Privacy Policy
This Privacy Policy explains how we collect, use, and protect your personal data. It is to be read alongside our Terms of Use.
Operated by: Walnut Coach LLP, Vision Co Work, 293, Lane-2, Westend Marg, Near Saket Metro Station Gate No. 02, Saket, New Delhi, Delhi – 110030.
Contact: info@happinesscoach.com | +91 9999585460
P1. Overview and Scope
P1.1 Walnut Coach LLP (“Walnut”, “we”, “us”, “our”) is committed to protecting your personal data. This Privacy Policy explains what personal data we collect about you, why we collect it, how we use it, with whom we share it, and your rights in respect of it.
P1.2 This Policy applies to all individuals who use the Walnut.coach Platform — including individual coaching clients, corporate HR administrators, employees enrolled in corporate programs, and visitors to the Walnut.coach website.
P1.3 This Policy is to be read alongside the Terms of Use. Capitalised terms used in this Policy and not separately defined have the meaning given to them in the Terms of Use.
P1.4 This Policy complies with the Information Technology Act, 2000; the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (“SPDI Rules”); and the Digital Personal Data Protection Act, 2023 (“DPDP Act”).
P2. Data Fiduciary (Controller)
P2.1 For the purposes of the DPDP Act, 2023, and applicable Indian data protection law, Walnut Coach LLP is the Data Fiduciary (the entity that determines the purpose and means of processing your personal data).
Grievance Officer
In accordance with the Information Technology Act, 2000, and the SPDI Rules, 2011, Walnut has designated a Grievance Officer to address concerns relating to personal data processing.
Complaints will be acknowledged within 24 hours and resolved within 30 days of receipt.
P3. Personal Data We Collect
P3.1 Account and Registration Data. When you create an account, we collect: full name; email address; mobile number; and password (stored in encrypted form).
P3.2 Personality Assessment Data (Sensitive Personal Data). Upon registration, you complete a gamified OCEAN + DISC + Enneagram personality assessment. The results of this assessment constitute Sensitive Personal Data under the SPDI Rules, 2011. This data is collected with your express consent and is used solely for: generating your personalised Skill Tree; powering the Platform's coach recommendation algorithm; and enabling your coach to personalise their coaching approach.
P3.3 Coaching Session Data. We collect data relating to your coaching sessions, including: session dates, times, and durations; session completion status; skill tree progression and skill sign-off records; in-app assignment submissions and completion records; and mid-session progress assessment inputs.
P3.4 In-App Chat Communications. Messages exchanged between you and your coach via the Platform's in-app messaging feature are stored on our servers. You are informed of this within the chat interface via a caution banner. Chat data is used to support continuity of your coaching engagement and, where necessary, to investigate reports of misconduct or abuse.
P3.5 Payment and Credit Data. When you purchase credits, we collect transaction reference data, credit bundle details, and payment timestamps. Full payment card details are processed by our third-party payment gateway and are not stored by Walnut.
P3.6 Usage and Technical Data. We automatically collect certain technical data when you use the Platform, including: device type and operating system; browser type and version; IP address; session logs and page interaction data; and Zoom session metadata (date, duration — not content).
P3.7 HR and Corporate Program Data. For corporate programs, HR administrators provide employee contact details and organisational information necessary to enrol employees and manage program configurations. Employee assessment data and aggregated engagement data are processed as described in this Policy.
P3.8 Communications Data. If you contact Walnut's support team by email or through the Platform, we retain records of that correspondence.
P4. How We Use Your Personal Data
| Purpose of Processing | Legal Basis (DPDP Act, 2023 / SPDI Rules) |
|---|---|
| Account creation and authentication | Consent at registration; performance of contract with you |
| Generating your personalised Skill Tree and coach recommendations | Consent (express, for Sensitive Personal Data) |
| Matching you to coaches and enabling coach selection | Performance of contract; consent |
| Scheduling, confirming, and delivering coaching sessions via Zoom | Performance of contract |
| Enabling in-app communication between User and Coach | Performance of contract; consent |
| Processing credit purchases and managing your credit balance | Performance of contract |
| Providing the HR analytics dashboard to corporate clients (aggregated data only) | Legitimate interests of the corporate client; consent of the employee at enrollment |
| Improving and maintaining the Platform's features and algorithm | Legitimate interests of Walnut; anonymised/aggregated data used where possible |
| Investigating complaints, abuse reports, or breach of Terms | Compliance with legal obligations; legitimate interests of Walnut |
| Sending service communications (session reminders, invoices, policy updates) | Performance of contract; legal obligation |
| Complying with applicable Indian law and responding to lawful requests from authorities | Compliance with legal obligations |
P5. Sensitive Personal Data
P5.1 Your personality assessment data (OCEAN + DISC + Enneagram results) constitutes Sensitive Personal Data under Rule 3 of the SPDI Rules, 2011, as it includes psychological information.
P5.2 We collect this data only with your free, informed, and specific consent, obtained at the time of assessment. You may withdraw your consent for the use of this data at any time (see Clause P9 for your rights), provided that withdrawal may affect the Platform's ability to provide coach recommendations and Skill Tree personalisation.
P5.3 Sensitive Personal Data is processed only for the purposes described in Clause P4 and is not shared with third parties except as described in Clause P6. It is stored with appropriate security measures as described in Clause P7.
P5.4 Your personality assessment results are shared with your selected coach to enable them to personalise their coaching approach. This sharing is explained to you at the time of assessment and forms part of the coaching service you have contracted for.
P6. How We Share Your Data
P6.1 With Your Coach. Your personality assessment profile, Skill Tree, session history, and in-app assignment data are shared with your selected coach for the purpose of delivering your coaching engagement. Your coach is bound by confidentiality obligations and the ICF Code of Ethics.
P6.2 With Corporate HR Teams (Aggregated Data Only). For corporate programs, aggregated and anonymised engagement data — session completion rates, skill progression metrics, and cohort sentiment trends — is shared with the employer's HR team via the HR analytics dashboard. Individual session content, personal disclosures, and 1:1 session notes are never shared with employers.
P6.3 With Service Providers. We share data with trusted third-party service providers who assist us in operating the Platform, including: payment gateway providers (for credit purchase processing); Zoom (for session delivery — Zoom is subject to its own privacy policy); cloud hosting and infrastructure providers; and analytics and performance monitoring tools. All service providers are contractually bound to process data only as instructed by Walnut and to maintain appropriate security standards.
P6.4 For Legal Compliance. We may disclose personal data where required to do so by applicable Indian law, court order, or lawful request from a government authority. We will, where permitted by law, notify you of such disclosure.
P6.5 Business Transfers. In the event of a merger, acquisition, or sale of Walnut's business or assets, personal data may be transferred to the acquiring entity, subject to equivalent data protection commitments.
P6.6 No Sale of Data. Walnut does not sell, rent, or trade your personal data to third parties for marketing or commercial purposes.
P7. Data Security
P7.1 Walnut implements reasonable security practices and procedures as required under Rule 8 of the SPDI Rules, 2011, including: encryption of data in transit (TLS/SSL); encryption of sensitive data at rest; access controls limiting data access to authorised personnel only; regular security reviews of the Platform's infrastructure; and secure third-party payment processing (Walnut does not store full payment card details).
P7.2 While we implement industry-standard security measures, no method of electronic transmission or storage is 100% secure. In the event of a data breach that is likely to result in a high risk to your rights, we will notify you and the relevant authorities as required by applicable law.
P7.3 You are responsible for maintaining the security of your account credentials. Walnut will never ask for your password by email, phone, or in-app message.
P8. Data Retention
P8.1 We retain your personal data for as long as your account is active and for a reasonable period thereafter to fulfil the purposes described in this Policy, comply with our legal obligations, resolve disputes, and enforce our agreements.
P8.2 The following indicative retention periods apply:
| Data Type | Retention Period |
|---|---|
| Account registration data | 5 years from account closure |
| Personality assessment data (Sensitive Personal Data) | Duration of active account + 1 year post-closure, unless earlier deletion is requested |
| Coaching session records (dates, durations, completion) | 5 years from last session date |
| In-app chat communications | 3 years from the date of each message |
| Payment and credit transaction records | 7 years (as required for tax and financial compliance under Indian law) |
| HR analytics data (aggregated, corporate programs) | Duration of corporate program + 2 years |
| Technical and usage data | 12 months on a rolling basis |
P9. Your Rights
P9.1 Under the Digital Personal Data Protection Act, 2023, and applicable Indian law, you have the following rights in respect of your personal data:
- Right of Access: You may request a copy of the personal data Walnut holds about you.
- Right to Correction: You may request correction of inaccurate or incomplete personal data.
- Right to Erasure: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations.
- Right to Withdraw Consent: Where processing is based on your consent (including for Sensitive Personal Data), you may withdraw consent at any time. Withdrawal does not affect the lawfulness of processing before withdrawal. Withdrawal of consent for assessment data may limit Platform functionality.
- Right to Grievance Redressal: You may lodge a complaint with Walnut's Grievance Officer (see Clause P2) or with the Data Protection Board of India, once established under the DPDP Act, 2023.
- Right to Nominate: You may nominate another individual to exercise these rights on your behalf in the event of your death or incapacity, in accordance with the DPDP Act, 2023.
P9.2 To exercise any of the above rights, please contact us at info@happinesscoach.com or write to the Grievance Officer at the address in Clause P2. We will respond within 30 days of receiving your request.
P10. Cookies and Tracking Technologies
P10.1 The Platform uses cookies and similar tracking technologies to: maintain your login session; remember your preferences; analyse Platform usage and performance; and improve the Platform's user experience.
P10.2 You may control cookie settings through your browser. Disabling certain cookies may affect the functionality of the Platform.
P10.3 We do not use cookies to track your activity on third-party websites for advertising purposes.
P11. Children's Privacy
P11.1 The Platform is intended for users who are 18 years of age or older. We do not knowingly collect personal data from individuals under the age of 18.
P11.2 If we become aware that we have inadvertently collected personal data from a person under 18, we will take steps to delete that data promptly. If you believe a minor has registered on the Platform, please contact us immediately at info@happinesscoach.com.
P12. Third-Party Services and Links
P12.1 The Platform integrates with Zoom for session delivery. Zoom's privacy practices are governed by Zoom's own Privacy Policy. Walnut is not responsible for Zoom's data processing practices.
P12.2 The Platform may contain links to third-party websites or services. Walnut is not responsible for the privacy practices of those third parties. We encourage you to review the privacy policies of any third-party services you access through the Platform.
P13. Changes to This Privacy Policy
P13.1 Walnut may update this Privacy Policy from time to time. Material changes will be communicated to you by email and/or by prominent notice on the Platform not less than 14 days before they take effect. Your continued use of the Platform after the updated Policy takes effect constitutes your acceptance of the changes.
P13.2 The current version of this Policy is always available at walnut.coach/privacy.
P14. Contact and Complaints
P14.1 For any questions, concerns, or requests relating to this Privacy Policy or your personal data, please contact:
P14.2 If you are not satisfied with our response, you may escalate your complaint to the Data Protection Board of India, once operational under the Digital Personal Data Protection Act, 2023.
Walnut Coach LLP · Vision Co Work, 293 Lane-2, Westend Marg, Near Saket Metro Station Gate No. 02, Saket, New Delhi – 110030 · info@happinesscoach.com · +91 9999585460