Effective Date: 4th Feb 2025
Questions, comments, concerns? Please reach out to customersupport@tranquilmind.ai
TranquilMind Privacy Policy
Your thoughts and insights are entirely yours, and we value your privacy above all else. We're dedicated to protecting your personal information and ensuring it remains confidential.
Pledge 1: Your Conversations with Mitra are Private.
We guarantee that the transcripts of your conversations with Mitra will not be shared with third parties, except when it’s necessary to deliver, enhance, or protect our Services and those who use them.
Pledge 2: Your Personal Data is Not for Sale.
We have never sold or shared your personal data with advertisers, and we never will.
Pledge 3: You Have Full Control Over Your Personal Data.
You can request access to, correction of, or deletion of your personal data whenever you choose. Share as much or as little as you feel comfortable with.
Pledge 4: We Collect Personal Data with Clear Intent.
Every piece of personal data we collect serves a specific purpose. For instance, when we ask about your symptoms, it’s to help you reflect on your progress, tailor your experience, and potentially inform your clinical care in partner programs.
Pledge 5: Transparency About Your Data.
We are fully transparent about who has access to your personal data and why. Certain technical service providers may need access to help our Services function effectively. If you engage with Mitra through a clinical partner, more personal data may need to be shared with them compared to other types of partners. Rest assured, we will always communicate clearly about who views your data and for what reasons.
INTRODUCTION
Avisk Private Limited (“TranquilMind”) are the makers of the TranquilMind Mitra app (“Mitra”) and its services. TranquilMind is a company with offices in India. The app Mitra and services are available in native English.
Avisk Private Limited d/b/a TranquilMind (“Mitra”, “us”, “we”, or “our”) is committed to protecting and respecting your privacy. This privacy policy applies to and describes how we collect, store, use, and share personal data in compliance with the Digital Personal Data Protection Act, 2023 (DPDP Act), Information Technology Act, 2000, General Data Protection Regulation (GDPR), and other applicable global data protection laws like CCPA, COPPA, etc, about you through our software, website, mobile application, augmented reality or virtual reality content and devices, engage with us on social media, or otherwise interact with us, documentation, and related services (together, the “Services”). References to “you” means the person whose personal data we collect, use, and process as a user of the Services (“Subscribers”). We will manage your personal data only as described below and consistent with applicable laws.
By using our Services, you agree to the collection, use, and disclosure of your information as described in this Privacy Policy. If you do not agree, please discontinue the use of our Services.
Where applicable, you must agree to the Terms of Service and Privacy Policies of both TranquilMind. This Privacy Policy should be read in conjunction with the Terms of Service (the "Terms of Service"), https://www.tranquilmind.ai/termsandconditions
We reserve the right to make changes to this Privacy Policy at any time. Any changes will be posted on the Website/Mobile App and your continued use of the Services will constitute your acceptance of the changes. You agree to periodically review the current version of the Privacy Policy posted by the Company.
HOW WILL YOU USE MITRA?
You may use our apps to access one or more of the following services and offerings:
Gen AI-Powered Companion (Mitra):
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We integrate Generative AI (Gen AI) with high repeatability and clinical safety into our Companion Conversation Empathic Bot—“Mitra”—to support mental well-being.
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Mitra is not a replacement for a licensed therapist but offers guided interactions similar to our regular therapist services.
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Clinical Review & Safety Measures: TranquilMind clinicians rigorously test and review Mitra's AI responses to ensure accuracy, appropriateness, and compliance with safety standards before deployment.
Digital Self-Care & Mindfulness Tools:
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Access self-care toolkits, mindfulness packs, and personalized mental wellness resources.
Empathic Therapist Support:
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Connect with qualified therapists for online or offline counselling and consultations tailored to your needs.
Immersive Digital Wellness Systems:
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Utilize guided and unguided mindfulness experiences, therapeutic support, mental health assessments, and wellness interventions through AR/VR-enabled solutions.
Subscription & On-Demand Services:
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Purchase or subscribe to specialized wellness services through our website and mobile applications.
Digital Front Door:
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A centralized digital access point that enables users to engage with TranquilMind's services, including appointment booking, AI-powered interactions, and virtual mental health support. It serves as the primary interface for accessing digital wellness solutions.
