Version 1.0. Updated 22, 2026
Rachmanas (“Company,” “we,” “our,” or “us”) is committed to protecting the privacy, dignity, and confidentiality of individuals who access or use our behavioural counselling and well-being services (collectively, the “Platform”).
We recognise that the nature of services offered through the Platform involves the collection and processing of behavioural insights, reflective disclosures, psychological questionnaires, and other personal information that may be sensitive in character. We treat such information with heightened care and responsibility.
This Privacy & Cookie Policy (“Policy”) explains how we collect, use, process, store, disclose, and protect personal data in connection with:
This Policy forms an integral part of the Terms & Conditions governing use of the Platform.
Rachmanas acts as a “Data Fiduciary” within the meaning of the Digital Personal Data Protection Act, 2023 (“DPDP Act”), as we determine the purpose and means of processing personal data collected through the Platform.
As a Data Fiduciary, we undertake to process personal data:
Where required under law, Rachmanas shall comply with additional obligations applicable to designated categories of Data Fiduciaries, including but not limited to enhanced governance, impact assessments, or appointment of designated officers.
This Policy is structured in alignment with applicable Indian law, including:
In the event of conflict between this Policy and applicable statutory requirements, the latter shall prevail.
This Privacy & Cookie Policy applies to all personal data collected, processed, stored, or otherwise handled by Rachmanas in connection with its services, whether collected directly from Users or through automated technologies.
This Policy governs data processing activities across the following channels and systems:
Where Rachmanas integrates with external service providers for hosting, analytics, communication, AI processing, advertising, or payment services, this Policy applies to the extent that personal data is processed under Rachmanas’ control as Data Fiduciary.
This Policy does not apply to independent third-party platforms or websites that are not controlled by Rachmanas. Users are encouraged to review the privacy policies of such third-party services.
Rachmanas collects and processes personal data necessary for delivery of behavioural counselling services, operation of the Platform, compliance with law, and improvement of services.
The categories of personal data collected may include the following:
We may collect basic identifying information, including:
This information is required for account creation, communication, and session scheduling.
Given the nature of services offered, Rachmanas may collect and process behavioural and reflective information shared by Users during counselling interactions.
This may include:
Such data may be sensitive in nature. Rachmanas processes this information strictly within the defined scope of behavioural counselling services.
Rachmanas does not solicit medical diagnostic records unless voluntarily disclosed by the User.
Sessions may be recorded only upon explicit prior consent of the User.
Where consent is provided:
If consent is not provided, sessions shall not be recorded.
We may automatically collect technical information when Users access the Platform, including:
This data assists in maintaining security, improving functionality, and analysing usage patterns.
Rachmanas may use third-party analytics tools to collect information regarding:
Such analytics tools may utilise cookies, tracking pixels, or similar technologies.
Where Rachmanas engages in online advertising and remarketing, certain tracking technologies may collect:
This information may be used for:
Users may manage advertising preferences through platform-specific controls and cookie settings.
Payments are processed through authorised third-party payment gateways.
Rachmanas may collect:
Rachmanas does not store complete credit card, debit card, or banking credentials on its servers.
Where Users access services through employer-sponsored programs, we may collect:
Individual session content shall not be disclosed to Corporate Clients without explicit consent, except where legally required.
We may retain records of:
Such records are retained for operational, compliance, and security purposes.
Rachmanas may generate derived data through analysis of User inputs, including:
Where data is anonymised in a manner that prevents re-identification, it may no longer constitute personal data under applicable law.
Rachmanas collects and processes personal data solely for specified, lawful, and proportionate purposes connected to the delivery of behavioural counselling services and operation of the Platform.
Personal data may be processed for the following purposes:
To:
To:
AI-assisted tools operate as supportive systems and do not independently make medical, legal, or employment decisions.
To:
Where session recordings are retained (with consent), they may be used for supervision, training, research, or compliance purposes.
To:
No identifiable personal data shall be published in research outputs.
To:
Individual session content is not disclosed to employers without explicit consent, except where legally required.
To:
Users may not opt out of essential administrative communications necessary for service delivery.
To:
Where required, such processing is based on User consent through cookie preferences or platform settings.
To:
To:
To:
Rachmanas does not provide continuous monitoring and does not assume ongoing supervisory responsibility beyond scheduled sessions.
Rachmanas processes personal data only where a valid legal basis exists under applicable law, including the Digital Personal Data Protection Act, 2023.
The legal bases relied upon may include the following:
Where required under law, Rachmanas processes personal data based on the User’s free, specific, informed, and unambiguous consent.
