Privacy Policy

Effective Date: June 1, 2026

This Privacy Policy (“Policy”) applies to the Website priyamsarma.com (“Website”) and explains how personal information is collected, used, stored, processed, retained, shared, protected, and handled in connection with the Website, Website Services, booking system, communications, payments, and related service activities.

This Policy is issued by Priyam Sarma, an individual sole proprietor and the Service Provider under the Website Terms and Conditions (“Terms”). This Policy forms an integral part of the Terms and must be read together with the Terms and the Refund and Cancellation Policy.

1. Policy Scope

1.1. This Policy applies to personal information collected, used, stored, processed, retained, shared, protected, or handled in connection with the Website, Website access, contact forms, booking forms, Website Services, payments, communications, session records, recordings, screenshots, and related service activities.

1.2. This Policy applies to Prospective Clients, Clients, parents or lawful guardians acting for minors, and any person who accesses the Website, submits information through the Website, uses the booking system, communicates with the Service Provider, completes payment, or participates in any Website Service.

1.3. This Policy applies only to personal information handled in connection with the Website and Website Services. Off-website services, products, memberships, customised offerings, private engagements, and non-website transactions may be governed by separate written terms, consent forms, invoices, confirmations, agreements, or privacy-related disclosures.

1.4. This Policy does not override the Terms or the Refund and Cancellation Policy. This Policy must be read in a manner consistent with the Terms and the Refund and Cancellation Policy.

2. Defined Terms

2.1. Capitalised terms used in this Policy shall have the meanings assigned to them in the Terms unless this Policy expressly defines them separately.

2.2. “Service Provider” means Priyam Sarma, an individual sole proprietor offering selected Services through the Website.

2.3. “Prospective Client” means a person who accesses the Website, browses Services, submits an enquiry, uses a contact form, selects a Service, enters details, or initiates a booking before successful booking/payment confirmation.

2.4. “Client” means a person who has booked, paid for, received confirmation for, or participated in a Service with the Service Provider.

2.5. “Personal Information” means information that identifies, relates to, describes, or may reasonably be associated with a Prospective Client, Client, parent, lawful guardian, minor, or other person communicating with the Service Provider.

2.6. “Service-related Information” means information submitted, shared, generated, recorded, or maintained in connection with an enquiry, booking, payment, Consultation, Coaching, session, communication, post-session support, or related Service activity.

2.7. “Third-Party Platform” means any independent third-party tool, platform, software, plugin, payment gateway, communication system, hosting service, meeting platform, booking system, or digital infrastructure used in connection with the Website or Services.

3. Policy Acceptance

3.1. The Prospective Client or Client is deemed to have accepted this Policy by accessing the Website, using the contact form, using the booking system, submitting personal details, selecting any Service, selecting any Paid Add-on, completing payment, communicating with the Service Provider, or participating in any Service.

3.2. By submitting Personal Information or Service-related Information through the Website, contact form, booking system, payment process, Communication Channel, or session-related communication, the Prospective Client or Client acknowledges that the Service Provider may collect, use, store, process, retain, and disclose such information for the specific purposes stated in this Policy, the Terms, and the Refund and Cancellation Policy.

3.3. A Prospective Client or Client who does not agree with this Policy must immediately stop using the Website and must not submit personal information, book any Service, complete payment, communicate with the Service Provider, or participate in any Service.

3.4. A parent or lawful guardian who submits information or books a Service for a minor confirms that they have authority to provide the minor’s information and consent to its use in accordance with this Policy, the Terms, and any applicable written consent submitted to the Service Provider.

4. Information Collected

4.1. The Service Provider may collect Personal Information and Service-related Information directly from the Prospective Client, Client, parent, lawful guardian, minor, Website forms, booking system, payment gateway records, Communication Channels, session interactions, and Third-Party Platforms used in connection with the Website or Services.

4.2. The information collected may include:

(a) identity information;

(b) contact information;

(d) booking information;

(e) appointment information;

(f) payment-related information;

(g) Service-related information;

(h) communication records;

(i) session records;

(j) consent records;

(k) technical and platform-related information;

(l) any other information voluntarily submitted, shared, generated, or made available in connection with the Website or Services.