E-Triage:
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An AI-powered initial assessment system that evaluates user-reported symptoms and directs them to appropriate mental health resources, including self-help tools, therapy sessions, or emergency care, ensuring effective and timely intervention.
Research Participation & Studies:
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Participate in controlled online and real-world mental health research studies designed to advance psychological insights.
Neurosensory Emotion Detection & Progress Tracking:
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Utilise neurosensory technologies to assess emotional states and track progress using AI-based psychological metrics.
Organizational Services:
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TranquilMind may also provide these and other services on behalf of an organization, including businesses, universities, hospitals, and research institutions. These services may involve processing personal data on behalf of the institution, in accordance with applicable privacy laws and agreements.
DEFINITIONS
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AI Companion: A conversational AI-driven service utilizing text, voice, and video interactions, integrated within TranquilMind Apps for user engagement.
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Anonymization: The irreversible process of modifying personal data to remove or obscure identifiers, ensuring individuals cannot be directly or indirectly identified.
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Cookie: A small data file stored on a user’s device to enhance service functionality, improve user experience, and support analytics.
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Data Controller: A natural or legal entity that determines the purposes and means of processing personal data, as defined under applicable data protection laws.
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Affiliate: Any individual or organization associated with TranquilMind, including service providers, counsellors, or business partners.
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Application: The TranquilMind software platform accessible via web, mobile, and extended reality (XR) environments.
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Confidential Information: Proprietary or personal data that is not publicly available and must be safeguarded against unauthorized disclosure.
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Consent Form: A document requiring explicit user agreement before TranquilMind collects or processes personal data, ensuring informed consent.
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Data Subject: Any identifiable individual whose personal data is collected and processed by TranquilMind.
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Encryption: A security method that encodes data to protect it from unauthorized access, ensuring confidentiality and integrity.
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Personal Data: Any information relating to an identified or identifiable individual, processed in compliance with data protection laws.
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Processing: Any operation performed on personal data, including but not limited to collection, storage, usage, modification, disclosure, or deletion.
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Pseudonymisation: A data security technique wherein personal identifiers are replaced with pseudonyms to reduce identifiability while maintaining analytical utility.
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Non-Personal Data: Information that has been anonymized, ensuring it cannot be linked to an identifiable individual.
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Dispute: Any disagreement or legal claim arising between a user and TranquilMind regarding service use or data handling.
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Therapist: A licensed mental health professional providing counselling or consultation services through TranquilMind’s platform.
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Intellectual Property Rights (IPR): Legal protections covering copyrights, trademarks, patents, and other creative or proprietary content.
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IP Content: Any digital materials, including text, images, videos, or software, protected under intellectual property laws.
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IP License: A limited, non-transferable, revocable right granted by TranquilMind to users for accessing and using its proprietary content.
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Linked Sites: Third-party websites or platforms accessible via TranquilMind services but not controlled or owned by TranquilMind.
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Minor: An individual under the age of 18, subject to parental or guardian consent requirements for service access.
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Personal Information: Data that can be used to uniquely identify an individual, such as name, contact details, and demographic information.
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Red Flags: Indicators of potential risks to user security, mental health, or data protection that warrant further review or intervention.
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Sensitive Personal Information: Highly confidential data, including health records, financial details, biometric data, and information on racial or sexual identity.
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Terms of Service: The legally binding agreement between TranquilMind and its users, governing service usage and obligations.
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User Account: A registered account enabling access to TranquilMind services, requiring authentication credentials.
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User Credentials: A combination of username and password utilised for secure authentication and access control.
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User Data: All personal, behavioural, or session-related information collected from users during service interactions.
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Website: The TranquilMind website, which is accessible at https://TranquilMind.ai.
LEGAL BASIS FOR DATA PROCESSING
TranquilMind processes personal data strictly in accordance with applicable data protection laws and regulations, ensuring lawful, fair, and transparent processing. The legal bases for processing personal data are as follows:
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Consent: We process personal data where users have provided explicit, informed, and unambiguous consent. This applies to data collection for personalized mental health services, AI-driven interactions, and marketing communications. Users have the right to withdraw consent at any time.
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Contractual Necessity: Processing is necessary for the fulfilment of a contractual obligation, including but not limited to the provision of therapy sessions, AI-assisted mental wellness tools, and subscription-based services.
