Privacy Policy

Premkumar Ragav — Senior Performance Marketing Specialist
Last updated: 31 July 2026  ·  Effective: 31 July 2026

The short version. If you message me on Instagram or Facebook, or comment on my posts, I use an AI assistant to reply and to note down what you need. I collect your name, email, phone number and business details only if you choose to give them, and only to answer your enquiry. I don't sell your data or add you to marketing lists. Reply STOP in any conversation to end all automated messages, or email me to have your data deleted.

1. Who I am

I am Premkumar Ragav, an independent senior performance markerting consultant operating as a sole proprietor from Kallakurichi, Tamil Nadu, India. I am the data controller (and, under India's Digital Personal Data Protection Act, 2023, the Data Fiduciary) responsible for the personal data described in this policy.

ContactDetail
NamePremkumar Ragav
Trading asPremkumar Ragav
Email[email protected]
Websitehttps://premkumarragav.in
Instagram@premkumarragav
Facebook Pagehttps://www.facebook.com/profile.php?id=61580841087422
Grievance OfficerPremkumar Ragav — [email protected]

2. What this policy covers

This policy applies to personal data I collect when you:

It does not cover Instagram, Facebook, or any other third-party platform itself. Your use of those platforms is governed by their own privacy policies. It also does not cover personal data belonging to my clients' customers that I may process while delivering advertising services — that data is handled under a separate agreement with the client concerned, who remains its controller.

3. Data I collect

3.1 Data you give me directly

When you message me, my assistant may ask for the following. All of it is optional — you decide what to share, and you can decline any question and still get a reply.

3.2 Data I receive automatically from Meta

When you interact with my Instagram account or Facebook Page, Meta's platform sends me:

3.3 What I do not collect

If you volunteer sensitive information in a message, I will not record it in my records and will ask you not to send it again.

4. Why I collect it

PurposeData used
Reply to your enquiry and answer your questionsMessage content, user ID, name
Understand what service you need and whether I can helpBusiness details, need, budget, timeline
Follow up on a conversation you startedName, email, phone, user ID
Schedule and prepare for a callName, email, phone, business details
Honour your opt-out so I don't message you againUser ID and opt-out flag only
Reply to and moderate comments on my own postsComment content, username
Keep records of enquiries and improve how I answer themAnonymised or aggregated conversation themes
Meet legal, tax and accounting obligationsClient billing details only

I do not: sell, rent or trade your personal data; add you to a marketing mailing list without your explicit separate consent; use your data to build advertising audiences; send you unsolicited messages; or share your details with other businesses for their own marketing.

5. Legal basis for processing

Where India's Digital Personal Data Protection Act, 2023 applies, I process your data on the basis of the consent you give by voluntarily starting a conversation with me and choosing to share details, having been given this notice.

Where the EU or UK GDPR applies, my legal bases are:

You can withdraw consent at any time. Withdrawal does not affect processing that already lawfully took place, and I will retain the minimum record needed to respect your withdrawal.

6. Automated processing and AI

Please read this section. Conversations on my Instagram and Facebook accounts are handled in part by an AI assistant, not by me personally, particularly outside working hours.

Specifically:

Message text is sent to a third-party AI provider (see section 7) purely to generate the reply. It is not used to train that provider's public models under the API terms I operate under.

You always have a right to a human. Ask to speak to a person at any point and the automation stops for your conversation — permanently — and I take over personally.

No decision is made about you by automated means alone that has a legal or similarly significant effect. The assistant gathers information and drafts replies; whether I take you on as a client is always my own decision.

7. Who I share data with

I use a small number of service providers (processors) to run my business. Each receives only the data necessary for its function.

ProviderPurposeLocation
Meta PlatformsDelivers the Instagram and Facebook messages and comments themselvesUSA / global
Google — Sheets & DriveStores my enquiry recordsUSA / global
Google — Gemini APIGenerates AI replies and classifies commentsUSA / global
n8n (self-hosted)Automation connecting the above. Runs on infrastructure I control.India (self-hosted)
TelegramSends me internal alerts about enquiries needing my attentionGlobal
GmailEmail correspondenceGlobal
Accountant / tax advisorStatutory accounts and client invoices onlyIndia

I may also disclose data where I am legally required to — for example in response to a valid order from a court, tax authority, or law enforcement — or where necessary to establish or defend a legal claim.

