Privacy Policy

1. Who is responsible for your information

The legal entity responsible for administering the DRS Arts Grant is Dhanvi Rasiklal Shah Arts Pvt. Ltd., operating under its registered brand/trademark DRS Arts Company®, with correspondence address at Shapath II, Opp. Rajpath Club, SG Road, Ahmedabad 380015, Gujarat, India. Where applicable under Indian data protection law, Dhanvi Rasiklal Shah Arts Pvt. Ltd. acts as the relevant Data Fiduciary in relation to personal data processed for the DRS Arts Grant.

2. Privacy & grievance contact

Privacy questions, requests or grievances may be addressed to Mrs. Aesha Mistry, Grievance Officer, DRS Arts Company®, at [email protected]. For privacy-related communication, please use the subject “PRIVACY REQUEST | DRS ARTS GRANT.” Correspondence may also be sent to Dhanvi Rasiklal Shah Arts Pvt. Ltd., DRS Arts Company®, Shapath II, Opp. Rajpath Club, SG Road, Ahmedabad 380015, Gujarat, India.

3. Who this policy applies to

This Policy may apply to applicants, nominated or invited artists, grant and award recipients, nominators, referees, jurors, advisors, patrons, sponsors, donors, supporters, collectors, purchasers, event participants, website visitors, vendors, service providers, members of the media, professional contacts and other persons who interact with DRS Arts Company® or the DRS Arts Grant.

4. Information we may collect

Depending upon how you interact with us, we may collect information such as your name, age or date of birth, postal address, city, state, residency information, email address, telephone number, identity or eligibility documents, educational and professional information, artist biography, CV, artist statement, application or nomination responses, portfolio material, artwork images, videos and details, information about artistic practice, proposed budgets and timelines, professional references, correspondence, interview or studio-visit records, jury or administrative information, photographs, audio, video, event participation information and grant-administration records. For selected recipients, supporters, patrons, collectors or persons entering into transactions with DRS, we may also process bank details, PAN, GST or taxation information, invoices, payment information, shipping details, donation or sponsorship records, collector enquiries and transaction documentation where reasonably necessary. We seek to collect only information required for the purpose for which it is requested.

5. Financial and sensitive information

Where banking, taxation or financial information is required for grant payments, refunds, purchases, donations, sponsorships, accounting or statutory purposes, we seek to collect only what is reasonably necessary. Where payments are processed by an independent bank, payment gateway or payment-service provider, certain information may be processed directly by that provider under its own systems, terms and privacy practices. DRS Arts Company® will never require you to disclose an OTP, UPI PIN, card PIN, online-banking password or similar authentication credential. Applicants should also avoid providing medical, biometric or other highly sensitive information unless specifically requested and genuinely necessary for an identified purpose.

6. Information about other people

If you provide information relating to another person, including when nominating an artist or identifying a referee, representative, collaborator or contact person, you should be authorised or otherwise lawfully entitled to provide that information. Where appropriate, we may contact that person directly before requesting additional information. A nomination does not give DRS unrestricted permission to use the nominated person’s information for unrelated purposes.

7. Publicly available information

We may review information available through legitimate public or professional sources for artist research, invitations, programme development, verification, conflict checks, due diligence or professional communication. The fact that information is publicly available does not automatically mean that it will be used for unrelated purposes where applicable law requires otherwise.

8. Website and technical information

When you visit the DRS Arts Grant website, certain technical information may be collected automatically depending upon the technologies used. This may include IP address, browser type, device information, operating system, pages visited, date and time of access, referral source, approximate location derived from technical information, security logs and similar website-use information. Such information may be used for website operation, security, fraud prevention, troubleshooting, analytics and improvement. Our web server keeps standard access and error logs for security and troubleshooting. Analytics through Google Analytics takes place only with your consent, as explained in section 23.

9. Why we process your information

We may process personal information to receive and administer applications, nominations and invitations; determine and verify eligibility; communicate with participants; organise jury review; identify conflicts of interest; conduct shortlisting, interviews or studio visits; select and administer grants and awards; make payments; maintain accounting, taxation and statutory records; document artistic development and programme outcomes; operate exhibitions, events, publications and archives; maintain the institutional history of the DRS Arts Grant; manage patrons, sponsors, donors, supporters and collector relationships; issue invoices and documentation; respond to enquiries or grievances; prevent fraud, misuse, impersonation or unlawful activity; protect our systems; establish, exercise or defend legal rights; comply with legal and regulatory requirements; improve future programmes; and undertake other lawful purposes communicated when information is collected.