4.3. The Service Provider may collect information only where relevant to Website operation, enquiry handling, booking management, payment coordination, Service delivery, communication, legal compliance, record-keeping, dispute handling, safety, security, or business administration.

5. Contact Form Data

5.1. Where a Prospective Client or Client submits information through a Website contact form, the Service Provider may collect:

(a) name;

(b) email address;

(d) occupation;

(e) gender;

(f) address;

(g) date of birth;

(h) message or query;

(i) service interest.

5.2. Contact form information may be used for responding to enquiries, service clarification, appointment coordination, administrative communication, legal and record-keeping purposes, dispute handling, compliance, and business administration.

5.3. The Prospective Client or Client must provide accurate, lawful, complete, current, and authorised information while using any Website contact form.

5.4. The Prospective Client or Client shall not submit false, misleading, incomplete, unauthorised, third-party, unlawfully obtained, or fraudulently used information through any Website contact form.

6. Booking Form Data

6.1. Where a Prospective Client or Client uses the Amelia booking form, booking panel, or any similar booking system adopted by the Service Provider, the Service Provider may collect booking-related information, including:

(a) name;

(b) email address;

(d) gender;

(e) address;

(f) occupation;

(g) selected Service;

(h) selected date;

(i) selected time;

(j) selected Paid Add-ons;

(k) notes;

(l) messages;

(m) topic or subject of discussion, specifically for Coaching.

6.2. Booking form information may be used for appointment scheduling, booking management, booking confirmation, payment coordination, Service preparation, Service delivery, post-booking communication, rescheduling, record-keeping, dispute handling, compliance, and business administration.

6.3. Coaching-related topic or subject information may be used to understand the general context of the Client’s intended discussion and to prepare for the relevant Coaching session.

6.4. The Client must ensure that all booking form information remains accurate, complete, current, lawful, and authorised at the time of submission and until completion of the relevant Service.

7. Payment Data

7.1. Website payments may be processed through Razorpay or any other payment gateway approved by the Service Provider from time to time.

7.2. The Service Provider may receive or access limited payment-related information necessary for booking confirmation, transaction verification, payment reconciliation, refund assessment, chargeback handling, dispute handling, record-keeping, and compliance.

7.3. Payment-related information may include transaction status, transaction reference, payment amount, payment date and time, payment method category, booking reference, refund status, payment confirmation, failed payment information, settlement information, and payment gateway records made available to the Service Provider.

7.4. The Service Provider does not directly collect or store full card details, UPI PIN, CVV, banking passwords, OTPs, or sensitive payment authentication details.

7.5. Razorpay or the applicable payment gateway processes payment authentication information through its own independent payment infrastructure, systems, security practices, and policies.

7.6. The Client must review the applicable terms and privacy practices of Razorpay, the relevant bank, UPI provider, card network, payment method provider, or other payment-related Third-Party Platform used during payment.

8. Communication Data

8.1. The Service Provider may collect, store, use, review, process, and retain communications exchanged with a Prospective Client or Client through WhatsApp, SMS, email, telephone call, regular phone call, WhatsApp audio call, WhatsApp video call, Google Meet, Zoom, or any other Communication Channel used in connection with the Website or Services.

8.2. Communication data may include messages, call details, contact details, appointment coordination messages, booking confirmations, payment confirmations, rescheduling requests, refund requests, consent statements, support messages, post-session communications, chat-support communications, and Service-related instructions.

8.3. Communication data may be used for enquiry handling, booking coordination, Service delivery, session preparation, post-session support, record-keeping, dispute handling, payment verification, refund assessment, legal compliance, and protection of rights.

8.4. The Client must communicate respectfully, lawfully, accurately, and in a Service-related manner when contacting the Service Provider through any Communication Channel.

9. Session Records

9.1. The Service Provider may collect, store, use, review, process, and retain session records connected with Consultation, Coaching, or related Service communications.