Consent may be obtained through:
Users may withdraw consent at any time, subject to legal or contractual limitations. Withdrawal of consent may affect the ability of Rachmanas to continue providing certain services.
Processing is necessary to perform the contractual relationship between the User and Rachmanas, including:
Where processing is essential to service delivery, withdrawal of consent may result in suspension or termination of services.
Rachmanas may process personal data to comply with applicable legal requirements, including:
Where permitted by law, Rachmanas may process personal data to pursue legitimate operational interests, provided such interests do not override the fundamental rights of Users.
Such legitimate interests may include:
Where Users voluntarily provide information during counselling sessions, activities, or communications, such disclosures may constitute deemed consent for processing within the defined scope of behavioural counselling services.
However, Rachmanas does not interpret voluntary disclosure as consent for public dissemination or marketing use without explicit written agreement.
Processing related to non-essential cookies, advertising pixels, and remarketing tools is based on User consent obtained through cookie preference mechanisms or equivalent consent tools.
Users may withdraw such consent through:
Withdrawal of advertising consent does not affect core counselling services.
Rachmanas may utilise artificial intelligence systems, algorithmic tools, and large language model (LLM) technologies to support service delivery, enhance behavioural insights, and improve operational efficiency.
AI tools are used strictly as assistive technologies and do not replace human professional judgment.
AI systems may be used for purposes including:
AI outputs are probabilistic in nature and may not be fully accurate, exhaustive, or contextually complete.
All counselling decisions, interpretations, and recommendations are subject to human oversight by qualified professionals.
No AI system independently:
Human judgment remains central to all counselling interactions.
Rachmanas does not engage in decision-making that produces legal or similarly significant effects based solely on automated processing.
Users are not subject to automated denial of services without human review.
Rachmanas may utilise third-party AI infrastructure providers, including large language model APIs or AI-processing platforms, to support behavioural analysis and content generation.
Where such infrastructure is used:
Rachmanas does not guarantee error-free outputs from AI systems and shall not be liable for inaccuracies inherent to probabilistic model behaviour.
AI systems may reflect limitations or biases inherent in training data.
Rachmanas undertakes reasonable efforts to monitor and mitigate bias; however:
Users acknowledge that AI-assisted insights are supportive tools intended for behavioural reflection and guidance.
Users remain responsible for:
Rachmanas may use advertising, analytics, and tracking technologies to:
These technologies may operate across websites, social media platforms, and search engines.
We may use third-party analytics services to collect and analyse information such as:
Analytics tools may use cookies, tracking pixels, SDKs, or similar technologies to collect usage data.
Rachmanas may use advertising technologies such as:
These tools may collect information regarding:
Such technologies may enable the display of Rachmanas advertisements on third-party websites or social media platforms.
Advertising partners may use cookies or similar technologies to:
Rachmanas does not control how third-party advertising networks process data once collected under their independent privacy policies.
Users are encouraged to review the privacy policies of such third-party providers.
Processing related to non-essential advertising cookies and tracking technologies is based on User consent obtained through:
Users may withdraw or modify advertising consent at any time through cookie settings or browser-level controls.
Withdrawal of advertising consent shall not affect access to core counselling services.
Users may manage advertising preferences by:
Rachmanas does not guarantee that all advertising tracking can be fully disabled due to technical limitations inherent in third-party ecosystems.
Under no circumstances does Rachmanas:
Advertising and tracking technologies operate independently of counselling session content.
Rachmanas uses cookies and similar tracking technologies to operate, secure, and improve the Platform, and to support analytics and advertising functions.
Cookies are small text files placed on a User’s device when visiting a website. Similar technologies may include:
These technologies enable the Platform to recognise returning Users, maintain session integrity, and analyse interaction patterns.
Rachmanas may deploy the following categories of cookies:
These cookies are essential for:
These cookies cannot be disabled without affecting core services.
These cookies collect information regarding:
Such data is generally aggregated and used to improve platform performance and user experience.
These cookies enable:
These cookies may be used to:
Advertising cookies may be set by Rachmanas or third-party advertising partners.
Certain cookies and tracking technologies may be placed by third-party providers, including:
Rachmanas does not control the independent data processing practices of such third parties. Users are encouraged to review the privacy policies of these providers.
Upon first access to the Platform, Users may be presented with a cookie consent banner allowing them to:
Consent for non-essential cookies (including analytics and advertising cookies) may be withdrawn or modified at any time through cookie preference settings.
Users may manage or delete cookies through:
Disabling certain cookies may impact functionality or limit access to specific features.
