Enlightened Circle Foundation (ECF)
01. PREAMBLE & INSTITUTIONAL COMMITMENT
Enlightened Circle Foundation (“ECF”, “we”, “our”, “us”) is a registered Section 8 non-profit organization committed to building safe, disciplined, and confidential environments for spiritual growth, meditation, and inner transformation.
ECF acknowledges that its participants may share:
- Personally identifiable information
- Behavioral and engagement data
- Sensitive emotional, psychological, and spiritual reflections
Accordingly, ECF operates under a two-tier privacy protection framework:
Layer 1: Legal Data Protection Compliance
Strict adherence to:
- Digital Personal Data Protection Act, 2023
- Applicable provisions under the Information Technology Act, 2000 and allied rules
- Emerging regulatory standards governing digital platforms and user data
Layer 2: Spiritual Confidentiality Doctrine
A higher ethical obligation recognizing that:
What is shared within ECF is not transactional data — it is deeply personal, reflective, and often sensitive in nature.
02. SCOPE, APPLICABILITY & CONSENT
This Policy applies to all data collected across:
- Website and digital platforms
- LMS systems and mobile applications (including Swadhyan App)
- Online and offline program registrations
- Retreats, satsangs, and experiential engagements
- Membership communities
- Donations and contribution channels
- Communication channels (email, WhatsApp, forms, surveys)
By accessing or engaging with ECF, you:
- Provide free, informed, specific, and unambiguous consent
- Acknowledge lawful data processing under applicable regulations
- Agree to data handling practices outlined herein
03. CATEGORIES OF PERSONAL DATA COLLECTED
3.1 Basic Personal Information
- Full name
- Email address
- Mobile number
- City/location
- Age and gender (where relevant)
3.2 Financial & Transaction Data
- Payment transaction IDs
- Billing details (processed via third-party gateways)
Important:
ECF does not store sensitive financial credentials such as card numbers or banking passwords.
3.3 Usage & Interaction Data
- Platform login activity
- Session participation
- Program engagement metrics
- Device and browser data (where applicable)
3.4 Sensitive Personal Data (SPIRITUAL CONFIDENTIALITY CATEGORY)
Participants may voluntarily share:
- Personal reflections and journaling responses
- Emotional experiences
- Spiritual insights
- Verbal sharing during sessions
Special Classification
This data is treated as:
- Highly confidential and protected
- Non-commercial and non-exploitative
- Restricted from disclosure without explicit consent
04. PURPOSE & LAWFUL BASIS OF PROCESSING
Data is collected and processed strictly for:
4.1 Service Delivery
- Program enrollment and execution
- Communication of schedules, updates, and access
4.2 Platform Functionality
- Account management
- Access control and authentication
4.3 Experience Enhancement
- Improving program design
- Personalizing participant journeys
4.4 Legal Compliance
- Maintaining records for statutory purposes
- Responding to lawful requests
4.5 Legitimate Interest
- Ensuring platform safety, discipline, and integrity
05. CONSENT MANAGEMENT & USER RIGHTS
In alignment with applicable Indian law, users have the right to:
- Request access to personal data
- Request correction or updating of inaccurate data
- Withdraw consent (subject to service limitations)
- Request deletion of data (where legally permissible)
- Grievance redressal
Withdrawal Impact
Withdrawal of consent may result in:
- Restricted access
- Termination of participation
06. DATA MINIMIZATION & PURPOSE LIMITATION
ECF adheres to:
- Data minimization: Collect only what is necessary
- Purpose limitation: Use data strictly for declared purposes
- Storage limitation: Retain data only as long as required
07. DATA SECURITY & PROTECTION MEASURES
ECF implements:
- Encryption protocols
- Secure server infrastructure
- Access control mechanisms
- Role-based data access
- Regular monitoring and safeguards
Despite best practices, users acknowledge that:
No digital system is entirely immune to risks.
08. CONFIDENTIALITY OF SESSIONS & COMMUNITY INTERACTIONS
Sacred Confidentiality Clause
All sessions, discussions, and interactions within ECF are treated as:
- Confidential
- Non-recordable (unless authorized)
- Non-disclosable
Participants agree:
- Not to record sessions
- Not to share content externally
- Not to disclose identities or experiences of others
Violation may lead to:
- Immediate removal
- Legal action
- Permanent access restriction
09. DATA SHARING & DISCLOSURE RESTRICTIONS
ECF follows a strict non-commercial data policy.
ECF does NOT:
- Sell user data
- Rent or trade personal information
- Use data for advertising or profiling
Limited Data Sharing Permitted Only:
9.1 Internal Use
- Authorized ECF team members
- Mentors (only where necessary)
9.2 Service Providers
- Payment processors
- Technology and hosting platforms
All such parties are bound by confidentiality obligations.
9.3 Legal Disclosure
Data may be disclosed:
- When required by law
- Under court or government orders
- For protection of rights and safety
10. CROSS-BORDER DATA TRANSFER
If data is processed or stored outside India:
- ECF ensures adequate safeguards
- Transfers comply with applicable Indian regulations
11. DATA RETENTION POLICY
ECF retains data:
- For the duration of user engagement
- As required for legal, operational, and audit purposes
Post this:
- Data may be securely deleted or anonymized
12. CHILD DATA PROTECTION
- Data of individuals under 18 is collected only with parental consent
- Any inadvertent collection will be rectified and deleted
13. COOKIES & TRACKING
ECF may use cookies to:
- Enhance platform performance
- Analyze usage patterns
Users may control cookies through browser settings.
14. LIMITATION OF LIABILITY
ECF shall not be liable for:
- Unauthorized access due to user negligence
- Cyber incidents beyond reasonable control
- Voluntary disclosures made by participants outside ECF platforms
15. GRIEVANCE REDRESSAL MECHANISM
In compliance with Indian law, ECF provides a grievance mechanism.
Users may raise concerns regarding:
- Data misuse
- Privacy violations
- Access or correction requests
16. POLICY MODIFICATIONS
ECF reserves the right to:
- Update or modify this Policy
- Align with evolving legal requirements
Continued usage constitutes acceptance.
17. GOVERNING LAW & JURISDICTION
This Policy shall be governed by the laws of India.
Jurisdiction: New Delhi, India
18. CONTACT & DATA PROTECTION OFFICER
For privacy-related queries or requests:
Email: info@enlightenedcircle.org