10. Consent and lawful processing

We process personal information only where permitted by applicable law. Depending upon the circumstances, processing may occur with your consent, for a purpose for which you have voluntarily provided the information, under a legitimate use specifically recognised by applicable law, to comply with legal obligations, for the establishment, exercise or defence of legal claims, or under another lawful ground available under applicable law. Where consent is required, we seek to ensure that it is free, specific, informed and unambiguous. Where processing relies upon consent, you may withdraw that consent through the means communicated to you. Withdrawal will not invalidate processing lawfully undertaken before withdrawal and may not require deletion where continued retention is permitted or required by law. If particular information is essential for processing an application, administering a grant, making a payment or providing another requested service, withdrawal may mean that the relevant activity cannot continue.

11. Application-specific notice

Where appropriate or legally required, an application form or other important data-collection point may contain a shorter privacy notice explaining the information requested, the purpose of collection, applicable consent, how consent may be withdrawn, how rights may be exercised and how DRS may be contacted. This Privacy Policy does not replace any separate notice or consent mechanism required by law.

12. Accuracy and your responsibilities

Applicants and other persons interacting with DRS should provide information that is accurate, authentic and reasonably complete. We may undertake reasonable verification where information materially affects identity, eligibility, grant payments, taxation, security or legal compliance. You should not knowingly impersonate another person, provide false identity information, submit another person’s personal information without lawful authority, submit fabricated records or deliberately provide materially misleading information. Nothing in this provision limits any statutory privacy right available to you.

13. Jury review and confidentiality

Application materials may be shared with independent jurors, the DRS Arts Company® representative participating in the selection process, authorised programme personnel and professional advisors where reasonably necessary. Jurors should receive only information reasonably required to evaluate applications or perform their role. Applying for the DRS Arts Grant does not by itself make an artist’s application public. Persons receiving confidential application information may be subject to appropriate confidentiality and conflict-of-interest requirements.

14. Technology and artificial intelligence

Technology or automated tools may be used for administrative functions such as organising information, file handling, translation, transcription, security, duplicate detection, formatting or operational assistance. Final grant and award decisions will not be delegated solely to an automated system. Selection remains subject to human consideration and the applicable jury process unless a future programme expressly provides otherwise. We will seek not to place confidential application material into publicly accessible artificial-intelligence systems in a manner inconsistent with our privacy, confidentiality or legal obligations.

15. Technology, business and future changes

DRS Arts Company® and the DRS Arts Grant may from time to time adopt new technologies, digital systems, artificial-intelligence tools, cloud services, communication platforms, security systems, payment systems, administrative processes or service providers as technology and the operation of the initiative evolve. Personal information may be processed through such technologies where reasonably necessary for the purposes described in this Privacy Policy and where permitted by applicable law. The adoption of a new technology or service provider does not by itself change the purposes for which personal information was originally collected. Where a materially new purpose requires additional notice or consent under applicable law, DRS will provide such notice or obtain such consent as required. DRS may modify its technological, organisational and security practices where reasonably necessary to improve security, efficiency, accessibility, compliance or operation of the programme.

16. Service providers

We may use third-party providers for website hosting, application forms, cloud storage, email, communications, cybersecurity, analytics, banking, payments, accounting, printing, couriers, logistics, documentation, IT support, legal services and other professional or administrative functions. Such providers may receive information reasonably necessary to perform their services. Where required and appropriate, we will seek suitable contractual, confidentiality, privacy and security protections from providers processing information on our behalf. Use of a third-party provider does not remove obligations imposed upon DRS under applicable law.

17. We do not sell applicant personal information

DRS Arts Company® does not sell or rent applicant personal information to advertisers or data brokers. Information supplied for a grant application will not be provided to unrelated parties for behavioural advertising merely because an individual applied to the DRS Arts Grant.

18. Selected artists and public information

If an artist receives a grant or award, information reasonably connected with their participation may become public. This may include their name, biography, photograph, city, grant or award category, artwork images and details, interviews, studio documentation, approved quotations and information relating to their practice or participation. Such information may appear through the DRS Arts Grant or DRS Arts Company® websites, social media, publications, exhibitions, presentations, educational communication, press communication, annual or impact reports, archives and fundraising materials connected with the initiative. Copyright in an artist’s original artwork remains governed by applicable copyright law and any separate agreement entered into with the artist.

19. Photography, video, audio and interviews

Selected artists and other participants may be photographed, filmed, recorded or interviewed in connection with the programme. Where consent or permission is legally required, appropriate permission will be sought. Once material has been lawfully published, it may subsequently be indexed, reported, archived, reposted, screenshotted or reproduced by independent third parties. DRS may not be technically or legally capable of removing such material from independent media organisations, search engines, archives, social-media users or other third parties outside its reasonable control. DRS will not be responsible for independent third-party use outside its reasonable control except to the extent liability cannot lawfully be excluded.

20. Patrons, sponsors, donors and supporters

Where an individual or organisation supports the DRS Arts Grant, we may process information required to communicate with them, administer the relationship or contribution, maintain financial records, issue invoices, receipts or acknowledgements where applicable, comply with accounting and taxation requirements, provide agreed recognition, prevent fraud and maintain the historical or institutional records of the initiative. Public acknowledgement will be undertaken in accordance with the relevant arrangement, permission or programme terms.

21. Collectors and transactions

Where DRS Arts Company® enters into an artwork, fundraising or other permitted transaction with a collector or purchaser, information may be processed for communication, identity verification, invoicing, payment, GST and taxation, provenance and transaction documentation, shipping, insurance, fraud prevention, legal compliance and record keeping. A separate invoice, sale agreement, authentication document or other transaction terms may govern a particular transaction. This Privacy Policy does not replace those contractual documents.

22. Communications and marketing

We may communicate with you where reasonably necessary in connection with an application, nomination, grant, award, purchase, sponsorship, donation, patron relationship, event, enquiry, security matter or other existing interaction with DRS. Non-essential promotional communication may be sent where permitted by applicable law and appropriate consent will be obtained where required. You may opt out of non-essential promotional communication by using an available unsubscribe facility or contacting us. Opting out will not prevent necessary administrative, transactional, security or legal communications.

23. Cookies and analytics

Essential browser storage. The website stores a small number of items in your browser that it needs in order to work and that do not identify you: a note that the opening animation has already played during your visit (deleted when you close the browser tab) and your cookie choice (kept until you change it or clear your browser data). These items are not shared with anyone and do not require consent.

Google Analytics. With your consent, we use Google Analytics 4, a web analytics service provided by Google LLC (and, for visitors in the European Economic Area and the United Kingdom, by Google Ireland Limited), to understand how the website is used and to improve it and the DRS Arts Grant. Google Analytics may collect information such as the pages you visit, how long you stay, the links, videos, downloads and forms you interact with, the website that referred you, your device, operating system and browser type, screen size, language and approximate location (country and city) derived from your IP address. Google Analytics 4 does not log or store full IP addresses. It sets first-party cookies named _ga and _ga_Z921VKXTXH, which hold a random identifier and generally expire after up to two years.

We have switched off Google signals and advertising personalisation, we do not use Google Analytics for advertising or remarketing, and we do not attempt to identify individual visitors. We view analytics only as aggregated reports, and analytics data is retained in Google Analytics for no longer than 14 months. Google processes this information under its own Privacy Policy and may process it on servers outside India, as described in section 28. You can read how Google uses information from websites that use its services at policies.google.com/technologies/partner-sites.

Your choice. Google Analytics is not loaded and no analytics cookies are set unless you select “Accept” in the cookie banner. If you select “Decline”, no analytics takes place. You can change your choice at any time using “Cookie settings” at the foot of every page; if you withdraw consent, analytics stops and the analytics cookies are removed from your browser for this website. Withdrawal does not affect analytics carried out before it. You can also block or delete cookies through your browser settings, or install the Google Analytics opt-out browser add-on.

Other services. The website loads its fonts from Google Fonts, which receives your IP address and browser information in order to deliver them. Films on the website are hosted on YouTube: nothing is loaded from YouTube until you press play, and the film then plays through YouTube’s privacy-enhanced mode (youtube-nocookie.com), under Google’s Privacy Policy. Application forms are hosted by Google Forms, and links to social media, maps or other services take you to websites operated by those providers, which apply their own cookie and privacy practices (see section 35). We will update this section and, where required, ask for your consent before introducing any other non-essential cookies or tracking technologies.

24. Information security

DRS seeks to maintain reasonable administrative, organisational and technical safeguards appropriate to the nature of the information and the risks involved. Depending upon the circumstances, these may include access controls, role-based permissions, authentication measures, encryption or masking where appropriate, secure backups, logging and monitoring, malware protection, software updates, vendor controls, confidentiality obligations and incident-response procedures. Security measures may change as technology and risks change. For security reasons, DRS is not required to publicly disclose technical configurations that could increase vulnerability. No website, email system, cloud service, electronic transmission or digital-storage system can be guaranteed to be completely secure.

25. Personal data and cybersecurity incidents

DRS will seek to maintain reasonable procedures to identify, assess, contain and respond to suspected personal-data or cybersecurity incidents. Where notification is required by applicable law, DRS will seek to notify affected persons and competent authorities in the manner and within the timeframe prescribed by law. This may include the Data Protection Board of India, CERT-In or another competent authority, where legally applicable. We may retain logs, records or evidence where reasonably necessary for investigation, remediation, legal compliance, insurance, legal proceedings or prevention of recurrence.

26. Data retention

Personal information will be retained only for as long as reasonably necessary for the purposes for which it was collected or another purpose permitted or required by law. Retention may take into account the duration of the application or grant process, verification, accounting, taxation, contractual obligations, audit requirements, legal limitation periods, disputes, fraud prevention, security, programme evaluation, institutional history, archival requirements and statutory retention periods. When information is no longer reasonably required, it may be securely deleted, anonymised or placed in an appropriately restricted archive. Information relating to successful grants, awards, exhibitions, publications, artworks and significant institutional activities may be retained for longer periods as part of the historical and cultural archive of DRS Arts Company® and the DRS Arts Grant, subject to applicable law. Sensitive information not required for that archival purpose should not be retained merely for convenience.

27. Anonymised and aggregated information

We may create statistical, aggregated or anonymised information for programme evaluation, research, reporting, fundraising, understanding programme reach and measuring impact. Where information has been genuinely anonymised so that an individual is no longer identifiable under applicable law, it may no longer constitute personal data. We will not intentionally seek to re-identify properly anonymised information except where required for security, legal compliance or another lawful purpose.

28. International and cloud-based processing

Some providers used for cloud storage, application forms, email, communication, analytics, website hosting, payments, security or other technology services may process, transmit or make information accessible outside India. Such processing or transfers will remain subject to applicable Indian restrictions and any other mandatory legal requirement that applies. Where appropriate, we will seek providers and contractual arrangements reasonably suited to the nature and sensitivity of the information. DRS may change, restrict or discontinue use of a service provider where legal requirements make continued processing or transfer inappropriate.

29. Your privacy rights

Subject to the law applicable at the relevant time, you may have rights to obtain information concerning personal data being processed, request access where applicable, request correction, completion or updating, request erasure where legally available, withdraw consent where processing relies upon consent, raise a grievance and exercise other rights provided by applicable law. Where available under applicable Indian law, an individual may also have the right to nominate another person to exercise prescribed rights in the event of death or incapacity. These rights may be subject to lawful limitations. Information may, for example, need to be retained for legal compliance, accounting, taxation, security, fraud prevention, contractual obligations, legal claims or another lawful purpose. We may take reasonable steps to verify the identity and authority of a person making a request before disclosing, altering or deleting information.

30. Withdrawal of consent and grievances

Where processing depends upon your consent, you may request withdrawal by writing to [email protected] with the subject “PRIVACY REQUEST | DRS ARTS GRANT.” Withdrawal will not invalidate processing lawfully undertaken before withdrawal and will not require DRS to erase information that must lawfully be retained. Privacy grievances may be submitted through the same contact and will be handled by the designated Grievance Officer. We will seek to acknowledge, investigate and address them in accordance with applicable legal requirements. Nothing in this Policy prevents any person from exercising a non-waivable statutory right or approaching a competent governmental, judicial or regulatory authority where permitted by law.

31. Persons under 18

Current DRS Arts Grant application categories begin at 18 years of age, and the current grant application process is therefore not intended for children under 18. If a future programme specifically includes children, appropriate age-verification and parental or lawful guardian consent procedures will be implemented where required. If we become aware that information relating to a child has been submitted improperly, we may delete, restrict or otherwise appropriately handle that information, subject to applicable legal requirements.