Cookies may remain on a User’s device for varying durations, including:
Retention periods are determined based on operational necessity and third-party provider configurations.
The Platform may not respond to “Do Not Track” browser signals due to technical limitations and varying industry standards.
Rachmanas does not sell, rent, or trade personal data for monetary consideration.
Personal data may be shared only in the circumstances described below and strictly for legitimate purposes.
Rachmanas may engage trusted third-party service providers (“Data Processors”) to support operational activities, including:
Such service providers process personal data only under contractual safeguards and are required to implement reasonable security measures.
Rachmanas remains responsible for ensuring that such processing is conducted in accordance with applicable law.
Where AI tools or large language model APIs are used:
Rachmanas does not authorise such providers to use personal data for independent marketing purposes.
Where services are provided under employer-sponsored programs:
Rachmanas does not permit Corporate Clients to access confidential counselling content.
Advertising and analytics partners may collect certain technical or device-level data through tracking technologies as described in Part VII and Part VIII.
Such partners may act as independent data controllers under their own privacy policies.
Rachmanas does not share counselling session content, PIQ responses, or behavioural disclosures with advertising partners.
Rachmanas may disclose personal data:
Disclosure shall be limited to what is legally necessary.
In the event of:
personal data may be transferred to a successor entity, subject to confidentiality safeguards and applicable law.
Users shall be notified where required by law.
Rachmanas does not publicly disclose identifiable personal data without explicit consent.
Anonymised and non-identifiable data may be used for research, awareness, or marketing purposes in accordance with this Policy.
Rachmanas primarily operates within India. However, certain service providers engaged by Rachmanas may process personal data on infrastructure located outside India.
Such cross-border processing may occur in connection with:
Where personal data is transferred outside India, such transfer shall occur:
Rachmanas shall take reasonable steps to ensure that overseas service providers implement appropriate data protection measures.
Rachmanas undertakes reasonable due diligence when selecting third-party service providers, including assessment of:
However, Rachmanas does not control the internal operational practices of independent third-party infrastructure providers.
While reasonable security measures are implemented, Rachmanas cannot guarantee that data processed outside India will be subject to identical legal standards as those applicable under Indian law.
By using the Platform, Users acknowledge that cross-border processing may occur in connection with legitimate service delivery and infrastructure support.
Cross-border transfers shall not be made for the purpose of selling personal data or permitting independent commercial exploitation by third parties.
Rachmanas retains personal data only for as long as necessary to fulfil the purposes described in this Policy, comply with legal obligations, resolve disputes, and enforce contractual rights.
Retention periods may vary depending on the nature of the data and the purpose of processing.
Identity information, communication records, behavioural activity logs, and related service data may be retained for up to five (5) years from the date of the User’s last interaction with the Platform, unless:
Session notes, behavioural insights, questionnaire responses, and activity records may be retained for up to five (5) years from the date of the last session, subject to legal requirements and internal governance policies.
Retention beyond this period may occur where:
Where Users have expressly consented to session recording:
After expiry of the applicable retention period, recordings may be securely deleted or anonymised in accordance with internal policies.
Analytics and advertising-related data may be retained in accordance with:
Such data is typically aggregated or pseudonymised.
Where Rachmanas is required to preserve data in connection with:
such data may be retained beyond standard retention periods until the matter is resolved.
Upon expiry of the applicable retention period:
Anonymised data may be retained for research, statistical analysis, service improvement, or AI training purposes.
Rachmanas shall not be obligated to preserve personal data, session records, or recordings beyond the retention periods described herein, unless required by law.
Users may request deletion in accordance with applicable rights; however, such requests remain subject to legal, contractual, and operational limitations.
Rachmanas implements reasonable technical, administrative, and organisational safeguards to protect personal data against unauthorised access, alteration, disclosure, or destruction.
Security measures are proportionate to:
Security measures may include:
Access to personal data is restricted on a need-to-know basis.
Measures include:
Counsellors and staff are granted access only to information necessary for service delivery and operational duties.
All employees, counsellors, contractors, and service providers who process personal data are bound by:
Where third-party service providers process personal data on behalf of Rachmanas, contractual safeguards are implemented to require:
Rachmanas undertakes reasonable due diligence when selecting service providers but does not control their internal operational systems.
Rachmanas maintains internal processes to:
Where required under applicable law, affected Users and regulatory authorities shall be notified in accordance with statutory obligations.
While Rachmanas employs reasonable security measures, no method of electronic transmission or storage is completely secure.
