PRIVACY POLICY

Document version: v2.1 Effective date: 2026-05-01 Last updated: 2026-09-17 — Section 4A added (the mobile app and the AI in it); Sections 6, 7 and 8 extended to cover it.

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, the Decode Life Transformation mobile app, 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.
• Mobile app entries (with explicit consent): your daily mood check-in; what you write in the dream journal (dreams, intentions, morning notes); the messages you exchange with an in-app companion or guide; your date of birth where you ask for an ank jyotish reading; what you tell us at a Clarity Session intake. See Section 4A, which is about the app specifically.

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. Your lesson notes and workbook answers stay on your device. By default we do not receive them at all — they are stored by your own browser, on the device you wrote them on, and nothing about them reaches our servers except a marker saying that you worked on a lesson. Two consequences follow, and the second is the reason we say this so plainly:

• Because the notes are yours alone, clearing your browser data or changing your phone loses them. Use Save as PDF to keep a copy you own.
• You may switch on “keep my notes in my account”, which is off unless you turn it on. Switching it on means we hold your lesson notes so they follow you to another device. Switching it off again deletes them from our servers; the copy on your device is untouched. Workbook answers are never synced, whatever this setting says.

4.6. 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.

4A. THE MOBILE APP, AND THE ARTIFICIAL INTELLIGENCE IN IT

This section is new. It exists because the app now does things that Sections 4, 6 and 7 were written before, and a policy that does not say so is not a policy.

4A.1. What the app is. The Decode Life Transformation app offers a daily mood check-in, a dream journal, guided practices, and several guides you can write to — a companion, and guidance on dreams, on jyotish, on stones and on ank jyotish. It is for reflection, learning and self-understanding. It is not medical care, it is not a diagnosis, and it is not a substitute for a doctor or a mental-health professional.

4A.2. An AI model reads what you write. When you use a guide, a companion, or the dream-pattern reading, what you wrote is sent to an artificial-intelligence provider that generates the reply. That provider is Anthropic PBC, United States, acting as our processor under a written agreement. In plain terms: your dream text, your question and the relevant part of your conversation leave India to be answered. No human at that provider reads your entries in the ordinary course, and they are contractually barred from using your entries to train their models.

4A.3. What is kept, and where. Your moods, dream entries and conversations are stored in our database hosted on Supabase, separately from the learning platform. Row-level security is on and no anonymous key opens any of it; only a server key held by our hosting provider can read it, and that key is never in the app on your phone.

4A.4. The guide remembers. A companion or guide is shown recent turns of your own conversation so that it does not ask you the same thing twice. You can clear that memory from within the app, and clearing it deletes those turns.

4A.5. What the AI is instructed never to do. Our prompts forbid it from naming a disease or a disorder, from telling you to start, stop or change a medicine, from giving a date on which something will happen to you, from calling any number lucky or unlucky, and from selling you a remedy. If you ever see it do one of these, that is a fault and we want to hear about it at grievance@healersmeet.com.

4A.6. A machine can be wrong. These replies are generated, and generated text can be mistaken, incomplete, or simply not right for you. Treat it as something to reflect on, never as instruction. Decisions about your health, your money, your medicines or your relationships are yours, and should be taken with a qualified human being.

4A.7. If you are in danger. If what you write suggests you may be at risk of harming yourself, we record that an escalation happened, with your name, e-mail and region, so that a real person can reach you. This is the one place where we may contact you without waiting to be asked, and we believe reaching a person in crisis is the right thing to do. Nothing you wrote is published, and the record exists only so that somebody follows up.

4A.8. Your entries are yours. You may read, export or delete your moods, dreams and conversations, and you may withdraw consent for the app entirely — see Section 9. Deleting the app from your phone does not delete what is on our servers; ask us, and we will.

4A.9. Consent for the app is asked separately. Accepting the learning platform's terms is not consent for the app. The app asks for its own, at first use, before anything is collected, as an active tick.

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.
• App database — Supabase. Where the mobile app's moods, dream entries, conversations, orders and entitlements are stored. See Section 4A.3.
• Artificial intelligence — Anthropic PBC (United States). Receives what you write to a guide or companion, and the dream entries used for a pattern reading, in order to generate the reply. Contractually barred from training on your entries. See Section 4A.2.
• 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.

7.3. Named plainly, because it is the transfer you would most want to know about: when you write to a guide or companion in the mobile app, or ask for a dream-pattern reading, that text is sent to Anthropic PBC in the United States and answered there. This includes anything personal you chose to put in it. If you would rather that did not happen, do not use those features — the mood check-in, the dream journal on its own, the library and the practices do not send anything to an AI provider.

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