Privacy Policy

1.1. Averitt Technologies Private Limited is a company incorporated under the Companies Act, 2013, bearing Corporate Identification Number (CIN) U74999PB2022PTC056460 and Goods and Services Tax Identification Number (GSTIN) 03AAXCA3855D1ZM, with its registered office at H.No. 298, Ward No. 1, Near Royal Enfield Agency, Main Bazar, Morinda, Rupnagar, Punjab, India, 160055.

1.2. Leap14 is a digital, self-paced, fourteen-day behavioural program intended to help adults reduce and ultimately quit smoking. It is delivered entirely online through a web-based dashboard and associated messaging.

1.3. This policy applies to all personal data we collect from or about you through the Leap14 website, the assessment, the dashboard, our payment and messaging processes, and any related communications, regardless of the device or channel through which you access the service.

1.4. This policy should be read together with our Terms & Conditions and our Cancellation & Refund Policy, which together govern your use of Leap14.

2.1. Contact and identity data. We collect your mobile phone number, which is captured at the result stage of the assessment and which is intended to be verified through a one-time password (OTP) delivered over WhatsApp. Your phone number is the primary identifier through which the program and its reminders are delivered to you. We also collect your email address, which is captured alongside your phone number and used for sign-in, account recovery, purchase confirmations, and other service communications.

2.2. Assessment data. We collect the responses you provide to the questions in the Leap14 assessment. These responses describe your smoking patterns and related behaviour and are used to determine your behavioural profile and to construct your personalised fourteen-day program.

2.3. Program and progress data. We collect data generated as you use the program, including which days you have opened and completed, your use of in-program tools, any optional reviews or ratings you submit, and similar engagement information.

2.4. Technical and usage data. We collect limited technical information such as your device type, browser type, approximate region, and product-usage events that describe how the program is navigated and used.

2.5. Transaction data. When you make a purchase, we collect and retain records of the transaction, including the product purchased, the amount paid, the currency, the date and time, and the payment status. We do not collect, receive, or store your full card numbers, banking credentials, or UPI credentials; these are handled exclusively by our payment processor.

2.6. We collect only the data described above and do not seek to collect any special or sensitive categories of data beyond what is necessary to operate a behavioural quit-smoking program for adults.

3.1. To create, configure, and operate your personalised fourteen-day program based on your assessment responses.

3.2. To deliver the program and its daily reminders, which are intended to be sent to you over WhatsApp across Days 1 to 14 of the program.

3.3. To verify your contact details, including the verification of your phone number through a WhatsApp one-time password.

3.4. To enable you to create an account, sign in, and return to your dashboard, and to maintain the security of that account.

3.5. To process your payments, grant access upon successful payment, issue and redeem gift codes where applicable, and send you purchase-related and account-related communications.

3.6. To provide customer support and to respond to your enquiries, requests, and complaints.

3.7. To understand, maintain, secure, troubleshoot, and improve the service, including through aggregated and anonymised analytics.

3.8. To comply with our legal, regulatory, tax, and accounting obligations, and to establish, exercise, or defend legal claims.

4.1. We process your personal data principally on the basis of the consent that you provide when you sign up for and use Leap14, and which you may withdraw at any time as described in this policy.

4.2. We also process certain data as necessary to perform the service you have requested, to comply with applicable law, and for our legitimate interests in operating, securing, and improving the service, in each case to the extent permitted by the DPDP Act and other applicable law.

5.1. All payments for Leap14 are processed by our third-party payment processor, Razorpay Software Private Limited ("Razorpay").

5.2. When you make a payment, your card, banking, or UPI details are collected and processed directly by Razorpay through its own secure systems and in accordance with its own privacy policy and the applicable card-network and regulatory standards.

5.3. We do not receive or store your full payment-instrument details. We receive only the information necessary to confirm whether a payment succeeded or failed and to maintain our transaction records.

6.1. We do not sell, rent, or trade your personal data to any third party for their own marketing purposes.

6.2. We share your personal data only with the service providers who help us operate Leap14, and only to the extent necessary for them to perform their functions, namely:

• (a) our WhatsApp Business API provider (Interakt and/or AiSensy), which processes your phone number in order to deliver verification messages and program messages;
• (b) Razorpay, which processes your payments as described above;
• (c) PostHog, which provides product analytics describing how the program is used; and
• (d) our hosting, infrastructure, and database providers, which store and serve the application and its data.

6.3. We require each such provider to process your data securely and only for the purposes we specify.

6.4. We may also disclose your personal data where we are required to do so by law, regulation, court order, or other valid legal process, or where we believe in good faith that disclosure is necessary to protect our rights, enforce our terms, prevent fraud or harm, or protect the safety of our users or the public.

6.5. In the event of a merger, acquisition, restructuring, or sale of assets, your personal data may be transferred as part of that transaction, subject to the continued protection of this policy.

7.1. Your individual assessment answers are used solely to construct and operate your personal program.

7.2. Your individual assessment answers are not shared with our analytics providers. Our analytics tools receive only anonymised usage events, such as which day of the program was opened, and never your individual smoking-related responses.

8.1. Subject to applicable law, you have the right to request access to the personal data we hold about you, to request correction of inaccurate or incomplete data, to request erasure of your data, to withdraw any consent you have given, and to request that we stop sending you WhatsApp messages.

8.2. You may exercise these rights by emailing us at hello@leap14.com. WhatsApp messages we send will also contain a one-tap option to opt out of further messages.

8.3. We may need to verify your identity before acting on a request. We will respond to your request within a reasonable period as required under the DPDP Act.

8.4. Please note that certain data may need to be retained even after a request for erasure, where we are legally required or permitted to retain it, for example for tax, accounting, or dispute-resolution purposes.

9.1. We retain your account and program data for the duration of your access period, which is one year from the grant of access.

9.2. After your access period ends, we retain your personal data only for as long as is necessary to satisfy our legal, tax, accounting, and dispute-resolution obligations, after which we delete it or irreversibly anonymise it.

10.1. We implement reasonable technical, administrative, and organisational measures designed to protect your personal data against unauthorised access, use, alteration, disclosure, loss, or destruction.

10.2. Despite these measures, no method of transmission over the internet or method of electronic storage is completely secure, and we therefore cannot guarantee the absolute security of your data. You are responsible for keeping your account credentials confidential.

11.1. Leap14 is intended exclusively for adults aged eighteen years and older.

11.2. We do not knowingly collect personal data from any person under the age of eighteen. If we become aware that we have inadvertently collected such data, we will take steps to delete it promptly.

12.1. We and our analytics provider (PostHog) may use cookies and similar technologies to operate the service and to understand how the program is used.

12.2. You can control or disable cookies through your browser settings. Disabling certain cookies may affect the functioning of parts of the service.

13.1. If you have any questions, requests, or complaints regarding your personal data or this policy, you may contact us at hello@leap14.com.

13.2. We will acknowledge and address grievances within a reasonable time and in the manner required under the DPDP Act and applicable rules.

14.1. We may update this Privacy Policy from time to time to reflect changes in our practices, the service, or the law.

14.2. Where changes are material, we will indicate this on this page together with a revised "last updated" date. Your continued use of Leap14 after any such change constitutes your acceptance of the updated policy.