Privacy Policy

1. Introduction

Atsrc Technologies Private Limited ("we," "us," or "our"), a company registered in India, operates the KnowingLives platform. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal data when you use our website, mobile applications, and related services (the "Platform"). It applies to users in India, the United States, the European Union, the European Economic Area, the United Kingdom, and other jurisdictions where we offer the Platform.

We are committed to protecting your privacy and complying with applicable data protection laws, including the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (India), the Digital Personal Data Protection Act, 2023 (India, where applicable), the General Data Protection Regulation (EU) 2016/679 (GDPR), the UK GDPR, and the California Consumer Privacy Act (CCPA) as amended by the CPRA, where applicable.

2. Data Controller

The data controller responsible for your personal data is Atsrc Technologies Private Limited, with its registered office in India. For users in the European Economic Area or the United Kingdom, we may work with a representative or process data in accordance with cross-border transfer mechanisms as described in this policy.

3. Data We Collect

We may collect the following categories of data:

• Account and profile: Name, email address, phone number, password (hashed), profile photo, date of birth (optional), and preferences you provide when registering or updating your profile.
• Payment and transaction: Payment method details (processed by licensed payment gateways; we do not store full card numbers), KL Credits balance, transaction history, and billing-related information as needed for refunds and support.
• Usage and device: IP address, device type, operating system, browser type, app version, log data, and usage patterns (e.g., pages visited, features used, session duration). We may use cookies and similar technologies as described in our Cookie Policy.
• Communications: Content and metadata of chat and call sessions (such as timestamps, session identifiers, participants, and delivery status) as necessary for service delivery, quality, safety, fraud prevention, and dispute resolution.
• Location: Approximate location derived from IP or device settings if you grant permission, for regional customization and fraud prevention.

3A. KL Credits (Not a PPI)

KL Credits (also shown as your in-platform balance) are prepaid service credits that you purchase to pay for digital consultations on the Platform. KL Credits are not legal tender, not a bank account or e-wallet, have no cash redemption value except where required by law, and are not issued or regulated as a Prepaid Payment Instrument (PPI) under Reserve Bank of India (RBI) Master Directions on Prepaid Payment Instruments or similar prepaid-wallet rules. Payments for KL Credit top-ups are processed by licensed payment gateways; your usable balance is an internal ledger for Platform services only.

4. Legal Basis and Purposes (GDPR / UK)

For users in the EEA and UK, we process personal data on the following bases:

• Contract: To perform our contract with you (e.g., account management, sessions, payments).
• Legitimate interests: To operate and improve the Platform, prevent fraud, ensure security, and communicate about the service, where not overridden by your rights.
• Consent: Where we ask for your consent (e.g., marketing, non-essential cookies, optional features). You may withdraw consent at any time.
• Legal obligation: Where required by law (e.g., tax, anti-money laundering, responding to lawful requests).

5. How We Use Your Data

We use the data we collect to: (a) provide, maintain, and improve the Platform; (b) process payments and manage your KL Credits balance; (c) connect you with advisors and facilitate chat and call sessions; (d) send service-related communications (e.g., confirmations, security alerts); (e) respond to support requests and disputes; (f) detect and prevent fraud and abuse; (g) comply with legal obligations; (h) analyze usage for product improvement (in anonymized or aggregated form where possible); (i) send marketing communications where you have opted in; (j) enforce our Terms and policies.

5A. Device Permissions (Camera, Microphone, Notifications)

Depending on the features you use, the Platform may request access to certain device permissions. We request permissions only when needed for specific functionality and in accordance with your device and browser settings.

• Camera: Used for video consultation and video call sessions when you choose to enable video.
• Microphone: Used for voice and video call sessions so participants can communicate in real time.
• Notifications: Used to send service alerts, call/chat updates, reminders, and account/security notices where permitted by your settings.

You can deny or revoke these permissions at any time through your device or browser settings. If certain permissions are denied, related features (for example, video or voice calling) may not function properly. We do not access camera or microphone data unless you initiate or join a call session that requires it, and we do not use camera or microphone access for background surveillance.

6. Sharing and Disclosure

We may share your data with: (a) Advisors with whom you have a session (e.g., name, session content as needed); (b) Payment processors (e.g., Stripe) to process payments; (c) Service providers (hosting, analytics, email, push notifications, customer support) under contracts that require them to protect your data and use it only for the purposes we specify; (d) Legal and regulatory authorities when required by law or to protect our rights; (e) Affiliates or successors in connection with a merger, sale, or restructuring, subject to this policy. We do not sell your personal data to third parties for their marketing. We do not share sensitive personal data (as defined under Indian law) except as necessary for the purposes stated or with your consent.

