Blooming Guardian — Privacy Policy

• “Data Principal” means the individual to whom personal data relates to. Where the individual is a Child, Data Principal includes the Lawful Guardian.
• “Child” means an individual who has not completed Eighteen (18) Years of age.
• “Voice Input” means any audio recorded, uploaded, streamed or otherwise submitted to the Platform.
• “Voice Features” means the numerical representations We derive from a Voice Input, for example pitch contour, energy, jitter, shimmer, spectral coefficients and timing features.
• “Emotion Output” means the indicators, scores, summaries, trends or reports generated by the Emotion Analysis.
• “Processing” has the same meaning as given under Section 2(x) the DPDP Act.

• A voice recording is capable of identifying an individual. Accordingly, we treat Voice Inputs and Voice Features as among the most sensitive data and We hold, and apply the safeguards in Clause 11 to them by default.
• We do not build or store voiceprints for identification. Voice Features are used to estimate affective signals and are not used to recognise or authenticate the identity of the speaker. We do not match a Voice Feature set against any identity database.
• By default, We retain the raw audio only for as long as needed to produce the Emotion Output and to enable your review thereof in accordance with Clause 10.

• We process a Child’s personal data only after obtaining the verifiable consent of the Lawful Guardian, in the manner required by Section 9 of the DPDP Act and the rules made under it. The verification process may involve confirming the Guardian’s identity against a reliable identity token or a virtual token mapped to it, and confirming the declared relationship with the Child.
• We do not:
  • undertake tracking or behavioural monitoring of Children;
  • serve targeted advertising to Children; or
  • process a Child’s personal data in a manner likely to cause any detrimental effect on the wellbeing of the Child.
• We collect the minimum data necessary for a Child’s profile and apply shorter default retention period to Children’s Voice Inputs as compared to adult users.
• A Guardian may at any time view, correct, export or delete a Child’s data, and withdraw consent, from the Guardian dashboard.
• If We become aware that a Child’s account was created without the valid consent of a Lawful Guardian, We shall suspend all processing of the Child’s personal data with immediate effect and shall delete such data, save where retention is required by applicable law.
• Where a Child is of an age and understanding sufficient to comprehend the nature of audio recording, We encourage the Lawful Guardian to explain the recording process to the Child. In all cases, the Platform shall display a visible recording indicator whenever audio is being captured.

Our processing is based on Your consent under Section 6 of the DPDP Act, except where a “legitimate use” under Section 7 of the DPDP Act applies (for example, circumstances where You have voluntarily provided data for a specified purpose and have not indicated Your objection to its processing, or where processing is necessary for Us to comply with a legal obligation or a court order).

Purposes:

If We wish to process Your data for a new purpose that is not compatible with the above, We will give You notice and, where required, obtain fresh consent.

• In the interest of transparency: the Platform operates by extracting acoustic features from the Voice Input and applies statistical models to estimate affective indicators. Where You have enabled transcription, linguistic content may also be used for this purpose. The result represents a probability and does not constitute a fact determination.
• Emotion Outputs are not a diagnosis and are not clinical assessments. They may be inaccurate, and the accuracy varies with recording quality, language, accent, age, health, neurodivergence and cultural expression.
• We do not make automated decisions about You that produce legal or similarly significant detrimental effects. Emotion Outputs are shown to You (or the Guardian) as information, and are not used by Us to restrict access, set prices, or determine any entitlement.
• Emotion Outputs are not shared with a Provider unless You expressly choose to share them at the time of booking or during a session.

• Providers. When You book an appointment, We share with that Provider the information necessary to deliver the session for example Your name (or the Child’s first name), age band, appointment time, contact channel, and any notes or Emotion Outputs You have expressly chosen to share. Providers are independent Data Fiduciaries in respect of the clinical records they create, and their handling of that information is governed by their own obligations and privacy notices.
• Data Processors. We engage service providers who process data on Our instructions under a written contract that restricts their use of the data and imposes security obligations on them. Categories:
  • cloud hosting and storage — [PROVIDER, REGION]
  • speech processing and model inference — [PROVIDER, REGION]
  • video and voice session infrastructure — [PROVIDER]
  • payment gateway — [PROVIDER]
  • transactional email and SMS — [PROVIDER]
  • analytics and crash reporting — [PROVIDER]
  • customer support tooling — [PROVIDER]
• Legal and regulatory. We may disclose data where required under law, by a court, or by a government agency lawfully authorised to make the request. Where We are required to do so, We will notify You of such disclosure.
• Corporate transactions. In a merger, acquisition, restructuring or sale of assets, data may be transferred to the successor entity, subject to this policy and notice to You.
• What We never do. We do not sell personal data. We do not share Voice Inputs, Voice Features or Emotion Outputs with advertisers, data brokers, insurers, employers, or schools.

