Privacy Policy
Privacy Policy
In addition to our Terms of Use, RNJP Technologies respects your privacy and is committed to protecting it. This Privacy Policy (the “Policy”) explains the types of information collected by RNJP Technologies when you use the Platform (as defined in Terms of Use) that references this Policy, how we collect, use, share and store such information collected and also explains the rationale for collection of such information, the privacy rights and choices you have regarding your information submitted to us when you use the Services.
Use of the terms “RNJP Technologies”, “we”, “us, and/or “our” refer to RNJP Technologies Private Limited, a company incorporated in India and having its registered office at Office 2, 22, Paradise Villa Comp., Bhulabhai Road, Cumballa Hill, Mumbai – 400026 which has the license to host the Platform and offer Services. Similarly, use of the terms “you”, “yours” and/or “User(s)” refer to all users of the Platform and includes all Learners and Leaders (as more particularly defined under our Terms of Use).
The Services are governed by this Policy, Terms of Use, and any other rules, policies or guidelines published on the Platform as applicable to you. Please read this Policy carefully prior to accessing our Platform and using the Services. By accessing and using the Platform, providing your Personal Information (defined below), or by otherwise signalling your agreement when the option is presented to you, you consent to the collection, use, disclosure, sharing and storing of information described in this Policy, Terms of Use and any other rules, policies or guidelines published on the Platform as applicable to you (collectively referred to as the“Platform Terms”), and RNJP Technologies disclaims all the liabilities arising therefrom. If you have inadvertently submitted any Personal Information to RNJP Technologies prior to reading this Policy statements set out herein, or you do not agree with the way your Personal Information is collected, stored, or used, then you may access, modify and/or delete your Personal Information in accordance with this Policy (refer to the sections about ‘Your Choices and Your Rights’).
If any information you have provided or uploaded on the Platform violates the Platform Terms, RNJP Technologies may be required to delete such information upon informing you of the same and revoke your access to the Platform if required.
Capitalized terms used but not defined in this Policy can be found in our Terms of Use.
1. Personal Information
“Personal Information” shall mean the information which identifies a User i.e., first and last name, identification number, email address, age, gender, location, photograph and/or phone number provided at the time of registration or any time thereafter on the Platform.
“Sensitive Personal Information” shall include (i) passwords and financial data (except the truncated last four digits of credit/debit card), (ii) health data, (iii) official identifier (such as biometric data, aadhar number, social security number, driver’s license, passport, etc.,), (iv) information about sexual life, sexual identifier, race, ethnicity, political or religious belief or affiliation, (v) account details and passwords, or (vi) other data/information categorized as ‘sensitive personal data’ or ‘special categories of data’ under the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, General Data Protection Regulation (GDPR) and / or the California Consumer Privacy Act (CCPA) (“Data Protection Laws”) and in context of this Policy or other equivalent / similar legislations.
Usage of the term ‘Personal Information’ shall include ‘Sensitive Personal Information’ as may be applicable to the context of its usage.
We request you to not provide RNJP Technologies with any Personal Information unless specifically requested by us. In the event you share any Personal Information with us without us having specifically requested for the same, then we bear no liability in respect of such Personal Information provided by you.
RNJP Technologies is the controller of Personal Information that it collects and processes in connection with the use of the Platform and the provision of the Services on the Platform.
2. Information We Collect
RNJP Technologies will collect the information about you if we have a reason to do so — for example, to provide our Services on the Platform, to communicate with you, or to make our Services better. (“User Information”):
Information we collect from You:
2.1. Basic account information: Information we collect from the Users: In order to access the Courses on the Platform, you will need to create an account and register with us. We ask for basic information including but not limited to name, state of residence country phone number, email address, and password, along with a username and other relevant information. A User may also be asked about its feelings, interests and other general information.
2.2. Know Your Customer ('KYC') information: If you are a Leader registered with us, then, we also collect the KYC information, which may include information pertaining to your PAN number, aadhaar number, driver’s license, passport, your entity details such as name, MOA/AOA, certificate of incorporation, list of directors/partners, etc., along with the relevant documents. We collect this information and documents from you to complete our verification process including pursuant to any other agreement executed with you.
2.3. User Inputs: A User may share comments, messages, and questions on the Platform for their Leaders, which may contain Personal Information. RNJP Technologies will collect information about you when you send, receive or engage with messages, comments, etc. in connection with the Platform. When you browse pages on our Platform, we will track that for statistical purposes which may be to improve the Platform and the Services. You may also provide us your Personal Information or other information when you respond to surveys, enter any form of contests, tests, events, competitions, webinars, etc., hosted by RNJP Technologies, either on the Platform or otherwise, or when you otherwise communicate with us via form, e-form, email, phone, or otherwise, we store a copy of our communications (including any call recordings or emails, if any, as permitted by applicable law).
2.4. Information related to location: You may also choose to provide location related information, including but not limited to access to GPS, which will enable us, with your consent, to offer customized offerings for specific services where location data is relevant and/or applicable such as informing you whether services on the Platform that you have expressed interest in may be availed of at or near your location.
2.5. Minor’s Information: The Platform does not address anyone who does not qualify the Age Qualification (as defined in the Terms of Use). Any portion of the data containing Personal Information relating to a Minor shall be deemed to be given by the Minor’s Parent.
Information we collect automatically:
2.6. Device and Login information: When you access our Platform, we collect information that web browsers, mobile devices, and servers typically make available, including the browser type, IP address, unique device identifiers, language preference, referring site, the date and time of access, operating system, and mobile network information. We collect log information when you use our Platform - for example, when you create or make changes to your account information on the Platform.
2.7. Usage information: We collect information about your usage of our Platform. We also collect information about what happens when you use our Platform (e.g., page views, support document searches, features enabled for your account, interactions with other parts of our Services) along with information about your device (e.g., screen size, name of cellular network, and mobile device manufacturer). We use this information to provide our Platform to you, get insights on how people use our Platform so that we can make our Platform better, and understand and make predictions about User retention.
2.8. Location information: We may determine the approximate location of your device from your Internet Protocol (IP) address. We may collect and use this information to calculate how many people visit from certain geographic regions or to improve our Platform Services.
2.9. Information from cookies & other technologies: We may collect information about you through the use of cookies and other similar technologies. A cookie is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns.
Information we collect from other sources:
2.10. Public domain: We might receive and collect information about you from other sources in the course of their services to us or from a publicly available sources, as permitted by law, which we may combine with other information we receive from or about you. For example, we may receive information about you from a social media site or a Google service if you connect to the Services through that site or if you use the Google sign-in.
3. Basis of Collection and Processing of Your Personal Information
3.1. Basis for collection: We collect and process your Personal Information based on the following legal parameters depending upon the nature of Personal Information and the purposes for which it is processed:
(a) Consent: We rely on your consent to process your Personal Information in certain situations. If we require your consent to collect and process certain Personal Information, as per the requirements under the applicable Data Protection Laws, your consent is sought at the time of collection of your Personal Information and such processing will be performed where consent is secured.
(b) Compliance with a legal obligation: Your Personal Information may be processed by us, to the extent that such processing is necessary to comply with a legal obligation.
3.2. Processing of your Personal Information: We may process your Personal Information in connection with any of the purposes and uses set out in this Policy or as permitted by law. Where the processing of your Personal Information is based on your consent, you have the right to withdraw your consent at any point in time in accordance with this Policy. Please note that should the withdrawal of consent result in us not being able to continue offering our Services to you, we reserve the right to withdraw or cease from offering our Services to you upon your consent withdrawal. You may withdraw consent by contacting us with a written request to the contact details provided in the ‘Grievances’ section below. Upon receipt of your request to withdraw your consent, the consequences of withdrawal may be communicated to you. Upon your agreement to the same, your request for withdrawal will be processed.
4. Purpose and Usage of Information
RNJP Technologies uses and processes the information collected for the following purposes:
4.1. To Provide Services: We use your information to provide the Users with access to the Platform and the Services including without limitation to set-up and maintain your account, provide customer service, fulfil purchases through the Platform, verify User information and to resolve any glitches with our Platform. The legal basis for this processing is consent or, where applicable, our legitimate interests in the proper administration of our Platform, and/or the performance of a contract between you and us.
4.2. To Communicate and Share Information with the Users: We use your information to send automated messages to the Users for various purposes including sharing Course content, information, notes (if any), links to join/attend the Courses, WhatsApp groups/communities, and/or to access and/or download third party applications; appreciation messages for completing a Course. We may also send messages on WhatsApp, text messages, emails or push notifications to the Users to provide updates about the Platform.
