Privacy Policy
Last Updated: 01-08-2025
Data Controller Information
Legal Entity: SHIRANOA WELLNESS PRIVATE LIMITED
Trading As: Breathing Journey
Address: 281/1 Sadolxem Poinguinim, Goa 403702, India
Email: energywash.shiran@gmail.com
Phone: +91-9307654530
Introduction
SHIRANOA WELLNESS PRIVATE LIMITED (trading as "Breathing Journey") has created this Privacy Policy to demonstrate our commitment to safeguarding the information you share with us. This Privacy Policy applies to all data collected through our website, services, and communications, including breathwork sessions, health assessments, mindful practices, mentorship, and related activities.
We offer a variety of breathwork, mindful exercises, and wellbeing consultancy services to individuals, professionals, and organizations worldwide. This policy governs all personal data processing activities conducted by us.
Legal Basis for Processing
We process your personal data based on the following legal grounds:
● Consent: Newsletter subscriptions, Google Analytics, marketing communications
● Legitimate Interests: Responding to inquiries, website improvement, service delivery
● Vital Interests: Health assessments for safety purposes during breathwork sessions
● Legal Obligations: Retaining health documentation for legal compliance and safety requirements
Information We Collect
Contact Information
We collect your name, email address, phone number, and messages submitted through our contact forms to respond to your inquiries and provide requested services.
Health Assessment Data
When you complete our health statement form, we collect:
● Personal details (name, email, nationality, ID number, date of birth)
● Health-related information necessary for safe service delivery
● Digital signature for consent verification
Newsletter Subscriptions
If you voluntarily subscribe to our newsletter, we collect your email address and name to send periodic updates about our services and content.
Website Analytics
Through Google Analytics, we automatically collect:
● IP address (anonymized)
● Device and browser information
● Website usage patterns and page interactions
● Geographic location (country/region level)
Communication Data
We may collect communication records from:
● Email correspondence
● Video session recordings (with explicit consent)
● WhatsApp communications (subject to WhatsApp's privacy policy)
How We Use Your Information
Your personal data is used for:
● Service Delivery: Conducting breathwork sessions, health assessments, and consultations
● Communication: Responding to inquiries and providing customer support
● Safety: Ensuring breathwork sessions are appropriate for your health conditions
● Marketing: Sending newsletters and service updates (with consent)
● Legal Compliance: Meeting regulatory and safety requirements
● Website Improvement: Analyzing usage patterns to enhance user experience
Third-Party Services
We use the following third-party services that may process your personal data:
Website and Hosting
● Wix: Website hosting and form processing
● Google Analytics: Website traffic analysis and performance monitoring
Communication Services
● Mailchimp: Newsletter delivery and email marketing
● Zoom, Google Meet, Microsoft Teams: Video session delivery
● WhatsApp: Optional communication channel
These services operate under their own privacy policies and may transfer data internationally. We ensure all third-party processors provide adequate data protection safeguards.
Data Storage and International Transfers
Your data is stored on:
● Google servers (primarily US, with global redundancy)
● Wix hosting infrastructure (global CDN, primary servers in US)
● Mailchimp servers (US-based with global processing)
Some of our service providers process data outside India, including in the United States and European Union.
