1. Introduction

Panhacare Emotional Private Limited ("Panha", "Company", "we", "us", or "our") owns and operates the Panha digital platform available at www.panhacare.com and via our mobile application (collectively, the "Platform"). We are dedicated to providing a safe, confidential, and empathetic environment for emotional well-being through accessible peer support and meaningful human connection.

This Privacy Policy ("Policy") explains in clear terms: what personal data we collect from you, why we collect it, how we use and protect it, with whom we may share it, your rights over your data, and how to contact us with any concerns.

By accessing the Platform, registering an account, booking a session, or clicking "I Accept", you confirm that you have read, understood, and agreed to this Privacy Policy. This Policy is to be read together with our Terms and Conditions, which are incorporated herein by reference.

We may update this Policy from time to time. We will notify you of material changes via email or an in-app notification. Continued use of the Platform after such updates constitutes your acceptance of the revised Policy.

2. Who This Policy Applies To

This Privacy Policy applies to all individuals who access or use the Panha Platform, including registered users who have created an account and use the Platform's services, visitors who browse the Platform without registering, and individuals who contact us for support, feedback, or information.

The terms "you" and "your" refer to any person accessing the Platform. "Buddy" refers to trained individuals engaged by Panha to provide one-to-one peer emotional support sessions as empathetic listeners. "Therapist" refers to qualified mental health professionals engaged by Panha to provide one-to-one professional therapy sessions. Buddys and Therapists each have separate registration processes and are bound by their own confidentiality and conduct agreements with Panha.

3. Information We Collect

Panha collects the minimum information necessary to deliver its services safely and effectively. We collect information in two ways: directly from you, and automatically through your use of the Platform.

3.1 Information You Provide Directly (by User Type)

Registration Data: Panha operates separate registration processes for each user type. For Users: mobile number (authenticated via OTP) only. For Buddys and Therapists: full name, mobile number (authenticated via OTP) and personal details required for verification and onboarding.

Profile Information: Any additional details you choose to add to your profile.

Buddy Profile Photo: Buddys provide a profile photograph which is displayed publicly on the Platform to Users browsing available Buddys. This photograph is visible to all Platform users as part of the Buddy’s public profile. Buddys consent to this display upon onboarding.

Buddy and Therapist Personal Details: Buddys and Therapists provide their mobile number and other details required for onboarding, and professional credentialing. This information is held privately by Panha and is not shared with Users.

Session Content: Text chat messages exchanged during one-to-one sessions with Buddys or Therapists on the Platform. Panha does not currently record audio or video during sessions. Chat records are retained for safety, quality, and dispute resolution purposes.

Payment Information: Transaction details, payment method, and amount when you purchase session credits or membership packages. We do not store sensitive payment credentials such as card numbers, PINs, OTPs, or UPI PINs — these are handled exclusively by our certified payment gateway partners.

Communications: Any messages, feedback, complaints, or support queries you send to us via email or in-app channels.

Survey Responses: Responses to optional surveys or feedback forms, conducted with prior notice.

3.2 Information Collected Automatically

Technical & Device Data: IP address, device type, operating system, browser type, device identifiers, and network information.

Usage Data: Pages visited, features used, session duration, clicks, search queries on the Platform, and interaction logs.

Cookies and Tracking Technologies: Small data files placed on your device to remember your preferences, analyse Platform performance, and enhance your experience. See Section 8 for full details.

Log Data: Server logs that record how and when you access the Platform, including timestamps and error reports.

3.3 Information We Do Not Collect

Panha does not intentionally collect or store sensitive personal information beyond what is reasonably necessary to provide our services. Specifically, Panha does not collect: date of birth, location data from Users, Buddys, or Therapists. We strongly advise Users not to share sensitive medical, psychiatric, financial, or other highly personal information during sessions. If such information is shared voluntarily, it is done at your sole discretion and risk.

4. How We Use Your Information

We use the information we collect for the following purposes:

4.1 Service Delivery

We process data to create, manage, and maintain your user account; facilitate booking, scheduling, and conducting peer support sessions with Buddys; authenticate your identity and secure your account via OTP verification; and process payments and manage your session credits or membership.

4.2 Platform Safety and Quality

We monitor, review, and moderate interactions on the Platform for safety and community standards compliance; investigate and resolve complaints, disputes, and reports of misconduct; detect, prevent, and respond to fraud, abuse, and unauthorised access; and enforce our Terms and Conditions and other applicable policies.

4.3 Technology Improvement and Data Usage

Panha does not currently use your data for AI model training. No AI models are being trained, fine-tuned, or developed using any user data, session content, or platform interactions at this time. Should this change in the future, we will update this Policy and notify you in advance of any such use.

Anonymised or aggregated data may be used for internal analytics and research to improve Platform quality and safety. Panha does not sell any user data to third parties.

4.4 Communications

We use information to send you service-related notifications, booking confirmations, and account updates; send promotional communications such as newsletters, offers, and platform announcements (with an option to opt out at any time); and respond to your queries, support requests, and feedback.

4.5 Research and Analytics

We conduct anonymised research and data analysis to improve service quality, understand how Users interact with the Platform and identify areas for improvement, and generate aggregated, non-identifiable statistical reports.

4.6 Legal and Regulatory Compliance

We process information to comply with applicable Indian laws and regulations, including the Digital Personal Data Protection Act, 2023 (DPDP Act); respond to lawful requests from courts, regulators, or government authorities; and protect the rights, safety, and property of Panha, its Users, and third parties.

5. Recording of Sessions

PANHA DOES NOT CURRENTLY RECORD AUDIO OR VIDEO DURING SESSIONS. TEXT CHAT LOGS FROM YOUR ONE-TO-ONE SESSIONS WITH BUDDYS OR THERAPISTS ARE RETAINED FOR SAFETY, QUALITY ASSURANCE, AND DISPUTE RESOLUTION PURPOSES.

Text chat records from sessions on the Panha Platform are retained for safety and community standards enforcement, quality assurance and Buddy performance evaluation, dispute resolution and complaint handling, fraud detection and prevention, internal quality improvement and anonymised research (no AI model training), and legal and regulatory compliance.

Chat records are stored securely for a period determined by Panha's data retention policy and are not made publicly accessible. Panha does not use session data for AI model training or development.

You must not record any session, conversation, or interaction through any means external to the Platform, including screen recording, screen capture, or third-party recording software. Unauthorised recording constitutes a violation of these Terms and applicable law. Audio and video calls are not recorded by Panha at this time.

6. Legal Basis for Processing Your Data

Panha processes your personal data in accordance with the Digital Personal Data Protection Act, 2023 (DPDP Act) and other applicable Indian laws. Our legal bases for processing include:

Consent: Where you have given your explicit consent to specific processing activities, such as retention of chat records or receipt of marketing communications. You may withdraw consent at any time (see Section 10).

Contractual Necessity: Where processing is necessary to provide the services you have requested, including account management, session facilitation, and payment processing.

Legitimate Interests: Where we have a legitimate interest in processing your data, such as improving the Platform, preventing fraud, ensuring platform safety, and conducting internal analytics — provided such interests are not overridden by your rights.

Legal Obligation: Where processing is required to comply with applicable laws, court orders, or regulatory requirements.

7. How We Share Your Information

Panha does not sell, rent, or trade your personal data to any third party for their marketing purposes. We may share your information only in the following limited circumstances:

7.1 With Buddys

Panha is designed to protect your anonymity. Your identity and personal identifiers are not disclosed to Buddys or Therapists as part of the standard functioning of the Platform. Only the minimum information necessary for a session — such as your in-app display name and session context — is made available. All Buddys and Therapists are contractually bound by strict confidentiality and non-disclosure obligations.

7.2 With Trusted Service Providers

We may share information with trusted third-party vendors and service providers who assist us in operating the Platform, including cloud hosting and infrastructure providers, payment gateway processors (who handle payment data under their own PCI-DSS compliant security standards), analytics and platform performance tools, and customer support tools. All such providers are contractually required to process your data only as instructed by Panha, maintain confidentiality, and implement appropriate security measures.

7.3 For Legal and Safety Reasons

Panha may disclose your information where required or permitted by law, including in response to a court order, subpoena, or lawful request from a government authority or regulator; to investigate, prevent, or take action against suspected illegal activity, fraud, or violations of our Terms; and to protect the rights, property, or safety of Panha, its Users, Buddys, or the public.

7.4 Safety Disclosures

Notwithstanding any other provision, if Panha, in its reasonable judgement, believes that a User may pose an imminent risk of harm to themselves or others, Panha reserves the right to use all information available to it to take any action it deems appropriate, including disclosing information to law enforcement, emergency services, or other relevant parties.