4.3. To Improve the Platform and maintain safety: We use your information to improve the Platform’s features and functionality and customize the Platform and Services offered by us, including providing automatic updates to newer versions of our Platform and creating new features based on the Platform usage analysis. Further, we also use your information to prevent, detect, investigate, and take measures against criminal activity, fraud, misuse of or damage to our Platform or network, and other threats and violations to RNJP Technologies or a third party's rights and property, or the safety of RNJP Technologies, its users, or others. The legal basis for this processing is consent or, where applicable, our legitimate interests in the proper administration of our Platform, and/or the performance of a contract between you and us.
5. Disclosure of Information
We share the information collected as per terms of this Policy only in the manner specified hereinbelow. We do not sell or otherwise disclose Personal Information we collect about you for monetary or other valuable consideration. Further, only authorized representatives of RNJP Technologies and on a need-to-know basis use any information received from you and as consented by you. In the event of any identified unauthorized use or disclosure of information or upon your complaint as stated under the ‘Grievances’ section below, we will investigate any such complaint and take the appropriate action as per the applicable Data Protection Laws.
5.1. Third party service providers: We may share your information with third party service providers or vendors (including consultants, payment processors, and other service providers and integrated services) who need the information to provide their support services to us or you, or to provide their services to you on our behalf either directly or through the Platform. These services may include providing customer support, performing business and sales analysis, supporting our website functionality, facilitating payment processing, and supporting contests, surveys, and other features offered on our Platform. Such third-party vendors are not allowed to use the information for any purpose other than what it was provided for, and they are required to process and use the information in accordance with this Privacy Policy.
5.2. Leaders: We may share your information with the Leaders to widen and enhance interactions with their Users.
5.3. Legal Compliance: We may disclose your information if it is under a duty to disclose or share your information in order to comply with any order or legal obligation, under any law, or in order to enforce or apply the Terms of Use. This includes disclosing information to government agencies, other companies and organizations for the purposes of prevention, detection and investigation of fraud including cyber related crimes.
5.4. Affiliates and Subsidiaries: We may disclose information about you to our affiliates, subsidiaries and other businesses under the same control and ownership, and their respective officers, directors, employees, accountants, attorneys, or agents, who need the information to help us provide the Services or process the information on our behalf. or to market similar services/offerings to you. We require our affiliate, subsidiaries and other businesses under the same control and ownership to follow this Privacy Policy for any Personal Information that we share with them.
5.5. Business transfers: In the event RNJP Technologies undergoes any merger, acquisition, or sale of company assets, in part or in full, with another company, or in the unlikely event that RNJP Technologies goes out of business or enters bankruptcy, user information would likely be one of the assets that is transferred or acquired by a third party. If any of these events were to happen, this Privacy Policy would continue to apply to your information and the party receiving your information may continue to use your information, but only consistent with this Privacy Policy.
5.6. Advertising and Analytics Partners: We may share usage data with third-party advertisers, advertisement networks, and analytics providers through cookies and other similar technologies.
5.7. With Your Consent: We may share and disclose information with your consent or at your direction.
6. Duration for which your Information is Stored
6.1. Generally, when you delete any of the information provided by you or when you delete your account, on the Platform, the same will be deleted from our servers too. However, in certain cases, we will retain your information for as long as it is required for us to retain for the purposes stated hereinabove, including for the purpose of complying with legal obligation or business compliances.
6.2. Further, please note that we may not be able to delete all communications or photos, files, or other documents publicly made available by you on the Platform (for example: comments, feedback, etc.), however, we shall anonymize your Personal Information in such a way that you can no longer be identified as an individual in association with such information made available by you on the Platform. We will never disclose aggregated or de-identified information in a manner that could identify you as an individual.
7. Your Choices
7.1. Reject Cookies and other similar technologies: You may reject or remove or disable (some but not all) cookies through the browser settings on your electronic device but doing so may limit the User’s ability to use some features or functionalities of the Platform.
7.2. Limit the information You provide: You always have an option to choose the information you provide to us, including the option to update or delete your information. However, please note that lack of certain information may not allow you the access to the Platform or any of its features, in part or in full.
7.3. Limit the communications You receive from us:Further, you will also have the option to choose what kind of communication you would like to receive from us and whether you would like to receive such communication at all or not. However, there may be certain communications that are required for legal or security purposes, including changes to various legal agreements, that you may not be able to limit.