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Legal Obligation: We process personal data to comply with statutory and regulatory obligations under Indian law, such as the Digital Personal Data Protection Act, 2023 (DPDP Act) and the Information Technology Act, 2000. This includes compliance with governmental requests, legal proceedings, and fraud prevention measures.
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Legitimate Interests: Processing may occur to further TranquilMind’s legitimate business interests, including platform improvement, AI model refinement, security enhancements, and user experience optimization, provided such processing does not override the fundamental rights and freedoms of users.
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Vital Interests: In rare cases, we may process personal data to protect the life, health, or safety of individuals, particularly in emergency mental health situations.
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Public Interest: In cases where data processing is necessary for research, statistical analysis, or services contributing to public health or safety, we ensure compliance with relevant data protection safeguards.
TranquilMind adheres to the principles of data minimization, purpose limitation, and user transparency, ensuring all processing activities are legally justified and aligned with user rights under applicable data protection frameworks.
WHAT INFORMATION WE COLLECT?
In the course of providing our Services, we collect various categories of personal and non-personal data in compliance with applicable data protection laws. The types of information collected are detailed below and are gathered solely for lawful and legitimate purposes.
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Information Provided Directly by Users:
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Full name, contact details (email, phone number), date of birth, gender, and occupation.
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Payment and billing information for processing service subscriptions (handled through secure third-party payment gateways).
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Any details voluntarily shared during therapy, counselling, self-care sessions, or related interactions.
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Information Collected Automatically:
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Device Information: Hardware model, operating system version, unique device identifiers, mobile network information, and application usage metrics.
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Usage Data: Log files containing IP address, browser type, access times, page views, referring URLs, and user navigation patterns on our platforms.
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Cookies and Tracking Technologies: Data collected through cookies, pixel tags, web beacons, and other tracking technologies, as described in our Cookie Policy.
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Sensitive Personal Data:
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Information regarding physical or mental health, medical history, or conditions, collected only when necessary for therapy and support services and always with the user's explicit consent.
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Biometric or neurosensory data (where applicable), used for emotion detection and user experience enhancement, with prior consent.
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Conversation Data:
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Any content you input into our Services, including but not limited to messages, journal entries, preferences, emotions, moods, thoughts, task lists, and safety-related information.
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Responses to surveys, feedback forms, or assessments conducted by TranquilMind or an affiliated institution.
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Interactions with AI-powered assistants, including text, voice, or video conversations within the Mitra App or therapist ecosystem.
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Correspondence Data:
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Personal information shared when you contact us via email or other forms of communication, including your name, email address, residential address, the company you are affiliated with, your job title, and any content contained within your message.
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Feedback Data:
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Information voluntarily provided in response to feedback requests about our app, services, or user experience.
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Contact details and other relevant data associated with feedback submissions.
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TranquilMind ensures that all collected data is handled in accordance with legal obligations, implementing safeguards to protect user privacy and prevent unauthorized access, misuse, or disclosure. Users retain control over their data and may exercise their rights as outlined in this Privacy Policy.
WHO CAN USE OUR SERVICES?
TranquilMind’s App and service are not intended for use by children under 13 years of age. TranquilMind is not responsible for any misrepresentation of age and use. If you are between 13 and 18 years old, please read the Privacy Policy and Terms of Service with your parents or legal guardian and agree before using the service. We do not knowingly collect or solicit Personal Information from minors or knowingly allow minors to register for the Services without prior consent from their legal guardian or parent. If you are a minor, we will only allow you to register for the Services with a duly filled-in consent form signed by your legal guardian or parent ("Consent Form"). If we are informed that we have collected Personal Information from a minor without a Consent Form, we will verify such information internally and delete that information as quickly as possible. If you believe that we might have any Personal Information from or about a minor (without due consent), please contact us at customersupport@tranquilmind.ai.
HOW WE USE YOUR DATA?
TranquilMind utilizes your personal data in a lawful, fair, and transparent manner for the purposes outlined below, ensuring compliance with applicable data protection regulations.
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Enhancing User Experience and Service Personalization:
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We utilize personal data to customize your browsing experience, improve content recommendations, and optimize our platform’s functionality.
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This includes analysing user behaviour, preferences, and interactions to tailor our services to your needs.
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Marketing, Promotions, and Service Improvements:
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With your explicit consent, we may use your information for targeted marketing campaigns, promotional activities, and service advertisements.
