Legal
GDPR Alignment
Version 1.0 · Effective 21 June 2024
1. Our Position
Sahayogi One Private Limited is an Indian company incorporated under the Companies Act, 2013. We are headquartered in Noida, Uttar Pradesh, India, and our products and services are primarily designed for Indian businesses, professionals, and individuals.
Our primary data protection framework is India's Digital Personal Data Protection Act, 2023 (DPDP Act). Our DPDP Act compliance is described in full at /legal/dpdp-act.
On GDPR: The EU General Data Protection Regulation (GDPR) applies to organisations that are established in the European Economic Area (EEA), or that offer goods or services to individuals in the EEA, or that monitor the behaviour of individuals in the EEA. If any of these conditions apply to our activities, we are committed to meeting our GDPR obligations for affected data.
Sahayogi is not EU GDPR certified. However, the principles underlying the GDPR — lawful processing, purpose limitation, data minimisation, accuracy, storage limitation, security, and accountability — are principles we apply to all personal data we process, regardless of where the data subject is located. Our DPDP Act compliance framework substantially implements these principles for all users.
This page explains how our data practices align with GDPR principles, and what additional rights EEA-based users may have.
2. GDPR Principles and How We Apply Them
The GDPR establishes seven data protection principles. This section explains how Sahayogi implements each principle across its products.
Principle 1 — Lawfulness, Fairness, and Transparency
GDPR requirement: Personal data must be processed lawfully, fairly, and transparently.
How we apply it: We process personal data only on the lawful bases described in our Privacy Policy — primarily contractual necessity (to provide the service you signed up for), legitimate interests (to improve our products and prevent fraud), legal obligation (to comply with Indian law), and consent (for marketing and analytics). We document our lawful basis for each processing activity. We publish our Privacy Policy, DPDP Act Compliance page, and this GDPR Alignment page to be transparent about how we process data.
Principle 2 — Purpose Limitation
GDPR requirement: Data collected for one purpose must not be used for a different, incompatible purpose.
How we apply it: We collect data for specific purposes described in our Privacy Policy and do not repurpose it for incompatible uses without obtaining fresh consent. For example, operational data entered into BoSS by a client is used to provide the BoSS service — not for Sahayogi's marketing or analytics.
Principle 3 — Data Minimisation
GDPR requirement: Only data that is necessary for the specified purpose should be collected.
How we apply it: We collect only the personal data fields required to provide each product or service. We review our data collection practices periodically to ensure we are not collecting data that is not needed. For example, Tax Sahayogi collects tax-related information relevant to query resolution — not broader personal data fields that are not relevant to that service.
Principle 4 — Accuracy
GDPR requirement: Personal data must be accurate and kept up to date.
How we apply it: Users can update their account information at any time through their account settings or by writing to us. We encourage users to keep their information current. Where we hold data provided by client organisations (such as employee data in BoSS), we rely on the client to maintain accuracy for that data, as the client is the Data Fiduciary for that data.
Principle 5 — Storage Limitation
GDPR requirement: Personal data should not be kept longer than necessary for the purpose.
How we apply it: We maintain data retention periods for all categories of personal data, as described in our Privacy Policy. Data is deleted or anonymised when its retention period expires or when the purpose for which it was collected no longer applies (subject to mandatory legal retention requirements under Indian law).
Principle 6 — Integrity and Confidentiality (Security)
GDPR requirement: Personal data must be processed securely, protected against unauthorised access, loss, or destruction.
How we apply it: We implement security measures aligned with ISO 27001 principles across our products and infrastructure — including encryption in transit and at rest, role-based access controls, access logging, and regular security reviews. Full details are in our Security Policy (/legal/security-policy).
Principle 7 — Accountability
GDPR requirement: The data controller must be able to demonstrate compliance with all principles.
How we apply it: We maintain internal records of our data processing activities. We document our lawful bases, retention periods, and data sharing arrangements. We publish our privacy documentation publicly. We have a designated contact for data protection queries and grievances (see Section 6).
3. GDPR Lawful Bases
Where GDPR applies to our processing of personal data of EEA-based individuals, we rely on the following lawful bases under Article 6 GDPR:
| Processing Activity | Lawful Basis |
|---|---|
| Providing contracted Sahayogi products and services | Article 6(1)(b) — Performance of a contract |
| Managing accounts and user authentication | Article 6(1)(b) — Performance of a contract |
| Complying with Indian legal obligations | Article 6(1)(c) — Legal obligation |
| Security monitoring and fraud prevention | Article 6(1)(f) — Legitimate interests |
| Product improvement and analytics | Article 6(1)(f) — Legitimate interests (or consent where required) |
| Marketing communications | Article 6(1)(a) — Consent |
| Cookie processing beyond strictly necessary | Article 6(1)(a) — Consent |
For any processing of special categories of personal data (sensitive data under Article 9 GDPR) — such as health data or financial data that qualifies as special category — we rely on explicit consent under Article 9(2)(a) or other applicable grounds.
4. Rights of EEA-Based Data Subjects
If you are located in the European Economic Area, you have the following rights under the GDPR in addition to the rights provided under the DPDP Act:
Right of Access (Article 15)
You have the right to obtain a copy of your personal data and information about how it is processed.
Right to Rectification (Article 16)
You have the right to have inaccurate personal data corrected and incomplete data completed.
Right to Erasure (Article 17)
You have the right to request deletion of your personal data where it is no longer necessary, where consent has been withdrawn, where you object to processing, or where processing was unlawful. This right is subject to mandatory retention periods.
Right to Restriction of Processing (Article 18)
You have the right to request that processing of your personal data is restricted in certain circumstances — for example, while the accuracy of data is contested, or where processing is unlawful but you prefer restriction to erasure.
Right to Data Portability (Article 20)
Where processing is based on consent or contract and is carried out automatically, you have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit it to another controller.
Right to Object (Article 21)
You have the right to object to processing based on legitimate interests. We will cease processing unless we can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms, or where processing is for the establishment, exercise, or defence of legal claims.
Right to Withdraw Consent (Article 7(3))
Where processing is based on consent, you may withdraw consent at any time without affecting the lawfulness of processing before withdrawal.
Right to Lodge a Complaint
You have the right to lodge a complaint with your national data protection supervisory authority in the EEA if you believe your rights under GDPR have been violated.
To exercise any of these rights, write to info@sahayogi.in with subject “GDPR Rights Request — [Right Being Exercised]”. We will respond within 30 days as required by GDPR.
5. International Data Transfers
Sahayogi One Private Limited is an Indian company. If you are located in the EEA and use our services, your personal data is transferred to and processed in India.
India is not currently recognised by the European Commission as providing an “adequate” level of data protection under Article 45 GDPR. Where GDPR applies to our processing of EEA personal data, we rely on the following safeguards for international transfers:
- Standard Contractual Clauses (SCCs): Where required, we use the European Commission's Standard Contractual Clauses for international transfers of personal data from the EEA to India.
- Your Explicit Consent: In certain circumstances, we may rely on your explicit consent to the transfer after being informed of the risks (Article 49(1)(a) GDPR).
As India's DPDP Act matures and international transfer frameworks are established, we will update our transfer mechanisms accordingly.
6. Data Protection Contact
For GDPR-related queries, rights requests, and complaints from EEA-based individuals:
Sahayogi One Private Limited
Email: info@sahayogi.in
Subject: “GDPR — [Your Request/Query]”
We acknowledge all GDPR requests within 72 hours and aim to respond within 30 days. Complex requests may take up to 90 days with prior notification of the extension.
If you are dissatisfied with our response, you have the right to lodge a complaint with your national data protection supervisory authority in the EEA — for example, the Irish Data Protection Commission (for EU matters) or the UK Information Commissioner's Office (for UK GDPR matters post-Brexit).
7. Scope and Limitations
This page applies to: EEA-based individuals whose personal data is processed by Sahayogi One Private Limited in circumstances where GDPR applies.
This page does not apply to: Data processed by Investor Sahayogi Partnership Firm, which is a separate legal entity with its own privacy and compliance framework.
Not a GDPR certification: This page describes Sahayogi's alignment with GDPR principles. It is not a certification of full GDPR compliance. Sahayogi One Private Limited has not undergone a formal GDPR audit and is not certified under any EU data protection framework.
8. Updates
We will update this page as our product scope, user base, or applicable legal frameworks change. Material updates will be communicated to registered users by email.
Sahayogi One Private Limited | CIN: U62010UP2024PTC205006 · GDPR Alignment Version 1.0