Privacy Policy

Effective date: [EFFECTIVE DATE]

Draft for legal review. This is a template based on the product's actual data flows and has not been reviewed by a lawyer. It must be kept in sync with what the apps actually collect. Do not publish before counsel review and before replacing every [PLACEHOLDER].

This Privacy Policy explains how [LEGAL ENTITY NAME] ("Samskara Kula", "we", "us") collects, uses, shares, and protects personal data when you use the Samskara Kula website at [WEBSITE URL], the customer app, and the priest app (together, the "Service").

Because our users include the Hindu NRI diaspora across many countries, this policy is written to address the EU/UK GDPR, the India Digital Personal Data Protection Act, 2023 (DPDP) and applicable IT Rules, and the US CCPA/CPRA. Where these laws grant you specific rights, the relevant sections below apply to you based on your location.

We handle religious, lineage, and birth data. Some information we process (Gotra, Veda/Shakha, Kula Devata, family lineage, and birth details used for astrological calculation) can reveal religious or philosophical beliefs and is treated as sensitive/special-category personal data. We process it only to provide the Service you request, and only with the appropriate legal basis (your explicit consent and/or performance of our contract with you).

1. Who is the controller

The data controller (and, under DPDP, the Data Fiduciary) is [LEGAL ENTITY NAME], [REGISTERED ADDRESS]. Contact: [PRIVACY EMAIL]. Where required, our Data Protection Officer / EU representative is [DPO CONTACT]. Our India grievance officer is [GRIEVANCE OFFICER NAME + EMAIL].

2. What data we collect

a) Account & contact data — email address and/or phone number (used for one-time-passcode sign-in), and your display name.

b) Family member & lineage data — for each family member you add: name, birth date, birth time (optional), birth location (city / latitude / longitude), and optional Gotra, Veda/Shakha, and Kula Devata. These fields are provided by you. We never infer or default them; where you leave them blank they are recorded as "unknown".

c) Astrological / Kundali data — birth details are used to compute a Vedic birth chart (planetary positions, ascendant). You may also upload your own kundali document (PDF/image), which we store as your private reference.

d) Booking & marketplace data — ceremonies you book, mode (in-person or virtual), scheduled dates, venue or shipping address, assigned priest, ratings/ reviews you submit, and booking status history.

e) Priest data (priest app) — for priest users: profile details, tradition, languages, service regions/locations, qualifications, availability, avatar, and verification/vetting status.

f) Proof-of-Ritual & Vault media — videos captured as proof of a performed ceremony, and media stored in your Generational Vault, together with content hashes and capture metadata.

g) Payment data — payments are processed by Stripe and/or Razorpay. We receive limited transaction metadata (amount, currency, status, a token/ reference). We do not collect or store your full card number, CVV, or bank credentials — those go directly to the payment provider.

h) Device & usage data — app/device information, push-notification token, language preference, and product-analytics events (screens viewed, actions taken) used to operate and improve the Service. Analytics events are designed to avoid sensitive lineage/birth fields.

i) Location data — birth locations you enter, and (for priests, with permission) service-location data used for proximity features.

We do not knowingly collect data from anyone under 18 as an account holder. Minors may appear only as family members added by a parent/guardian responsible for that data.

3. Why we use it, and our legal basis

Under DPDP, we rely primarily on your consent and on the legitimate uses permitted by the Act. Under CCPA/CPRA, we process the categories above for the listed business purposes; we do not "sell" your personal information and do not "share" it for cross-context behavioural advertising.

4. How we share data

We share personal data only as needed to run the Service:

• Priests you book — receive the booking details necessary to perform the ceremony (e.g. the relevant family member's ceremony details, venue/address, and, for religious correctness, lineage fields you choose to provide).
• Payment processors (Stripe, Razorpay) — to take payment.
• Logistics/shipping partners (e.g. Shiprocket and its carriers) — to ship Samagri/Prasad, using the shipping address you provide.
• Infrastructure & tooling — our self-hosted Supabase backend, cloud/VPS hosting, push-notification delivery (Expo/Apple/Google), geocoding/maps, and streaming providers for virtual ceremonies.
• Legal & safety — where required by law, to enforce our Terms, or to protect rights and safety.
• Business transfers — in a merger, acquisition, or asset sale, subject to this policy.

We do not sell your personal data or use your Vault media, uploaded documents, or lineage data for advertising or model training.

5. International transfers

We operate for a global diaspora, so your data may be processed in countries other than your own (including [LIST PRIMARY HOSTING REGIONS]). Where data is transferred out of the EU/UK, we rely on appropriate safeguards such as Standard Contractual Clauses. Data-residency requirements under DPDP, where applicable, are addressed at [DATA RESIDENCY APPROACH — confirm with counsel].

6. How long we keep it

We keep personal data for as long as your account is active and as needed to provide the Service, then for the period required to meet legal, tax, accounting, dispute-resolution, and fraud-prevention obligations. Proof-of-Ritual and Vault media are retained as part of your archive until you delete them or close your account, subject to any legal hold. When no longer needed, data is deleted or anonymised.

7. How we protect it

• Cross-family isolation is enforced at the database layer (row-level security), not only in the UI — a family cannot access another family's data.
• Proof-of-Ritual and Vault media live in private storage, encrypted at rest, and are served only through time-limited signed URLs, never public links.
• We do not store raw card/bank credentials; payment data is tokenised by the provider.
• We avoid logging sensitive birth/lineage fields in plaintext.
• Priest verification status is enforced server-side on every read path.

No system is perfectly secure; we cannot guarantee absolute security, but we work to protect your data and to notify you and regulators of breaches where the law requires.

8. Your rights

Depending on where you live, you may have the right to: access your data; correct it; delete it; restrict or object to processing; withdraw consent (without affecting prior processing); data portability; and to lodge a complaint with a supervisory authority.

• EU/UK (GDPR): the rights above; complain to your local Data Protection Authority (EU) or the ICO (UK).
• India (DPDP): access, correction, erasure, grievance redressal, and the right to nominate another person to exercise your rights; contact our Grievance Officer above, and you may approach the Data Protection Board of India.
• California (CCPA/CPRA): know/access, delete, correct, and opt out of sale/ sharing (we do not sell or share for advertising); you will not be discriminated against for exercising these rights.

To exercise any right, contact [PRIVACY EMAIL]. We will verify your request and respond within the timeframe the applicable law requires. You may also edit or delete much of your data directly in the app.

9. Cookies & analytics (website)

The website uses only what is necessary to function and privacy-respecting product analytics. Where required by law, we ask for your consent before setting non- essential cookies/trackers, and default to the most privacy-preserving option. See [COOKIE POLICY / this section] for details and controls.

10. Third-party links & services

The Service links to and integrates third parties (payment, shipping, streaming, maps). Their handling of your data is governed by their own privacy policies. We encourage you to review them.

11. Changes to this policy

We may update this policy. Where changes are material, we will notify you (in-app or by email) and update the effective date. Continued use after changes take effect constitutes acceptance where permitted by law.

12. Contact

Privacy questions or requests: [PRIVACY EMAIL]. Data Protection Officer / EU representative: [DPO CONTACT]. India Grievance Officer: [GRIEVANCE OFFICER NAME + EMAIL]. Postal: [REGISTERED ADDRESS].