Privacy Policy — Navaniit Creation

Last updated: 2018-10-20

1. Who we are

Navaniit Creation is a numerology + spiritual guidance reflection service operated by Dr. Navaniit Mandhaani. We are based in India and our service is offered first to Indian users, with global expansion later. This Privacy Policy describes how we handle your personal data under India's Digital Personal Data Protection Act, 2023 (DPDPA).

2. What we collect

For your premium reflection report, we collect:

  • Name — used to compute the Chaldean numerology values from your letters.
  • Date of birth — used to compute Moolank, Bhagyank, Lo Shu Grid, Kua, Personal Year, and Sun Signs.
  • Gender — used to apply gender-specific Kua and remedy rules from the lineage methodology.
  • Language preference — English or Hindi.
  • Email address — collected at account creation (sign-in identity), not on the reflection form. Generating a reflection requires you to be signed in; we associate your saved reflections with your account.
  • IP address — used for rate-limiting and grievance traceability. We do not store the raw IP; we store only a HMAC-SHA256 hash.
  • Consent record — timestamp + HMAC hashes of your IP, the consent copy you agreed to, the privacy policy version, your browser user-agent string. NO raw name.
  • Saved Ramal readings (Ramal Consultation Tool, subscribers only) — when you cast a reading, we save it to your account automatically so your history survives a reinstall or a second device. What is saved is the cast itself (the sixteen dice values and the method), the client name you entered if any, and — where you asked a question — its house, its direction, and the question in your own words. The verdict, the timing and the answering figure are NOT saved; they are recomputed from the saved cast each time you open the reading, so later corrections to the method reach your history. The field that collects the question tells you it is saved.
  • Optional voice input (Ramal Consultation Tool) — if you tap the microphone button, your spoken question is transcribed in your browser via the Web Speech API. On Chrome / Edge the audio is sent to Google for transcription; on Safari it is sent to Apple. We never receive your raw audio — only the resulting text, which is then sanitised and processed the same way as a typed question. You can use the tool without voice; typing is always available.

3. How we use it

  • To generate your premium reflection report.
  • To enforce the abuse-prevention rate limits that cap how many reports may be generated from one connection in a given period.
  • To respond to grievances and erasure requests under DPDPA §12 and §17.
  • To meet our compliance obligations.

Because generating a reflection requires you to be signed in, it relies on the consent you gave when you created your account (the cross-border transfer, retention, and generation purposes in the sign-up consent). You can withdraw that consent at any time via the Grievance Officer (section 7).

We do NOT use your data for advertising, profiling, fine-tuning AI models, or sharing with third parties beyond what is described in section 4.

4. Who we share it with

To generate your reflection, your name + date of birth + gender + language preference are sent to Anthropic, PBC in the United States, our AI provider. This is a cross-border transfer.

  • Anthropic operates under their published Commercial-tier terms, which contractually exclude your data from model training ("no-training tier").
  • Anthropic retains your data for up to 30 days under their default retention policy, after which it is deleted.
  • We have a signed Data Processing Agreement (DPA) with Anthropic. A copy is held on file at .claude/memory/legal/anthropic-dpa-signed.pdf and can be requested through the Grievance Officer.

We do NOT share your data with any other third party. We do NOT sell your data. We do NOT use your data to train any AI model, including our own.

5. How long we keep it

  • The share link for a freshly generated reflection: maximum 1 hour. While a reflection is being generated and for one hour afterwards, a copy sits in a temporary cache (Vercel KV) keyed by an unguessable link. After 1 hour that cache entry expires and is deleted automatically. This is a delivery buffer, not the record — the record is the account copy below.
  • Your saved reflections: generating a reflection requires you to be signed in, so a copy — your name, date of birth, the computed numerology data, and the reflection content — is stored durably against your account so you can revisit it under "My Reflections". This account-linked data is protected by row-level security so only you can read it. To have it deleted, contact our Grievance Officer (see sections 6 and 7); we process erasure requests manually.
  • Your saved Ramal readings: kept for 2 years from the date of the reading, then deleted. They are protected by row-level security so only you can read them, and they are erased along with your account: deleting your account deletes every saved reading, including the question text, in the same operation.
  • Consent audit log: indefinitely, as a HMAC-hashed record (no raw PII). This is retained for DPDPA grievance defense. You may request erasure of the linkable hash via our Grievance Officer.
  • IP-hash for rate limiting: until UTC midnight on the day of the request (typically <24 hours).
  • UPI transaction reference (UTR) and tax invoice records: retained for 8 years as required by GST Rules 56 and RBI Master Direction on Digital Payments §6. After the retention window, UTRs are HMAC-hashed and the linkable record is deleted; the hash remains for compliance defence only. UTR values are excluded from application logs by our log redactor.
  • Anthropic-side: up to 30 days, then deleted (their policy).

6. Your rights under DPDPA

You have the right to:

  • Access — request a copy of the data we hold about you.
  • Correction — request correction of inaccurate data.
  • Erasure (DPDPA §12) — request deletion of your data. Your saved reflections (name, date of birth, numerology data, and reflection content stored against your account) and your saved Ramal readings (including the question in your own words) are deleted on request: contact the Grievance Officer (see section 7) and we process the erasure manually within the timeline in section 7. For our consent and rate-limit logs we store only HMAC hashes (no raw PII), so erasure there means we redact your hash. Anthropic's 30-day retention on their side decays independently.
  • Grievance redressal (DPDPA §17) — file a grievance through the Grievance Officer (see section 7).
  • Withdraw consent — at any time, by contacting the Grievance Officer.

To exercise any of these rights, use the Grievance page and select the appropriate category.

7. Grievance Officer

Name: Dr. Navaniit Mandhaani Role: Phase 1 Grievance Officer (per DPDPA §17) Contact: Through the Grievance page (preferred) or by email to the address listed there.

We aim to acknowledge your grievance within 7 days and resolve it within 30 days.

8. Cookies and local storage

We use:

  • A language preference cookie (lang=en|hi) — first-party, 30-day, non-tracking.
  • A consent-variant cookie (cb-variant=a|b) — first-party, 30-day, non-tracking. A/B-testing on consent-block layout only.
  • An authentication session cookie (__Host-navaniit_session, plus a _data companion) — first-party, HTTP-only, Secure, SameSite=Strict, 30-day maximum lifetime. Set when you sign in and required for every signed-in page; it identifies your session so we can show you your own reflections and readings, and it carries no name, date of birth or reading content. Signing out clears it. It is strictly necessary for the service and is not used for tracking or advertising.

We do NOT use third-party tracking cookies. We do NOT use Google Analytics. We do NOT use Meta Pixel.

9. Security

  • All data in transit is encrypted (HTTPS/TLS).
  • API keys and secrets are stored encrypted and flagged Sensitive at our hosting provider (Vercel), never in our source code, and are rotated on a documented internal schedule that sets a separate interval for each secret. The runbook is an internal operations document rather than a published page; you may request a summary of it through the Grievance Officer.
  • All HMAC hashing uses a server-side pepper (AUDIT_LOG_PEPPER) that is never exposed client-side.
  • We do NOT log raw names, dates of birth, phone numbers, or generated report content. Our log redactor runs on every log line.

10. Children

Our service is for users 18 years of age or older. We do not knowingly collect data from minors. The form has an explicit age-attestation checkbox. If you believe a minor has used our service, please contact the Grievance Officer.

11. Changes to this policy

If we make a material change to this policy, we will update the version number and the "Last updated" date at the top, and post a notice on the home page for 30 days.

12. Contact

For any privacy concern, use the Grievance page.