9.2. Session records may include session notes, discussion points, Client-provided information, Service-related observations, audio recordings, video recordings, screenshots, chat messages, emails, SMS, WhatsApp messages, post-session communications, and chat-support communications.

9.3. The Service Provider may use session records for lawful internal reference, analysis, record-keeping, Service continuity, future Client support, quality review, evidence, dispute handling, legal protection, compliance, and business administration.

9.4. Recordings, screenshots, session notes, and related records shall be handled as confidential internal records, subject to this Policy, the Terms, and any disclosure required or permitted under applicable Indian law.

9.5. The Client acknowledges that session records may include personal, sensitive, private, or Service-related information voluntarily shared by the Client before, during, or after the Service.

10. Use of Information

10.1. The Service Provider may collect, use, store, review, process, and retain Personal Information and Service-related Information for lawful, operational, administrative, and Service-related purposes.

10.2. The purposes under Clause 10.1 may include:

(a) responding to enquiries;

(b) verifying identity, age, consent, and contact details;

(d) coordinating payments and confirmations;

(e) preparing for and delivering Services;

(f) communicating before, during, and after Services;

(g) providing post-session or chat-support communication where applicable;

(h) assessing cancellation, refund, rescheduling, no-show, late attendance, payment failure, and chargeback matters;

(i) maintaining records;

(j) handling disputes, complaints, legal claims, misconduct issues, and policy breaches;

(k) protecting confidentiality, privacy, intellectual property, safety, reputation, systems, and legal rights;

(l) complying with legal, tax, regulatory, accounting, and administrative requirements;

(m) improving Website operation, Service administration, security, and business processes.

10.3. The Service Provider shall not use personal information for newsletter subscription or email marketing purposes where the Prospective Client or Client has not subscribed to such communication.

10.4. The Service Provider does not currently collect newsletter subscribers or maintain an email marketing subscriber database through the Website.

11. Third-Party Platforms

11.1. The Website, booking process, payment process, communications, Service delivery, data storage, security, hosting, and related digital operations may involve Third-Party Platforms.

11.2. Third-Party Platforms may include booking systems, payment gateways, Website plugins, hosting services, email systems, SMS systems, messaging applications, meeting platforms, software tools, cloud-based systems, security tools, and similar digital infrastructure.

11.3. The Service Provider does not own, operate, or control the independent terms, privacy policies, security practices, data practices, technical performance, availability, functionality, or service standards of any Third-Party Platform.

11.4. A Prospective Client or Client must review the applicable privacy policies, terms, technical requirements, and data practices of any Third-Party Platform used in connection with the Website, booking system, payment process, communications, or Services.

11.5. The Service Provider may use Third-Party Platforms to host, process, transmit, store, secure, analyse, manage, or support Personal Information, Service-related Information, Website operations, booking management, payment processing, communication, and Service delivery.

11.6. The Service Provider shall not be responsible for any unauthorised access, disclosure, loss, leakage, corruption, delay, technical failure, cyber incident, platform error, cloud-system issue, hardware issue, software issue, internet failure, or third-party infrastructure failure caused by any Third-Party Platform where such event is outside the Service Provider’s reasonable control.

12. Information Sharing

12.1. The Service Provider may share or disclose Personal Information and Service-related Information only where reasonably necessary for lawful, operational, administrative, Service-related, legal, security, compliance, dispute-handling, or business purposes.

12.2. Information may be shared with or processed through:

(a) booking systems;

(b) payment gateways;

(d) hosting providers, Website systems, software tools, and cloud-based systems;

(e) communication platforms, email systems, SMS systems, and messaging applications;

(f) meeting platforms used for Consultation or Coaching;

(g) legal, accounting, tax, technical, or compliance support providers, where required;

(h) government authorities, courts, law enforcement agencies, regulators, or other competent authorities where required or permitted by law.

12.3. The Service Provider shall not sell Personal Information to advertisers or third-party marketing companies.

12.4. The Service Provider shall not share Personal Information for newsletter or email marketing purposes where the Prospective Client or Client has not subscribed to such communication.