7.5 Business Transfers

In the event of a merger, acquisition, reorganisation, or sale of all or substantially all of Panha's assets, your information may be transferred to the successor entity, subject to equivalent privacy protections.

8. Cookies and Tracking Technologies

8.1 What We Use

Panha uses cookies, pixels, local storage, and similar tracking technologies to enhance your experience on the Platform. These technologies help us remember your preferences and settings, analyse Platform traffic and usage patterns, improve security and detect fraudulent activity, and deliver relevant content and (where applicable) personalised communications.

8.2 Types of Cookies

Necessary Cookies: Essential for the Platform to function correctly (e.g., keeping you logged in). Cannot be disabled without affecting core Platform functionality.

Performance Cookies: Collect anonymous, aggregated data about how the Platform is used to improve its performance.

Functionality Cookies: Remember your preferences (e.g., language settings) to personalise your experience.

Analytics Cookies: Help us understand user behaviour and engagement patterns across the Platform.

8.3 Managing Cookies

You can manage or disable cookies through your browser settings at any time. Please note that disabling certain cookies may impact the functionality and user experience of the Platform. For detailed guidance, refer to your browser's help documentation.

9. Data Storage, Security, and Retention

9.1 Storage

Your personal data is stored on secure servers. Data may be stored on servers located within or outside India, subject to applicable data protection laws. Where data is transferred outside India, Panha ensures that appropriate safeguards are in place to protect your information.

9.2 Security Measures

Panha employs industry-standard security measures to protect your data from unauthorised access, alteration, disclosure, or destruction. This includes encryption of data in transit using SSL/TLS protocols, encryption of sensitive data at rest, access controls restricting data access to authorised personnel only, regular security assessments and vulnerability testing, and strict contractual confidentiality obligations on all personnel and third-party providers.

While we implement robust security practices, no method of electronic storage or transmission is entirely secure. By using the Platform, you acknowledge and accept the inherent risks of data transmission over the internet. Panha shall not be liable for data breaches or unauthorised access beyond its reasonable control.

9.3 Data Retention

We retain your personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law. Specifically:

Account Data: Retained for the duration of your account and for a reasonable period thereafter to address any outstanding matters.

Chat Records: Chat records and session transcripts are retained for a period determined by Panha’s operational and legal requirements. Audio and video are not recorded.

Payment Records: Retained as required by Indian financial and tax regulations.

De-identified Data: De-identified or anonymised data may be retained for internal research and quality improvement purposes only, and is not used for AI model training.

Upon expiry of the applicable retention period, your data will be securely deleted or anonymised. You may request deletion of your account and associated data at any time (see Section 10).

10. Your Data Rights

Subject to applicable law, including the Digital Personal Data Protection Act, 2023, you have the following rights in relation to your personal data:

Right of Access: You may request a copy of the personal data Panha holds about you.

Right to Correction: You may request correction of any inaccurate or incomplete personal data.

Right to Deletion (Erasure): You may request deletion of your personal data. To delete your account — whether you are a User, Buddy, or Therapist — please send an email to [email protected] with the subject line "Account Deletion Request" from your registered email or mobile number. We will process your request within thirty (30) days. Note that certain data may be retained where required by law or for legitimate business purposes.

Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing prior to withdrawal, but may limit your access to certain features.

Right to Opt Out of Marketing: You may opt out of receiving marketing communications at any time by following the unsubscribe link in our emails or contacting us at [email protected].

Right to Lodge a Complaint: If you believe your data rights have been violated, you may file a complaint with the relevant data protection authority under the DPDP Act.

To exercise any of the above rights, please contact us at [email protected]. We will respond to your request within thirty (30) days, as required by applicable law. We may request verification of your identity before processing your request.

11. Confidentiality and User Anonymity

Panha is designed as a safe, confidential, and private space for emotional support. Your identity and personal identifiers are not disclosed to Buddys or Therapists as part of the Platform’s standard functioning. You remain anonymous to your Buddy or Therapist unless you choose to share identifying information voluntarily.

Any such voluntary disclosure is made entirely at your own discretion and risk. Panha expressly disclaims all liability for consequences arising from your choice to share personal information with a Buddy or other User.

Buddys and Therapists are contractually obligated to adhere to strict ethical, empathy-based, and confidentiality standards. Panha takes all reasonable steps to enforce these obligations and to investigate any reported breaches.

12. Nature of Buddy and Therapist Services

Panha offers two distinct types of one-to-one support sessions, each with a separate registration, onboarding, and engagement process:

Buddy Sessions: Buddys are empathetic, trained individuals who serve as good listeners and supportive companions for emotional well-being. A Buddy is not a therapist, counsellor, psychiatrist, or medical professional. Buddy sessions are peer support conversations, not clinical consultations. Panha is not a dating, social, or matchmaking service; all interactions between Users and Buddys are strictly limited to emotional support and well-being.

Therapist Sessions: Therapists on the Panha Platform are qualified, licensed, and experienced mental health professionals. Therapist sessions are professional, structured one-to-one consultations conducted within the bounds of the Therapist’s professional qualifications and applicable ethical standards. Therapists register separately from Buddys and are subject to professional credentialing and verification by Panha.

All sessions — whether with a Buddy or a Therapist — are conducted on a strictly one-to-one basis and are private. Users are matched with a single Buddy or Therapist per session. Group sessions, multi-party sessions, or any form of collective interaction are not part of the current Platform offering.

13. Payment Data

When you make a purchase on the Platform, we collect transactional information including your payment method, transaction amount, and bank name for confirmation purposes. This information is necessary to process your payment and maintain financial records.

Panha does not store sensitive payment credentials including debit or credit card numbers, expiry dates, CVV/CVC codes, PINs, OTPs, or UPI PINs. All payment processing is handled by PCI-DSS compliant third-party payment gateway providers in accordance with applicable statutory guidelines.

14. Third-Party Links and Services

The Platform may contain links to third-party websites, social media platforms, or external resources provided for your convenience. Panha does not own, operate, or control these third-party sites and is not responsible for their content, privacy practices, or security measures.

Accessing third-party sites is entirely at your own discretion and risk. We strongly encourage you to review the privacy policies of any external website before sharing your personal information with them. The inclusion of any link does not constitute an endorsement, recommendation, or partnership by Panha.

15. Children's Privacy

The Panha Platform is not intended for use by individuals under the age of sixteen (16) years. We do not knowingly collect personal data from minors. Users below 16 may access publicly available informational content (such as blogs) only under active parental or guardian supervision, and are strictly prohibited from registering an account, booking sessions, or making payments.

If Panha becomes aware that personal data has been collected from a minor without verifiable parental consent, we will take immediate steps to delete such information. If you believe we may have inadvertently collected data from a minor, please contact us at [email protected].

16. Communications and Marketing

By using the Platform, you consent to receive communications from Panha through any mode, including SMS, WhatsApp, RCS messages, and email. Communications may include service notifications, booking confirmations, and account alerts; newsletters, feature updates, and platform announcements; and promotional offers, special announcements, and customer surveys.

You may opt out of non-essential marketing communications at any time by clicking the "Unsubscribe" link in any marketing email, adjusting your communication preferences in your account settings, or contacting us at [email protected]. Opting out of marketing communications will not affect service-related notifications, which are necessary for the functioning of your account.

17. Grievance Redressal

In accordance with the Information Technology Act, 2000 and the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021, Panha has designated a Grievance Officer to address any complaints or concerns relating to your data or use of the Platform.

If you have any complaint or grievance regarding the processing of your personal data, please contact the Grievance Officer at the details above. We are committed to resolving all legitimate concerns promptly and fairly.

18. Panha's Status as an Intermediary

Panha, insofar as its publishing and online involvement is concerned, operates as an intermediary as defined under the Information Technology Act, 2000 and the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021. Panha does not modify, edit, or manipulate user-generated content and is therefore protected under the applicable provisions of Indian law.

Panha is not a medical facilitator, clinical service provider, or emergency response service. The Platform is an intermediary technology platform enabling peer support interactions between consenting adults.

19. Changes to This Privacy Policy

Panha reserves the right to modify, amend, or update this Privacy Policy at any time. Changes will be posted on the Platform with an updated "Last Updated" date. Where changes are material, we will provide you with additional notice via email or an in-app notification at least fourteen (14) days before the changes take effect.

Your continued use of the Platform after the effective date of any changes constitutes your acceptance of the updated Privacy Policy. If you do not agree with any changes, you must discontinue use of the Platform and may request deletion of your account.

20. Governing Law

This Privacy Policy is governed by and construed in accordance with the laws of India, including the Digital Personal Data Protection Act, 2023, the Information Technology Act, 2000, and all rules and regulations made thereunder. Any dispute arising out of or relating to this Privacy Policy shall be subject to the dispute resolution mechanism set out in our Terms and Conditions.

21. Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data, please contact us at: