Effective Date: 08/11/2026

Welcome to The Inner Smile. Your privacy is important to us. This Privacy Policy explains how The Inner Smile, operated by Aparna Aggarwal, collects, uses, stores, and protects your personal information when you visit our website, contact us, book a session, or use our services.

By accessing this website or using our services, you agree to the practices described in this Privacy Policy.

1. Who We Are

The Inner Smile is an online practice dedicated to supporting emotional wellbeing, self-awareness, and personal growth through Emotional Wellbeing Coaching, delivered through an integrative approach drawing on psychology-informed counselling skills and psychotherapy-informed techniques and Emotional Freedom Technique (EFT).

Services are offered by Aparna Aggarwal.

Information about Aparna Aggarwal’s professional qualifications, certifications, and training is available on the Terms of Use.

For any questions regarding this Privacy Policy, you may contact us at:

Email: aparnaaggarwal18@gmail.com

Legal Basis for Processing information. Personal information is processed on the basis of your consent, or, where you have voluntarily provided personal information for a specified purpose (such as booking a session or using the information for providing services) on the basis of that specified and legitimate use, in each case, in accordance with the Digital Personal Data Protection Act, 2023.

2. Information We Collect

We may collect the following information when you interact with our website or services.

Personal Information

• Full name
• Email address
• Phone number
• Country or city of residence
• Emergency contact details (if voluntarily provided)

Booking Information

• Appointment details
• Session preferences
• Payment confirmation
• Communication related to appointments

Intake Information

Before your first session, you may voluntarily provide information relating to:

• Your concerns or goals
• Personal history relevant to the counselling process
• Previous support received
• Lifestyle and wellbeing information

This information helps us understand your needs and provide appropriate support.

Contact Form Information

If you contact us through our website’s contact form, we collect the information you voluntarily provide to respond to your enquiry.

Website Information

When you visit our website, certain technical information may be collected automatically, including:

• IP address
• Browser type
• Device information
• Pages visited
• Date and time of access

This information helps us improve website functionality, security, and user experience.

3. How We Use Your Information

Your information may be used to:

• Schedule and manage appointments
• Deliver counselling and psychotherapy-informed services
• Respond to your enquiries
• Process payments securely
• Maintain appropriate client records
• Improve our services and website
• Send appointment reminders and important service-related communications
• Comply with applicable legal and professional obligations

We do not sell, rent, or trade your personal information to third parties.

4. Compliance with Applicable Laws

The Inner Smile is committed to handling personal information responsibly and in accordance with applicable laws, including the Digital Personal Data Protection Act, 2023 (India), and other applicable laws, where relevant. In accordance with the Digital Personal Data Protection Rules, 2025, Aparna Aggarwal is designated as the Grievance Officer for The Inner Smile. Grievances or requests relating to your personal information may be sent to aparnaaggarwal18@gmail.com, and will generally be acknowledged and addressed within seven (7) working days, and in any event within the outer limit of ninety (90) days, as prescribed under the Digital Personal Data Protection Rules, 2025.

5. Payment Information

Payments made through our website are processed securely through Razorpay.

The Inner Smile does not store your complete debit card, credit card, UPI, net banking, or other payment credentials.

Payment information is processed directly by Razorpay in accordance with their privacy and security practices.

6. Confidentiality

Respecting your privacy is one of the core values of The Inner Smile.

Information shared during counselling sessions is treated with care and confidentiality.

However, confidentiality may be limited where disclosure is:

• Required by applicable law;
• Necessary to reduce a serious risk of harm to you or another person; or
• Required under a lawful order or legal obligation.

Where legally appropriate and reasonably possible, every effort will be made to discuss such disclosure with you beforehand.

7. Cookies

Our website may use cookies and similar technologies to:

• Improve website functionality
• Understand website usage
• Enhance user experience

You may disable cookies through your browser settings; however, some features of the website may not function as intended.

8. Data Security

Reasonable administrative, technical, and organisational safeguards are implemented to protect your personal information against unauthorised access, misuse, alteration, disclosure, or loss.

While we take reasonable steps to protect your information, no online transmission or electronic storage system can be guaranteed to be completely secure.

In the event of a personal data breach, The Inner Smile will take reasonable steps, without undue delay, to contain and assess the breach, and will intimate the Data Protection Board of India and each affected Data Principal in the manner and within the timelines prescribed under the Digital Personal Data Protection Act, 2023 and the rules made thereunder.

9. Third-Party Services

Our website may use trusted third-party service providers, including but not limited to:

• Razorpay (payment processing)
• Online video conferencing platforms
• Appointment scheduling services
• Email communication providers

These third-party providers operate under their own privacy policies, and we encourage you to review them before sharing personal information. Where such third-party service providers process personal information on our behalf, they are engaged under contractual arrangements requiring them to maintain appropriate confidentiality and security safeguards for your personal information, consistent with Section 8(2) of the Digital Personal Data Protection Act, 2023. You will be notified and your consent will be obtained if any of your personal information is being shared with a third party.

10. Data Retention

Your personal information will be retained only for a period of three (3) years following the conclusion of sessions, for record-keeping and legal purposes, unless a longer period is required by applicable law.

In particular, personal information is retained to:

• Provide our services
• Maintain appropriate professional records
• Comply with applicable legal obligations
• Resolve disputes
• Enforce our policies

When information is no longer required, reasonable steps will be taken to securely delete or anonymise it.

11. International Clients

If you access our services from outside India, please note that your personal information may be collected, processed, and stored in India.

By using our services, you consent to such processing in accordance with this Privacy Policy.

12. Your Rights

Subject to applicable law, you may request to:

• Access your personal information
• Correct inaccurate information
• Update your information
• Withdraw consent where applicable — withdrawal will be as easy as giving consent, though it will not affect the lawfulness of processing carried out before withdrawal
• Request deletion of your personal information, subject to applicable legal, ethical, and professional record-keeping requirements
• Nominate another individual to exercise these rights on your behalf in the event of your death or incapacity, in accordance with Section 14 of the Digital Personal Data Protection Act, 2023

Requests may be sent to:

Email: aparnaaggarwal18@gmail.com

Requests and grievances will generally be acknowledged and addressed within seven (7) working days, and in any event within the outer limit of ninety (90) days, as prescribed under the Digital Personal Data Protection Rules, 2025.

13. Children’s Privacy

The Inner Smile’s services are intended for individuals 18 years of age and above only.

No personal information is knowingly collected from individuals under 18 years of age. If The Inner Smile becomes aware that information has been inadvertently collected from a minor, that information will be deleted, save where retention is required by applicable law.

14. Governing Law and Jurisdiction

This Privacy Policy shall be governed by and construed in accordance with the laws of India. Any dispute arising out of or in connection with this Privacy Policy shall be subject to the exclusive jurisdiction of the courts at New Delhi, India, consistent with the governing law and jurisdiction clause in the Informed Consent for Emotional Wellbeing Coaching.

15. Changes to This Privacy Policy

This Privacy Policy may be updated from time to time to reflect changes in our services, legal requirements, or business practices.

Any updates will be published on this page together with a revised Effective Date.

16. Important Disclaimer

The information provided on this website is for educational and informational purposes only and does not constitute medical, psychiatric, psychological, or legal advice, nor is it a substitute for emergency services.

If you are experiencing a medical or mental health emergency, or believe that you or someone else is at immediate risk of harm, please contact your local emergency services or seek immediate assistance from an appropriate healthcare provider.

17. Contact

If you have any questions regarding this Privacy Policy or the way your personal information is handled, please contact:

The Inner Smile
Aparna Aggarwal
Email: aparnaaggarwal18@gmail.com
Website: theinnersmile.in