PRIVACY POLICY

Intuition Process Mobile Application

Effective Date: 15 July 2026 Last Updated: 15 July 2026

1. Introduction

This Privacy Policy explains how The Art of Living, India, operated by its registered public charitable trust Vyakti Vikas Kendra India (VVKI), on behalf of itself and its affiliated and associated organisations (the “Organisation”, “we”, “us” or “our”), collects, uses, shares, protects and otherwise processes your personal data when you use the Intuition Process mobile application (the “App”).

We understand that your privacy — and the privacy of your child — is important to you. We are committed to handling personal data responsibly and in accordance with applicable law, in particular the Digital Personal Data Protection Act, 2023 and the Digital Personal Data Protection Rules, 2025 of India (together, the “DPDP Law”). Where the App is made available to users outside India in future, additional laws may apply, and we will update this Policy accordingly.

By creating or using an account on the App, you (and, where the user is a child, the parent or lawful guardian who provides consent) acknowledge that you have read and understood this Privacy Policy. If you do not agree with it, please do not use the App.

Because a significant number of our users are children, this Policy places special emphasis on how we protect children’s data. Please read Section 7 (Children’s Privacy) carefully.

2. Scope

This Policy applies only to the Intuition Process mobile application for Android and iOS.

Enrolment and registration for the Intuition Process program take place outside the App and are not governed by this Policy. Accounts are pre-created when an individual registers for an Intuition Process program using their (or their parent’s) mobile number. The App itself is used to:

log registered participants and their parents in, using the mobile number provided at registration;
deliver the program experience, including guided content and daily self-practice;
allow a child to maintain a personal journal within the App; and
enable participation in live online classes conducted by our teachers.

This Policy does not cover any third-party websites, services or applications that may be linked from the App. We encourage you to review the privacy policies of any third parties before providing them with data.

3. Key Definitions

Child – under the DPDP Law, any individual who has not completed 18 years of age.
Parent / Guardian – a parent or lawful guardian of a child, who provides verifiable consent on the child’s behalf and is the Data Principal in respect of the child’s data.
Personal Data – any data about an individual who is identifiable by or in relation to such data.
Data Fiduciary – the entity that determines the purpose and means of processing personal data. For the App, this is the Organisation.
Data Principal – the individual to whom personal data relates. Where the individual is a child, the Data Principal includes the child’s parent or lawful guardian.
Processing – any operation performed on personal data, such as collection, storage, use, sharing or deletion.

4. Information We Collect

We practise data minimisation and collect only what is needed to run the Intuition Process program. The App handles the following categories of data.

4.1 Profile information (collected at program registration, used in the App)

Name of the participant.
Contact (mobile) number — this is generally the parent’s or guardian’s number.
Gender.

These three items form the participant profile used within the App and are the only participant details visible to your assigned teacher (see Section 7).

The mobile number registered for the program, used to authenticate you when you log in.

4.3 Content you create in the App

Journal entries written by the child within the App.
Daily self-practice records — for example, whether and how regularly a child completes their daily practice.

Journal entries and self-practice records are private to the child (and, where applicable, the child’s parent). They are not visible to teachers and are not used for advertising, profiling or behavioural monitoring.

4.4 Live online class information

When you join a live class, real-time audio and video are transmitted through the Zoom Meeting SDK so that you can see and hear the teacher and other participants during the session. Live classes are not recorded by us, by teachers or by participants. See Section 8 for full details.

4.5 Information collected automatically

To operate the App securely and reliably, we (and the service providers described in Section 9) may collect limited technical data, such as: device type and model, operating system and version, app version, a device push notification token, IP address, and basic in-app activity logs. This data is used for authentication, security, delivery of notifications, and to keep the App working correctly.

4.6 Information we do NOT collect

For clarity, the App does not:

collect health, medical or other special/sensitive personal data (records of daily-practice regularity are engagement information, not health data);
collect biometric identifiers or precise geolocation;
collect payment or financial information (there are no in-app payments);
serve advertising, use advertising cookies, or track users across other apps or websites; or
record live sessions.

5. How We Use Your Information

We use personal data only for the following purposes:

to authenticate you and provide access to your account;
to deliver the Intuition Process program, including guided content, daily practice and live classes;
to enable a child to keep a personal journal and to view their own practice progress;
to send you service-related and program-related communications and, where you have enabled them, push notifications;
to maintain the security, integrity and proper functioning of the App and to prevent misuse or abuse;
to respond to your queries, requests and grievances; and
to comply with our legal obligations and lawful requests from authorities.

We do not use personal data for targeted advertising, and we do not carry out behavioural monitoring, tracking or profiling of children.

6. Legal Basis for Processing

Under the DPDP Law, we process personal data on the basis of:

Consent – the free, specific, informed and unambiguous consent of the Data Principal for a defined purpose. For a child, we rely on the verifiable consent of the parent or lawful guardian (see Section 7).
Certain legitimate uses permitted by the DPDP Law, such as processing necessary to respond to a request you have made, or to comply with law.

You may withdraw your consent at any time (see Section 13). Withdrawing consent does not affect the lawfulness of processing carried out before the withdrawal, but it may limit or prevent your continued use of the App.

7. Children’s Privacy

Protecting children is central to how the App is designed. The Intuition Process program is intended for children and young people, and the following safeguards apply.

7.1 Who is a child

Under the DPDP Law, everyone under 18 years of age is a child. We treat all users under 18 as children and apply the protections in this section to them.

When signing up, users go through an age gate:

to sign up as a child, the user must be 13 years or older; and
a child under 13 does not sign up on their own — a parent or guardian signs up as the parent of a child.

Before a child’s personal data is processed, we obtain verifiable consent from the child’s parent or lawful guardian. The parent’s mobile number is generally the contact number associated with the account, and parental consent is captured as part of program registration and account set-up. We maintain records of the consent obtained.

7.4 Parental involvement in live classes

All live sessions are group classes. Children do not attend live sessions on their own — parents are guided to accompany their child during live online classes.

7.5 What teachers can see

Our teachers are authorised representatives and volunteers of the Organisation. A teacher can see only the following details, and only for participants enrolled in that teacher’s own program: the participant’s name, contact number and gender. Teachers cannot see a child’s journal entries or self-practice records.

7.6 No tracking or targeted advertising of children

Consistent with the DPDP Law, we do not track or behaviourally monitor children, and we do not direct targeted advertising at children. We do not undertake any processing that is likely to cause a detrimental effect on the well-being of a child.

7.7 Parental rights and controls

A parent or guardian may, at any time, request access to, correction of, or deletion of their child’s data, and may withdraw consent, by contacting us using the details in Section 18. Withdrawing consent or deleting the account may end the child’s participation in the program through the App.

If you believe we have processed a child’s data without appropriate parental consent, please contact us and we will take prompt steps to address it, including deleting such data where appropriate.

8. Live Video Sessions (Zoom Meeting SDK)

Live classes are delivered using the Zoom Meeting SDK, which is embedded in the App.

Live video and audio only. The feature provides real-time video and audio so participants and the teacher can interact during class. No other Zoom features (such as in-session chat, file transfer or screen sharing) are enabled.
No recording. Sessions are not recorded by the Organisation, teachers or participants, and no recordings are stored.
Zoom as a service provider. Zoom acts as our service provider (processor) for the delivery of live sessions. To provide the video service, Zoom processes session audio/video streams in real time and certain technical/connection information (for example, device and network information needed to connect the call). Zoom’s processing of this information is also governed by Zoom’s own privacy terms applicable to its SDK services.
Group setting with a parent present. Classes are conducted in a group format, and children are accompanied by a parent or guardian.

Because sessions are live and unrecorded, once a session ends there is no session recording retained by us.

We do not sell or rent your personal data. We share personal data only as described below.

Our teachers, representatives and volunteers, strictly on a need-to-know basis and limited to the participant details described in Section 7.5, to deliver the program.
Service providers (processors) who help us operate the App, bound by confidentiality and data-protection obligations and permitted to use the data only to provide services to us. These currently include:
- Zoom – live video class delivery (Meeting SDK), as described in Section 8;
- Google Firebase Cloud Messaging (FCM) – push notifications on Android;
- Apple Push Notification service (APNs) – push notifications on iOS;
- Secure cloud hosting/infrastructure providers engaged by us to host and run the App.
App stores – the App is distributed via the Google Play Store and the Apple App Store, which process certain data under their own privacy policies when you download or manage the App.
Legal and regulatory disclosures – where we are required to share data to comply with applicable law, a court order, or a lawful request from a governmental or regulatory authority, or to protect the rights, safety and security of our users, the public or the Organisation.

10. Cross-Border Data Transfers

The App is currently intended for users in India, and personal data is primarily processed in India. However, some of our service providers (such as Zoom, Google and Apple) may process or route certain data through servers located outside India.

Where such transfers occur, we will comply with the requirements of the DPDP Law, including any restrictions the Government of India may notify on transfers to specific countries or territories, and we will take reasonable steps to ensure your data continues to be protected.

11. Data Retention

We retain personal data only for as long as it is necessary for the purposes described in this Policy, or for as long as required to comply with our legal obligations. In general:

profile, account and in-app content (such as journal entries and practice records) are retained while the account remains active and the user participates in the program;
when data is no longer required — for example, on account deletion or withdrawal of consent — we will delete or anonymise it within a reasonable period, unless a longer retention period is required by law; and
we do not retain personal data indefinitely.

You may request deletion of your (or your child’s) data at any time, as set out in Section 13.

12. Data Security

We implement appropriate technical and organisational measures to protect personal data against unauthorised access, alteration, disclosure, loss or destruction. These include, as applicable, encryption of data in transit, access controls limiting who can view participant data, secure authentication, logging and monitoring, and regular review of our safeguards.

No system can be guaranteed to be completely secure, and transmission of data over the internet carries inherent risks. However, we take our security obligations seriously.

In the event of a personal data breach, we will act in accordance with the DPDP Law — including intimating the affected Data Principals and notifying the Data Protection Board of India with the required details, generally within 72 hours of becoming aware of the breach.

13. Your Rights

Subject to the DPDP Law, you (and, for a child, the child’s parent or guardian) have the right to:

Access – obtain a summary of the personal data we process about you and the processing activities undertaken.
Correction and completion – request that we correct inaccurate or misleading data, and complete or update incomplete data.
Erasure – request deletion of your personal data, subject to any legal retention requirements.
Grievance redressal – have your grievances addressed by us (see Section 18).
Nomination – nominate another individual to exercise your rights under the DPDP Law in the event of your death or incapacity.
Withdraw consent – withdraw your consent at any time, as easily as it was given.

To exercise any of these rights, please contact us using the details in Section 18. We may need to verify your identity (and, for a child, your status as parent or guardian) before acting on a request, in order to protect the data.

14. Cookies and Similar Technologies

The App is a mobile application and does not use advertising or tracking cookies. It uses only essential on-device storage and identifiers necessary to keep you logged in, maintain your session, and deliver push notifications (for example, a device push token). We do not use these technologies to build advertising profiles or to track you across other apps or websites.

15. Push Notifications

With your permission, we send push notifications about the program, your practice and related information via FCM (Android) and APNs (iOS). You can turn push notifications off at any time in your device settings.

16. Third-Party Links

The App may contain links to third-party content or services. We are not responsible for the privacy practices of those third parties, and this Policy does not apply to them. Please review their privacy policies before providing any data.

17. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or in applicable law. When we make material changes, we will notify you through the App or by other appropriate means, and we will update the “Last Updated” date above. Your continued use of the App after an update takes effect indicates your acknowledgement of the revised Policy.

18. Grievance Officer / Data Protection Officer and Contact

If you have any questions, requests or complaints about this Privacy Policy or how we handle personal data — or if you wish to exercise your rights — please contact:

Data Protection Officer / Grievance Officer The Art of Living, India (Vyakti Vikas Kendra India) Intuition Process Program (PYSE Department) Shanmuka Hall, The Art of Living International Centre, 21st KM, Kanakapura Road, Udayapura, Bangalore – 560082, Karnataka, India Email: techops@in.artofliving.org

We will respond to your request within the timelines required under applicable law.

19. Governing Law

This Privacy Policy is governed by and construed in accordance with the laws of India, and any matters relating to it are subject to the jurisdiction of the courts and the Data Protection Board of India, as applicable.

20. Language

This Privacy Policy was prepared in English. Any translation provided is for convenience only; in case of any conflict, the English version prevails.