PRIVACY POLICY - FREEDOM GURU

Last updated date: 05.05.2020

1. INTRODUCTION
 

Thank you for choosing Freedom Guru!

 

This document, i.e., Privacy Policy (“Policy”) contains the manner and details in which FREEDOMGURU REFLECTIONS PRIVATE LIMITED, that owns and controls the platform known as Freedom Guru (“Freedom Guru”, “we”, “our”, “us”) collects and processes the data that you, the reader of this Policy (“User”, “you”, “your”), provide to us.

 

In order to guide you through a personalized journey towards freedom, we bring to attention the areas in your life that could be holding you back from a life of freedom and abundance. Therefore, as you may have noticed, we collect and process your data in the course of providing our Services, such as through the Freedom Guru App/Website, which among other things, allows us to offer you personalized guided reflection services.

 

We understand that the data that we may collect in the course of providing you Services, may contain information that is personal in nature. Since we value the privacy and security of your personal information as much as you do, we would like you to understand the exact nature of the personal data that we collect from you and how we go about using it, how we store it, how we use it, and whom we share it with.

 

Additionally, please also read our Terms & Conditions of Use for Freedom Guru available at https://www.freedomguru.com/terms-of-use/. Any capitalised terms not defined herein, shall be interpreted to mean as defined in the Terms & Conditions of Use.

2. WHAT IS THE AIM OF THIS POLICY?
 

Broadly, this Policy governs the manner in which Freedom Guru handles all personal data provided by you while using the Services.

 

Specifically, this Policy aims to achieve the following:

  • Help you understand the exact nature of the personal data that we collect;
  • Explain why we collect and what we do with the personal data that you share with us to help us create your personal freedom journey;
  • Explain to you, your rights in relation to what personal data we use and how we can use it.

We may change the terms of this Policy from time to time. The date at the top of the Policy shall reflect the date on which the Policy was last revised. In the event that there are material changes to the Policy, we may send you an additional notice by way of a notification or adding a statement on the Services.

 

Should you have any questions or concerns in relation to this Policy, you are always welcome to contact us by writing to us at support@freedomguru.com and we’ll endeavour to do our best to address them.

3. INFORMATION THAT WE COLLECT FROM YOU WHILE PROVIDING THE
SERVICES
Type of user data. Legal basis for collecting and processing this data. When do we collect this data?
Your name Performance of a contract in the case of name and location, email ID and password.

Legitimate interests in the case of the other information which is necessary for us to provide the service relevant to different locations. Profile pictures are optional.
We ask you for this information when you log in to the App/Website. Additionally, you may optionally choose to upload a picture at any point while using the App/Website.
Your age
Your gender
Your location
The local time
Your email ID
A unique password
A profile picture
4. INFORMATION THAT IS GENERATED BY YOU WHILE USING THE SERVICES
Type of usage data Legal basis for collecting and processing this data. When do we collect this data?
Information that you post on your Account through the various features and functionalities of the App, such as through the Freedom Journal feature. Performance of a contract in relation to information you choose to post since this is part of the contracted service. You can choose what you make public.

Legitimate interests in relation to inferences about your interests which we use in our business to tailor and improve the services. Where cookies are used for such processing (as explained below), we obtain prior consent where required under applicable laws.
When you input such information on your Account.
Inferences about your life, your interests and your motivations (Profiling). We draw these inferences based on your answers to the vector questions directed towards you in the App/Website/Services.
Inferences about how you interact with the Services including but not limited to your subscription plan, your search queries, the guided reflections you like and dislike, the duration for which you use the App, your browsing history, your favourite guided reflections tracks, the playlists you create, and the content you post on your Account in the App, such as on the Freedom Journal (Profiling). Information related to your usage of the App/Website/Services is collected automatically and in a dynamic manner as and when you use the App/Website.
5. TECHNICAL INFORMATION COLLECTED BY US THROUGH YOUR USE OF THE SERVICES
Type of data Legal basis for collecting and processing this data. When do we collect this data?
Information about the types of Devices you are using such as unique device IDs, network connection type, provider, network and Device performance, browser type; information enabling digital rights management, operating system, and the version of the App/Website. Legitimate interests in managing and improving our services and protecting our content Technical information is collected automatically and in a dynamic manner as and when you use the App/Website or any Services provided us.
6. WHY WE COLLECT AND PROCESS PERSONAL DATA
 
  • To allow us to create and administer your Account on the App/Website and provide support services.
  • To comply with legal obligations and requests by law enforcement.
  • To establish, exercise, or defend legal claims.
  • Inferences drawn from your answers allow us to understand you better, thereby allowing us to create a personalized freedom journey for you and optimise our Services.
  • Inferences drawn from how you interact with the Services allow us to constantly identify what we could do better to help our users in their journey towards freedom.
  • To help you track your progress in the App/Website/Services.
  • To conduct business planning and forecasting.
  • Financial and business interest in marketing, promotional, and advertising purposes.
  • To constantly enable us to diagnose and identify any technical advancements, troubleshoot issues.
  • Improve our Services and develop new Services from time to time.

