PRIVACY POLICY

Document version: v2.0 Effective date: 2026-05-01 Last updated: 2026-05-01

Pitambhara Educom Consultancy Pvt Ltd ("Company", "we", "us", "our") respects your privacy. This Privacy Policy explains how we collect, use, disclose, store, and protect your personal data when you use our website, Learning Management System ("LMS"), courses, and related services (the "Services") operated under the brands HealersMeet, Mission Niramaya, InnerZen Wellness Program, and the Decode Life Transformation (DLT) program.

This Policy is issued in compliance with:

• the Digital Personal Data Protection Act, 2023 (DPDP Act);
• the Information Technology Act, 2000 and the IT (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (SPDI Rules);
• the IT (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021;
• the Consumer Protection (E-Commerce) Rules, 2020.

By using the Services you acknowledge this Policy. Where we rely on your consent, we will ask for it separately and explicitly.

1. WHO WE ARE (DATA FIDUCIARY)

Under the DPDP Act, the Data Fiduciary is:

• Entity: Pitambhara Educom Consultancy Pvt Ltd
• Registered office: 279, Mandakini Colony, Kolar Road, Bhopal, Madhya Pradesh, 462042, India
• Email: privacy@healersmeet.com
• Grievance Officer / Data Protection Contact: Manoj Jain ("Manudada"), grievance@healersmeet.com, +91 99814 45177

2. PERSONAL DATA WE COLLECT

2.1. Information you provide

• Identity & contact: name, date of birth, gender, email, mobile/WhatsApp number, postal address, ID proof (for certification).
• Account: username, password (stored hashed — we never see it), profile photo, biography, languages.
• Payment: billing name, address, GSTIN (if applicable), UPI ID, masked card details, transaction references. We do not store full card numbers or CVV.
• Educational & professional: qualifications, prior training, certifications.
• Course interaction: assignments, workbook entries, reflections, testimonials, practice logs, Q&A, session recordings (where you consent).
• Sensitive health & wellness (with explicit consent): physical/mental health history, medications, pregnancy, trauma, spiritual experiences, emergency contact. See Section 4.

2.2. Information collected automatically

• Device, browser, IP address, approximate location (from IP).
• LMS analytics — lessons viewed, time spent, progress, quiz scores, login timestamps.
• Cookies and similar technologies (see the Cookie Policy).

2.3. Information from third parties

• Payment confirmations from gateways (Razorpay / Stripe / PayU / UPI handlers).
• OAuth profile data if you sign in via Google (only what you authorize).
• Referral data from affiliate partners.

3. PURPOSES AND LAWFUL BASES

We process your data for the following specified, lawful purposes only:

4. SENSITIVE PERSONAL DATA — HEALTH, MENTAL HEALTH, SPIRITUAL

4.1. Our courses involve disclosure of deeply personal information (mental health history, trauma, relationships, past-life experiences, spiritual crises). Under the SPDI Rules, 2011, this is classified as Sensitive Personal Data or Information (SPDI).

4.2. We process such data only with your express, informed, written (electronic) consent, given at the point of collection.

4.3. Access is strictly limited to:

• the lead instructor (Manoj Jain / "Manudada";
• designated support staff on a strict need-to-know basis under signed confidentiality agreements;
• yourself.

4.4. No public exposure. We will never publish or share identifiable sensitive data externally without your separate written consent. Anonymized excerpts may be used in teaching with all identifying features removed.

4.5. Peer sessions. In group circles and live practicums, other Students may hear what you share. Peers accept a Confidentiality Pledge, but we cannot fully police peer compliance. Share only what you are comfortable sharing.

5. CONSENT

5.1. Where consent is our basis, you will be asked for it separately from the Terms, through a clear, affirmative action (e.g., an unchecked tick-box that you actively tick).

5.2. No pre-ticked boxes, no bundled consents. Consent for marketing is separate from consent to enroll.

5.3. You may withdraw consent at any time by writing to privacy@healersmeet.com or using in-product controls. Withdrawal does not affect the lawfulness of earlier processing, and may end services that depend on that data.

6. SHARING AND DISCLOSURE

We do not sell your personal data. We share it only as follows:

• Data Processors / vendors — hosting (AWS / DigitalOcean / equivalent), LMS infrastructure, transactional email, WhatsApp Business API, video conferencing (Zoom), analytics (Google Analytics), payment gateways. All processors are bound by a written Data Processing Agreement that mirrors your DPDP Act protections.
• Certification partners — limited identity and completion data shared with Medhavi Skills University and similar bodies strictly to issue your credential.
• Professional advisors — our lawyers, auditors, and insurers under duty of confidence.
• Legal authorities — where required by valid legal process, court order, or Indian law.
• Corporate events — in a merger, acquisition, or restructuring, data may transfer to the successor entity with notice.
• With your explicit consent — any other sharing outside the above.

7. CROSS-BORDER DATA TRANSFERS

7.1. Some of our processors operate servers outside India. Where this is the case, we rely on contractual safeguards that require protection equivalent to Indian standards.

7.2. We do not transfer data to any country restricted by notification of the Central Government under the DPDP Act.

8. DATA RETENTION

After the retention period, data is deleted or anonymized irreversibly.

9. YOUR RIGHTS AS A DATA PRINCIPAL

Under the DPDP Act, you have the following rights, exercisable free of charge:

• Right to information about the personal data we process and with whom it is shared;
• Right to correction and erasure of inaccurate, outdated, or unnecessary data;
• Right to grievance redressal via our Grievance Officer (Section 15);
• Right to nominate (Section 14 of the DPDP Act) — you may nominate another person to exercise your rights in the event of your death or incapacity; see Section 10 below;
• Right to withdraw consent at any time;
• Right to data portability — receive your data in a structured, machine-readable format;
• Right to opt-out of marketing communications at any time.

How to exercise: email privacy@healersmeet.com from your registered email. We respond within 30 days (ordinary requests) or sooner where the law requires.

10. NOMINEE

To nominate a person to exercise your DPDP rights in case of death or incapacity, log in to your LMS account → Settings → Privacy → Nominee, or email privacy@healersmeet.com with:

• your full name and registered email;
• the nominee's full name, relationship, email, and phone;
• a scanned copy of the nominee's government-issued ID;
• your signed (or electronically signed) nomination.

You may revoke or change the nominee anytime through the same channel.

11. COOKIES AND TRACKING

Covered in detail in our separate Cookie Policy, which explains each category of cookie, its purpose, and how you can control it.

12. CHILDREN'S DATA

The Services are intended for persons 18 and older. We do not knowingly process children's data without verifiable parental consent. Children under 18 are not permitted to provide sensitive health disclosures on their own account. If you believe a child has registered, contact privacy@healersmeet.com and we will delete the data within 72 hours.

13. SECURITY

We apply reasonable and appropriate technical and organizational measures to protect your data, including TLS 1.2+ encryption in transit, password hashing, encrypted backups, role-based access control, multi-factor authentication for staff, vendor due diligence, and staff training. Full details are in our Security Statement.

14. BREACH NOTIFICATION

In the event of a personal-data breach likely to cause harm:

• We will notify affected Data Principals without undue delay.
• We will report to the Data Protection Board of India in the manner and within the timelines prescribed under the DPDP Act.
• For incidents covered by the CERT-In Cyber Security Directions, 2022, we will report to CERT-In within 6 hours of noticing.

15. GRIEVANCE OFFICER

If you have any concern about how we handle your data, please contact:

• Name: Manoj Jain ("Manudada")
• Designation: Grievance Officer & Data Protection Contact
• Postal: 279, Mandakini Colony, Kolar Road, Bhopal, Madhya Pradesh, 462042, India
• Email: grievance@healersmeet.com
• Phone: +91 99814 45177
• Hours: Monday–Friday, 10:00–18:00 IST

The Grievance Officer will acknowledge your complaint within 24 hours and resolve it within 15 days. If you remain dissatisfied, you may approach the Data Protection Board of India once constituted, or other competent authority.

16. THIRD-PARTY LINKS

Our Services may link to third-party sites (Medhavi Skills University, Futred.com, Studi Global, partners, social media). Their privacy practices are their own. Please review their policies before providing them data.

17. CHANGES

We may update this Policy. Material changes will be notified by email and a conspicuous LMS banner at least 15 days before they take effect. The "Last Updated" field reflects the current version.

18. CONTACT

• Privacy queries: privacy@healersmeet.com
• Grievance Officer: as in Section 15
• Postal: 279, Mandakini Colony, Kolar Road, Bhopal, Madhya Pradesh, 462042, India