1. Who We Are

Project Never Give Up (projectnevergiveup.com) is an independent website dedicated to resilience, comeback stories, and emotional support. It is operated by Mohit Goel, an individual based in India, who is the data controller for the personal data described in this policy. The website is not a registered company or legal entity.

If you have any questions about this policy, you can reach us at: projectnevergiveup.com/contact

Privacy contact: contact@projectnevergiveup.com
Postal address: 7/2 Jaidev Park, East Punjabi Bagh, New Delhi, India – 110026

2. What Information We Collect

Information You Give Us

• Name and email address — when you sign up for our free guide or newsletter via our website forms
• Account information — name, email address, and password when you create a Risha account
• Conversation content — messages you send to Risha, our AI Friend, on the website or on WhatsApp, which are stored so you can access your conversation history
• WhatsApp number and messages — if you message Risha on WhatsApp, we receive your WhatsApp number and your messages, whether or not you have an account. If you link the number to your Risha account, those conversations also appear in your account history
• Order and payment information — when you buy from our shop, we receive your name, email address, delivery address and order details. Payment is processed by PayPal, and we do not see or store your card details.
• Risha plan payments — if you buy a paid Risha plan, your payment details are collected and processed by our payment provider, which acts as the Merchant of Record for these orders. We do not see or store your full card details. We keep your plan, subscription status and renewal or cancellation status so we can give you the right access

Information Collected Automatically

• Usage data — pages visited, time spent on site, referring URLs, browser type, and device type, collected via analytics tools
• IP address — used for security purposes and approximate geographic location (country level only)
• Plan and usage data — your plan and the number of messages you have used in the current period, so we can apply the free message limit. For a WhatsApp number without an account, we keep a daily message count against the number
• Cookies — small files stored in your browser to remember your preferences and keep you signed in. See Section 7 for details.

3. How We Use Your Information

• To deliver the free guide or newsletter you signed up for
• To operate your Risha account, store your conversation history, and, if you use WhatsApp, reply to you there and link your number to your account if you ask us to
• To count free messages and to provide and manage paid Risha plans, including renewals and cancellations
• To improve the website and understand how people use it
• To send you occasional emails about new stories, resources, or features (you can unsubscribe at any time)
• To process and deliver shop orders
• To detect and prevent abuse or fraudulent activity

4. Legal Basis for Processing

For visitors from the European Union or UK, we process your data under the following legal bases:

• Consent — for email marketing and newsletters. You can withdraw consent at any time.
• Contract — to provide services you have signed up for, including your Risha account and any paid Risha plan
• Legal obligation — to keep financial and tax records where the law requires it
• Legitimate interests — for website analytics and security, where these do not override your rights

For visitors from India, we process your data in accordance with the Information Technology Act, 2000 and the Digital Personal Data Protection Act, 2023 (DPDP Act).

5. How We Share Your Information

We do not sell your personal data. We share data only with the following service providers, strictly to operate this website:

• Brevo — email marketing and list management (EU-based, GDPR compliant)
• Hostinger — website hosting and data storage
• Anthropic — AI technology powering Risha. Messages sent to Risha are processed by Anthropic’s API. Please refer to Anthropic’s Privacy Policy for details on how they handle API data.
• Payment provider — payments for paid Risha plans. Our payment provider is the authorised reseller and Merchant of Record for these orders: it processes your payment, handles taxes and receipts, and processes refunds. Depending on where you are, the company involved is named at checkout and on your receipt. The provider is responsible for the personal data it collects to do this, as described in its own privacy notice.
• Twilio — the messaging provider that delivers WhatsApp messages between you and Risha, if you use WhatsApp
• WhatsApp (Meta) — the messaging network that carries your WhatsApp messages. Meta and Twilio handle messages under their own terms and privacy policies
• Printful — order fulfilment. Order and shipping details are shared as necessary to fulfil your purchase.
• PayPal — payment for shop orders. PayPal processes your payment under its own terms and privacy policy

We may also disclose your information to our professional advisers (such as accountants and lawyers), and if required by law or to protect the rights and safety of this website and its users.

6. Data Retention

• Email subscribers — your data is retained until you unsubscribe or request deletion
• Risha accounts and conversations — retained while your account is active, including any linked WhatsApp number. You may request deletion at any time by contacting us.
• WhatsApp messages and numbers — on our hosting server we keep your WhatsApp number and your most recent 50 messages with Risha so the conversation can continue; older messages are replaced automatically as new ones arrive. The number and these messages are kept until you ask us to delete them. If your number is linked to a Risha account, the conversation also appears in your account history, which is kept as described above
• Subscription records — retained while your plan is active and afterwards for the period required by applicable law (typically 7 years for financial records under Indian law)
• Analytics data — retained in aggregated, anonymised form
• Order data — retained for the period required by applicable law (typically 7 years for financial records under Indian law)

7. Cookies

We use the following types of cookies:

• Essential cookies — required for the website to function, including keeping you signed in to your Risha account
• Analytics cookies — to understand how visitors use the site (e.g. Google Analytics, if enabled)
• Preference cookies — to remember your settings and dismissals (e.g. popup dismissed)

You can control cookies through your browser settings. Disabling cookies may affect some website functionality.

8. Your Rights

Depending on where you are located, you may have the following rights regarding your personal data:

• Access — request a copy of the data we hold about you
• Correction — ask us to correct inaccurate data
• Deletion — ask us to delete your data (“right to be forgotten”)
• Portability — request your data in a portable format
• Restriction — ask us to limit how we use your data in certain cases
• Objection — object to certain types of processing
• Withdraw consent — unsubscribe from emails at any time using the link in any email we send
• Complaint — complain to your local data protection authority if you believe your data has been mishandled

To exercise any of these rights, please contact us via our contact page. We will respond within 30 days.

9. Data Security

We take reasonable technical and organisational measures to protect your data, including secure HTTPS connections, encrypted password storage, and access controls on our hosting environment. However, no method of transmission over the internet is 100% secure, and we cannot guarantee absolute security.

10. Children’s Privacy

This website is not directed at children under the age of 13. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, please contact us and we will delete it promptly.

11. International Transfers

This website is operated from India. If you are accessing it from the EU, UK, or elsewhere, your data may be transferred to and processed in India or other countries where our service providers operate. We ensure appropriate safeguards are in place for such transfers.

12. Changes to This Policy

We may update this policy from time to time. When we do, we will update the “Last updated” date at the top of this page. We encourage you to review this policy periodically. Continued use of the website after changes constitutes acceptance of the updated policy.

13. Contact

If you have any questions, concerns, or requests regarding this Privacy Policy or your personal data, please reach out via our contact page or at contact@projectnevergiveup.com.