USES MADE OF THE DATA

The different purposes for which we will use information held about you are:

  • To provide you with the Services and improve upon them.
  • To answer your questions or requests for information or handle your complaints.
  • To ensure that content provided by on the Services is presented in the most effective manner for you and for your computer or other Device.
  • To provide you with promotional communications such as email, to the extent that you have provided consent to receive such communications under applicable law.
  • To carry out our obligations arising from any agreements entered into between you and us.
  • To allow you to participate in interactive features of the App, when you choose to do so.
  • To notify you about updates or changes to Services, Website and the App features and content.
  • To understand your broad, non-specific geographic location to help us identify groups of users by general geographic market (such as zip code, state or country).
  • To serve our advertisements to you through third party platforms, such as Facebook or Google, on other sites and apps or across your Devices, to the extent that you have provided consent for such uses under applicable law.
  • For profiling purposes (as highlighted above). You have right to object to profiling, as set out at section 10.
  • We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
  • To manage your payments and orders.
  • If you are an existing customer, we will only contact you by electronic means (e-mail or in-product communication) to enhance your experience of the product.
7. TRACKING TECHNOLOGIES
 

Freedom Guru and our analytics partners use technologies such as cookies, beacons, tags, and scripts to enable a service to recognize your Device so you don’t have to provide the same data several times during one task, to recognize that you may have already given a username and password so you don’t need to do it for every web page requested, and to measure how people are using the Services.

 

We use local storage, such as HTML5, to store content data and preferences. Third parties with whom we partner to provide certain features on the Products also use HTML5 to collect and store data. Various browsers may offer their own management tools for removing HTML5.

 

We partner with third parties, such as Facebook and Google, to manage our advertising of the Services on other sites or platforms as well as across other Devices you use, based on your past visits to our Website. Our third-party partners may use technologies such as cookies to gather data about your activities within the Services to deliver such advertising to you, including retargeting ads. We are not always able to respond to ‘do-not-track signals’ and in the UK and EU we obtain prior consent to the use of any cookies or tracking technologies. Please note that this does not opt you out of being served advertisements. You may continue to receive generic ads on these third-party platforms. You may also opt out of receiving advertisements across Devices by adjusting your ad preference in your relevant Device account, Google account, Apple account.

 

We use third party trackers to let us know when users have visited the Services by “clicking-through” our sponsored advertising or content hosted on third party platforms. The Services use Google Analytics code to gather statistical data. Google Analytics sets cookies to help us accurately estimate the number of visitors to the Services and the volume of usage of the Services. This is done to ensure that the Services are available when you want them and are fast.

 

We will acquire consent from you in order to use such trackers to the extent required by applicable law.

 

MOBILE ANALYTICS

We use mobile analytics software to allow us to better understand the functionality of our mobile software on your phone. This software may record data such as how often you engage with the products, the events that occur within the Services, aggregated usage and performance data, and where the App was downloaded from. We may link the data we store within the analytics software to any personal data you submit within the App.

 

LOG FILES

As is true of most websites, we gather certain data and automatically and store it in log files. This data may include Internet Protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data.

Subject to obtaining such consent from users as is required under applicable laws, if you receive the HTML-formatted version of our email newsletter, your opening of the newsletter is notified to us and saved. Your clicks on links in the newsletter are also saved. These and the open statistics are used in aggregate form to give us an indication of the popularity of the content and to help us make decisions about future content and formatting.

 

SOCIAL MEDIA WIDGETS

Our Services include social media features, such as the Facebook Like button, and widgets, such as the “Share This” button, or interactive mini-programs. These features may collect your IP address, which page you are visiting on the Services, and may set a cookie to enable the feature to function properly. Social media features and widgets are hosted by a third party or hosted directly on our Services. Your interactions with these features are governed by the privacy statement of the company providing it.

8. COOKIE POLICY
 

INFORMATION COLLECTED USING COOKIES AND OTHER WEB TECHNOLOGIES

 

Like many website owners and operators, we, as well as third parties that provide content, advertising, or other functionality on our Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Services. We use Technologies that are essentially small data files placed in a Device that allow us to record certain pieces of information whenever you visit or interact with our Services, and to recognize you across Devices. We use automated data collection tools such as Cookies and Web Beacons to collect certain information.