Accordingly, Rachmanas cannot guarantee absolute security of personal data.
Users are encouraged to:
In accordance with the Digital Personal Data Protection Act, 2023, individuals whose personal data is processed by Rachmanas (“Data Principals”) may exercise certain rights, subject to applicable legal limitations.
Requests may be submitted through the grievance or data protection contact details provided in this Policy.
Users may request confirmation as to whether Rachmanas is processing their personal data.
Where applicable, Users may request access to:
Access requests shall be fulfilled within statutory timelines, subject to identity verification and lawful exemptions.
Users may request correction of:
Rachmanas may require reasonable verification before implementing corrections.
Users may request erasure of personal data where:
Erasure requests remain subject to:
Where erasure is granted, data may be deleted or irreversibly anonymised.
Where processing is based on consent, Users may withdraw such consent at any time.
Withdrawal shall not affect processing conducted prior to withdrawal.
Withdrawal of consent may:
Users may lodge grievances regarding:
Grievances shall be addressed within the timelines prescribed under applicable law.
If unresolved, Users may approach the appropriate statutory authority as permitted under the DPDP Act.
Users may nominate another individual to exercise their rights under applicable law in the event of death or incapacity, in accordance with statutory provisions.
Rachmanas may require appropriate verification prior to acting upon such nomination.
The exercise of rights under this section shall be subject to:
Rachmanas reserves the right to decline requests that are manifestly unfounded, excessive, repetitive, or abusive, in accordance with applicable law.
Rachmanas provides behavioural counselling services exclusively to individuals who are eighteen (18) years of age or older.
The Platform is not intended for use by minors.
Rachmanas does not knowingly collect, solicit, or process personal data from individuals below the age of eighteen (18).
By registering or using the Platform, Users represent and warrant that they are at least eighteen (18) years of age and legally capable of entering into a binding agreement.
Rachmanas shall not be liable for misrepresentation of age by any User.
If Rachmanas becomes aware that personal data of a minor has been collected without lawful authority:
Parents or guardians who believe that a minor has provided personal data may contact Rachmanas through the grievance mechanism provided in this Policy.
Rachmanas does not engage in behavioural profiling, targeted advertising, or counselling services directed at minors.
Rachmanas maintains internal procedures to identify, assess, and respond to suspected or confirmed personal data breaches in a timely and responsible manner.
A “personal data breach” refers to unauthorised access, disclosure, alteration, destruction, or loss of personal data.
Upon becoming aware of a suspected incident, Rachmanas shall:
Where appropriate, Rachmanas shall take reasonable steps to:
Where required under the Digital Personal Data Protection Act, 2023, or other applicable laws, Rachmanas shall notify the relevant regulatory authority within prescribed timelines.
Where a breach is likely to result in significant harm to affected individuals, Rachmanas may notify impacted Users in accordance with legal requirements.
Such notification may include:
Rachmanas may document:
Internal review processes may be implemented to strengthen security posture.
While reasonable security safeguards are implemented, Rachmanas shall not be liable for unauthorised access or breaches resulting from:
Rachmanas is committed to addressing concerns relating to personal data processing in a timely and transparent manner.
Users may submit grievances relating to:
Grievances may be submitted via email at support@rachmanas.com.
Rachmanas shall designate a Grievance Officer in accordance with applicable law.
The Grievance Officer shall be responsible for:
Unless otherwise required by law, grievances shall be addressed within sixty (60) working days from receipt.
Where required under the Digital Personal Data Protection Act, 2023, or where Rachmanas is designated as a Significant Data Fiduciary, a Data Protection Officer (DPO) may be appointed.
The DPO, if appointed, shall:
Contact details of the DPO, where applicable, shall be made publicly available.
If a grievance remains unresolved after internal review, Users may approach the appropriate statutory authority as permitted under the Digital Personal Data Protection Act, 2023.
Nothing in this Policy restricts statutory rights available under applicable law.
To protect confidentiality, Rachmanas may require reasonable identity verification before acting upon grievance or data access requests.
Rachmanas reserves the right to modify, amend, or update this Privacy & Cookie Policy at any time to reflect:
Any updated version of this Policy shall:
The “Last Updated” date shall reflect the date on which the revised version becomes operative.
Continued access to or use of the Platform after the effective date of a revised Privacy & Cookie Policy shall constitute acceptance of the updated terms.
Where material changes significantly affect User rights or data processing practices, reasonable efforts may be made to notify Users through:
This Policy supersedes all prior versions of privacy notices issued by Rachmanas with respect to the matters addressed herein.
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