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This may involve analysing aggregated user trends to refine our product offerings and communication strategies.
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Technical Optimization and Performance Monitoring:
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We collect and analyse device-related data, such as IP addresses and browser types, to diagnose and resolve technical issues.
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Cookies and similar tracking technologies are used to facilitate seamless navigation, enhance site security, and improve overall website performance.
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Third-Party Advertising and Analytics:
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With user consent, we may share anonymized location data with third-party advertisers to deliver relevant advertisements.
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We employ third-party analytics tools to assess traffic trends, monitor engagement patterns, and refine user experience metrics.
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Data Aggregation and Anonymization for Research & Development:
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Personal information may be anonymized and combined with data from other users to enhance service efficiency, train AI models, and contribute to broader mental health research.
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This anonymized data may be shared with research institutions or partners in compliance with privacy laws.
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Secure Communication and User Interaction:
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Information provided by users is utilized to facilitate secure communication channels between users and TranquilMind professionals.
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Chat logs and recorded interactions may be retained solely for quality assurance, training, and compliance purposes.
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Compliance with Legal and Regulatory Obligations:
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We may retain and disclose personal data when required by law, regulatory authorities, or to comply with court orders.
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Retention of personal data for a minimum of 10 years ensures compliance with legal, tax, and evidentiary requirements under applicable laws.
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Use of Generated Insights within Weekly Reports:
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Where applicable, TranquilMind provides users with personalized Weekly Reports within the app. These reports offer insights derived from user interactions, aimed at enhancing self-awareness, mental health, and overall well-being. Certain insights within the Weekly Reports are generated using Gen AI (short for 'Generated Insights'), which forms a part of the Mitra service. Additionally, some data used in the reports is sourced from neurosensory tracking and mobile health app permissions, where users have granted explicit consent.
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Data Collection and Usage for Weekly Reports:
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TranquilMind processes only derived and anonymized data when generating insights through the Gen AI service provider. The insights are drawn from user interactions and preferences within the app. The following types of data are processed each week:
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Mood Description: Derived from user conversations and periodic reminders to log mood levels using visual indicators (e.g., smiley faces). Mood classifications range from low, neutral, to high spirits, helping users track their emotional well-being over time.
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Stress Levels: TranquilMind may assess user stress levels throughout the day based on user interactions and specific stress measurement tasks suggested by Mitra. This allows for personalized intervention recommendations.
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Topics and Feelings: Keywords extracted from user interactions with Mitra, identifying emotions and discussion topics. Feelings may include sad, calm, confused, happy, numb, or confident, while topics may relate to work, education, personal growth, relationships, etc.
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Tools Utilized: A list of Mitra tools accessed by the user during their time on the app, enabling TranquilMind to improve service recommendations.
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Important Data Protection Measures:
TranquilMind does not share any personal identifiers, including device information, with third-party Gen AI service providers.
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All data utilized for Weekly Reports is anonymized and aggregated, ensuring that user privacy is maintained.
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Users retain the right to opt-out of Weekly Reports and the associated data processing by adjusting their settings within the app.
TranquilMind ensures that all data processing activities align with legal obligations and industry best practices, with stringent safeguards to protect against unauthorized access, misuse, or disclosure. Users retain the right to manage their data preferences, including opting out of targeted advertising and requesting data access or deletion as outlined in this Privacy Policy.
DATA SHARING & DISCLOSURE
TranquilMind adheres to strict data-sharing policies that align with applicable data protection laws, ensuring transparency, security, and lawful processing. Personal data collected from users shall not be sold, rented, or disclosed to unauthorized third parties. However, in specific circumstances, we may share user data as outlined below:
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Affiliates and Service Providers: We may share personal data with trusted affiliates, third-party service providers, and business partners who assist in delivering and improving our Services. These entities are bound by confidentiality agreements and may only process data per our lawful instructions.
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Regulatory and Legal Compliance: We may disclose personal data when required by law, court orders, legal processes, or government requests, ensuring compliance with the Digital Personal Data Protection Act (DPDP Act) and other applicable laws. This includes responding to legal proceedings, enforcing our Terms of Service, and protecting the rights, property, or safety of our users and the platform.