 

COOKIES

A cookie is a small text file that is placed on your hard drive by a web page server. Cookies contain information that can later be read by a web server in the domain that issued the cookie to you. You can find out more about each cookie by viewing our current cookie list below. We update this list every six months, so there may be additional cookies not yet listed. Web beacons, tags, and scripts may be used on the Website or in emails to help us deliver cookies, count visits, understand usage and advertising campaign effectiveness, and determine whether an email has been opened and clicked on. We may receive reports based on the use of the Technologies by our service/analytics providers on an individual and aggregated basis.

 

PIXELS

 

“Pixels”/“Web Beacons” (also known as Web bugs, pixel tags or clear GIFs) are tiny graphics with a unique identifier that may be included on our Services for several purposes, including to deliver or communicate with Cookies, to track and measure the performance of our Services, to monitor how many visitors view our Services, and to monitor the effectiveness of our advertising. Unlike Cookies, which are stored on the User’s hard drive, Web Beacons are typically embedded invisibly on web pages (or in an email).

 

Why does Freedom Guru use cookies?

 

When you visit our Website, we may place a number of cookies in your browser. These are first-party cookies, and they allow us to hold session information as you navigate within the site. For example, we use cookies on our Website to understand visitor and User preferences, improve their experience, and track and analyse usage, navigational, and other statistical information. You can control the use of cookies at the individual browser level. If you choose not to activate cookies or to later disable them, you can still visit our Website, but your ability to use some features may be limited.

 

Cookies Freedom Guru uses

 

Many jurisdictions require or recommend that website operators disclose the types of cookies they use and occasionally get consent from Users before placing certain cookies.

 

We may use any of the following categories of cookies on our Website as detailed below. Each cookie falls within one of these four categories:

Type of Cookies Description
Essential Cookies Essential cookies (first-party cookies) are sometimes called “strictly necessary” as without them we cannot provide many services that you need on a website. For example, essential cookies help remember your preferences as you move around the Website.
Analytics Cookies These cookies track information about Website visits so we can make improvements and report our performance. For example, we analyse visitor and User behaviour to provide more relevant content or suggest certain activities. These cookies collect information about how visitors use the Website, which site the User came from, the number of each User’s visits, and how long a User stays on the Website. We might also use analytics cookies to test new ads, pages, or features to see how Users react to them.
Functionality or Preference Cookies During your visit to the Website, these cookies are used to remember information you have entered or choices you make such as your username, language, or region. They also store your preferences when personalizing the Website to optimize your use of Freedom Guru, for example, your preferred language. These preferences are remembered through the use of the persistent cookies, and the next time you visit the Website you won’t have to set them again.
Targeting or Advertising Cookies These third-party cookies are placed by third-party advertising platforms or networks in order to deliver ads and track ad performance, enabling advertising networks to deliver ads that may be relevant to you based upon your activities (this is sometimes called behavioural, tracking, or targeted advertising) on the Website. They may subsequently use information about your visit to show you ads that you may be interested in our Website and other Websites. For example, these cookies remember which browsers have visited the Website.
9. SENSITIVE DATA
 

When you make an Account with us and use the Services, you have access to features that allow you to post information on the App. Some of the information you choose to provide us may be considered “special” or “sensitive” in certain jurisdictions, for example your racial or ethnic origins, sexual orientation, health information and religious beliefs. By choosing to post this information on the App, you consent to our processing of that information.

10. YOUR RIGHTS OVER THE PERSONAL DATA THAT YOU SHARE WITH US
 

The General Data Protection Regulation and other privacy laws across the world grant individuals rights over their personal data. These rights allow you to control the personal data that we collect and the manner in which we use it.

Your rights Explanation
Right to confirmation and access The right to be informed of, and request access to your personal data that is collected and processed by us.
Right to correction, rectification, and erasure The right to request that any incomplete or inaccurate personal data provided be updated, corrected or erased.
Right to restrict The right to request that we temporarily or permanently stop processing all or some part of the personal data that you provide to us.
Right to object
  • The right, at any time, to object to us processing your personal data on grounds relating to your particular situation;
  • The right to object to your personal data being processed for direct marketing purposes.
Right to data portability The right to request a copy of your personal data in an electronic format and the right to have such personal data transferred or transmitted to a third-party service.
Right to not be subject to automated decision making The right to not be subject to a decision based on automated decision making basis the personal data that you share with us. This includes profiling, in the event that such profiling would have a legal effect on you or a similar significant effect.
11. WHO DO WE SHARE YOUR DATA WITH?
 

From time to time, we may share your personal data with third-parties such as:

I.T SERVICE PROVIDERS,
EMAIL SERVICE PROVIDERS.

FRAUD PREVENTION VENDORS
PAYMENT PROCESSORS

LAW ENFORCEMENT AUTHORITIES

OUR GROUP COMPANIES, SUBSIDIARIES AND AFFLIATES.

