Privacy & Terms — template structure

Draft skeleton for counsel to complete. Structured to satisfy India DPDP Rules 2025 and EU GDPR Art. 9 from day one.

1. What we collect

Account details; assessment responses; session check-ins; audio-program preferences; device data (when headband ships: EEG signals); payment records via processor.

2. Why (purpose limitation)

Deliver sessions, generate your reports, improve programs. No sale of personal data. No advertising use of assessment responses.

3. Consent & rights (DPDP + GDPR)

Explicit, revocable consent at signup; withdraw anytime; access, correction, erasure; grievance officer named here.

4. Children's data

Student programs require verifiable guardian consent below applicable age thresholds (DPDP children's rules).

5. Organization programs

Individuals opt in and own their data; organizations receive aggregate, cohort-level statistics only — never individual emotion/state profiles.

6. Security & retention

Encryption at rest/in transit; access control; breach notification per law; defined retention schedule.

7. Wellness disclaimer

Neuromin is not a medical device and does not diagnose, treat, cure or prevent any disease or condition.