Last updated:01/11/2025
- Introduction
Positive Circles (“Positive Circles”, “we”, “us”, “our”) respects your privacy and is committed to protecting your personal information.
This Privacy Policy explains how we collect, use, disclose, and protect personal information when you visit our website, interact with us on social media, or use our coaching, courses, programs, and related services in India (“Services”).
By using our website or Services, you agree to the terms of this Privacy Policy and our Terms and Conditions.
- Who We Are and Contact Details
Positive Circles is a coaching and personal development business operating in India.
If you have any questions about this Privacy Policy or how we handle your data, you can contact us at:
Positive Circles
[Insert registered business name if different]
Address: [Insert full postal address in India]
Email: [Insert official contact email]
Website: [Insert website URL]
- Scope and Applicable Law
This Privacy Policy applies to personal information we collect from individuals located in India in connection with our website and Services.
We aim to align our practices with applicable Indian data protection laws, including the Digital Personal Data Protection Act, 2023, as and when it comes into force, and other relevant rules and guidelines.
- Information We Collect
We may collect the following categories of personal information:
Identity details: Name, gender (if provided), age or date of birth (if provided), professional background.
Contact details: Email address, phone number, postal address, social media handles (if shared).
Booking and service information: Session dates and times, programs and courses you sign up for, preferences you share for coaching or learning.
Payment and billing information: Limited payment details such as transaction ID, payment method, billing address; card details are handled by our payment processors, not stored by us directly.
Usage data: Information about how you use our website and Services, such as pages visited, time spent, clicks, IP address, browser type, device information, and approximate location.
Communication data: Emails, messages, and other communications you send to us (including contact forms and feedback).
Program/coaching information: Notes you voluntarily share in forms, exercises, pre-work, or during coaching and group programs (to the extent recorded in our systems).
We generally do not intend to collect highly sensitive personal data (such as financial account passwords, health records, or government IDs) via the website. If such data is shared in coaching, we treat it with high confidentiality and only as necessary for our Services.
- How We Collect Information
We collect personal information in the following ways:
Directly from you: When you fill out forms on our website, book a session, subscribe to our email list, download a resource, join a program, submit feedback, or communicate with us via email or social media.
Automatically: When you visit our website, certain information is collected automatically through cookies, pixels, and similar technologies (see the Cookies section below).
From third parties: From payment processors, scheduling tools, webinar platforms, analytics providers, or social media platforms, in accordance with their own privacy policies and your settings with them.
- How We Use Your Information
We use your personal information for the following purposes:
To provide, manage, and improve our coaching, courses, and related Services.
To process bookings, payments, and invoices.
To create and manage your account, if applicable.
To communicate with you about sessions, programs, updates, and administrative matters.
To send you newsletters, resources, and marketing communications about our offerings, where permitted by law and your preferences.
To respond to your inquiries, feedback, or support requests.
To personalise your experience and improve our content and Services.
To analyse website usage and effectiveness of our marketing using analytics tools.
To comply with legal obligations, resolve disputes, and enforce our agreements.
We will only process your personal information where we have a lawful basis under applicable law, such as your consent, performance of a contract, compliance with a legal obligation, or our legitimate business interests balanced with your rights.
- Cookies and Similar Technologies
We may use cookies, pixels, and similar technologies on our website to:
Remember your preferences and improve user experience.
Understand how visitors use our website (pages visited, time on page, etc.).
Measure and improve our marketing and campaigns.
You can usually control cookies through your browser settings by blocking or deleting them. If you disable cookies, some features of the website may not function properly.
If we use tools such as Google Analytics, Meta/Facebook Pixel, or similar, your data may be processed by those providers in accordance with their privacy policies.
- Sharing and Disclosure of Information
We do not sell your personal information.
We may share your information with:
Service providers and vendors: Third parties that help us operate our business and Services, such as payment gateways, email service providers, scheduling tools, webinar platforms, analytics services, and IT support.
Professional advisors: Lawyers, accountants, or consultants, when reasonably necessary.
Legal and regulatory authorities: If required to comply with law, regulation, legal process, or government request, or to protect our rights, property, or safety and that of others.
Business transfers: In connection with any merger, sale of assets, restructuring, or similar event, your data may be transferred as part of that transaction.
When we share personal information with third-party processors, we aim to ensure they use it only for the purposes we specify and protect it appropriately.
- International Transfers
Our website tools or service providers may be based outside India, which means personal information could be transferred, stored, or processed in other countries with different data protection laws.
Where we transfer data internationally, we will take reasonable steps to ensure appropriate safeguards are in place, in line with applicable Indian law and any future rules under the Digital Personal Data Protection Act.
- Data Retention
We retain your personal information only for as long as necessary to fulfil the purposes for which it was collected, including:
Providing the Services you signed up for.
Complying with legal, accounting, or reporting requirements.
Resolving disputes and enforcing our agreements.
When personal information is no longer needed, we will delete, anonymise, or securely store it as required or permitted by law.
- Data Security
We take reasonable technical and organisational measures to protect your personal information from unauthorised access, loss, misuse, or alteration.
However, no method of transmission over the internet or electronic storage is completely secure, and we cannot guarantee absolute security. You are responsible for keeping your account credentials safe and notifying us promptly of any suspected unauthorised access.
- Your Rights and Choices
Depending on applicable Indian law and future rules under the Digital Personal Data Protection Act, you may have certain rights in relation to your personal information, which may include:
The right to know what personal information we hold about you.
The right to correct inaccurate or incomplete information.
The right to request deletion of your personal information, subject to legal and contractual limitations.
The right to withdraw consent where we rely on consent (for example, for marketing emails).
The right to opt out of marketing communications at any time.
To exercise these rights or update your preferences, please contact us using the details in the “Who We Are and Contact Details” section. We may need to verify your identity before processing certain requests.
You can also unsubscribe from our marketing emails by using the “unsubscribe” link included in those emails.
- Children’s Privacy
Our website and Services are intended for adults (18 years and older) and are not directed to children.
We do not knowingly collect personal information from children under 18 years of age. If you believe a child has provided us with personal information, please contact us so that we can take appropriate action, including deletion if required.
- Third-Party Websites and Social Media
Our website and communications may contain links to third-party websites, products, or services that are not controlled by Positive Circles.
We are not responsible for the privacy practices of third-party sites or services. We encourage you to review the privacy policies of any third-party sites you visit or services you use.
If you engage with our content on social media platforms (such as LinkedIn, Instagram, Facebook), your interactions are also governed by the privacy policies of those platforms.
- Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or for other reasons.
When we make material changes, we will update the “Last updated” date at the top of this page and may provide additional notice (for example, via the website or email). Your continued use of the website or Services after the updated policy is posted means you accept the changes.
- Grievance Redressal
If you have any concerns or grievances regarding how we handle your personal information, you may contact us using the details above and mark your communication as “Privacy/Grievance”.
We will endeavour to respond and resolve your concerns within a reasonable time, in accordance with applicable Indian law and any future regulatory requirements.
- Acceptance of This Policy
By using our website, booking sessions, joining our programs, or otherwise providing your personal information to Positive Circles, you acknowledge that you have read and understood this Privacy Policy and agree to its terms.