Privacy Policy

Important Note

We do not sell or share any Personal Data, including emotion inference data, images, audio, or video, without explicit consent.

We, Nihilent Ltd. and all our entities and subsidiaries (hereafter referred to as “Nihilent,” “we,” “us,” “our”, “Company”) have developed and own the nSEPIA application, made available through the mobile application or web-based version (herein referred to as “nSEPIA” or “Application”). The Application is an AI-powered emotional wellness application designed to help users manage their emotional wellness through personalized relaxation plans based on near real-time emotion scans (“Offering/s”). The Application relies on emotion scans, body movement detection, advanced music therapy in the form of ragas, yoga, breathwork, meditation, and other wellness content to offer instant relief and long-term emotional fitness tools.

We respect data privacy rights and are committed to protecting Personal Data collected on nSEPIA. This Privacy Notice (“Privacy Notice”) sets forth how we collect, use, and protect the personal data collected through the Application. This Privacy Notice applies to nSEPIA and should not be referred to for any other products, applications, or services offered by Nihilent.

PLEASE READ THIS PRIVACY NOTICE CAREFULLY. BY CLICKING ON THE CONSENT CHECK BOX, AND BY ACCESSING AND USING THE APPLICATION, YOU AGREE TO THE TERMS OF THIS PRIVACY NOTICE OUTLINED BELOW. YOU HEREBY AGREE AND PROVIDE CONSENT TO THE COMPANY FOR PROCESSING PERSONAL DATA FOR THE PURPOSES AND THE SCOPE DEFINED IN THIS PRIVACY NOTICE. IF YOU DO NOT AGREE TO THE TERMS OF THIS PRIVACY NOTICE, YOU MAY WITHDRAW YOUR CONSENT OR CHOOSE NOT TO PROVIDE YOUR PERSONAL DATA ON THE APPLICATION. SUCH AN INTIMATION TO WITHDRAW YOUR CONSENT CAN BE PROVIDED BY EMAIL ON privacy@nsepia.com.

IF YOU ARE ACCESSING THE APPLICATION ON BEHALF OF A THIRD PARTY, YOU REPRESENT THAT YOU HAVE THE AUTHORITY TO BIND SUCH THIRD PARTY TO THE TERMS AND CONDITIONS OF THIS PRIVACY NOTICE AND, IN SUCH AN EVENT, YOUR USE OF THE APPLICATION SHALL REFER TO USE BY SUCH THIRD PARTY. IF YOU DO NOT HAVE SUCH AN AUTHORITY (TO PROVIDE PERSONAL DATA OF A THIRD PARTY) OR DO NOT AGREE TO THE TERMS OF THIS PRIVACY NOTICE, THEN YOU SHOULD REFRAIN FROM USING THE APPLICATION.

This Privacy Notice is an electronic record in the form of an electronic document and construed in accordance with the data protection laws of the applicable jurisdictions.

1. DEFINITIONS

1. “Personal Data” means any information/data that relates to an identified or identifiable natural person.
2. “User(s)”, “you”, “your” shall mean a natural person who uses, registers, or accesses the Application and the Offerings.

2. WHAT PERSONAL DATA IS COLLECTED BY US?

We may receive your Personal Data in the following ways:

1. Information Collected through the Use of the Application: When you use the Application, we may receive information about you and your usage of the Application. Such information may include your Personal Data and your facial data or facial scan data, skeletal/pose points, emotion inference scores, user images, audio and video to detect the emotions of the user.
2. Onboarding and Account Creation: You may share your Personal Data on the Application when you create an account. Such data may include, but is not limited to, your name, age, sex, email address, contact number, faith, and any other information you provide when registering.
3. Social Sign-Up Methods: If you choose to sign up through providers such as Google, Facebook, or others, we may receive additional Personal Data from such providers.
4. Online Identifiers and Log Data: We may receive information about your system, device, browser type, usage duration, system logs, etc.
5. Payment Information: Users who upgrade to premium subscriptions may provide data such as full name, phone number, billing address, and email address. Payments are processed through third-party providers. We do not store or access your financial information (e.g., credit/debit card details). We may retain only payment confirmation numbers.
6. Communications: We may collect information you provide when you contact us, including your name, email, phone number, and any additional details about your inquiry.

3. ACCURACY OF INFORMATION

The User is solely responsible for the accuracy, correctness, or truthfulness of the Personal Data shared with us. If sharing data on behalf of a third person, the User represents that they have the necessary authority and written consent to do so. Such Personal Data shall be subject to this Privacy Notice.

4. HOW WE USE YOUR PERSONAL DATA

We may use the Personal Data for the following purposes:

1. to provide and inform you about our Offerings,
2. to respond to your requests,
3. for the creation or development of business intelligence or data analytics,
4. to provide an improved experience when you access our Application,
5. to personalize content, insights, and recommendations aimed at enhancing your emotional state and well-being,
6. to maintain and manage our Application,
7. to support operations and service delivery,
8. to manage our relationship with you,
9. for internal record keeping,
10. to comply with legal or statutory obligations.