13. Legal Disclosure

13.1. The Service Provider may disclose Personal Information, Service-related Information, communications, records, recordings, screenshots, session notes, payment records, booking records, or related information where required or permitted by applicable law.

13.2. Disclosure under Clause 13.1 may occur in connection with:

(a) court orders, legal notices, government directions, or regulatory requirements;

(b) law enforcement requests or public authority requests;

(d) enforcement of the Terms, Refund and Cancellation Policy, or this Policy;

(e) protection of rights, safety, reputation, privacy, confidentiality, intellectual property, or business interests;

(f) prevention, detection, or handling of fraud, misconduct, threats, harassment, unlawful conduct, chargebacks, payment disputes, or policy breaches;

(g) emergency, safety-related, or protective circumstances.

13.3. The Service Provider may preserve and rely on available records where reasonably necessary for dispute handling, legal protection, compliance, or enforcement of rights.

14. Minor Information

14.1. The Website, booking system, payment process, Services, and related communications are intended only for persons who are at least eighteen (18) years of age, except where a parent or lawful guardian books a Service for a minor in accordance with the Terms.

14.2. Where a parent or lawful guardian books Consultation or Coaching for a person below eighteen (18) years of age, the Service Provider may collect and process information relating to the parent or lawful guardian and the minor.

14.3. Minor-related information may include the minor’s name, age, Service-related information, participation details, consent statements, communication records, session records, and any information reasonably required to verify consent, booking authority, suitability, or Service participation.

14.4. The parent or lawful guardian must provide accurate, lawful, complete, current, and authorised information relating to the minor.

14.5. The Service Provider may refuse, suspend, cancel, or terminate any booking, communication, session, or Service where the Service Provider does not receive adequate parental or lawful guardian consent, cannot reasonably verify booking authority, or considers the Service unsuitable or inappropriate for the minor.

14.6. The Service Provider may retain minor-related information where reasonably necessary for Service delivery, consent verification, legal compliance, record-keeping, dispute handling, safety, protection of rights, or business administration.

15. Testimonials and Feedback

15.1. The Client may voluntarily share feedback, appreciation, review, testimonial, message, result, experience, or other positive communication regarding the Service Provider, the Website, or any Service received from the Service Provider.

15.2. The Service Provider may use anonymised testimonials, reviews, feedback, appreciation messages, screenshots, or excerpts for marketing, promotional, educational, portfolio, credibility-building, or business purposes, provided that the Client’s name, contact details, photograph, face, and other directly identifying information are hidden, removed, or anonymised.

15.3. The Service Provider must obtain the Client’s prior written permission before publicly disclosing the Client’s name, photograph, face, contact details, profile, or other directly identifying information in connection with any testimonial, review, feedback, appreciation message, screenshot, excerpt, or promotional material.

15.4. The Service Provider may edit testimonials, reviews, feedback, appreciation messages, screenshots, or excerpts only for formatting, grammar, length, privacy protection, anonymisation, or clarity, provided that the edit does not materially change the meaning of the Client’s original statement.

15.5. The Client shall not demand removal of anonymised testimonial content unless the content contains directly identifiable personal information, violates applicable law, or the Service Provider expressly agrees in writing to remove it.

16. Cookies and Tracking

16.1. The Service Provider does not currently use Google Analytics, Meta Pixel, advertising pixels, tracking tools, analytics tools, or newsletter tracking tools on the Website.

16.2. The Website does not currently collect newsletter subscribers or maintain an email marketing subscriber database through the Website.

16.3. The Service Provider does not currently use cookies for independent behavioural tracking, advertising targeting, or marketing analytics.

16.4. Third-Party Platforms connected with the Website, including hosting systems, WordPress tools, booking systems, payment gateways, security tools, embedded services, or communication tools, may use cookies, logs, device information, or similar technical data according to their own terms and privacy policies.

16.5. The Service Provider does not own, operate, or control the independent cookie practices, tracking practices, technical logs, device-data practices, or analytics practices of any Third-Party Platform.