We ensure all international transfers comply with:
● Standard Contractual Clauses (SCCs)
● Adequacy decisions where applicable
● Other appropriate safeguards as required by law
Data Retention Periods
● Contact inquiries: 2 years after last contact
● Health assessments and session records: 7 years (or as required by local medical/legal requirements)
● Newsletter subscriptions: Until unsubscribed plus 1 year for compliance purposes
● Google Analytics data: 26 months (Google's default retention period)
● Communication records: 3 years for business correspondence
Cookies and Tracking Technologies
Essential Cookies
We use essential cookies for:
● Website functionality and security
● Session management
● User preference storage
Analytics Cookies
Google Analytics uses cookies to:
● Track website performance
● Understand user behavior patterns
● Generate usage statistics
Cookie Consent
We use cookies as described below. You can manage your preferences:
● Essential cookies: Required for website functionality (no consent needed)
● Analytics cookies: Used for Google Analytics (requires your consent)
● Manage cookie preferences: Through your browser settings
● Opt-out of Google Analytics: Using Google's opt-out tools
● Contact us: To discuss cookie-related concerns
Data Security
We implement appropriate technical and organizational measures to protect your
personal data, including:
● Encryption of data in transit and at rest
● Access controls and authentication systems
● Regular security assessments and updates
● Staff training on data protection principles
● Secure backup and recovery procedures
Data Breach Notification
In the event of a personal data breach, we will:
● Notify relevant supervisory authorities within 72 hours (where required)
● Inform affected individuals without undue delay if there's a high risk to their
rights
● Take immediate steps to contain and remedy the breach
● Conduct thorough investigations to prevent future incidents
Your Rights
Under applicable data protection laws, you have the right to:
Access and Portability
● Access: Request copies of personal data we hold about you
● Portability: Receive your data in a structured, commonly used format
Correction and Deletion
● Rectification: Correct inaccurate or incomplete personal data
● Erasure: Request deletion of your personal data ("right to be forgotten")
Processing Control
● Restriction: Limit how we process your personal data
● Objection: Object to processing based on legitimate interests
● Withdraw Consent: Revoke consent for processing at any time Complaints
● Supervisory Authority: Lodge complaints with relevant data protection authorities
● Direct Contact: Raise concerns directly with us
How to Exercise Your Rights
To exercise your data protection rights:
1. Send a request to energywash.shiran@gmail.com
2. Include your full name and contact details used with our services
3. Specify which right(s) you want to exercise
4. We may request identity verification for security purposes
5. We will respond within 30 days as required by law
Important Note: While you can exercise these rights, we may need to retain certain information (such as health statements) for legal protection and safety compliance.
WhatsApp Communications
If you contact us via WhatsApp:
● Communications are subject to WhatsApp's privacy policy
● You share personal/medical information at your own discretion
● We may use WhatsApp for follow-up questions regarding submitted forms
● You acknowledge responsibility for information shared through this channel
● Important: WhatsApp communications may not provide the same level of
data protection as our website. For sensitive health information, we recommend using our secure contact form or email.
Age Restrictions and Minors
● Minimum Age: Services are available to individuals 18+ without parental consent
● Minors: Private sessions for under-18s require prior written parental/guardian approval
● Group Activities: Most group sessions are for adults; exceptions will be clearly stated
● Parental Rights: Parents/guardians can exercise data rights on behalf of minors
Marketing Communications
● Newsletter Consent: Explicit opt-in required for newsletter subscriptions
● Frequency: Approximately monthly updates about services and relevant content
● Unsubscribe: Easy opt-out available in every communication
● No Targeted Advertising: We do not engage in behavioral advertising or tracking pixels
Business Transfers
In the event of a merger, acquisition, or sale of business assets, personal data may be transferred to the new entity.
We will:
● Notify affected individuals in advance
● Ensure the new entity maintains equivalent privacy protections
● Provide options for data deletion if desired
Compliance and Governing Law
This Privacy Policy complies with:
● India: Digital Personal Data Protection Act (DPDP) 2023
● European Union: General Data Protection Regulation (GDPR)
● California: California Consumer Privacy Act (CCPA)
● Other Jurisdictions: Applicable local privacy laws where we provide services
Governing Law: This policy is governed by Indian law, with respect for applicable international privacy regulations.
Supervisory Authorities
If you have concerns about our data processing practices, you may contact:
India:
● Ministry of Electronics and Information Technology (MeitY)
● Data Protection Board of India (when operational)
● Email: privacy@meity.gov.in (for DPDP Act related matters)
European Union (for EU residents):
● Your local Data Protection Authority
● European Data Protection Board (edpb.europa.eu)
United States (California residents):
● California Attorney General's Office
Policy Updates
We may update this Privacy Policy to reflect:
● Changes in our practices or services
● New legal requirements or regulations
● Improvements in data protection measures
Notification: We will post updates on our website and notify subscribers via email for material changes.
Continued use of our services constitutes acceptance of updated terms.
Contact Us
For any privacy-related questions, concerns, or requests:
Email: energywash.shiran@gmail.com
Phone: +91-9307654530
Mail: SHIRANOA WELLNESS PRIVATE LIMITED
281/1 Sadolxem Poinguinim, Goa 403702, India
Response Time: We aim to respond to all privacy-related inquiries within 30 days.
Thank you for trusting us with your information and for being part of our breathing
journey, which includes breathwork, mindful exercises, mindset and wellbeing consultancy, mentorship, and supervision.
SHIRANOA WELLNESS PRIVATE LIMITED
Trading as Breathing Journey