ADVERTISING PARTNERS

DATA ANALYTICS AGENCIES

SOCIAL MEDIA PARTNERS AND OTHER  REEDOM GURU PARTNERS

AN ENTITY SEEKING TO ACQUIRE OR INVEST IN FREEDOM GURU

12. HOW DO WE PROTECT YOUR DATA?
 

We implement appropriate technical and organisational measures to help protect the security of your personal data including pseudonymisation, encryption, access, and retention policies to guard against unauthorised access and unnecessary retention of personal data in our systems.

 

Your password protects your Account and therefore we recommend using a strong password that is unique to your Freedom Guru Account.

13. RETENTION AND DELETION OF DATA
 

Retention of data: We collect and store your data for only as long as it is necessary for you to access your Account on the Services/App. In addition to this, we may also retain your data for legitimate and essential business purposes, including but not limited to making data-driven business decisions, complying with legal obligations and resolving any disputes that may arise from time to time.

 

Deletion of data: Unless legally allowed or legally mandated to store such data, upon receiving a request, we will delete all your personal data or anonymize it so that such data is no longer identifiable to you as an individual.

14. TRANSFER OF DATA
 

While Freedom Guru is based in India, you consent to us transferring your data to third-parties that are located in countries other than India or to the country you are accessing the Services from. By giving us your consent in this regard, you acknowledge and understand that, your personal data may be subject to privacy laws that are different from your country. For example, if you are based in the United States of America, your personal data may be processed by a third-party based outside the United States of America. In such an instance, please note that Freedom Guru shall transfer your personal data in accordance with applicable privacy laws. However, please note that some of these countries may not provide equivalent levels of data protection as the country that you are accessing the App/Website/Services from.

 

Whenever we transfer your personal data out of the United Kingdom (“UK”) or European Economic Area (“EEA”), we will ensure similar protection and, where transfers are made to countries that have not been found to provide an adequate level of protection for personal data, we will use specific approved contracts with our service providers that are based in countries outside the EEA. These contracts give your personal data the same protection it has in the EEA.

15. THIRD PARTY LINKS
 

The Services may contain links to external websites owned and operated by third parties. We have no responsibility in relation to the accuracy, completeness and quality of the information contained within such third-party sites, and you access these sites at your own risk. Any and all contents on such third- party sites do not reflect the services or information provided by us. Please note that when you use third-party services, their own terms of use and privacy policies will govern your use of those services. References to any external links should not be construed as an endorsement of the links or their content by us. Please check these policies before you submit any personal data to these external websites.

16. PAYMENT INFORMATION
 

Please note that any payments by you in connection with the Services are processed by third parties and that we do not collect or retain any credit card or similar information. We take such steps as are reasonable in the circumstances to ensure that such information (and other personal or sensitive data) held by third parties is protected as required by law.

17. CALIFORNIA PRIVACY RIGHTS
 

If you are a California resident, California law also provides you with specific rights regarding your personal information, including:

 

  • The right to request to know more details about the categories and specific pieces of personal data we have collected about you; and
  • The right to request deletion of your personal data; and
  • The right to not be discriminated against for exercising these rights.

Freedom Guru does not “sell” the personal data we collect. In the event that we may sell the personal data that we collect in the future, we shall provide you notice and the opportunity to opt out.

 

California residents may make a rights request by emailing us at support@freedomguru.com. You may designate, in writing or through a power of attorney, an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require the agent to provide proof you have authorized it to act on your behalf, and we may need you to verify your identity directly with us.

 

If you are based in California, you may make a rights request by emailing us at support@freedomguru.com.

18. SPECIFIC POLICY FOR AUSTRALIAN RESIDENTS
 

This section provides additional information for consumers based in Australia.

 

If you are based in Australia, the terms “personal data” and “sensitive data” in this Policy refer respectively to “personal information” and “sensitive information” within the meaning of the Privacy Act 1988 (Cth). We will only collect sensitive data from you with your consent (which may be inferred by you choosing to post that information to the App) and will only use sensitive data consistently with your consent, as reasonably required to provide the Services or as otherwise permitted by law.

 

We will treat any complaint about a breach of privacy legislation or any relevant registered code seriously and will investigate any breach of which we become aware – including how it occurred and how best to prevent such a breach occurring again.

 

If at any time you do not wish to receive any direct marketing communications whether from us or from third parties, you may ask us not to send you any further direct marketing communications and not to disclose your personal information to third parties for that purpose by using the “unsubscribe” facility included in a prominent statement in the direct marketing communications or by contacting us via the details set out below.

19. CONTACT US
 

If you have any questions regarding this Policy, please feel free to reach out to our Grievance Officer/Data Protection Officer, by writing to Mr. Sandeep Gaykhe, through an e-mail at support@freedomguru.com or by writing to us at the following address 401-A, Neelam Centre, A-Wing, Hind Cycle Road, Worli, Mumbai, Maharashtra – 400030, India.