8. Security
8.1. We follow generally and commercially accepted, appropriate electronic, and managerial procedures to safeguard and help prevent unauthorized access to Personal Information, as submitted and collected in accordance with the Terms of Use and to maintain data security. These safeguards take into account the sensitivity of the information that the Platform collects, processes and stores and the current state of technology. Our security measures may be reviewed and updated in terms of technological advances. We assume no liability or responsibility for disclosure or leak of any Personal Information due to errors in transmission, unauthorized third-party access, or other causes beyond our control.
8.2. Notwithstanding anything contained in the Privacy Policy or elsewhere your agree that we will not be held responsible for any loss, damage or misuse of Personal Information, as collected in accordance with the Terms of Use, if such loss, damage or misuse is attributable to negligence on part of the User, or on part of any third-party or a force majeure event.
9. Rights Of the Users
The User is entitled to the following rights in relation to its User Information:
9.1. Right to confirmation and access: You have a right to get information and/or confirmation, and access to your Personal Information that is with us along with other supporting information.
9.2. Right to correction: You have the right to ask us to rectify your Personal Information that is with us that you think is inaccurate You also have the right to ask us to update your Personal Information that you think is incomplete or out-of-date.
9.3. Right to be forgotten: You have the right to restrict or prevent the continuing collection, processing, usage and disclosure of your Personal Information under certain circumstances.
9.4. Right to Erasure: If you wish to withdraw/remove your Personal Information from our Platform, you have the right to request erasure of your Personal Information from our Platform. However, please note that such erasure will remove all your Personal Information from our Platform (except as specifically stated in this Policy) and may result in deletion of your account on the Platform permanently, and the same will not be retrievable.
10. Duties of Users
10.1. User shall comply with the provisions of all applicable laws for the time being in force while exercising rights;
10.2. Users shall ensure not to impersonate another person while providing your personal data for a specified purpose;
10.3. User shall ensure not to suppress any material information while providing your personal data for any document, unique identifier, proof of identity or proof of address;
10.4. User shall ensure not to register a false or frivolous grievance or complaint with RNJP Technologies, its Grievance Officer or any other legal authority; and
10.5. User shall always furnish only such information as is verifiably authentic, while exercising the right to correction or erasure.
11. Cookies
The Platform uses 'cookies' to collect data to recognize you and your devices and the devices where you have accessed the services. Cookies are small file of letters and numbers that we put on your device when you use the Platform. We use cookies to improve the quality of our Services by storing user preferences and tracking user trends, such as how people search. The information collected through cookies is not sold, rented or shared with any third parties except for event analytics service company that tracks user interactions with web and mobile applications. Most browsers are initially set up to accept cookies, but you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, some Courses and Services may not function properly if your cookies are disabled. We shall use both persistent cookies which could remain on your device until their expiry (which, in some cases, upto 10 years) and session cookies, which are temporary files removed from your device once your browser is closed. We may use the analytical/tracking cookies which allows us to recognize and count the number of visitors and analyze use of the services, as well as to verify transactions.
12. Modification to Privacy Policy
Our business changes constantly and our Policy may change from time to time. We may, at our discretion (unless required by applicable laws to mandatorily do so), email periodic reminders of our notices and conditions, unless you have instructed us not to, but we encourage you to check our Platform frequently to see the recent changes. Unless stated otherwise, our current Policy applies to all information that we have about you and your account. We stand behind the promises we make, however, and will not materially change our policies and practices making them less protective of customer information collected in the past without your consent.
13. Grievance Redressal
You may address requests/grievances and / or complaints to support@soulsensei.in
RNJP is available to address grievances between 11:00 A.M. to 5:00 P.M. from Monday to Friday except public holidays. RNJP Technologies will endeavour to respond to the User’s grievances within a period of 24 hours from the receipt of the email and resolve the grievances within a period of 15 days from the receipt of the email.
In accordance with Information Technology Act 2000 and rules made there under, the name and contact details of the Grievance Officer are provided below:
Name – Janhavi Parikh
Company Name – RNJP Technologies Private Limited
Address: Office 2, 22, Paradise Villa Comp., Bhulabhai Road, Cumballa Hill, Mumbai - 400026
Phone - +91 9930011706
Email Address – support@soulsensei.in
14. Effective Date
14.1. The Privacy Policy and any amendments thereto will be effective from the date the Privacy Policy were last published.
14.2. This Privacy Policy was last published on [08.01.2024]