Privacy Policy

1. Introduction

Silver Hamster ("we", "our", or "us") operates globally and is committed to protecting the privacy and security of your personal data. This Privacy Policy applies to all users of our website and services worldwide, regardless of your location.

This policy complies with applicable data protection laws including, but not limited to, the General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), the UK Data Protection Act 2018, Brazil's Lei Geral de Proteção de Dados (LGPD), India's Digital Personal Data Protection Act (DPDPA), and other applicable regional regulations.

2. Data Controller / Data Fiduciary

Silver Hamster is the data controller responsible for your personal data — and, for individuals in India, the Data Fiduciary under the Digital Personal Data Protection Act, 2023 (DPDP Act). If you have questions about this policy or our data practices, contact us at:

• Email: privacy@silverhamster.com
• Grievance Officer (India): grievance@silverhamster.com
• Website: Contact Us

3. Information We Collect

3.1 Information You Provide

• Contact Information: Name, email address, company name, and phone number when you submit a contact form or request a consultation.
• Communication Data: Messages, feedback, and other content you send us through our website or email.
• Newsletter Subscriptions: Email address when you subscribe to our newsletter.

3.2 Information Collected Automatically

• Usage Data: Pages visited, time spent on pages, click patterns, and navigation paths.
• Device Information: Browser type, operating system, device type, screen resolution, and language preferences.
• Network Data: IP address (anonymized where required by law), approximate geographic location (country/region level only).
• Cookies and Similar Technologies: We use cookies and similar tracking technologies. See our cookie preferences for details.

3.3 Information from Third Parties

We may receive information about you from third-party services such as analytics providers, advertising partners, or social media platforms, only where you have consented to those third parties sharing your data.

4. How We Use Your Information

We process your personal data for the following purposes:

• Service Delivery: To respond to your inquiries, provide consultations, and deliver our services.
• Communication: To send you relevant information about our services, updates, and newsletters (with your consent).
• Website Improvement: To analyze usage patterns and improve our website's functionality and user experience.
• Legal Compliance: To comply with applicable laws, regulations, and legal processes.
• Security: To protect against fraud, unauthorized access, and other security threats.

5. Legal Basis for Processing (GDPR)

For users in the European Economic Area (EEA), UK, and other jurisdictions requiring a legal basis, we process your data based on:

• Consent: Where you have given clear consent for us to process your personal data (e.g., newsletter subscriptions).
• Contractual Necessity: Where processing is necessary to fulfill a contract or take steps prior to entering a contract with you.
• Legitimate Interests: Where processing is necessary for our legitimate business interests, provided these do not override your rights.
• Legal Obligation: Where processing is necessary for compliance with a legal obligation.

6. Data Sharing and Transfers

6.1 Third-Party Service Providers

We may share your data with trusted third-party service providers who assist us in operating our website and delivering our services. These providers are contractually obligated to protect your data and use it only for the purposes we specify.

6.2 International Data Transfers

As a global company, your data may be transferred to and processed in countries other than your own. When we transfer data internationally, we ensure appropriate safeguards are in place, including:

• Standard Contractual Clauses (SCCs) approved by the European Commission
• Adequacy decisions where applicable
• Binding Corporate Rules where relevant
• Your explicit consent where required

6.3 We Do Not Sell Your Data

We do not sell, rent, or trade your personal information to third parties for their marketing purposes. This applies globally, including under the CCPA's definition of "sale."

7. Your Rights

Depending on your location, you may have the following rights regarding your personal data:

• Right of Access: Request a copy of the personal data we hold about you.
• Right to Rectification: Request correction of inaccurate or incomplete data.
• Right to Erasure: Request deletion of your personal data (see our Data Deletion page).
• Right to Restrict Processing: Request that we limit how we use your data.
• Right to Data Portability: Receive your data in a structured, commonly used format.
• Right to Object: Object to processing based on legitimate interests or for direct marketing.
• Right to Withdraw Consent: Withdraw consent at any time where processing is based on consent.
• Right to Non-Discrimination: Exercise your rights without receiving discriminatory treatment (CCPA).

To exercise any of these rights, please contact us at privacy@silverhamster.com or visit our Data Deletion Request page.

8. Cookies and Tracking Technologies

We use cookies and similar technologies to enhance your browsing experience. Types of cookies we use include:

• Essential Cookies: Required for the website to function properly.
• Analytics Cookies: Help us understand how visitors interact with our website.
• Preference Cookies: Remember your settings and preferences (e.g., dark mode, country selection).

You can manage your cookie preferences through your browser settings. Note that disabling certain cookies may affect website functionality.

9. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes outlined in this policy, unless a longer retention period is required or permitted by law. Specifically:

• Contact form submissions: Retained for up to 2 years after your last interaction.
• Newsletter subscriptions: Retained until you unsubscribe.
• Analytics data: Retained in anonymized/aggregated form for up to 26 months.

10. Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These measures include:

• Encryption of data in transit (TLS/SSL)
• Regular security assessments and updates
• Access controls and authentication measures
• Employee training on data protection

11. Children's Privacy

Our website and services are not directed at individuals under the age of 16 (or the applicable age of digital consent in your jurisdiction). We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, please contact us and we will promptly delete it.

Under India's DPDP Act, we do not process the personal data of any individual under 18 years of age without verifiable consent from a parent or lawful guardian, and we do not undertake tracking, behavioural monitoring or targeted advertising directed at children.

12. Region-Specific Provisions

12.1 European Economic Area & United Kingdom

If you are located in the EEA or UK, you have the right to lodge a complaint with your local data protection authority if you believe we have not complied with applicable data protection laws.

12.2 California (CCPA/CPRA)

California residents have additional rights under the CCPA/CPRA, including the right to know what personal information is collected, the right to delete personal information, and the right to opt-out of the sale or sharing of personal information. We do not sell or share personal information as defined under the CCPA.

12.3 Brazil (LGPD)

If you are located in Brazil, you have rights under the LGPD including the right to confirmation of processing, access to data, correction, anonymization, portability, and deletion.

12.4 India (Digital Personal Data Protection Act, 2023)

If you are in India, we process your personal data as the Data Fiduciary under the Digital Personal Data Protection Act, 2023 (DPDP Act) and the rules made under it. The following applies to you as a Data Principal.

Consent & notice

We rely on your consent (or certain legitimate uses permitted by the DPDP Act) to process your personal data. Where we rely on consent, it is free, specific, informed, unconditional and unambiguous, given by a clear affirmative action, and limited to the purpose described to you at the point of collection. You can withdraw your consent at any time, as easily as you gave it, by contacting our Grievance Officer or using our Data Request page; withdrawal does not affect processing carried out before withdrawal.

Your rights as a Data Principal

• Access a summary of the personal data we process about you and the processing activities undertaken.
• Correction, completion and updating of your personal data.
• Erasure of your personal data where it is no longer required for the purpose it was collected.
• Grievance redressal — a readily available means to raise concerns with us (see below).
• Nomination — the right to nominate another individual to exercise your rights in the event of death or incapacity.
• Withdraw consent at any time.

Grievance Officer

For any questions, requests or grievances regarding your personal data, contact our Grievance Officer at grievance@silverhamster.com. We will respond within the timelines prescribed by the DPDP Act and its rules. If your grievance is not resolved to your satisfaction, you may escalate it to the Data Protection Board of India.

Retention

We retain your personal data only for as long as necessary to fulfil the stated purpose or to meet a legal obligation, after which it is erased (see Section 9).

Personal data breach

In the event of a personal data breach, we will notify the affected Data Principals and the Data Protection Board of India without undue delay, in the manner and within the timeframe prescribed by the DPDP Act.

Processors & cross-border transfer

We remain responsible for your personal data even when processing is carried out by a Data Processor (such as a cloud, hosting or communications provider) engaged under contract. Your data may be processed outside India; the DPDP Act permits such transfers except to countries or territories restricted by the Central Government of India.

13. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable laws. We will notify you of any material changes by posting the updated policy on this page and updating the "Last updated" date. We encourage you to review this policy periodically.

14. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

• Email: privacy@silverhamster.com
• Grievance Officer (India, DPDP Act): grievance@silverhamster.com
• Contact Form: silverhamster.com/contact