COMPREHENSIVE GOVERNANCE FRAMEWORK, TERMS OF SERVICE, AND PRIVACY POLICY
Website: Asthana Writes
URL: https://asthanawrites.org/
Proprietor: Major General (Dr.) Shashi Bhushan Asthana (Retd)
SECTION 1: WHO WE ARE (LEGAL IDENTIFICATION)
1.1 Ownership: The digital platform “Asthana Writes” is exclusively owned and operated by Major General (Dr.) Shashi Bhushan Asthana (the “Proprietor”).
1.2 Professional Standing: The Proprietor is a strategic analyst. A professional association with the United Service Institution of India (USI) exists for a specified duration; however, “Asthana Writes” is an independent entity. No content herein reflects the official policy of the USI, the Ministry of Defence, or the Government of India.
1.3 Contact: For legal or privacy concerns, contact the Proprietor at asthanawrites@gmail.com.
SECTION 2: INTELLECTUAL PROPERTY AND CREATIVE ORIGINALITY
2.1 Originality: Content is primarily original work authored by the Proprietor.
2.2 OSINT Methodology: Synthesis of Open Source Intelligence (OSINT) is conducted using exclusive analytical frameworks.
2.3 Mandatory Pre-Litigation Protocol: Before any legal action regarding content or sources, the aggrieved party MUST serve a “Notice of Clarification.” The Proprietor shall have thirty (30) days to resolve the grievance. Failure to follow this protocol constitutes a breach of these Terms.
SECTION 3: PERSONAL DATA WE COLLECT AND WHY
3.1 Subscription Data: We collect names and email addresses for the “Asthana Writes” newsletter.
3.2 Professional Continuity: Followers from LinkedIn, X, and YouTube are transitioned to our mailing list based on a pre-existing professional relationship.
3.3 Technical Data: We collect IP addresses and browser user agent strings to aid in spam detection and site analytics.
3.4 Legal Basis: Data is processed based on “Legitimate Interest” (for professional continuity) and “Explicit Consent” (for direct sign-ups) under the DPDP Act 2023.
SECTION 4: INTERACTIVE CONTENT (COMMENTS & MEDIA)
4.1 Comments: When visitors leave comments, we collect the data shown in the comments form, plus the visitor’s IP address. An anonymized string (hash) may be provided to the Gravatar service.
4.2 Media: If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors can download and extract any location data from images on the website.
SECTION 5: DATA RETENTION AND STORAGE
5.1 Retention Periods:
- Comments: Retained indefinitely for follow-up recognition.
- Contact Form Submissions: Retained for six (6) months for customer service purposes.
- Analytics Records: Retained for one (1) year.
- Subscription Data: Retained until the user exercises their right to “Opt-Out.”
5.2 Contact Forms: Data submitted via forms is used solely for the requested query and not for undisclosed marketing unless consented to.
SECTION 6: DATA SHARING AND TRANSFERS
6.1 Third-Party Providers: We share data with:
- Google (AdSense, Ad Manager, Analytics, Reader Revenue Manager).
- Email Service Providers (for newsletter distribution).
6.2 Cross-Border Transfers: Site data may be processed on servers located outside the Republic of India or the European Union. We ensure these providers adhere to standard contractual clauses (SCCs) equivalent to Indian and EU data protection standards.
SECTION 7: COOKIES AND TRACKING
7.1 Site Cookies: We use cookies to save your preferences and login information.
7.2 Third-Party Cookies: Advertisers (Google) use cookies to serve ads based on your prior visits. Users may opt-out of personalized advertising by visiting Google Ad Settings.
SECTION 8: USER RIGHTS OVER DATA
Users residing in India (under DPDP Act 2023) or the EU (under GDPR) have the right to:
- Access and receive a copy of their personal data.
- Request correction or erasure of their data.
- Withdraw consent at any time via the one-click “Unsubscribe” link in our emails.
SECTION 9: ADVERTISING AND PROFILING
9.1 Automated Decision Making: We use automated profiling via Google AdSense to deliver relevant advertising. We do not use automated decision-making for credit or essential services.
SECTION 10: JURISDICTION AND GOVERNING LAW
10.1 Law: Substantive laws of the Republic of India.
10.2 Forum: Exclusive territorial jurisdiction of the courts in New Delhi, India.
SECTION 11: DATA PROTECTION MEASURES
11.1 Security: We employ SSL encryption, two-factor authentication for administrative access, and regular security audits to protect your data.
11.2 Breach Procedures: In the event of a potential or real data breach, we have internal reporting systems in place and will notify the relevant authorities and affected users within 72 hours of discovery, as per statutory requirements.
SECTION 12: REGULATORY DISCLOSURE
12.1 Industry Compliance: As a digital news/analysis publisher, we comply with the IT Rules 2021 (Digital Media Ethics Code).
12.2 Grievance Officer:
Name: Major General (Dr.) Shashi Bhushan Asthana (Retd)
Email: asthanawrites@gmail.com
Any request for clarification or exercise of data rights should be directed to the Grievance Officer above.
