Privacy Policy

Soul Swara Private Limited (“Soul Swara”, “we”, “us”, “our”) is committed to protecting the personal data of every person who visits our website or enrols in our programmes. This Privacy Policy explains what personal data we collect, why we collect it, how we use and protect it, and what rights you have over it.

This policy applies to all personal data we process in connection with soulswara.com and our Online Certificate Program (OCP).

We are the Data Fiduciary as defined under the Digital Personal Data Protection Act, 2023 (DPDP Act). You are the Data Principal.

Note on DPDP Act commencement: The DPDP Act, 2023 and the Digital Personal Data Protection Rules, 2025 have a phased commencement schedule. The main operational provisions — including Data Principal rights (ss.11–14), processing and consent obligations (ss.3–17), and children’s data requirements (s.9) — are scheduled to come into force on 13 May 2027 (per G.S.R. 843(E), MeitY notification dated 13 November 2025). Soul Swara has structured its data practices in alignment with the DPDP Act and Rules framework ahead of those commencement dates and will comply with all provisions as they take effect. Where this policy refers to specific sections of the DPDP Act, those references indicate the provisions Soul Swara is aligning to; enforceability follows the official commencement schedule.

We collect the following categories of personal data:

Identity and contact data

• Full name
• Email address
• Phone number / WhatsApp number
• Country of residence

Enrolment and account data

• Course or trail enrolled in
• Payment plan selected
• Enrolment date and subscription status

Payment data

• Transaction reference numbers and payment status
• Payment method (card, bank transfer, UPI)

Note: Full card details and account numbers are processed by Razorpay directly. We do not store card numbers, CVVs, or full bank account details on our systems.

Usage and interaction data

• Attendance at live sessions (Google Meet — Tier 2 milestone sessions and Tier 3 as applicable)
• Lesson video access records
• Communications with Soul Swara staff (email, WhatsApp)

For minor students

Name and contact details of the parent or legal guardian.

Data we do NOT collect

We do not require or request any sensitive personal data including health information, biometric data, or government identification numbers unless specifically required to comply with a legal obligation.

We collect personal data:

• Directly from you when you register, enquire, or enrol;
• Through our payment gateway (Razorpay) when you make a payment;
• Through Google Workspace tools used in delivering our services (Google Meet attendance, email);
• Through our website when you fill out a contact or enrolment form.

We process your personal data on the following bases, aligned with the framework of the Digital Personal Data Protection Act, 2023. The consent and compliance-with-law provisions (ss.6–7) are scheduled to come into force from 13 May 2027; this table reflects the standards Soul Swara is building toward:

Note on marketing communications: We will send you marketing or promotional communications only where you have separately opted in to receive them. You may withdraw that opt-in at any time — see clause 9 below.

We do not use your data for automated profiling or behavioural marketing. We use PostHog for product analytics and error tracking on our website and learning platform, which may process usage data such as pages visited, errors encountered, and actions taken — see clause 5 and clause 11 below for more detail. We do not currently use any other analytics, advertising, or cross-site tracking tools.

We do not sell your personal data to anyone. We do not share your data with third parties for marketing purposes.

We share data only with the following Data Processors who act on our instructions:

Google Workspace (Google LLC)

• Used for: email communication (Gmail), live session delivery via Google Meet (Tier 2 milestone sessions; Tier 3 as applicable), file sharing (Google Drive)
• Governed by: Google Workspace Data Processing Agreement (included in Google Workspace subscription)
• Data transfers: Google may process data on servers outside India; Google’s Standard Contractual Clauses and GDPR-compliant DPA apply internationally.

Razorpay Software Private Limited

• Used for: payment processing, subscription auto-debit, refund processing
• Governed by: Razorpay’s Merchant Terms of Service and Privacy Policy
• Razorpay is a Payment Aggregator regulated by the Reserve Bank of India (RBI). Payment data is processed in accordance with PCI-DSS standards.

PostHog

• Used for: product analytics and error tracking on our website and learning platform
• Governed by: PostHog’s Data Processing Agreement and Privacy Policy
• Data transfers: processed on PostHog’s servers outside India (our account is configured to PostHog’s US region by default); PostHog’s Standard Contractual Clauses apply to such transfers.

We may also disclose data where required by law — for example, in response to a court order, tax authority request, or statutory compliance requirement.

If you are enrolling from outside India, your personal data will be transferred to and processed in India by Soul Swara Private Limited. By enrolling, you consent to this transfer. We process all data in accordance with the DPDP Act, 2023 and applicable Indian law.

Where our Data Processors (Google, Razorpay, PostHog) operate infrastructure outside India, such transfers are governed by those processors’ own cross-border transfer safeguards (Standard Contractual Clauses, adequacy frameworks, or equivalent).

Where a student is under 18 years of age, enrolment must be completed by a parent or legal guardian. We will only collect and process the minor’s data on the basis of verifiable parental consent. This practice is aligned with the children’s data obligations under section 9 of the DPDP Act, 2023, which is scheduled to come into force from 13 May 2027; Soul Swara applies this standard voluntarily from the effective date of this policy. The parent or guardian is responsible for ensuring the information they provide is accurate and for managing any data rights requests on the minor’s behalf.

We do not knowingly collect personal data from minors without verifiable parental consent.

We retain personal data for as long as your subscription is active and for a reasonable period thereafter for legitimate business and legal purposes:

After the applicable retention period, data is deleted or anonymised.

The following rights are provided for under the Digital Personal Data Protection Act, 2023 (sections 11–14). These sections are scheduled to come into force from 13 May 2027. Soul Swara commits to honouring these rights from the effective date of this policy as a matter of good practice, and will update this section as the relevant provisions commence:

Right to access (s.11): You may request a summary of the personal data we hold about you and the purposes for which it is processed.

Right to correction and erasure (s.12): You may request correction of inaccurate or incomplete data, or erasure of data we no longer have a legal basis to retain.

Right to grievance redressal (s.13): You have the right to raise a grievance with our Grievance Officer (see clause 12 below). If not resolved to your satisfaction, you may escalate to the Data Protection Board of India (constituted under the DPDP Act, 2023; its adjudicatory functions are subject to the phased commencement schedule).

Right to nominate (s.14): You may nominate another individual to exercise your data rights on your behalf in the event of your incapacity or death.

Right to withdraw consent: Where we process your personal data on the basis of your consent, you may withdraw that consent at any time by writing to us at [email protected] with the subject line “Consent Withdrawal”. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal. Please note that withdrawing consent for processing that is necessary to deliver your subscription may affect our ability to provide you with services.

Withdrawing marketing opt-in: If you have opted in to receive marketing or promotional communications from us, you may withdraw that opt-in at any time by writing to [email protected] with the subject line “Marketing Opt-Out” or by following the unsubscribe link in any marketing email we send you.

To exercise any other rights listed above, write to us at [email protected] with the subject line “Data Rights Request”. We will respond within the timelines prescribed under the DPDP Act.

We take reasonable technical and organisational measures to protect your personal data from unauthorised access, disclosure, alteration, or destruction. These include:

• Secure payment processing via Razorpay (PCI-DSS compliant)
• Google Workspace for communication and file storage (enterprise security)
• Access to student data restricted to authorised Soul Swara staff on a need-to-know basis

No method of electronic transmission or storage is 100% secure. If you believe your data has been compromised, please contact us immediately at [email protected].

Personal data breach: Soul Swara is committed to notifying affected individuals and the Data Protection Board of India in the event of a personal data breach. The formal breach-notification obligations under the DPDP Act, 2023 are scheduled to come into force from 13 May 2027. In the interim, if we become aware of a breach that may affect your personal data, we will inform you of what happened and the steps we have taken.

We use the following cookies and similar technologies on soulswara.com:

• Essential cookies: required for core site functionality, including keeping you signed in to your account.
• PostHog: our product analytics and error-tracking tool, which may set cookies or use your browser’s local storage to recognise repeat visits and understand how our website and learning platform are used.

We do not use advertising cookies or cross-site tracking. PostHog only initialises after you accept analytics cookies in the consent banner shown on your first visit — see our Cookie Policy for the full list of cookies and local storage we use, and how to change your choice at any time.

In accordance with the Consumer Protection (E-Commerce) Rules, 2020 and the Digital Personal Data Protection Act, 2023, we have appointed a Grievance Officer for all privacy and data-related concerns:

Name: Jayashree Ramamoorthy
Designation: Grievance Officer, Soul Swara Private Limited
Contact: [email protected]
Phone: +91 91505 44040
Address: Old No.12-A, New No.28, Flat-2A, Mahatma Gandhi Road, Shastri Nagar, Thiruvanmiyur, Chennai – 600041, Tamil Nadu, India

The Grievance Officer will acknowledge your complaint within 24 hours of receipt and endeavour to resolve it within one month. This applies to complaints relating to both general grievances and data protection matters.

We may update this Privacy Policy from time to time to reflect changes in law, our practices, or our services. Material changes will be communicated to enrolled students via email or WhatsApp at least 15 days before they take effect. The current version will always be available on our website.

For any questions about this Privacy Policy or how we handle your data:
Email: [email protected]
Address: Soul Swara Private Limited, Old No.12-A, New No.28, Flat-2A, Mahatma Gandhi Road, Shastri Nagar, Thiruvanmiyur, Chennai – 600041, Tamil Nadu, India