Policies

Effective from: 2026-09-03 · Last updated: 2026-09-03
These policies supersede the policies dated 30 May 2025 in their entirety.

These policies form part of, and are to be read with, the Terms and Conditions.

Privacy Policy
Refund and Cancellation Policy
Delivery Policy
Pricing
Contact

Privacy Policy

This Privacy Policy is issued by Clanflare Solutions Private Limited and constitutes the notice required to be given to a Data Principal under Section 5 of the Digital Personal Data Protection Act, 2023 and Rule 3 of the Digital Personal Data Protection Rules, 2025. It is written in clear and plain language, as those provisions require.

1 · Who we are, and what this policy covers

Clanflare Solutions Private Limited — Corporate Identity Number U62099HR2024PTC125644, registered office at Plot No. 14, Village Saroorpur, Industrial Area, Faridabad, Haryana — 121004, India.

This policy applies to the Clanflare checkout and to every community application operated by Clanflare (each, an “Application”). Each Application carries the brand and content of a creator (the “Creator”). Clanflare sells access to you as merchant of record; the Creator supplies the content.

If any part of this policy is unclear to you, please contact us under Section 12.

2 · Who is responsible for which data

The Act designates the person who determines the purpose and means of processing as the Data Fiduciary. In respect of an Application that responsibility is divided as set out below. The division is substantive and not a matter of form.

Category of data	Examples	Data Fiduciary
Registration and authentication	Mobile number, OTP logs, display name, optional photograph, record of age affirmation	Clanflare
Payment and settlement	Transaction records, access status, purchase history, invoices	Clanflare
Security and reliability	Crash and error monitoring, access logs, backup records	Clanflare
Support	Support tickets and correspondence	Clanflare
Learning and engagement	Onboarding answers, task completion, streak history, course progress	The Creator. Clanflare processes such data on the Creator’s instructions
User-generated content	Discussion posts, replies, voice notes, live-session chat, practice recordings, notes	The Creator. Clanflare processes such data on the Creator’s instructions
Declared attributes	Gender, where declared in order to use a restricted room	The Creator. Clanflare processes such data on the Creator’s instructions
Moderation records	Reports, actions taken, warnings, suspensions, action log	The Creator. Clanflare processes such data on the Creator’s instructions
Voice-room audio	—	None. Such audio is never recorded or stored, and accordingly no data exists

Whichever side of that division your question falls upon, please address it to us in the first instance. We will answer it or route it, and we will not refer you elsewhere.

3 · What we collect, why, and on what basis

We collect only such personal data as an Application requires in order to function. The following is the itemised description required by Rule 3 of the Digital Personal Data Protection Rules, 2025.

The Act permits processing on the basis of your consent under Section 6, or for a certain legitimate use enumerated in Section 7. It does not contain a general “legitimate interests” ground. The basis stated below is accordingly either your consent or a specified provision of Section 7.

Personal data	Purpose	Basis
Mobile number and OTP	To create your account and to authenticate you. We do not offer social login	Consent (Section 6)
Display name and optional photograph	So that other members may recognise you. Members see one another by display name and optional photograph only	Consent (Section 6)
Age affirmation	The Applications are for persons aged 18 and above. We record your declaration together with its date, time and device particulars	Compliance with law (Section 7(c)), read with Section 9 of the Act
Onboarding answers, task completion, streaks and course progress	To operate the daily practice and to display your own history to you	Consent (Section 6), on the Creator’s behalf
Content you post — discussions, replies, voice notes, session chat	To deliver it to the members entitled to receive it	Consent (Section 6), on the Creator’s behalf
Practice recordings, where an Application offers a record-and-compare feature	So that you may play your own recording against the reference audio. No score is produced and no person grades it	Consent (Section 6), on the Creator’s behalf
Declared gender, where you provide it	Solely to operate a restricted room or filter which you have chosen to use. It is not disclosed to any other member	Consent (Section 6)
Payment and transaction records	To take payment, to issue your tax invoice, to manage renewals and to effect refunds	Consent (Section 6); retention on the basis of compliance with law (Section 7(c)) under the tax and company legislation
Support correspondence	To answer you	Consent (Section 6)
Device, crash and error data	To keep the Application operational and to diagnose and correct faults	Consent (Section 6)
Usage analytics	To understand which features are used — see Section 4	Consent (Section 6)

We do not collect or store your card number, your bank credentials or your UPI PIN. Payments are processed by Razorpay, as set out in Section 6.

4 · What our analytics do not contain

The following is a limitation in the construction of the software, and not merely an undertaking of restraint.

Analytics events carry a pseudonymous account identifier only. They do not carry:

(a) your telephone number, your name, or any free text entered by you;
(b) any voice audio, or any transcript of it;
(c) the content of any typed answer, post or comment; or
(d) any assessment or scoring of you as a person.

We do not profile or score you, and we do not use analytics as a criterion of moderation.

5 · Voice rooms are not recorded

Where an Application offers live voice rooms, the audio is not recorded or stored at any point or in any circumstance. There is no archive and no file.

The consequence, stated plainly, is that where something is said in a voice room, no recording exists which we or any other person can retrieve and review — including for the purpose of investigating a report. Please report any incident while it is occurring or immediately afterwards.

Practice recordings which you make yourself within a task are different. They are stored, they are yours, and they are deleted in accordance with Section 9.

6 · Disclosure of your data

We do not sell your personal data. We have never done so and we will not do so.

We engage the following categories of service provider, each bound by obligations no less onerous than our own, and each processing only such data as is necessary:

Category of provider	Function
Razorpay	Processes your payment. Your card, bank and UPI credentials are furnished to Razorpay and not to us
Cloud, database and storage providers	Host the Application
Voice-room and streaming providers	Carry live audio and live sessions
SMS and messaging providers	Deliver your OTP and service notices
Crash and error monitoring providers	Notify us of faults

Lawful requests. We disclose data where a court, a regulator or a law enforcement agency lawfully requires it, where it is necessary in order to establish, exercise or defend a legal claim, or where it is necessary in order to protect the safety of any person.

Corporate transactions. Where our business is transferred, data may be transferred with it, subject to this policy.

We disclose your data to no other person.

7 · Disclosure to the Creator — a separate and optional consent

This consent is sought separately. You may decline it and use every part of the Application.

Creators frequently wish to reach their own community directly. We will not disclose your data to a Creator unless you have specifically consented to it.

How the consent operates

(a) At account creation you are shown this disclosure and asked to give or to decline consent, separately from anything required in order to use the Application.
(b) If you decline, you may nevertheless register and use the Application in full. Nothing is withheld, nothing is degraded, and no person may represent otherwise to you or offer you any inducement to consent.
(c) You may withdraw your consent at any time from a setting within the Application. Withdrawal operates prospectively and does not affect your account, your access or anything you have purchased.
(d) Upon withdrawal we cease to include you in any further disclosure and notify the Creator, who is thereupon required to cease processing your data and to delete it, save such data as the law requires the Creator to retain.

What is disclosed if you consent

Your name, registered telephone number, account and access status, purchase and entitlement history, onboarding answers, and your learning progress and streak history, together with the content you have generated within that community.

What is not disclosed, whether or not you consent

(a) Voice-room audio, which does not exist;
(b) any data concerning any other Application or the community of any other Creator; and
(c) anything belonging to the Clanflare platform rather than to you.

The effect of consenting

Upon disclosure, the Creator becomes an independent Data Fiduciary in respect of the copy received. From that point the Creator, and not Clanflare, determines the purpose and means of its use, and may use it for the Creator’s own community management, service delivery and marketing. Your rights of access, correction, erasure and grievance in respect of that copy lie against the Creator, and Clanflare ceases to be responsible for it. The Creator is required to protect it to the same standard, to honour every withdrawal, correction and erasure request made by you to the Creator, and not to sell or further disclose it.

Identity of the Creator

The Creator of each Application is identified on the listing of that Application, in the consent screen presented to you at account creation, in your order confirmation and on your tax invoice. Where you consent to disclosure, the registered name and contact particulars of that Creator are shown to you before your consent is taken.

Any request concerning data held by a Creator may be addressed to us at support@clanflare.com and we will route it and pursue it on your behalf.

8 · Where your data is held

All personal data is stored and processed upon infrastructure situate in India. We do not transfer it outside India save where the law permits and the requisite consents are in place.

9 · Retention

Category of data	Retention period
Voice-room audio	Never recorded. There is nothing to retain
Practice recordings	For so long as the compare feature requires. Deleted upon your deletion of the recording or of your account, and in any event within ninety (90) days of being made
Your account and its content	For so long as your account subsists
Following deletion of your account	Deleted or anonymised within thirty (30) days, save as set out below
Invoices and transaction records	For so long as the tax and company legislation requires, irrespective of account deletion
Backups	Routine backups are cycled out within thirty (30) days, being the same period as applies to account deletion
Moderation and safety records	For so long as is necessary for safety and for any pending or reasonably foreseeable proceeding

Any data which we are required by law to retain remains protected by this policy for so long as we hold it.

10 · Security safeguards

We maintain reasonable security safeguards in accordance with Rule 6 of the Digital Personal Data Protection Rules, 2025, comprising:

(a) encryption of personal data in transit and at rest;
(b) access control, access being confined to personnel who require it, each bound by obligations of confidentiality;
(c) logging and monitoring, and regular backups with tested recovery.

No system is perfectly secure and we make no claim to the contrary. In the event of a personal data breach we shall notify the affected users and the Data Protection Board of India in the manner and within the periods prescribed by the Act and the Rules, stating in plain language what has occurred, what it affects and what you should do.

11 · Your rights

Under the Digital Personal Data Protection Act, 2023 you are entitled:

(a) to obtain a summary of the personal data we hold concerning you and of the processing undertaken;
(b) to have it corrected, completed or updated;
(c) to have it erased, save where we are required to retain it;
(d) to withdraw your consent at any time, including the consent to disclosure to the Creator under Section 7, with the ease of doing so being comparable to that with which the consent was given;
(e) to nominate another person to exercise your rights on your behalf in the event of your death or incapacity; and
(f) to have your grievance redressed by us, under Section 12, before approaching any other forum.

Manner of exercise. Write to support@clanflare.com from your registered email address, or use You → Help within the Application. We respond within fifteen (15) days.

Deletion of your account is self-service. Within the Application: Home → Profile (navigation bar) → scroll to the foot of the page → Delete account → confirm and complete the short feedback form → Delete. You may also delete your account from the web, without recourse to the Application, at the account-deletion page of your Application, which is linked from its listing and from within the Application.

Communications. Transactional messages — OTPs, confirmations of purchase, renewal and cancellation, and service and safety notices — are sent by SMS, email, WhatsApp or in-app notification, whether or not you are registered upon the National Do Not Call registry, being necessary to the service. Promotional messages are separate, require their own consent, and may be declined at any time without affecting anything else.

12 · Grievances and contact

Step 1 — Support. support@clanflare.com · +91 94227 99646

Step 2 — Grievance Officer. The following officer is appointed under the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021 and under the Consumer Protection (E-Commerce) Rules, 2020, and is our contact for the purposes of data protection:

Sidhant Shahi, Director and Grievance Officer
support@clanflare.com, marked GRIEVANCE in the subject line
+91 94227 99646
Clanflare Solutions Private Limited, Plot No. 14, Village Saroorpur, Industrial Area, Faridabad, Haryana — 121004, India
Monday to Friday, 10:00–19:00 IST, excluding gazetted holidays in Haryana

We acknowledge every grievance within twenty-four (24) hours and dispose of it, with reasons, within fifteen (15) days.

Step 3 — Appeal. You may prefer an appeal to a Grievance Appellate Committee constituted under Rule 3A of the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021, at gac.gov.in, within thirty (30) days. You may additionally complain to the Data Protection Board of India in respect of the handling of your personal data.

13 · Children

The Applications are for adults aged 18 years and above. We do not knowingly collect the personal data of a child, and we do not track, behaviourally monitor or profile any child, nor direct advertising at any child. Where we become aware that an account is held by a person under 18 years of age, we close the account, delete the data, and refund in full the consideration paid in respect of the then-current billing period.

14 · Amendment

We may amend this policy. Material amendments are notified in-app and to your registered contact before they take effect. The “Last updated” date above identifies the subsisting version, and any previous version will be furnished upon request.

Refund and Cancellation Policy

Refunds are determined and effected by Clanflare. No Creator determines or effects any refund. As merchant of record that responsibility rests with Clanflare alone, and you are not required to approach any Creator in respect of your money.

1 · Cancellation

(a) You may cancel at any time, from within the Application, from your account on the checkout, or by written notice to support@clanflare.com. The steps required to cancel are no more numerous than those required to subscribe.
(b) Cancellation takes effect at the expiry of the period in respect of which consideration has already been paid, and you retain access until that date.
(c) We confirm your cancellation in writing within twenty-four (24) hours and notify you of the date upon which your access ends.
(d) No cancellation fee, exit fee or penalty is levied.
(e) Cancellation with us does not of itself cancel a bank e-mandate, and cancellation of an e-mandate does not of itself cancel your subscription. Where you require both to be terminated, you must effect both. Where any amount is debited after cancellation, we refund it in full.
(f) Where the purchase was made through the Apple App Store or Google Play, cancellation must be effected through that store and cannot be effected by us.

2 · The general position

App Access and Courses are digital services in respect of which there is nothing to ship, access being granted within twenty-four (24) hours of payment as set out in the Delivery Policy. Accordingly, once a billing period has commenced and access has been made available, that period is not refundable merely by reason of a change of mind or of your ceasing to use it.