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Research and Analytics: We may anonymize and aggregate personal data for academic, research, and analytical purposes. This ensures the development of evidence-based mental health interventions while safeguarding individual privacy. Anonymized data may also be shared with research institutions or industry partners for studies aimed at enhancing mental health technologies.
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Third-Party Analytics and Advertising: We employ third-party analytics tools to assess traffic trends, monitor engagement, and improve service offerings. Where applicable, users will have the ability to manage their advertising preferences and opt out of targeted advertisements.
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Business Transfers and Mergers: In the event of a merger, acquisition, or sale of assets, user data may be transferred to the acquiring entity under conditions ensuring continued compliance with this Privacy Policy. Users will be notified of any significant changes in data handling policies.
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Emergency Situations and Vital Interests: Where necessary, we may disclose personal data to protect the vital interests of an individual, including responding to medical emergencies or imminent threats to personal safety.
TranquilMind ensures that all shared data is processed under strict legal, contractual, and technical safeguards, with user privacy as a core principle. Users retain the right to access, modify, or withdraw consent for data sharing as outlined in this Privacy Policy. We do not sell or rent personal data.
DATA SECURITY MEASURES
TranquilMind is committed to ensuring the highest level of security for all user data. We implement comprehensive organizational, technical, and administrative safeguards to protect data integrity, confidentiality, and availability. Our security framework aligns with the Digital Personal Data Protection Act, 2023 (DPDP Act), Information Technology Act, 2000, GDPR, and global cybersecurity best practices.
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Privacy by Design and Default
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We adhere to Privacy by Design and Privacy by Default principles, ensuring data protection is embedded into all service offerings.
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We minimize data collection to only what is necessary for the functionality of our services.
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We employ pseudonymization and anonymization techniques to limit the exposure of personally identifiable information.
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Our AI systems automatically redact sensitive identifiers to prevent accidental disclosure.
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Data Encryption & Secure Storage
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All personal data is encrypted in transit and at rest using industry-standard encryption algorithms.
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We apply role-based access control (RBAC) to ensure only authorized personnel can access sensitive data.
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User authentication credentials remain the sole responsibility of the user. Any unauthorized access or compromise is beyond TranquilMind’s liability.
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AI Companion & Confidentiality Measures
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Our AI-driven mental wellness support tool operates under strict confidentiality policies.
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No third parties, including TranquilMind personnel, have direct access to real-time AI interactions.
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The AI validates user input before responding, ensuring contextual accuracy and reducing risks of misinterpretation.
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User-Controlled Data Management
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Users retain full control over their data, with options to manage, review, and delete their personal data.
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The "Reset My Data" feature enables users to permanently erase stored data from our systems.
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Users can withdraw consent for data processing at any time, subject to legal and contractual obligations.
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Compliance & Security Audits
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We conduct regular security audits, penetration testing, and Data Protection Impact Assessments (DPIAs) to identify and mitigate vulnerabilities.
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TranquilMind ensures compliance with the seven key principles of GDPR, including lawfulness, fairness, transparency, purpose limitation, data minimization, accuracy, storage limitation, integrity, and accountability.
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Incident response mechanisms are in place to address security breaches, with users notified within the legally mandated time frame.
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Shared Responsibility for Security
While TranquilMind employs industry-standard security measures, users must also take proactive steps to protect their accounts, including:
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Not sharing login credentials with unverified third parties.
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Using strong passwords and enabling two-factor authentication where applicable.
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Avoiding the storage or transmission of sensitive discussions in unsecured environments.
Although no system can guarantee absolute security, TranquilMind continuously enhances its cybersecurity framework to align with evolving threats and technological advancements.
DISPUTE SETTLEMENT
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Each party shall designate an officer to meet with in order to attempt to resolve any dispute, controversy, or claim arising out of or relating to this privacy policy or any subsequent amendments to this privacy policy (each, a "Dispute"), including, without limitation, any breach of the terms hereunder, termination, validity, or invalidity thereof, or any non-contractual issues relating to this privacy policy.
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All Disputes that are not resolved in accordance with the issue resolution procedures outlined in Clause 1 above will be referred to and settled by a single arbitrator who will be mutually chosen by the parties under the terms of the Indian Arbitration and Conciliation Act, 1996, as amended, with Bengaluru serving as the arbitration's seat.