32. Fraud, impersonation and unauthorised communications

Applicants, artists, collectors, patrons, donors, sponsors and supporters should communicate and transact only through official DRS Arts Company® or DRS Arts Grant channels. DRS is not responsible for fraudulent websites, fake social-media accounts, impersonation, phishing emails or fraudulent payment requests created by unrelated third parties outside its reasonable control, except where liability cannot lawfully be excluded. We may process or disclose relevant information where reasonably necessary to detect, investigate, prevent or report suspected fraud, identity theft, impersonation, cybercrime, unauthorised access, payment fraud or other unlawful activity.

33. Legal and regulatory disclosures

Personal information may be disclosed where reasonably necessary or legally required in connection with a court order, judicial proceeding, law-enforcement request, governmental or regulatory requirement, taxation or accounting obligation, cybersecurity incident, fraud investigation, actual or potential legal claim, protection of an individual’s rights or safety, protection of DRS Arts Company® or the DRS Arts Grant, or another lawful requirement. Where legally possible, disclosure will be limited to information reasonably necessary for the relevant purpose.

34. Organisational change

If Dhanvi Rasiklal Shah Arts Pvt. Ltd., DRS Arts Company® or the DRS Arts Grant undergoes a lawful restructuring, succession, merger, acquisition, reorganisation, transfer of operations or similar change, relevant records and personal information may be transferred where reasonably necessary and permitted by law. Any recipient of such information will remain subject to applicable privacy and data-protection obligations.

35. Third-party websites and services

The DRS Arts Grant website or communications may contain links to independently operated websites, social-media platforms, payment providers or other third-party services. DRS does not control their privacy, security, content or operation, and use of those services may be governed by their own policies and terms. This provision does not remove any legal responsibility that DRS may have where a third party processes personal information on our behalf.

36. International visitors

The DRS Arts Grant is administered from India, and the current artist grant programme is primarily directed towards eligible Indian artists based in India, although patrons, supporters, collectors, website visitors and other persons may interact with us internationally. The fact that the website can be accessed from another country does not by itself mean that DRS intentionally offers every programme or service in every jurisdiction. Where DRS specifically targets, transacts with or processes information relating to persons in another jurisdiction and mandatory foreign privacy law applies, we will seek to comply with those mandatory requirements to the extent legally applicable. Where such law provides a greater non-waivable protection, that mandatory protection will prevail to the extent it applies.

37. Changes to this policy

We may revise this Privacy Policy from time to time to reflect changes in law, regulation, technology, cybersecurity risks, artificial intelligence, service providers, business practices, programme activities or the operation of DRS Arts Company® and the DRS Arts Grant. The most current version published on the website will carry the applicable “Last updated” date. Changes may apply prospectively from their effective date. Where applicable law requires separate notice, renewed consent or another action before a materially different use of previously collected personal information, DRS will take such action as required. No previous version of this Policy will prevent DRS from adopting lawful technological, administrative or security practices necessary for the future operation and protection of the programme.

38. Applicable Indian legal framework

This Privacy Policy is intended to operate in accordance with applicable Indian law, including, to the extent in force and applicable at the relevant time, the Information Technology Act, 2000, the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 for so long as they remain applicable, the Digital Personal Data Protection Act, 2023, the Digital Personal Data Protection Rules, 2025 as their relevant provisions come into force, applicable directions issued by CERT-In, and other applicable laws, rules, notifications, judicial decisions and regulatory requirements. Where legislation is amended, repealed, replaced or brought into operation in phases, this Policy will be interpreted consistently with the law applicable at that time.

39. No waiver of mandatory rights

Nothing in this Privacy Policy is intended to exclude liability that cannot lawfully be excluded, require any person to waive a statutory privacy right where such waiver is prohibited, prevent a court or governmental authority from exercising lawful powers, or reduce any mandatory protection available under applicable law. If any provision of this Policy conflicts with a mandatory legal requirement, the mandatory requirement will prevail to the extent of that conflict and the remainder of this Policy will continue to apply to the extent legally permissible.

40. Contact

For privacy-related questions, requests or grievances, please contact Mrs. Aesha Mistry, Grievance Officer, DRS Arts Company®, Dhanvi Rasiklal Shah Arts Pvt. Ltd., Shapath II, Opp. Rajpath Club, SG Road, Ahmedabad 380015, Gujarat, India. Email: [email protected]. Please use the subject “PRIVACY REQUEST | DRS ARTS GRANT.”