Privacy Policy
Last updated
This Privacy Policy explains how personal data is collected, used, shared, stored, and protected when you visit frametofunnel.com (the “Website”) or interact with the Frame to Funnel podcast (the “Podcast”). Frame to Funnel is produced by LowLightKing Productions Pvt Ltd, a company incorporated in India (“LowLightKing Productions”, “we”, “us”, or “our”). We are committed to protecting your privacy in accordance with the Digital Personal Data Protection Act, 2023 (the “DPDP Act”), the Information Technology Act, 2000 and the rules framed under it, including the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (“SPDI Rules”).
1. Who we are (Data Fiduciary)
For the purposes of the DPDP Act, LowLightKing Productions Pvt Ltd is the Data Fiduciary that determines the purpose and means of processing your personal data. You are the Data Principal — the individual to whom the personal data relates. Our registered office is:
LowLightKing Productions Pvt Ltd
43/2153 E1, Jewel Homes, Whitefield, SRM Road, Lissie Junction
Ernakulam, Kerala, India – 682018
CIN: U92490KL2022PTC074053 · GSTIN: 32AAECL9221H1ZP
2. Personal data we collect
We collect only the personal data we need to run the Website and the Podcast:
- Email subscription data — your email address, and the consent text and timestamp recorded when you subscribe.
- Contact-form data — your name, email address, company (optional), and the message you send us.
- Dark-Funnel Video Audit data — your answers to the diagnostic questions, the resulting score and tier, your self-reported source, and, if you choose to reveal your full result, your email address and consent record.
- Technical data — your IP address, browser type, device information, and request time, contained in standard server logs generated by our hosting provider for security and abuse-prevention.
- Campaign data — UTM parameters (source, medium, campaign) present in the links you arrive through, used to understand how people find the Podcast.
We do not knowingly collect sensitive personal data (such as financial, health, or biometric information), and we ask that you do not submit such information through our forms.
3. How we collect personal data
We collect personal data directly from you when you complete a form on the Website (subscribe, contact, or the Audit). We collect technical and campaign data automatically when you visit the Website. We use privacy-first, cookie-less web analytics to measure aggregate traffic and performance; this does not build an individual profile of you. We do not buy personal data about you from third parties.
4. Purposes and legal basis for processing
Under the DPDP Act we process your personal data on the basis of your consent, which you give freely, specifically, and on an informed basis when you submit a form, and — for security and the lawful operation of the Website — for the legitimate uses permitted by the Act. We process personal data to:
- send you Podcast updates and related emails you have opted in to receive;
- respond to and manage the enquiry you submit through the contact form;
- deliver your Dark-Funnel Video Audit result and any resource you request;
- operate, secure, and improve the Website and prevent fraud, spam, and abuse;
- understand, in aggregate, how people discover and use the Podcast; and
- comply with applicable law and enforce our Terms of Service.
Each form states its single, specific purpose. We do not silently expand a request for one purpose into unrelated uses.
5. Consent and how to withdraw it
Where processing relies on your consent, that consent is obtained through an unchecked checkbox that you actively select — we never use pre-ticked boxes. Our email list uses double opt-in: you confirm your email address through a follow-up link before you are added. You may withdraw your consent at any time — using the unsubscribe link in every marketing email, or by contacting the Grievance Officer. Withdrawing consent is as easy as giving it, and does not affect the lawfulness of processing carried out before withdrawal. If you withdraw consent, we will stop the relevant processing and erase your personal data unless we are required to retain it by law.
6. Sharing and disclosure
We do not sell your personal data. We share personal data only with Data Processors who process it on our behalf, under contract and only on our instructions, to provide the Website and the Podcast:
- Cloudflare, Inc. — website hosting, content delivery, security, and privacy-first analytics.
- HubSpot, Inc. — our customer-relationship system of record for enquiries and confirmed subscribers.
- Our email service provider (Brevo) — sending confirmation and subscription emails and managing the mailing list.
- Resend / transactional email — sending you the emails you request, such as an Audit result.
- Cloudflare Turnstile — protecting forms from automated abuse.
- Captivate.fm — hosting and delivering Podcast audio embedded on the Website.
We may also disclose personal data where required to comply with a lawful order, to enforce our Terms, or to protect the rights, safety, and property of LowLightKing Productions or others.
7. Transfers outside India
Some of our processors store or process data on servers located outside India. Where personal data is transferred outside India, we do so in accordance with the DPDP Act and any restrictions notified by the Central Government, and we take reasonable steps to ensure your data continues to be protected to the standard described in this Policy.
8. Data retention
We keep personal data only for as long as necessary for the purpose it was collected, or as required by law. We purge unconfirmed email subscriptions within 30 days. Confirmed subscription data is kept until you unsubscribe or ask us to erase it. Contact-form and Audit records are kept for as long as needed to handle your enquiry and any resulting relationship, after which they are deleted or anonymised. When personal data is no longer needed, we erase it and require our processors to do the same, unless retention is required under applicable law.
9. Security
We implement reasonable security practices and procedures as required by Section 8 of the DPDP Act and the SPDI Rules, including encryption in transit (HTTPS), access controls, minimisation of the data we collect, and vetting of our processors. No method of transmission or storage is completely secure; while we work to protect your personal data, we cannot guarantee absolute security. In the event of a personal data breach, we will notify the Data Protection Board of India and affected Data Principals as required by the DPDP Act.
10. Your rights as a Data Principal
Under the DPDP Act you have the right to:
- Access — obtain a summary of the personal data we hold about you and how it is processed;
- Correction and erasure — have inaccurate or incomplete data corrected, updated, or completed, and have your data erased where it is no longer needed;
- Grievance redressal — a readily available means of raising a grievance with us (see Section 12);
- Nominate — nominate another individual to exercise your rights in the event of your death or incapacity; and
- Withdraw consent — as described in Section 5.
To exercise any of these rights, contact the Grievance Officer. We may need to verify your identity before acting on your request. We will respond within the time required by law.
11. Children’s data
The Website and Podcast are intended for a professional, adult audience and are not directed at children. In line with the DPDP Act, we do not knowingly process the personal data of any individual below the age of 18 without the verifiable consent of a parent or lawful guardian, and we do not undertake tracking, behavioural monitoring, or targeted advertising directed at children. If you believe a child has provided us personal data, contact the Grievance Officer and we will erase it.
12. Grievance Officer and complaints
In accordance with the DPDP Act and the Information Technology Act, 2000, our Grievance Officer for privacy matters is:
Paul Joseph, Grievance Officer
LowLightKing Productions Pvt Ltd, 43/2153 E1, Jewel Homes, Whitefield, SRM Road, Lissie Junction, Ernakulam, Kerala,
India – 682018
Email: paul@pauljosephdp.com
We will acknowledge your grievance and endeavour to resolve it within the timeframes prescribed by law. If you are not satisfied with our response, you may escalate the matter to the Data Protection Board of India in accordance with the DPDP Act.
13. Cookies
The Website is designed to minimise cookies and does not set marketing cookies before consent. For details, see our Cookie Policy.
14. Changes to this Policy
We may update this Policy as our practices or the law evolve. The “Last updated” date above reflects the current version. Material changes will be notified on the Website. Your continued use of the Website after a change takes effect constitutes acknowledgement of the updated Policy.
15. Contact
For any question about this Policy or your personal data, contact us at paul@pauljosephdp.com. This Policy is governed by and construed in accordance with the laws of India.