17. Data Retention

17.1. The Service Provider may retain Personal Information and Service-related Information for as long as reasonably necessary for Service delivery, legal purposes, record-keeping, dispute handling, tax purposes, compliance, payment verification, fraud prevention, business administration, operational needs, or protection of rights.

17.2. The Service Provider does not guarantee deletion of records within a fixed period where retention is reasonably required for legal, record-keeping, dispute, tax, compliance, business, operational, or legitimate retention purposes.

17.3. Retained records may include contact form submissions, booking records, payment-related records, transaction records, consent records, communication records, session notes, recordings, screenshots, refund records, rescheduling records, attendance records, complaint records, and dispute-related records.

17.4. The Service Provider may retain anonymised, de-identified, administrative, accounting, statistical, or non-identifying records where such retention is reasonably required for lawful business purposes.

17.5. The Service Provider may delete, archive, restrict, or retain records at the Service Provider’s reasonable discretion, subject to applicable law, this Policy, the Terms, and legitimate record-keeping requirements.

18. Data Security

18.1. The Service Provider shall take reasonable steps to protect Personal Information and Service-related Information from unauthorised access, misuse, loss, disclosure, alteration, or destruction.

18.2. The Client acknowledges that no electronic communication, internet transmission, cloud storage, device storage, software system, Website system, payment system, or Third-Party Platform can be guaranteed as completely secure.

18.3. The Service Provider does not guarantee absolute security of Personal Information, Service-related Information, communications, records, files, recordings, screenshots, or materials transmitted, stored, processed, or maintained through electronic systems, cloud-based systems, Third-Party Platforms, software, hardware, internet services, or digital infrastructure.

18.4. The Client remains responsible for maintaining personal device security, email security, account security, password protection, internet security, software updates, and safe communication practices while using the Website, booking system, payment gateway, Communication Channels, or Third-Party Platforms.

18.5. The Service Provider shall not be liable for any privacy issue, data issue, unauthorised access, disclosure, loss, leakage, corruption, technical failure, cyber incident, platform error, or third-party infrastructure failure that occurs despite reasonable care by the Service Provider and is not directly caused by the Service Provider’s wilful misconduct or deliberate breach of this Policy.

19. Privacy Requests

19.1. A Prospective Client or Client may contact the Service Provider for privacy-related access, correction, deletion, withdrawal, clarification, or concern requests by email at request@priyamsarma.com

19.2. A privacy request must clearly identify the person making the request, the relevant information, the nature of the request, and any supporting details reasonably required by the Service Provider to verify and respond to the request.

19.3. The Service Provider may request reasonable verification before acting on any privacy-related request.

19.4. Privacy requests shall remain subject to legal, record-keeping, dispute, tax, compliance, business, operational, and legitimate retention requirements.

19.5. The Service Provider may refuse, limit, delay, or partially comply with any request where full compliance would conflict with applicable law, legal obligations, dispute handling, tax requirements, payment records, fraud prevention, safety concerns, protection of rights, or legitimate business and record-keeping requirements.

19.6. A withdrawal, deletion, correction, or access request shall not affect the lawfulness of any processing completed before the request was received and shall remain subject to legal, record-keeping, tax, payment, dispute, compliance, operational, and legitimate retention requirements.

20. International Access

20.1. The Website is operated from India.

20.2. Persons accessing the Website from outside India are responsible for ensuring that their access, booking, payment, communication, and participation comply with applicable local laws.

20.3. Personal Information and Service-related Information may be collected, stored, processed, retained, or accessed in India or through Third-Party Platforms that may operate infrastructure in India or other jurisdictions.

20.4. By accessing the Website, submitting information, booking any Service, completing payment, communicating with the Service Provider, or participating in any Service from outside India, the Prospective Client or Client acknowledges that their information may be handled in accordance with this Policy and Indian law.

20.5. This Policy and the Terms shall be governed by Indian law.

21. Client Information Duties

21.1. The Prospective Client or Client must provide accurate, lawful, complete, current, and authorised Personal Information and Service-related Information when using the Website, contact forms, booking system, payment process, Communication Channels, or Services.