If I ever transfer my business, enquiry records may transfer with it. You would be told before that happened and given the chance to have your data deleted first.

8. Where data is stored

Enquiry records are held in a private Google Workspace account protected by a strong unique password and two-factor authentication. Automation runs on my own self-hosted n8n instance over an encrypted HTTPS connection. Message content in transit is encrypted. Access credentials are stored in a password manager and in n8n's encrypted credential store, never in plain text.

Only I have access to the enquiry records. I have no employees. If I engage a contractor who needs access, they will be bound by a written confidentiality agreement.

9. How long I keep it

RecordRetention
Enquiry that did not become a client24 months from last contact, then deleted
Conversation message logs12 months, then deleted
AI conversation memoryRolling — only the most recent messages in a conversation are retained
Client records and contractsDuration of engagement, then as required by Indian tax law
Invoices and financial records8 years, as required by Indian law
Opt-out recordIndefinitely — the minimum needed to keep honouring your opt-out

The opt-out record is deliberately kept after everything else is deleted. It contains only your platform user ID and a flag. Without it I could not reliably guarantee I would never message you again.

10. Your rights

Whatever jurisdiction you are in, you can ask me to:

There is no charge, and I will respond within 30 days. I may need to verify you control the account making the request — usually by asking you to send it from the same Instagram or Facebook account, or the email address on file.

11. Requesting Data Deletion

You may ask me to delete all personal data I hold about you at any time, for any reason, without explanation.

Choose whichever is easiest:

  1. Message me on the Instagram or Facebook account you used, with the word DELETE. Sending STOP will also stop all automated messages immediately.
  2. Email [email protected] with the subject line Data deletion request. Include the Instagram handle, Facebook name, or email address you used so I can find your record.

What happens next:

What I may have to keep, and why:

Messages held inside Instagram or Facebook themselves are controlled by Meta, not me. To remove those, delete the conversation in the app and use Meta's own tools at accountscenter.instagram.com.

12. Stopping automated messages

Reply with any of STOP, UNSUBSCRIBE, or OPT OUT in a conversation with me on Instagram or Facebook. All automated messaging to you ends immediately and permanently. You will get one confirmation message and then nothing further.

Opting out does not delete your data — those are separate requests. Ask for both if you want both. And opting out does not stop you reaching me: if you message again, a human will reply.

13. Security

I take reasonable technical and organisational measures appropriate to a sole-proprietor business:

No system is completely secure. If a breach occurs that is likely to affect you, I will notify you and the relevant authority without undue delay — and, where the DPDP Rules apply, provide the Data Protection Board an initial report promptly and a detailed report within 72 hours.

14. Children

My services are for businesses and are not directed at anyone under 18. I do not knowingly collect data from children. If you believe a child has sent me personal data, email me and I will delete it promptly.

15. International transfers

Some providers in section 7 process data outside India, principally in the United States. Where the GDPR applies, such transfers rely on the European Commission's Standard Contractual Clauses or an applicable adequacy decision, as set out in each provider's own terms. Where the DPDP Act applies, transfers are made to countries not restricted by the Central Government.

16. Cookies

This page sets no cookies and runs no analytics or tracking scripts.

17. Changes to this policy

I may update this policy as my tools or the law change. The "Last updated" date at the top always reflects the current version. If a change materially affects how I handle your data, I will take reasonable steps to tell you — for example by message if we have an open conversation. Continuing to message me after a change means you accept the updated policy.

18. Contact and grievances

For any question or request about your data, or to raise a complaint:

Email[email protected]
Subject line to usePrivacy request or Data deletion request
Response timeAcknowledged within 3 working days; resolved within 30 days
Grievance OfficerPremkumar Ragav, Kallakurichi, Tamil Nadu, India

If you are not satisfied with my response, you may escalate to:

I would rather you came to me first. Most concerns I can fix the same day.