5. HOW WE SHARE YOUR PERSONAL DATA

We do not sell, rent, share, distribute, lease, or otherwise provide your Personal Data to third parties without your prior consent. However, we may disclose Personal Data in the following cases:

1. Emoscape: We may provide your Personal Data to our product “Emoscape” for processing to enhance and improve the Offerings.
2. Affiliates: We may provide your Personal Data to our affiliates to enable them to improve Offerings and provide feedback.
3. Service Providers: Personal Data may be shared with service providers who assist with operations. They are bound by strict confidentiality obligations.
4. Merger or Acquisition: If we are acquired, merged or transfer part of our business, Personal Data may be transferred to the new entity.
5. Safety, Legal and Regulatory Authorities: We may disclose Personal Data where required by law or necessary to protect our rights, users, property, or operations.

6. COOKIES

We use cookies and similar tracking tools such as beacons, tags, and scripts to track usage patterns and improve our websites.

7. ANONYMISED DATA

We may use your Personal Data to create aggregate anonymized data. Personal Data will be deleted, and anonymized data retained. Such anonymized data cannot identify you and may be used for research, analytics, AI training, and business improvements.

8. INTERNATIONAL DATA TRANSFER

We may transfer Personal Data to India or other locations depending on infrastructure requirements. All transfers comply with applicable laws.

9. YOUR PRIVACY RIGHTS

You have the following rights under applicable data laws:

1. Right to access your Personal Data,
2. Right to rectify or modify Personal Data,
3. Right to erase/delete your Personal Data,
4. Right to restrict processing,
5. Right to object to processing,
6. Right to withdraw consent at any time.

To exercise any of these rights, please contact privacy@nsepia.com.

10. INFORMATION FOR INDIA USERS AS PER DPDPA

These rights apply under the Digital Personal Data Protection Act, 2023, once enforced.

1. Right to access information about Personal Data,
2. Right to correction and erasure,
3. Right of grievance redressal,
4. Right to nominate,
5. Right to withdraw consent.

Contact privacy@nsepia.com to exercise these rights. After exhausting our grievance mechanism, you may approach the Data Protection Board of India when established.

11. INFORMATION FOR USERS AS PER CCPA

This section outlines Californian residents’ rights under the California Consumer Privacy Act (“CCPA”) and the California Privacy Rights Act (“CPRA”).

We do not sell, rent, distribute, lease, or otherwise provide your Personal Information to third parties without your prior consent. You may exercise your rights by emailing privacy@nsepia.com.

California consumers have the following rights:

1. Right to correct Personal Information and Sensitive Personal Information,
2. Right to limit use of Sensitive Personal Information to specific purposes,
3. Right to opt out of automated decision making and profiling,
4. Right to request access to information about automated decision-making,
5. Right to request deletion of Personal Information,
6. Right to know what Personal Information is collected and access it,
7. Right to know what Personal Information is sold or shared and with whom,
8. Right to opt out of sale or sharing of Personal Information,

We will not charge a fee unless requests are excessive, repetitive, or manifestly unfounded.

We will not discriminate against you for exercising CCPA/CPRA rights. We will not:

1. Deny access to our software or services,
2. Charge different rates,
3. Provide a different quality of service.

12. YOUR CHOICES AND OPT-OUT

We may send you communications such as notices, updates, promotional information, and newsletters. You may opt out at any time by selecting “unsubscribe” in emails or by contacting privacy@nsepia.com.

13. DATA RETENTION

We retain Personal Data as long as required for service delivery. Data may be retained further to comply with legal obligations, resolve disputes, or enforce agreements.

14. THIRD PARTY WEBSITES, APPLICATIONS AND PAGES

Our Offerings may contain links to third-party websites or applications. We do not control and are not responsible for their privacy practices. Users should review third-party privacy notices before interacting with those services.

15. SECURITY PRACTICES

We maintain security measures aligned with industry standards. However, no system is fully hack-proof. Unauthorized access, hacking, viruses, or technical issues may occur, and we will take necessary mitigation steps.

16. CHILDREN’S PERSONAL DATA

The Application is not intended for individuals under 18 years. If we learn of data collected from a child without parental consent, we will delete it. Please contact privacy@nsepia.com if you believe a child’s data has been collected.

17. GOVERNING LAWS AND DISPUTES

This Privacy Notice is governed by the laws of India and subject to the exclusive jurisdiction of courts in Pune.

18. CHANGES TO THIS PRIVACY NOTICE

We may update this Privacy Notice at any time. Updated versions will be posted with revision dates. If changes materially affect your rights, we will provide reasonable notice through email or the Application.

19. HOW TO CONTACT US

For questions, concerns, or withdrawal of consent, contact Mr. Swapnil Padhye at privacy@nsepia.com.

Office Address: