Privacy Policy

Last updated: [Date]

Your family's privacy matters to us. This Policy explains what data we collect, why, how we protect it, and the choices you have — with particular care for children's information.

1. Scope

This Privacy Policy explains how [Legal Entity Name] (“SuperAble”, “we”, “us”) collects, uses, shares, and protects personal data when you use our website, applications, and services (the “Platform”). It should be read with our Terms of Use. We act as a Data Fiduciary under India's Digital Personal Data Protection Act, 2023 (“DPDP Act”) in respect of the personal data we determine the purposes and means of processing.

2. Information We Collect

Account and contact data

Your name, mobile number, email address, role (parent or therapist), and authentication data (such as one-time passwords).

Child information (sensitive)

When you book or onboard as a parent, you may provide your child's name, date of birth, gender, photo, the concerns you're seeking help with, diagnoses, and current/ongoing therapies. This is sensitive personal data and is collected only with your consent as parent/guardian.

Therapist professional data

For therapists: qualifications, certifications, government-issued identification, years of experience, specialisations, languages, pricing, availability, and clinic/centre address and photos.

Booking, payment, and transaction data

Session details, booking history, amounts, platform fees, taxes, wallet balance, credits, referral activity, and payment references. Card and bank details are collected and processed by our payment provider, not stored by SuperAble.

Usage, device, and uploaded content

Log data, device and browser information, ratings and reviews you submit, files you upload (such as certificates or centre photos), and location information you provide (such as a map link or pin for a centre).

3. How We Use Your Data

We use personal data to:

  • create and manage your account and verify your identity via OTP;
  • enable parents to discover therapists and book, reschedule, or cancel sessions;
  • review and moderate therapist profiles before they go live;
  • process payments, fees, commissions, refunds, wallet balances, and credits;
  • generate session links (for online sessions) and share necessary details with the matched therapist;
  • operate the referral programme and ratings/reviews;
  • send transactional notifications (in-app, email, and, where enabled, messaging);
  • provide support, ensure safety and security, prevent fraud and abuse; and
  • comply with legal obligations.

4. Legal Basis and Consent

We process personal data based on the consent you provide and, where applicable, for the performance of services you request, our legitimate uses permitted under the DPDP Act, and to meet legal obligations.

For a child's personal data, we rely on verifiable parental/guardian consent. By providing a child's information, you confirm you are the parent or lawful guardian and consent to its processing for delivering services through the Platform. You may withdraw consent at any time (see “Your Rights”), though this may limit our ability to provide the service.

5. How We Share Data

We share personal data only as needed to operate the Platform:

  • With the matched therapist — the parent and child information necessary to deliver a booked session. Therapists are required to keep this confidential and use it only to provide services.
  • With service providers (processors) — payment processing, video conferencing for online sessions, email delivery, cloud storage for uploads, mapping, and (where enabled) messaging. These providers process data on our instructions.
  • For legal and safety reasons — to comply with law, enforce our Terms, or protect the rights, safety, and security of users, the public, or SuperAble.
  • In a business transfer — in connection with a merger, acquisition, or sale of assets, subject to this Policy.

We do not sell your personal data.

6. Data Retention

We retain personal data for as long as your account is active or as needed to provide services, comply with legal, tax, and accounting obligations, resolve disputes, and enforce agreements. When data is no longer required, we delete or anonymise it. You may request deletion as described below.

7. Security

We use reasonable technical and organisational measures to protect personal data, including access controls, encryption in transit, and restricted handling of sensitive data. No method of transmission or storage is completely secure, and we cannot guarantee absolute security. Please keep your account credentials confidential and notify us of any suspected compromise.

8. Your Rights

Subject to the DPDP Act and applicable law, you may:

  • access and obtain a summary of the personal data we process about you;
  • request correction, completion, or updating of inaccurate or incomplete data;
  • request erasure of your personal data where no longer necessary;
  • withdraw consent previously given (without affecting prior lawful processing);
  • nominate another individual to exercise your rights in case of death or incapacity; and
  • raise a grievance with our Grievance Officer.

To exercise these rights, contact us at [support/privacy email]. We may need to verify your identity before acting on a request.

9. Children's Data

The Platform is intended for use by adults (parents/guardians and therapists). Children's personal data is processed only on the basis of parental/guardian consent and solely to deliver requested services. We do not undertake profiling or targeted advertising directed at children, and we do not process children's data in a manner likely to cause harm.

10. Cookies and Similar Technologies

We use cookies and similar technologies necessary for authentication, security, and core functionality, and may use limited analytics to improve the Platform. You can control cookies through your browser settings; disabling essential cookies may affect functionality.

11. International Transfers

Some of our service providers may process data outside India. Where this occurs, we take steps consistent with applicable law to protect your data. By using the Platform, you acknowledge such processing as necessary to provide the service.

12. Changes to This Policy

We may update this Policy from time to time. The “Last updated” date reflects the latest version, and material changes will be notified through the Platform or email.

13. Contact and Grievance Officer

For questions or to exercise your rights, contact our Grievance Officer: [Name], [Legal Entity Name], [registered address], email [privacy/grievance email]. We will respond within the timelines required by applicable law.