Privacy Policy

1. Introduction

Welcome to ThinkUnlimited Media LLP ("we", "our", "us"). We operate the website thinkunlimited.media and the StepVista directory platform, along with lead management services powered by the WhatsApp Business API.

This Privacy Policy explains how we collect, use, store, share, and protect your personal data. It is drafted in compliance with:

• India's Digital Personal Data Protection (DPDP) Act, 2023
• Meta's WhatsApp Business API Policies (2026)
• General principles of data minimization, purpose limitation, and user transparency

By using our website, submitting a contact form, or interacting with us via WhatsApp, you agree to the terms of this Privacy Policy.

2. Data Controller (Data Fiduciary)

Under the DPDP Act, ThinkUnlimited Media LLP acts as the Data Fiduciary responsible for determining the purpose and means of processing your personal data.

3. What Personal Data We Collect

We practice data minimization — we only collect what is strictly necessary for the stated purpose.

3.1 Data You Provide Directly

• Name — to address you personally
• Phone Number — to communicate via WhatsApp or call
• Email Address — to send follow-up communications
• Message / Inquiry — to understand your requirements

3.2 Data Collected Automatically

• IP Address & Browser Type — for website security and analytics
• Pages Visited & Time Spent — via Google Analytics (anonymized)
• Device & OS Information — for optimizing user experience

3.3 WhatsApp Business API Data

When you interact with us via WhatsApp Business, we may collect your WhatsApp display name, phone number, and message content, solely for responding to your inquiry. We do not initiate contact without your explicit opt-in consent.

4. How We Use Your Personal Data

We use your data for the following purposes only:

• Responding to inquiries and providing requested services
• Managing leads through our internal lead management portal
• Communicating with you via WhatsApp Business API (with your prior opt-in)
• Improving our website and services through analytics
• Complying with legal obligations

We do not sell, rent, or trade your personal data to third parties for marketing purposes.

5. Opt-In & Consent for WhatsApp Communications

In accordance with Meta's WhatsApp Business API policies, we will only send you WhatsApp messages if you have explicitly opted in. Opt-in is obtained through:

• A checkbox on our contact/inquiry form (unchecked by default)
• A verbal or written request from you to be contacted via WhatsApp
• Initiating a WhatsApp conversation with our business number yourself

You may opt out at any time by replying "STOP" to any WhatsApp message or by emailing us at tech@thinkunlimited.in.

6. Artificial Intelligence & Automated Processing Disclosure

We use automated systems and artificial intelligence (AI) tools to assist in processing and triaging lead inquiries. This may include:

• Automated categorization and routing of inquiry messages
• AI-assisted response drafting for our internal team (not sent without human review)
• Analytics and sentiment analysis on aggregate, anonymized inquiry data

No fully automated decision-making with significant legal or personal effect is applied to your data. A human team member reviews and approves all significant actions. You have the right to request human review of any automated outcome that affects you.

7. Data Retention

We retain your lead data (name, phone number, email, and message) for a period of 12 months from the date of collection, unless:

• You request earlier deletion (see Section 9 — Your Rights)
• A longer retention period is required by applicable law
• An active contractual relationship exists, in which case data is retained for the duration of the contract plus 12 months

Upon expiry of the retention period, your data is securely deleted or anonymized so it can no longer be linked to you.

8. Data Sharing & Third-Party Processors

We share your data only with trusted service providers who are contractually bound to protect it:

• Meta Platforms, Inc. — to deliver WhatsApp Business API messaging. Governed by Meta's Privacy Policy.
• Web3Forms — our contact form submission processor.
• Google Analytics — anonymized website usage data. You may opt out via the Google Analytics Opt-out Add-on.
• Cloudflare — website hosting and CDN, may process your IP for security purposes.

9. Your Rights Under the DPDP Act

As a Data Principal under India's DPDP Act, 2023, you have the following rights:

9.1 Right to Access

You may request a summary of the personal data we hold about you and the purposes for which it is processed.

9.2 Right to Correction

You may request that we correct any inaccurate or incomplete personal data we hold about you.

9.3 Right to Erasure ("Right to Be Forgotten")

You may request permanent deletion of your personal data. We will action such requests within 30 days, except where retention is required by law.

9.4 Right to Withdraw Consent

Where processing is based on your consent (e.g., WhatsApp opt-in), you may withdraw it at any time. Withdrawal does not affect the lawfulness of processing before withdrawal.

9.5 Right to Grievance Redressal

You have the right to raise a grievance with us. We will respond within 30 days. If unsatisfied, you may escalate to the Data Protection Board of India once constituted under the DPDP Act.

To exercise any of the above rights, email us at tech@thinkunlimited.in with the subject line "DPDP Data Request".

10. Data Security

We implement appropriate technical and organizational measures to protect your data, including:

• HTTPS encryption for all data in transit
• Access controls limiting data access to authorized personnel only
• Regular security reviews of our systems and third-party integrations

11. Cookies & Tracking Technologies

Our website uses cookies for analytics (Google Analytics) and functional purposes. These cookies do not collect personally identifiable information in isolation. You can control cookie preferences through your browser settings.

12. Children's Privacy

Our services are not directed at individuals under the age of 18. We do not knowingly collect personal data from minors. If you believe a minor has submitted data to us, please contact us immediately for deletion.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. The "Last Updated" date at the top will always reflect the most recent revision. For material changes, we will notify you via email or a prominent notice on our website.

14. Contact Us

For any privacy-related queries, requests, or grievances: