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Ambrin Privacy Policy

by Snowflakes Counselling Private Limited

At Ambrin, we believe that privacy is fundamental to emotional wellbeing. When you use our platform, you trust us with personal information, including information about your mental and emotional health. We take that responsibility seriously.

This Privacy Policy explains what information we collect, how we use it, how we protect it, and the choices available to you regarding your data.

This policy applies to the Ambrin mobile application (Android and iOS), the Ambrin web platform, and all related services provided by Snowflakes Counselling Private Limited. For any privacy-related questions, please contact us at snowflakescounselling@gmail.com

Who We Are 

Ambrin is operated by Snowflakes Counselling Private Limited, the organization responsible for collecting, storing, and processing your personal information.

Registered Address: B-803, Aristo Anandam, Tragad, Ahmedabad, Gujarat

Email: snowflakescounselling@gmail.com

Website: www.snowflakescounselling.com/ambrin

What Data We Collect

To provide our services safely and effectively, we collect different categories of information.

 

Account Data

When you create or use an Ambrin account, we may collect:

  • Full name

  • Email address

  • Phone number (if provided)

  • School, college, or organization name

  • User role (student, teacher, counsellor, or administrator)

  • Profile photograph (optional)

 

Health & Wellness Data

As a mental wellbeing platform, Ambrin collects certain wellbeing and assessment information.

This may include:

  • PHQ-9 screening results and scores

  • GAD-7 screening results and scores

  • Mood check-in responses and scores

  • Assessment responses

  • Wellness history and trends over time

 

Session & Counselling Data

Where counselling services are provided, we may collect:

  • Session booking details

  • Assigned counsellor information

  • Session attendance records

  • Consultation history

  • Counsellor session notes

 

Usage Data

To improve user experience and platform performance, we may collect:

  • Screens and features accessed

  • Time spent using the platform

  • Login activity

  • Session duration

 

Device & Technical Data

We may also collect limited technical information, including:

  • Device type

  • Operating system version

  • App version

  • Push notification token

  • Anonymous crash and error reports

How We Use Your Data

We use your information to deliver and improve the services available through Ambrin.

Your information may be used to:

  • Provide mental health screenings and display results

  • Connect users with appropriate counsellors

  • Track wellbeing progress over time

  • Send reminders and wellbeing check-ins

  • Support institution administration functions

  • Improve platform stability and security

  • Meet applicable legal and regulatory obligations

 

Our Commitment To Privacy

We do NOT use your data for advertising.

We do NOT sell your data to any third party.

Health and assessment data is never shared with advertisers or data brokers.

Who We Share Data With

  Third-Party Processors

  We use the following services to run the platform:

  • Oracle Cloud Infrastructure — hosting, database & media storage — India (Mumbai)                                                                                        

  • Expo / Google FCM / Apple APNs — push notifications — US & Global (device tokens and notification text only; no health data)

  • Sentry — crash reporting — US (anonymised stack traces only; no personal or health data)

  We do not share health or assessment data with any other third parties.

Legal Basis for Processing

Under the DPDP Act, 2023, we process your data based on:

• Consent — account creation, assessments, profile photo (withdrawable at any time)
• Contractual Necessity — delivering booked sessions and assessment results
• Legitimate Use — security logging and fraud prevention
• Legal Obligation — compliance with court orders or government directives

Health data is processed only on explicit consent given when you take an assessment or book a session.

Cross-Border Data Transfers

Your data is primarily stored in India on Oracle Cloud Infrastructure (Mumbai). Limited cross-border transfers occur only for push notifications (Expo, FCM, APNs) and anonymised crash reports

  (Sentry), both in the US. No health data is included in these transfers. All processors are contractually bound to DPDP Act-consistent protections.

Data Storage & Security

Protecting your information is one of our highest priorities.

We use multiple security measures, including:

  • Encrypted data storage

  • Secure password hashing

  • HTTPS/TLS encryption

  • Secure authentication systems

  • Role-based access controls

  • Restricted production access for authorised personnel only

 

Your information is stored securely in accordance with industry-standard security practices.

Health Data Special Protections

Mental health information deserves additional safeguards.

PHQ-9 scores, GAD-7 scores, mood information, and other assessment results are treated as sensitive health data.

  • Health data is never used for advertising or marketing.

  • Health data is never sold or shared with third parties.

  • Health data is only accessible to the user and authorised support personnel.

  • Health data is permanently deleted when an account is deleted.

  • Additional security controls are applied to protect this information.

Data Retention

We retain information only for as long as it is necessary to provide services and meet legal obligations.

  • Account information is retained while an account remains active.

  • Health and assessment data is retained for 2 years to enable wellness trend tracking.

  • Following account deletion, personal information is permanently removed within 30 days.

  • Anonymous statistical information may be retained for platform improvement and research.

Session Notes

Counsellors may write clinical notes during your sessions. These contain observations and follow-up actions — not verbatim transcripts. Notes are accessible only to your assigned counsellor, formally reassigned counsellors, and institutional admins with safeguarding duties. Notes are confidential except where law or safety requires disclosure. Retained for 2 years, then deleted. To request a copy or correction, email privacy@snowflakescounselling.com

Your Rights

You have important rights regarding your personal information.

These include:

  • Right to Access

  • Right to Correction

  • Right to Deletion

  • Right to Data Portability

  • Right to Withdraw Consent

  • Right to Grievance

  • Right to Nominate — appoint someone to act on your behalf in case of incapacity or death

  • Right to Grievance Redressal — raise a complaint with our Grievance Officer

 

To exercise any of these rights, email:

privacy@snowflakescounselling.com

 

Subject line:

Data Request – [Right Type]

We aim to respond within 30 days.

Account Deletion

You may request account deletion at any time.

 

Through the App

Settings → Account → Delete My Account

 

Through Email

Send an email to privacy@snowflakescounselling.com

Subject: Delete My Account

All personal information, health information, assessment records, and counselling history will be permanently deleted within 30 days.

Account deletion is irreversible.

Children & Minors

Ambrin is designed for users aged 18 and above.

Users under 18 may only access Ambrin through their educational institution, which must obtain verifiable parental or guardian consent before enrollment, in accordance with Section 9 of the DPDP Act, 2023. We do not collect data from minors outside this pathway and do not track minors for advertising or profiling.

Parents or guardians may withdraw consent at any time by emailing snowflakescounselling@gmail.com

Push Notifications

Ambrin may send notifications relating to:

  • Session reminders

  • Assignment notifications

  • Wellbeing check-ins

Users may disable notifications through their device settings or through notification preferences within the application.

Analytics & Tracking

Ambrin does not use advertising trackers.

We do not use data for behavioural profiling or targeted advertising.

Sentry is used solely for anonymous crash reporting and technical issue resolution.

Medical Disclaimer

Ambrin is a wellness and counselling support platform. It is not a medical device and does not diagnose, treat, cure, or prevent any medical condition. The PHQ-9 and GAD-7 screening tools are provided for informational and wellness purposes only and are not a substitute for professional medical advice, diagnosis, or treatment. Always consult a qualified healthcare professional for medical concerns.

Changes to This Policy

We may update this Privacy Policy from time to time.

When significant changes are made, we may notify users through email, in-app notifications, or other appropriate channels.

The most recent version will always be available on this page.

For material changes, we will give at least 7 days' advance notice via the app or email.
 

GRIEVANCE OFFICER 

Contact Us

If you have any questions about this Privacy Policy or how your information is handled, please contact us.

Email: snowflakescounselling@gmail.com

Registered Address: B-803, Aristo Anandam, Tragad, Ahmedabad, Gujarat

Website: www.snowflakescounselling.com/ambrin

Response Time: Within 30 days of receiving your request.

Grievance Officer

As required under the IT (Intermediary Guidelines) Rules, 2021 and the DPDP Act, 2023:

Name: Sneha Paliwal, Director
Email: snowflakescounselling@gmail.com
Address: B-803, Aristo Anandam, Tragad, Ahmedabad, Gujarat 382470

Acknowledgement within 48 hours. Resolution within 30 days.
Unresolved complaints may be escalated to the Data Protection Board of India.
 

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