|---|
| Strictly necessary | Page delivery, security and basic site function | No |
| Analytics | Understanding how visitors use the site (e.g. Google Analytics 4) | Yes |
| Advertising | Measuring campaign performance and attributing conversions | Yes |
You can control cookies through your browser settings, including blocking or deleting them. Blocking strictly necessary cookies may prevent parts of the site from working. Where consent is required in your jurisdiction, analytics and advertising technologies are only loaded after that consent is given.
6. Advertising and measurement technologies
In operating campaigns, we use measurement and attribution technologies including Google Analytics 4 with server-side event collection, and conversion APIs provided by advertising platforms such as Meta, TikTok and Google, together with email and SMS platforms such as Klaviyo where a client uses them.
These technologies process identifiers such as click IDs, hashed contact identifiers, IP addresses and conversion events. Where hashed identifiers are transmitted to an advertising platform for conversion matching, this occurs only where a lawful basis exists and, where required, consent has been obtained.
Each platform processes that information under its own privacy policy and as an independent or joint controller, depending on the arrangement.
7. Sharing your information
We share personal information only with:
- Service providers who process data on our behalf — hosting, email delivery, form processing, analytics, tracking and CRM providers — under contracts requiring them to protect it and use it only for our instructions.
- Advertising platforms, for campaign delivery, conversion measurement and reconciliation.
- Professional advisers such as accountants, auditors and lawyers, where necessary.
- Authorities, where required by law, court order or to protect our legal rights.
- An acquirer, in connection with a merger, acquisition or sale of assets, subject to this policy continuing to apply.
We do not sell personal information, and we do not share it with third parties for their own independent marketing purposes.
8. Data retention
We keep personal information only as long as necessary for the purposes it was collected for:
- Enquiries that do not become clients — up to 24 months from last contact
- Client records — for the duration of the engagement and up to 7 years afterwards, to meet tax and accounting obligations
- Campaign and analytics data — typically up to 26 months, or as configured in the relevant platform
- Client store and customer data — processed only within the client’s own accounts and returned or deleted in line with the client agreement
9. Your rights
Subject to your jurisdiction, you may have the right to:
- Access the personal information we hold about you
- Have inaccurate information corrected
- Request deletion of your information
- Restrict or object to certain processing
- Receive your information in a portable format
- Withdraw consent at any time, without affecting prior processing
- Lodge a complaint with the Information Commissioner’s Office (ICO) or your local data protection authority
To exercise any of these rights, email contact@pragyajainltd.online. We respond within one month, and we may need to verify your identity first. Exercising your rights is free of charge unless a request is manifestly unfounded or excessive.
10. UK data protection and the ICO
We process personal information in line with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018 and the Privacy and Electronic Communications Regulations (PECR). Where we process information about individuals in the European Economic Area, we also apply the EU GDPR.
Pragya Jain Ltd does not sell personal information. To exercise any of your rights, contact contact@pragyajainltd.online with the subject line “Privacy Rights Request”. Someone you authorise may submit a request on your behalf with written proof of authorisation. If you are unhappy with how we have handled your information, you can complain to the Information Commissioner’s Office at ico.org.uk.
11. Security
We maintain administrative, technical and physical safeguards appropriate to the sensitivity of the information we hold, including encryption in transit, role-based access control, access review on personnel change, and revocation of access at the end of an engagement. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.
12. International transfers
We are based in the United Kingdom, and some of our service providers may process data in other countries, including the United States. Where personal information is transferred out of the United Kingdom or the European Economic Area, we rely on appropriate safeguards such as the UK International Data Transfer Agreement or Addendum, the European Commission's Standard Contractual Clauses, or an applicable adequacy decision or data bridge.
13. Children
Our services are directed at businesses and are not intended for children. We do not knowingly collect personal information from anyone under 16. If you believe a child has provided us with personal information, contact contact@pragyajainltd.online and we will delete it.
14. Third-party websites
This website may link to third-party sites. We are not responsible for their content or privacy practices, and we encourage you to read their policies before providing them with personal information.
15. Changes to this policy
We may update this policy to reflect changes in our practices or in the law. The “last updated” date at the top of this page shows when it was last revised. Material changes will be made prominent on this page. Continuing to use this website after a change indicates acceptance of the revised policy.
16. Contact us
For any privacy question or to exercise your rights:
Pragya Jain Ltd
22 Malvern Road, Handsworth
Birmingham B21 0AT
England, United Kingdom
Email: contact@pragyajainltd.online