Legal
Privacy policy
Draft, not for publication
This page is a draft prepared on 3 November 2026 for the client and for review by qualified Indian legal counsel. It is not legal advice. It does not claim that the site meets any legal requirement. It is not published as a final policy yet. Fields marked To be confirmed are unknown, and they are shown as pending rather than guessed.
Who we are
This website, https://topdholera.com, is operated by Bharat & Bina Traders, which trades publicly under the name TOP DHOLERA. Top Dholera is owned and operated by Bharat & Bina Traders. The business sources and coordinates industrial land, heavy machinery, construction equipment, construction materials and workforce for projects in and around Dholera, Gujarat.
Registration particulars such as a company registration number, a GST registration number and the date of incorporation have not been verified for publication, and are therefore not stated here.
For the purposes of applicable data protection law, Bharat & Bina Traders is the data controller for the personal data described in this policy. This statement remains subject to final review by qualified Indian legal counsel before publication.
Questions about this policy, or about any personal data we handle, go to the privacy contact above. The response time we commit to is To be confirmed, pending review by counsel.
Scope
This policy covers https://topdholera.com and the pages on it. It does not cover:
- WhatsApp, a separate service operated by Meta Platforms, Inc. This is important to understand: an enquiry sent on WhatsApp leaves this website's privacy environment entirely. The message is delivered to and processed by WhatsApp under Meta's own privacy policy, and we then receive it as our business and retain it for as long as the commercial relationship requires. We do not read, store, log or control your WhatsApp conversations, and we have no ability to see them beyond the messages our business receives in the ordinary way.
- Google and Meta advertising services, which are governed by their own policies, linked at the end of this page.
- Our suppliers and workforce contacts, who receive the details of a requirement we have agreed to source on your behalf. Their handling of that information is governed by their own arrangements with you and with us.
- Third-party websites we link to.
The short version
We do not run a customer database. There are no accounts, no login and no newsletter.
This site is static. It has no server that receives enquiries, no database that stores them and no lead store. It cannot collect an enquiry you have not chosen to send. Your consent choice is kept in your own browser, on your device, and is not sent to us.
What reaches us is only what you choose to send: a WhatsApp message, a phone call, or an email. If you refuse analytics and advertising cookies, everything on this site still works. You are simply not counted in our website statistics.
What we collect
Information you choose to send
We collect nothing about you until you actively contact us.
| What | When | Why | Where it is handled |
|---|---|---|---|
| The contents of a WhatsApp message you send us | You tap a WhatsApp button and press send | To respond to your enquiry | On WhatsApp, under WhatsApp's privacy policy |
| The telephone number you call us from | You call us | To respond to your enquiry | Our telephone records |
| The email you send us | You email us | To respond to your enquiry | Our email provider |
A WhatsApp button on this site composes a message in your browser and hands it to WhatsApp. It does not send anything to us. Nothing reaches us until you press send inside WhatsApp. The Project Resource Desk works the same way: it builds a short brief in your browser and opens WhatsApp with that text ready for you to send. What you type stays in your browser until you send it.
Information collected automatically, and only with consent
| What | When | Why | Consent category |
|---|---|---|---|
| Page viewed and the page path | Analytics consent granted | To understand which parts of the site are useful | Analytics |
| Division or category viewed, for example "excavators" | Analytics consent granted | To understand which capabilities interest visitors | Analytics |
| Scroll depth and navigation clicks | Analytics consent granted | To understand how the site is used | Analytics |
| Campaign parameters (utm_source, utm_medium, utm_campaign, utm_content, utm_term, landing page, referring site) | Analytics or advertising consent granted | To understand which campaigns bring relevant visitors, and whether those campaigns work | Analytics or advertising |
| Device and browser category, and approximate city | Analytics consent granted | To understand which devices and markets to serve | Analytics |
| Whether you clicked a WhatsApp, phone or enquiry button, and which one | Analytics or advertising consent granted | To know which capabilities generate enquiries, so we can improve them | Analytics or advertising |
What is never collected: your name, your phone number, your email address, your exact location, the contents of an enquiry form, the text of a search, or any document you upload. A runtime guard on our analytics payload rejects those values before they are sent, so the rule is enforced by the build rather than by good intentions.
What a WhatsApp click means
A click on a WhatsApp button is a signal of interest. It is not a confirmed enquiry, and it is not a sale.
We cannot see whether you actually sent the message, whether we replied, or whether the conversation led to business. Those things are known only to us and to you, through the conversation itself. Any figure we publish about "enquiries" describes clicks, and we do not describe clicks as customers.
Cookies and browser storage
We use four categories. Nothing is set before you make a choice, and the three non-essential categories are off until you allow them. The cookie policy explains the same thing in plain language.
Strictly necessary, always on
Analytics, off unless you allow it
Advertising and marketing, off unless you allow it
Functional preferences, off unless you allow it
The site works fully with all three non-essential categories rejected. Rejecting is exactly as easy as accepting. Changing a choice takes effect immediately, without a reload. You can also clear this site's browser storage at any time, which removes the consent record.
How we use personal data
| Purpose | Basis | Notes |
|---|---|---|
| Responding to your enquiry | Your consent and your request | Handled over WhatsApp, email or telephone |
| Understanding how the site is used | Consent | Analytics only. You can refuse |
| Measuring advertising campaigns | Consent | Advertising only. You can refuse |
| Complying with legal obligations | Legal obligation | Records we are required to keep |
| Protecting our business from abuse | Legitimate interests | Site security and spam prevention |
We do not sell personal data. We do not share it for anyone else's independent marketing.
How long we keep things
The periods below are placeholders. Qualified Indian legal counsel fixes them before this page is published. One point is already clear from our research: the Digital Personal Data Protection Act, 2023 and its Rules, 2025 are expected to set a minimum one-year retention floor for personal data, associated traffic data and processing logs, and to require notice before data is erased at the end of the purpose it was collected for. The schedule below is written to sit above that floor. Until counsel confirms the periods, no figure in this table is a commitment.
| Data | Retention |
|---|---|
| Consent record (category choices, timestamp, notice version) | To be confirmed Kept so we can show that consent was given |
| Analytics event data | To be confirmed Subject to the expected one-year floor under the Act and Rules |
| Advertising campaign data | To be confirmed |
| Functional preferences in your browser | Until you clear your browser storage or change your choice |
| WhatsApp conversations | Governed by WhatsApp's own retention policy, not by us |
| Enquiry records received by email or telephone | To be confirmed Linked to the commercial relationship |
| Server logs held by the hosting provider | To be confirmed |
Who we share data with
We use a small number of providers. If you consent to analytics or advertising, the relevant providers receive data from your visit.
| Provider | What for | What they receive |
|---|---|---|
| Google (Google Analytics 4, Google Ads) | Analytics and advertising measurement | Page views, event data, campaign parameters, device and approximate city. No name, phone number, email address or enquiry content. |
| Meta Platforms, Inc. (Meta Pixel) | Advertising measurement | Page views, event data, campaign parameters, device category. No name, phone number, email address or enquiry content. |
| WhatsApp (Meta Platforms, Inc.) | The channel on which you contact us | The message the site pre-writes, and anything you choose to send. Governed by WhatsApp's privacy policy. |
| Hosting provider To be confirmed | Hosting and serving the site | Standard server logs: IP address, user agent and the URL requested. The provider's name is not yet confirmed. |
| Suppliers and workforce contacts in our network | Sourcing the resources you ask us to arrange | The requirement details needed to check and fulfil your enquiry: the specification, the quantity, the location, the dates and the contact point you give us. We share only what is needed to source that requirement, and we tell you that we are doing it. Their handling of your details is governed by their own arrangements with you and with us. |
| Domain registrar and DNS provider To be confirmed | Domain registration and DNS | Administrative contact details |
We do not send names, phone numbers, email addresses, addresses, document details or the content of your messages to any analytics or advertising platform.
We disclose personal data where the law requires it, or where disclosure is necessary to protect the rights and safety of the business, its people or its customers.
Your rights
Subject to the law that applies to you, you can:
- Ask what we hold about you, and get a copy.
- Ask us to correct anything inaccurate.
- Ask us to erase your data, where the law allows it.
- Withdraw consent at any time through the "Cookie preferences" control in the footer. Withdrawal is as easy as granting consent, and takes effect immediately.
- Ask us not to use your data for a particular purpose, or object to certain processing.
- Raise a grievance with the contact named in this policy.
If you are in the EEA or the UK, you also have the rights provided by the GDPR, including the right to complain to your local supervisory authority.
The grievance response time is To be confirmed, pending review by counsel.
Security
We use HTTPS for all traffic. Analytics and advertising scripts are not loaded at all unless you have agreed to them, and the site refuses them by default. We keep the amount of personal data we process to the minimum needed for the purposes described here. We do not operate a login, an account system or a customer database, and the site has no server-side enquiry handling to breach.
Children
This is a business-to-business site intended for business users. It is not directed at children, and we do not knowingly collect personal data from children.
Changes to this policy
We update this policy when the site or the law changes. The date below is the last update. Where a change is material, and where it affects your choices, we ask you to make a fresh consent decision rather than rely on your earlier one.
Last updated: 3 November 2026
Version: 1.0, draft
Contact routes for data questions
| Route | Status | Use it for |
|---|---|---|
| Email to the named data contact | To be confirmed | Access, correction, erasure, objection and grievances |
| Postal address | To be confirmed | Written requests |
| Available now | A first question. We will point you to the published address |
The full legal entity details for this site are published in the terms of use once they are confirmed.
Data questions
Ask us about your data
Send a question and we will answer it once the named data contact is published. Nothing reaches us until you press send in WhatsApp. Rejecting analytics and advertising changes nothing about how this site works.