Depending on the service you use, third-party processors may include infrastructure providers, payment gateways, communication/call delivery providers, authentication providers, and notification providers. These parties process data on our behalf under contractual and security controls.

6A. Key Service Providers

We may engage trusted third-party providers to operate specific features of the Platform. Depending on your usage, these providers may include:

• Payment processors (for example, Cashfree, PayU, or Stripe) for KL Credit top-ups, payments, and refunds.
• Cloud and backend infrastructure providers for secure hosting, storage, and core service delivery.
• Authentication providers for sign-in services and account security.
• Communication and call-delivery providers for chat, voice, and video session functionality.
• Push notification providers for service alerts, reminders, and account/security notifications.

These providers process personal data only under our instructions and applicable contractual, confidentiality, and security obligations.

7. International Transfers

Your data may be processed in India and in other countries where our service providers operate. For EEA/UK users, transfers to countries outside the EEA/UK are carried out using appropriate safeguards, such as Standard Contractual Clauses approved by the European Commission or UK authorities, or other mechanisms permitted by law. You may request details of the safeguards we use.

8. Retention

We retain your data only as long as necessary to fulfil the purposes in this policy, including to satisfy legal, accounting, or reporting requirements. Account data is typically retained while your account is active and for a period thereafter (e.g., for disputes and legal compliance). Transaction and payment records may be retained as required by tax and financial regulations. You may request deletion subject to applicable law and our retention obligations.

Where technically and legally feasible, we may delete or de-identify data earlier upon valid request. Certain records (for example, transaction logs, security logs, and compliance records) may be retained for mandatory statutory periods.

9. Your Rights

Depending on your location, you may have the following rights:

• Access: Request a copy of the personal data we hold about you.
• Correction: Request correction of inaccurate or incomplete data.
• Erasure: Request deletion of your data, subject to legal exceptions.
• Restriction: Request restriction of processing in certain circumstances.
• Portability: Request a copy of your data in a structured, machine-readable format (where applicable).
• Object: Object to processing based on legitimate interests or for direct marketing.
• Withdraw consent: Where processing is based on consent, withdraw it at any time.
• Complaint: Lodge a complaint with a supervisory authority (e.g., in the EU/UK) or with us.

India: You may have rights under the Digital Personal Data Protection Act, 2023 and rules thereunder, including the right to access, correction, erasure, and grievance redressal.

California (CCPA/CPRA): You may have the right to know, delete, correct, and port your personal information, and to opt out of the "sale" or "sharing" of personal information. We do not sell personal information as defined under CCPA. You may designate an authorized agent. We will not discriminate against you for exercising your rights.

To exercise any of these rights, contact us using the details in Section 14. We will respond within the timeframes required by applicable law.

10. Security

We implement appropriate technical and organizational measures to protect your data against unauthorized access, alteration, disclosure, or destruction, in line with applicable law (e.g., reasonable security practices under Indian IT rules). No method of transmission over the Internet or electronic storage is 100% secure; we cannot guarantee absolute security.

Security measures may include encryption in transit, access controls, logging and monitoring, incident response controls, and periodic security review practices appropriate to the nature of our services.

11. Children

The Platform is not intended for users under 18 (or the age of majority in your jurisdiction). We do not knowingly collect personal data from children. If you believe we have collected data from a child, please contact us and we will delete it promptly.

12. Third-Party Links and Services

The Platform may contain links to third-party websites or services (e.g., Stripe, social login providers). We are not responsible for their privacy practices. We encourage you to read their privacy policies.

13. Changes to This Policy

We may update this Privacy Policy from time to time. We will post the revised policy on this page and update the "Last updated" date. For material changes, we may notify you by email or through the Platform. Your continued use after the effective date constitutes acceptance. Where required by law (e.g., GDPR), we will obtain your consent to material changes.

14. Contact and Grievance Officer

For privacy-related queries, to exercise your rights, or to lodge a complaint, contact us at the email or address provided on the KnowingLives website or in the app (Support / Contact). For users in India, a Grievance Officer may be designated in compliance with the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021; their contact details will be published on the Platform.