3 · Circumstances in which we refund in full

(a) you were charged twice in respect of the same period;
(b) you paid and access was not made available within twenty-four (24) hours, and we were unable to remedy the position within seventy-two (72) hours of your notifying us;
(c) you were charged after cancellation;
(d) the amount charged exceeds the price you confirmed at checkout;
(e) a payment was effected from your instrument without your authority, and that is established;
(f) an Application was withdrawn or discontinued mid-period;
(g) your account is closed by reason of the holder being under 18 years of age; or
(h) the law so requires.

4 · Circumstances in which we refund proportionately

Where we permanently discontinue an Application, or where we suspend your access otherwise than by reason of your breach, we refund the unexpired portion of your paid period.

5 · Circumstances in which we do not refund

(a) a period which you have used and no longer require;
(b) termination of your account by reason of your breach of the Terms or of the Community Guidelines;
(c) a Course which you have opened and consumed, where it conforms to its description; or
(d) anything purchased from a third-party retailer, physical books and similar articles not being sold by us (see the Delivery Policy).

6 · Manner of making a request

Write to support@clanflare.com from your registered email address, or from within the Application, stating your registered mobile number and the invoice number or transaction reference.

7 · Timelines

Step	Period
We acknowledge your request	Twenty-four (24) hours
We determine it and communicate the reasons	Within seven (7) working days of the request
We initiate an approved refund	Within two (2) working days of the determination
The sum reaches your original payment method	Ordinarily five to seven (5–7) working days after initiation, depending upon your bank

Refunds are made to the original payment method. We do not substitute credit, vouchers or in-app currency for a refund to which you are entitled, and we levy no processing fee in respect of the return of your money.

8 · Purchases through app marketplaces

Refunds in respect of purchases made through the Apple App Store or Google Play are governed by the policy of that store and are determined by that store. We shall assist you in making the request but are not able to overrule them. Where a store declines a request and you consider yourself entitled, please notify us.

9 · If you dispute our determination

You may escalate the matter to the Grievance Officer (Privacy Policy, Section 12). Nothing in this policy affects your rights under the Consumer Protection Act, 2019, including your right to complain to the Consumer Disputes Redressal Commission within the local limits of whose jurisdiction you reside.

Delivery Policy

Everything sold by Clanflare is digital and is delivered immediately.

(a) App Access is activated upon your account as soon as your payment succeeds — ordinarily within minutes, and in any event within twenty-four (24) hours of a successful payment. There is nothing to ship.
(b) Courses, where offered, are unlocked upon the same basis.
(c) Your access operates across your devices upon the same account, and across Sales Channels. Restoration of purchases is supported.
(d) Your tax invoice is transmitted to you by email and retained in your account.
(e) Where access does not appear, please notify us at support@clanflare.com or +91 94227 99646. Where we are unable to deliver it, we refund you in full — see the Refund and Cancellation Policy.

We do not sell or ship physical goods. Where an Application directs you to a book or other physical article, you leave the Application and contract with that retailer, on the retailer’s terms and at the retailer’s price. Delivery, returns and refunds in respect of such articles are the responsibility of the retailer and not of Clanflare.

Service area: India.

Pricing

(a) The price displayed at checkout is the total amount payable by you and is inclusive of GST, presently 18%. The break-up — base amount, any channel uplift, and GST — is displayed before you confirm. No amount is added thereafter.
(b) All prices are in Indian Rupees (INR).
(c) A tax invoice in the name of Clanflare, setting out our GSTIN, is issued in respect of every purchase.
(d) The same offering may cost more upon an app marketplace than upon the Clanflare web checkout. The marketplace operators levy a commission upon purchases processed through their billing systems, which is reflected in the price shown, and marketplace price tiers being fixed, the displayed price is set at the nearest available tier. The break-up applicable to your purchase is shown at checkout before you confirm.
(e) Prices are liable to variation, but never in respect of a period already paid for, and not without not less than fifteen (15) days’ notice and an opportunity to cancel beforehand.
(f) Current prices are displayed upon the listing of each Application and at checkout.

Contact

Clanflare Solutions Private Limited
Plot No. 14, Village Saroorpur, Industrial Area,
Faridabad, Haryana — 121004, India

Email: support@clanflare.com
Telephone: +91 94227 99646
Hours: Monday to Friday, 10:00–19:00 IST, excluding gazetted holidays in Haryana

Grievance Officer and data protection contact: Sidhant Shahi, Director — support@clanflare.com, marked GRIEVANCE in the subject line

CIN U62099HR2024PTC125644 · GSTIN 06AAMCC1915F1ZW