With effect from 12th September, 2023
1. Information Collection
- The Company collects information from you on the Register/Log-in page of the Platform. In the sign up page, you are required to give your personally identifiable contact information (such as name, mobile number and email ID etc.). A verification process is used to confirm your identity through the contact information that you provide. When the Platform requests your identity, the Platform will clearly indicate the purpose of the inquiry before the information is requested.
- Once a registered participant, you have the option of providing additional personally identifiable, health and other information including but not limited to age, height, weight, occupation, name of your doctor, hospital or other healthcare provider, location, data relating to your diet, activity levels, exercise, medical reports (if any), medical history, mobile number, email ID, name of a primary caregiver, contact details of the primary caregiver and other personal information to avail of the Services provided through the Platform. Providing additional information beyond what is required at registration is entirely optional and can be altered or removed by you at any time. We assume that any information provided by you relating to a primary caregiver has been provided after obtaining due consent of such primary caregiver.
- Every computer/mobile device connected to the Internet is given a domain name and a set of numbers that serve as that computer’s Internet Protocol or “IP” address. When you request a page from any page within the Company platform, our web servers automatically recognize your domain name and IP address. The domain name and IP address reveal nothing personal about you other than the IP address from which you have accessed the Platform.
2. Children’s And Minor’s Privacy
The Company strongly encourages parents and guardians to supervise the online activities of their minor children and consider using parental control tools available from online services and software manufacturers to help provide a child-friendly online environment. These tools also can prevent minors from disclosing their name, address, and other personally identifiable information online without parental permission. Although the Platform is not intended for use by minors, the Company respects the privacy of minors who may inadvertently use the internet or the Platform.
3. Data Retention
4. Opt Out Procedures
Upon initial communication from the Company, you may opt-out of receiving further communications from the Company. To be completely removed from the Company subscription list, you may contact us at email@example.com. If you are using an e-mail forwarding service or other similar service please make sure to include the correct e-mail address or addresses.
5. Company as a Pass-Through Facilitator
Please note however, that in respect of any information received by the Company under certain specific patient support program: (a) the Company shall retain identified data for a period of 5 (Five) years from the date of termination of such agreement, for performance of its contractual obligations, audits, diligence thereunder; and (b) the Company shall thereafter be permitted to retain only de-identified data for such period of time as may be necessary. The de-identified data at any point of time will be used for the purpose of compliance with applicable law, carrying on its contractual obligations, for carrying on audits and for improvement of its technology and strengthening its AI engine. All personal identification data will be deleted after a period of 5 years from the date of termination of agreement. However, the Company may retain additional time point data related to you if there is a legal obligation to retain the data, if required to comply with any statutory or regulatory retention requirement by law.
6. Use Of The Information Collected
1 Use Of The Information For Services
- Identify and reach you;
- Resolve technical issues of access to the Platform via telephone or email;
- Provide you with further information, products and services;
- Better understand users’ needs and interests;
- Personalize your experience and customizing experience;
- Diagnosing and assisting you in your clinical, health and general wellbeing progress;
- Run statistical research and undertake scientific publications
- Improving the product and services offered to current and future users and partners by improving parts of the Platform, including but not limited to the algorithms, logic systems, content, decision support, engineering, artificial intelligence;
- Providing access to your information to healthcare practitioners and partners;
- Providing data to clients or partners under the terms of agreement with them;
- Providing access to your “User Profile” to other users of the Platform, Company administrators, Company moderators, Health Coaches and Primary Caregivers;
- For carrying on audits, due diligence for effecting investments in the company
- Detect and protect us against error, fraud, and other criminal activity;
- Make disclosures as may be required under applicable law.
- Improve our Platform in order to better serve the user;
- Allow us to better service the user in responding to customer service requests;
- Administer a contest, promotion, survey or other site feature; and
- Provide access to other users as part of a social feed, in order to provide motivation or assistance to such other users
2. Disclosure to primary caregiver
- Information collected from you may be transferred to your primary caregiver (as identified by you), as part of the Services.
- The Company may, at its sole discretion, be entitled to contact the primary caregiver (as identified by you) at scheduled intervals and at unscheduled times and provide any information relating to you, as may be deemed beneficial or essential by the Company. The Company shall periodically update the primary caregiver relating to your health and progress based on the statistics available in the Platform, and any other relevant information that the Company believes is relevant to improve your health, clinical and general wellbeing outcomes. The Company may also reach out to the primary caregivers at unscheduled times upon occurrence of an Adverse Event, emergency event, or if you have not engaged with the Platform or your Health Coach for a long duration.
3. Sale of Assets, Merger, Acquisition
The Company may share your information, including your information with our parents, subsidiaries and affiliates for internal purposes. The Company also reserves the right to disclose and transfer all such information: (i) to a subsequent owner, co-owner or operator of the Platform, Website or applicable database; or (ii) in connection with a corporate merger, consolidation, restructuring, the sale of substantially all of our membership interests and/or assets or other corporate change, including, during the course of any due diligence process. You will be notified via email and/or a prominent notice on our Platform and/ or Website of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.
5. Ownership of work products
6. Non-disclosure of Information
- The Company may disclose your personal information in the event it is required to do so by law, rule, regulation, law, enforcement, governmental official, legal or regulatory authorities and, or, to such other statutory bodies who have appropriate authorisation to access the same for any specific legal purposes;
- The Company may disclose your information to such third parties to whom it transfers its rights and duties under any agreement entered into with such third parties; and
- The Company may disclose your information to any of its affiliates or related entity.
7. Sharing Of Information
The Company may share aggregated personal information with the Company’s partners / clients as per the terms of any agreement with such partner / client. The data shared may be on an identified or deidentified basis, based on the terms agreed by the Company with such partner / client. Information available with the Company may be shared by the Company even after completion of the Services. The Company shall not be liable for the transfer of any personal identification information resulting from loss or distribution of data, the delineation or corruption of storage media, power failures, natural phenomena, riots, acts of vandalism, sabotage, terrorism or any other event beyond the Company’s control.
2. Consulting and Sub-Contracting
The Company may sub-contract all or part of the Services to a third party sub-contractor, partner with another party to provide specific services. When you sign up for these services, the Company will share names, or other contact information that is necessary for the third party to provide these services. Per the Company’s contractual arrangements with parties, these parties are not allowed to use personally identifiable information except for the explicit purpose of providing these services.
The Company maintains a strict “No-Spam” policy, which means that the Company does not intend to sell, rent or otherwise give your e-mail address to a third party without your consent.
10. The Company Forums
When you interact with our Platform or avail the Services, your comments, your name, your mobile number and IP address may be recorded for purposes of maintaining your own account within the Platform. This information is not used to personally identify you outside the Company Platform and Services. In order to diffuse the information in the Company forum to a wider audience, the Company may, from time to time, collect some of your comments to use in a specific publication, print, electronic mailing or other public dissemination. At no point however will your name, your mobile number or IP address be revealed without your consent. In addition, when your comments are used in this fashion, they may be edited to fit with the general content of the publication being prepared.
Protection Of Information
1. Security of Information
The Company takes the security of your information very seriously. The Company protects your information from loss, misuse and unauthorized access, disclosure, alteration and destruction by using microservices architecture. It is an architectural style that structures an application as a collection of loosely coupled services, which implement business capabilities. for e.g. having separate services for user profile related operations and user’s health details related operations , these services reside on different servers having their own databases. Data is encrypted using the SHA-256 algorithm on both the server and the device The Company has put in place appropriate methods and managerial procedures to safeguard and secure such information. It only processes personal information in a way that is compatible with and relevant for the purpose for which it was collected or authorized by the individual. The Platform allows users access to their personal information and allows them to correct, amend or delete inaccurate information.
- The Company uses commercially reasonable precautions to preserve the integrity and security of your information against loss, theft, unauthorised access, disclosure, reproduction, use or amendment.
- In using the Platform, you accept the inherent security implications of data transmission over the internet. Therefore, the use of the Platform will be at your own risk and the Company assumes no liability for any disclosure of information due to errors in transmission, unauthorised third party access or other acts of third parties, or acts or omissions beyond its reasonable control and you agree not to hold the Company responsible for any breach of security.
- In the event the Company becomes aware of any breach of the security of your personal information, it will promptly notify you and take appropriate action to the best of its ability to remedy such a breach.
The Company takes all necessary precautions to protect your personal information both online and off-line. No administrator at the Company will have knowledge of your password.
The Platform may contain links to other sites, products, platforms and services. These are not necessarily under the control of the Company. Please be aware that the Company is not responsible for the privacy practices of such other sites. The Company encourages you to read the privacy policies of each and every web site that collects personally identifiable information. If you decide to access any of the third-party sites linked to Platform, you do this entirely at your own risk. Any links to any partner of the Platform should be the responsibility of the linking party, and the Company shall not be responsible for notification of any change in name or location of any information on the Platform.
12. Notification of Changes
Using the Company Services or accessing the Platform after a notice of changes has been sent to you or published on our website shall constitute your consent to the changed terms.
13. Consent To This Policy
14. Grievance Officer
If you have any grievance with respect to the Platform or the Services, including any discrepancies and grievances with respect to processing of information, you can contact our Grievance Officer at:
The Grievance Officer shall redress your grievances expeditiously, within 1 (one) month from the date of receipt of grievance. Except where required by law, the Company cannot ensure a response to questions or comments regarding topics unrelated to this policy or the Company’s privacy practices.
15. Contact person in data protection matters
If you have any questions regarding the processing of your personal data, please contact us via the following:
Data Protection Officer:
Contact Number: +91 22-49668867