USER RIGHTS UNDER DPDP ACT & GDPR
TranquilMind is committed to upholding the rights of users as prescribed under the Digital Personal Data Protection Act, 2023 (DPDP Act) and the General Data Protection Regulation (GDPR). Users are entitled to exercise the following rights in relation to their personal data:
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Right to Access: You have the right to request and obtain a copy of the personal data that TranquilMind holds about you, along with details on how it is being processed.
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Right to Rectification: You may request the correction or update of inaccurate or incomplete personal data maintained by TranquilMind.
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Right to Withdraw Consent & Erasure (Right to be Forgotten): Subject to legal and contractual obligations, you may withdraw consent for data processing and request the permanent deletion of your personal data from TranquilMind’s systems.
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Right to Restriction of Processing: You may request that the processing of your personal data be temporarily or permanently restricted in certain circumstances, such as when disputing data accuracy.
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Right to Object: You may object to the processing of your personal data where such processing is based on legitimate interests or is being used for direct marketing purposes.
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Right to Data Portability: You may request that your personal data be provided in a structured, commonly used, and machine-readable format, or be transmitted to another data controller where feasible.
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Right to Lodge Complaints: If you believe your data protection rights have been violated, you have the right to file a complaint with the Indian Data Protection Board (once operational) or the relevant data protection authority within your jurisdiction.
To exercise these rights, or for any data protection inquiries, please contact us at customersupport@tranquilmind.ai. TranquilMind will respond to requests in accordance with applicable legal requirements, typically within 30 days from the date of request submission. In cases where an extension is required, users will be duly notified of the reason and expected timeline.
INTERNATIONAL DATA TRANSFERS
TranquilMind is committed to ensuring the protection of personal data when it is transferred across international borders. Where user data is processed outside the jurisdiction in which it was collected, we implement appropriate safeguards in compliance with applicable data protection laws, including but not limited to the General Data Protection Regulation (GDPR), Digital Personal Data Protection Act, 2023 (DPDP Act), and other relevant international regulations.
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Legal Safeguards: We rely on Standard Contractual Clauses (SCCs), adequacy decisions, and binding corporate rules (BCRs) to ensure that international transfers meet legal and regulatory standards.
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Data Localization Requirements: Where legally required, TranquilMind ensures that specific categories of personal data remain stored and processed within the jurisdiction mandated by local laws.
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Third-Party Compliance: Any third-party service provider, affiliate, or business partner receiving data outside India is required to implement industry-standard data protection mechanisms and security frameworks that align with our internal policies.
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Transparency & User Rights: Users have the right to request information about how their data is transferred and the legal mechanisms used to ensure its protection. Requests can be submitted via customersupport@tranquilmind.ai.
TranquilMind continuously evaluates changes in global data protection laws and updates its data transfer mechanisms accordingly to ensure ongoing compliance with regulatory frameworks.
COOKIES & TRACKING TECHNOLOGIES
TranquilMind utilises cookies and similar tracking technologies to enhance the user experience, analyse service performance, and ensure secure platform functionality. Cookies are small data files stored on a user’s device that facilitate site navigation, preferences retention, and content personalization.
Types of Cookies We Use:
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Essential Cookies: Necessary for the operation of our website and applications, including authentication, session management, and fraud prevention. These cannot be disabled.
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Performance & Analytics Cookies: Collect anonymized data to monitor service usage, detect technical issues, and enhance overall platform efficiency. We utilize third-party analytics tools, including Google Analytics, with stringent data privacy controls.
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Functional Cookies: Store user preferences, language settings, and other customizations to improve the usability of our services.
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Advertising & Targeting Cookies: Enable TranquilMind and our authorized partners to deliver personalized advertisements based on user interactions and interests. Users can opt out of targeted advertising through their browser settings or by contacting us.
Managing Your Cookie Preferences:
Users have the ability to control and disable non-essential cookies through browser settings or our Cookie Preference Centre, available within our application and website settings. Disabling certain cookies may impact platform functionality and user experience.
For further details on how we use cookies and similar tracking technologies, please refer to our Cookie Policy or contact us at email at: customersupport@tranquilmind.ai.
CHANGES TO OUR PRIVACY POLICY
We reserve the right to change this Privacy Policy and our Terms & Conditions at any time. You will be informed of any changes to our Privacy Policy when such changes are affected.
Last updated: This Privacy Policy was last updated on 4th Feb 2025.