Privacy Policy

1. Who We Are

Crown Ventures is the legal entity operating the Poornam™ platform at poornam.health. Crown Ventures is registered in Faridabad, Haryana, India as an MSME with a valid GST registration. In this Privacy Policy, "Poornam," "we," "us," and "our" refer to Crown Ventures operating under the Poornam brand.

Crown Ventures is the Data Fiduciary under the Digital Personal Data Protection Act, 2023 (DPDPA), India, and is responsible for your personal data collected through the Poornam platform.

2. Scope of This Policy

This Privacy Policy applies to all personal data collected through:

• The Poornam website at poornam.health
• The Poornam mobile application (iOS and Android)
• The Poornam client portal
• Assessment and healing sessions booked through the platform
• Email, WhatsApp, or other communications with Poornam

3. What Personal Data We Collect

3.1 Information you provide directly

• Full name, email address, and phone number (for account registration and communication)
• Country, city, and timezone (for scheduling and practitioner matching)
• Health and wellbeing information shared voluntarily in assessment sessions or intake forms — including physical conditions, emotional concerns, and personal history
• Payment information (processed by our authorised payment gateway — we do not store card details)
• Correspondence sent to us via email or messaging platforms
• Where a practitioner connects their Google Calendar to the platform, we access only free/busy time intervals to prevent scheduling conflicts. We never access event titles, descriptions, attendees, or any calendar content. Free/busy information is checked at the time of scheduling and is not stored.
• A session is recorded only if you agree at booking, by ticking “Record this session” on the assessment form. The box is off unless you turn it on. If you do not agree, the session is not recorded. When you do agree: A recording lets us prepare a written summary of the session, which we review and then share with you. Over several sessions those summaries build a picture of what's shifting and what isn't — useful to you, and to Poornam's team supporting your care. Your assessor will be told the session is being recorded. The recording is made through Zoom. The audio transcript is kept in Poornam’s own storage and may be processed with an AI service (Anthropic) to draft that summary. The recording and the summary are available to Poornam’s admin team preparing your care, and to you once the summary is shared. A matched practitioner is not given the recording or the summary. No fixed period for keeping a recording is set in the product. The recording, its transcript, and the summary are kept until you ask for them to be deleted, or until your account is closed, at which point they are deleted. To ask for deletion, write to reach@poornam.health.
• Assessors may use an AI writing tool (Anthropic) to polish de-identified assessment notes; names and contact details are removed before anything is sent, and the assessor reviews every note before it is shared.

3.2 Information collected automatically

• Device type, browser, and operating system
• IP address and approximate geographic location
• Pages visited, session duration, and navigation behaviour on poornam.health
• Media content accessed and viewing duration (for subscription management)

Health information is Sensitive Personal Data under India's Digital Personal Data Protection Act, 2023. We collect health-related information only where you voluntarily provide it in the context of seeking healing services, and we treat it with the highest standards of confidentiality and security.

4. How We Use Your Personal Data

We use your personal data for the following purposes:

• To create and manage your Poornam client account
• To conduct the assessment session and facilitate practitioner matching
• To deliver your sessions and assigned practices through the client portal
• To provide access to subscribed media content
• To process payments and issue GST-compliant invoices
• To communicate with you about bookings, sessions, and your healing journey
• To improve the Poornam platform and the quality of our services
• To comply with applicable Indian laws and regulations

We do not use your personal data for unsolicited marketing without your explicit consent. We do not sell your personal data to any third party under any circumstances.

5. Sharing of Personal Data

Your personal data is shared only in the following limited circumstances:

• Matched practitioner: Relevant details from your assessment are shared with your matched Poornam practitioner so they can prepare for your sessions. Practitioners are bound by a confidentiality agreement.
• Payment processors: Payment data is shared with our authorised payment gateway (Razorpay for Indian transactions; Apple/Google for mobile in-app purchases) solely for transaction processing.
• Cloud and service providers: We use secure infrastructure and services to operate the platform: Supabase and Cloudflare (data storage and delivery), Zoom (session conferencing and recordings), Google (sign-in and calendar free/busy access), Resend (transactional email delivery), and Anthropic (AI-assisted processing of session transcripts, de-identified assessment notes, and website enquiries). These providers are bound by data processing agreements and access only the data necessary for their function.
• Legal requirements: We may disclose personal data if required to do so by Indian law, court order, or regulatory authority.

We never share your health information with insurers, employers, government bodies (except as legally required), or any marketing or advertising platform.

6. International Data Transfers

If you are accessing Poornam from outside India — for example from the UAE, Singapore, the United Kingdom, or elsewhere — your personal data may be transferred to and processed in India, where Crown Ventures is headquartered. By using the platform, you consent to this transfer.

We ensure that any international transfers of personal data are conducted in compliance with applicable data protection laws and with appropriate safeguards in place.

7. Data Retention

We retain your personal data for as long as your Poornam account is active and for a period of five years thereafter, or as required by applicable Indian law (including for GST and accounting purposes). Health information you share in sessions, other than a recording, is retained for the duration of your engagement with Poornam and for three years thereafter. A session recording is not covered by that three-year period: see section 3.1. No separate retention period for recordings is defined in the product.

You may request deletion of your account and personal data, including any recording, at any time by contacting reach@poornam.health. Certain data may be retained beyond deletion requests where required by law.

8. Cookies

The Poornam website uses essential cookies required for the platform to function (such as session management and authentication). We do not use advertising or tracking cookies. Analytics data, where collected, is aggregated and anonymised.

You may configure your browser to refuse cookies, though this may affect the functionality of certain features of the platform.

9. Your Rights Under the DPDPA 2023

Under India's Digital Personal Data Protection Act, 2023, you have the following rights in relation to your personal data:

• Right to access: You may request a summary of the personal data we hold about you
• Right to correction: You may request correction of inaccurate or incomplete personal data
• Right to erasure: You may request deletion of your personal data, subject to legal retention obligations
• Right to grievance redressal: You may raise a grievance with us and receive a response within a reasonable time
• Right to nominate: You may nominate another individual to exercise your rights in the event of your incapacity or death

To exercise any of these rights, please contact us at reach@poornam.health. We will respond within 30 days of receiving your request.

10. Data Security

Crown Ventures implements appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, destruction, or alteration. These measures include encrypted data storage, access controls, and secure data transmission via HTTPS.

No method of electronic storage or transmission is completely secure. Whilst we take every reasonable precaution, we cannot guarantee absolute security. In the event of a data breach that poses a risk to your rights, we will notify you and the appropriate authorities as required by the DPDPA 2023.

11. Age

Poornam is for adults aged 18 and over. We do not offer sessions to anyone under 18, and we do not knowingly collect personal data from anyone under 18. If you believe someone under 18 has submitted personal data, write to reach@poornam.health and we will delete it.

12. Changes to This Policy

Crown Ventures may update this Privacy Policy from time to time. Material changes will be communicated to registered users via email and by a prominent notice on the platform. The effective date at the top of this page will be updated accordingly. Continued use of the platform after notification of changes constitutes acceptance of the updated policy.

13. Grievance Officer

In accordance with the Digital Personal Data Protection Act, 2023, and the Information Technology Act, 2000, Crown Ventures has designated the following contact for data-related grievances:

Crown Ventures
Operating brand: Poornam™
4th Floor, B-942, Green Field Colony, NHPC Colony, Faridabad, Haryana 121010
India
GSTIN: 06AKNPD4227F2ZE
Grievance officer: Sauradeep Das
Grievance email: reach@poornam.health
We acknowledge complaints within 48 hours and resolve them within one month.
Email: reach@poornam.health
Website: poornam.health