CommfyCouch Privacy Policy Effective Date: July 9, 2025 📧 Contact: support@commfycouch.com 🌐 Website: www.commfycouch.com 📍 Jurisdiction: Jodhpur, Rajasthan, India (IT Act 2000 & DPDP Act 2023 compliant) Welcome to CommfyCouch. Your privacy is of utmost importance to us. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you visit our website, purchase our digital journals, or use our online counselling services. Please read this policy carefully. By using CommfyCouch, you consent to the data practices described in this policy. 1. Information We Collect We collect the following categories of personal information: 1.1 Information You Provide Directly ● Full name and email address when you register or contact us ● Payment information (processed securely via Razorpay / Stripe — we do not store card details) ● Information shared during counselling sessions or intake forms ● Messages, feedback, or enquiries submitted through our contact form ● Profile information if you create an account on our platform 1.2 Information Collected Automatically ● IP address, browser type, and device information ● Pages visited, time spent, and clickstream data via cookies and analytics tools ● Referring URLs and search terms used to reach our website 1.3 Sensitive Personal Data Because CommfyCouch offers psychological counselling services and wellness content, we may collect sensitive personal data including mental health information, emotional state disclosures, and related personal experiences shared during sessions. This information is treated with the highest standard of confidentiality and is never shared without your explicit consent, except where required by law. 2. How We Use Your Information We use the personal information we collect for the following purposes: ● To provide, operate, and maintain our website and services ● To process purchases of digital journals and facilitate payment transactions ● To schedule, conduct, and follow up on counselling sessions ● To send transactional emails (purchase confirmations, session reminders) ● To respond to your enquiries and provide customer support ● To send marketing communications (only with your explicit consent; you may unsubscribe at any time) ● To improve our website, products, and service quality through analytics ● To comply with legal obligations under Indian law ● To detect and prevent fraud or misuse of our services CommfyCouch — Privacy Policy | www.commfycouch.com | Page 1 3. Legal Basis for Processing (DPDP Act 2023) Under India's Digital Personal Data Protection Act 2023, we process your personal data on the following lawful bases: Consent: You have given clear consent for us to process your personal data for specific purposes (e.g., marketing communications, counselling intake). Contract: Processing is necessary to fulfil our contract with you — delivering digital products or providing counselling services you have purchased. Legal Obligation: Processing is necessary to comply with applicable Indian laws and regulations. Legitimate Interest: Processing is necessary for our legitimate business interests (e.g., fraud prevention, service improvement), provided these do not override your rights. 4. Cookies and Tracking Technologies We use cookies and similar tracking technologies to enhance your experience on our website. Cookies are small data files stored on your device. 4.1 Types of Cookies We Use ● Essential Cookies: Required for the website to function correctly (login sessions, cart functionality). Cannot be disabled. ● Analytics Cookies: Used to understand how visitors interact with our site (e.g., Google Analytics). Help us improve our content and services. ● Marketing Cookies: Used to display relevant advertisements and track campaign performance. Only enabled with your consent. ● Payment Gateway Cookies: Set by Razorpay or Stripe to securely process transactions. 4.2 Managing Cookies You may disable cookies through your browser settings; however, this may affect the functionality of certain parts of our website. A cookie consent banner appears on your first visit, allowing you to accept or decline non-essential cookies. 5. Sharing and Disclosure of Information We do not sell, rent, or trade your personal information to third parties. We may share your information in the following limited circumstances: ● Service Providers: With trusted third-party vendors who assist us in operating our website and services (e.g., payment processors Razorpay/Stripe, email service providers, video conferencing platforms for sessions), subject to strict confidentiality agreements. ● Legal Requirements: Where disclosure is required by law, court order, or government authority under Indian law (e.g., Information Technology Act 2000, DPDP Act 2023). ● Safety and Security: Where disclosure is necessary to protect the safety of any person, prevent harm, or address suspected illegal activity. ● Business Transfers: CommfyCouch will NEVER transfer, disclose, or share your personal data — including counselling records, client information, or any user data — with any third party, acquiring entity, or successor organisation in the event of a merger, acquisition, sale of assets, or any other form of business transfer. In such events, all personal data shall be permanently and securely deleted before any transaction is completed. No exceptions apply. ● With Your Consent: Any other sharing will only occur with your explicit prior consent. 6. Counselling Session Confidentiality CommfyCouch — Privacy Policy | www.commfycouch.com | Page 2 All information disclosed during counselling sessions is treated as strictly confidential. We do not share session content, personal disclosures, or mental health information with any third party, except in the following mandatory situations required by professional ethics and Indian law: ● If there is a reasonable belief of imminent risk of harm to yourself or others ● If required by a court of law or government authority ● If you provide written consent to share specific information with another professional Sessions are not recorded without your explicit written consent. Any notes taken during sessions are stored securely and accessed only by the counsellor involved in your care. 7. Data Storage and Security We take the security of your personal data seriously and implement appropriate technical and organisational measures to protect it against unauthorised access, alteration, disclosure, or destruction. ● All payment transactions are encrypted using SSL/TLS technology ● Payment card details are processed by PCI-DSS compliant payment gateways (Razorpay/Stripe); we do not store card numbers ● Session notes and sensitive counselling information are stored in secured, password-protected systems ● Access to personal data is restricted to authorised personnel only ● Our website is hosted on secure servers with regular security updates While we employ industry-standard security measures, no method of transmission over the internet or electronic storage is 100% secure. We cannot guarantee absolute security of your data. 8. Children's Privacy CommfyCouch services are intended for individuals aged 18 years and above. We do not knowingly collect personal information from children under the age of 18. If you are under 18, please do not use our website or submit any personal information. If we become aware that we have collected personal data from a minor, we will take immediate steps to delete such information. Parents or guardians who believe their child has provided us with personal information should contact us at support@commfycouch.com. 9. International Data Transfers Your information is primarily stored and processed in India. If you access our services from outside India, or if we use third-party service providers located outside India (such as Stripe for international payments), your data may be transferred to and processed in other countries. Such transfers will be subject to appropriate safeguards consistent with applicable Indian data protection law. By using our services, you consent to such transfers. 10. Third-Party Links Our website may contain links to third-party websites, social media platforms (Instagram, etc.), or payment portals. We are not responsible for the privacy practices or content of those external sites. We encourage you to review the privacy policy of any third-party site you visit. 11. Changes to This Privacy Policy We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or legal requirements. When we make material changes, we will update the Effective Date at the top of this policy and, where appropriate, notify you via email or a prominent notice on our website. Your continued use of CommfyCouch after such changes constitutes your acceptance of the revised policy. CommfyCouch — Privacy Policy | www.commfycouch.com | Page 3 12. Grievance Officer In accordance with the Information Technology Act 2000 and the Digital Personal Data Protection Act 2023, we have designated a Grievance Officer to address privacy-related concerns: Organisation: CommfyCouch Grievance Officer: CommfyCouch Support Team Email: support@commfycouch.com Website: www.commfycouch.com Response Time: Within 30 days of receiving your grievance