21.2. The Prospective Client or Client shall not submit false, misleading, incomplete, inaccurate, unauthorised, third-party, unlawfully obtained, or fraudulently used information.

21.3. The Client must promptly inform the Service Provider where any submitted contact detail, booking detail, consent detail, Service-related information, or communication detail becomes incorrect, outdated, inaccessible, or unusable.

21.4. The Service Provider shall not be responsible for failed bookings, missed communications, failed confirmations, loss of session access, loss of session time, payment issues, refund issues, or Service-related issues caused by inaccurate, incomplete, outdated, inaccessible, unauthorised, or misleading information submitted by the Prospective Client or Client.

21.5. The Service Provider may refuse, suspend, cancel, restrict, or terminate any enquiry, booking, communication, or Service where the Service Provider reasonably believes that submitted information is false, misleading, unauthorised, unlawful, incomplete, inconsistent, or unsuitable for Service delivery.

22. Policy Updates

22.1. The Service Provider may update, revise, modify, replace, or amend this Policy at any time for legal, operational, technical, compliance, privacy, security, policy, business, or Service-related reasons.

22.2. Updated versions of this Policy shall become effective when published on the Website or otherwise made available through reasonable electronic means, unless a later effective date is expressly stated.

22.3. The Prospective Client or Client remains responsible for reviewing the current version of this Policy before accessing the Website, submitting personal information, using the contact form, using the booking system, booking any Service, completing payment, communicating with the Service Provider, or participating in any Service.

22.4. Continued access to the Website, submission of information, use of the booking system, communication with the Service Provider, payment for any Service, or participation in any Service after the updated Policy is published or made available shall constitute acceptance of the updated Policy.

22.5. Personal Information and Service-related Information collected before an update may continue to be handled in accordance with the updated Policy, to the extent permitted by applicable law and reasonably necessary for the purposes stated in this Policy.

23. Relationship with Terms

23.1. This Policy forms part of and must be read together with the Terms and the Refund and Cancellation Policy published on the Website.

23.2. The Terms shall continue to govern Website access, Service scope, Client conduct, recording restrictions, confidentiality, intellectual property, refunds, cancellations, rescheduling, disclaimers, limitation of liability, indemnity, force majeure, termination, dispute resolution, governing law, jurisdiction, and all matters not expressly covered by this Policy.

23.3. This Policy shall govern privacy-related matters connected with Personal Information, Service-related Information, contact forms, booking forms, payment-related information, communications, session records, recordings, screenshots, retention, disclosure, privacy requests, and data handling in connection with the Website and Website Services.

23.4. In case of any direct inconsistency between this Policy and the Terms regarding privacy or personal information handling, this Policy shall apply only to the extent of that direct inconsistency, unless the Terms, applicable law, or the Service Provider’s written confirmation provides otherwise.

23.5. No informal communication, verbal statement, courtesy message, administrative clarification, WhatsApp message, SMS, email exchange, or casual discussion shall amend, waive, override, limit, or replace this Policy unless the Service Provider expressly confirms the change in writing as a formal amendment, separate agreement, service-specific term, or binding written confirmation.

24. Contact Information

24.1. A Prospective Client or Client may contact the Service Provider for privacy-related access, correction, deletion, withdrawal, clarification, or concern requests through the following email address:

Privacy Request Email: request@priyamsarma.com

24.2. General Website, booking, payment, refund, cancellation, rescheduling, or Service-related communication should be sent through the contact details stated in the Terms or the Refund and Cancellation Policy.

24.3. A privacy request must clearly identify the person making the request, the relevant information, the nature of the request, and any supporting details reasonably required by the Service Provider to verify and respond to the request.

24.4. The Service Provider may respond to privacy-related requests through email or any other reasonable Communication Channel, depending on the nature of the request, verification requirements, urgency, availability, operational capacity, and lawful business requirements.

24.5. The Service Provider does not guarantee immediate response to every privacy-related communication and may prioritise responses based on legal requirements, urgency, service relevance, verification needs, operational capacity, and the nature of the request.