• We prefer to store and process personal data on infrastructure located in India. Where a processor operates outside India, We transfer data only to countries not restricted by the Central Government under Section 16 of the DPDP Act, and only under contractual safeguards.
• Current processing locations: India. We will update this policy if there is a change in location of processing.

• When You withdraw consent or delete Your account, We will erase the associated personal data, and cause Our processors to do so, unless retention is necessary to comply with a law in force. Backups are purged on their normal cycle, within Thirty-Five (35) Days.
• If applicable fees remain unpaid for One (1) Month after the date on which they become due despite Our reminders, We may deactivate Your account in accordance with this Policy.

• Encryption of data in transit using TLS 1.2 or higher and at rest using AES-256 encryption.
• Voice Inputs are stored in a segregated bucket with restricted and logged access.
• Role-based access control and the principle of least privilege; staff access to Voice Inputs is limited to named personnel and audited.
• Multi-factor authentication for administrative access.
• Pseudonymisation of identifiers in analytics environments.
• Periodic vulnerability assessment and penetration testing; secure development practices.
• Contractual security obligations on all processors.
• An incident response plan which is tested [FREQUENCY].
• We follow reasonable security practices consistent with the SPDI Rules. Our information security programme is aligned to [ISO/IEC 27001 / IS/ISO/IEC 27001 — state actual status: certified / aligned].
• Breach notification. In the event of a personal data breach, We will notify the Data Protection Board of India and each affected Data Principal in the form and within the timelines prescribed under the DPDP Act and the rules made under it.
• No system can be guaranteed to be entirely secure. You are responsible for maintaining the confidentiality of Your login credentials and for ensuring the security of the device used to access the Platform.

As a Data Principal (or as the Lawful Guardian of one), You have the right to:

• Access - obtain a summary of the personal data We process about You, the processing activities undertaken, and the identities of other Data Fiduciaries and processors with whom it has been shared.
• Correction and completion - have inaccurate or misleading data corrected, incomplete data completed, and data updated.
• Erasure - request deletion of Your personal data, unless retention is required by law.
• Withdraw consent - withdraw consent at any time, as easily as it was given. Withdrawal does not affect the lawfulness of prior processing, and We will cease further processing within a reasonable time.
• Grievance redressal - a readily available means of registering a grievance with Us as per Clause 17.
• Data portability - export Your Emotion Outputs and journal entries in a machine-readable format.

• How to exercise. Use the in-app privacy controls, or write to info@bloominguardian.com from Your registered email address. We will respond within Fifteen (15) Days and in any event within the period prescribed by law. We may ask You to verify Your identity before acting.
• Duties of Data Principals. Under Section 15 of the DPDP Act, You must not impersonate another person, must not suppress material information when providing personal data, must not register a false or frivolous grievance, and must furnish only authentic information when seeking correction or erasure.

• On the website We use strictly necessary cookies (session, security, load balancing) and, with Your consent, analytics cookies. We do not use advertising or cross-site tracking cookies.
• You can manage preferences through the cookie banner or Your browser settings. Disabling necessary cookies may break parts of the site.
• The mobile application uses device identifiers solely for the purposes of crash reporting and session continuity, and does not use such identifiers for advertising purposes.

• We will use Your Voice Inputs or Voice Features to train, fine-tune or evaluate Our models only if You give separate, specific, opt-in consent. This is off by default, and is never offered in respect of a Child’s Voice Input without the Lawful Guardian’s explicit consent.
• If You opt in, the data is pseudonymised before it enters a training set, direct identifiers are stripped, and access is restricted to the model team.
• You may withdraw this consent at any time. Withdrawal stops future use; data already incorporated into a trained model cannot always be extracted, and We will explain the position honestly if You ask.
• We may always use fully aggregated, de-identified statistics that cannot reasonably be re-identified.

We may update this policy. The “Last updated” date will change, and where the change is material We will notify You by email or in-app at least Seven (7) Days before it takes effect. Where a change requires fresh consent, We will ask for such consent.

• If Your grievance is not resolved to Your satisfaction, You may complain to the Data Protection Board of India in the manner prescribed under the DPDP Act.
• General privacy queries: info@bloominguardian.com.