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Where required, implementing standard contractual clauses approved by the European Union commission, or similar contractual clauses in other jurisdictions;
Transferring personal information to countries that regulators deemed to have adequate protections for the treatment of personal information; and
Where required by law, obtaining your consent to share your personal information outside of your country.
Any critical personal data, as may be notified by the relevant authority in India, shall only be processed in India and shall be transferred outside India as may be provided under the data protection laws of India.
1.1.This Policy explains when, why and how we collect, store, transfer and use personal information about people who download our App or use our Services (“User(s)”), the conditions under which we may disclose your personal information to others, and how we keep your personal information secure. We advise our Users to familiarize themselves with our privacy practices.
1.2.We may change this Policy from time to time. Your continued use of our Services after we make changes is deemed to be acceptance of those changes. Hence, we request you to check the Policy periodically for updates.
1.3.By accessing or using any of our Services you provide us your consent to the collection, transfer, storage, disclosure, and use of your personal data in accordance with this Policy. This Policy is applicable to our users from the time they access our App or use the Services we provide. If you do not agree with the terms and conditions of this Policy, we advise you to refrain from accessing or using the Services.
1.5.The Services provided by SSPL are only limited to the people who have attained the age of majority. Thus, this Policy is not applicable to minors or individuals who are not competent to enter into a contract. You therefore acknowledge that you have attained the age of majority and are competent to enter into a contract, SSPL shall not be responsible for you and has no control over any information submitted by you for the purpose of using the Services.
2.PERSONAL DATA WE COLLECT AND HOW WE COLLECT IT
2.1.INFORMATION YOU GIVE TO US
a)When you make an account on the App to use our Services or otherwise contact SSPL, we collect your account data depending on your use of our Services which may include personal identification information such as your name, date of birth, age, nationality, gender, signature, phone number, physical mailing and/or billing address, and/or email address (business or personal), and formal identification information such as Tax ID number, passport number, driver's license details, national identity card details, photograph identification cards, and/or visa information. In addition to the above, we also gather activity information, heart rate variability, heart rate reading, blood pressure reading, oxygen level when you use our health monitor designed by us for you (collectively, “Account Data”).
b)The Account Data may be processed for the purposes of providing our Services to you, and know-your-customer obligations, and ensuring the security of the Services, maintaining back-ups of our databases, and communicating with you. This information is collected by us in order to provide you the optimum and best experience of our Services. Without which, we may not be able to provide you the best user experience which way provide.
c)We process financial information such as bank account details, credit card or other information when you use our Services and/or purchase the products available on our App or Website (“Personal Data”). You hereby grant us no objection consent for gathering the said Personal Data.
d)We may automatically process information contained in or relating to any communication that you send to us (“Correspondence Data”). The Correspondence Data may include the communication content and metadata associated with the communication. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our App, Website and business and communications with users.
e)We may process information included in your personal profile, which may include your location, time zone, website and any other such related data (“Profile Data”). The Profile Data may be processed for the purposes of providing you a better user experience when using the Services. The legal basis for this processing is your consent.
2.2.INFORMATION WE AUTOMATICALLY COLLECT FROM YOUR USE OF THE SERVICES.
When you use our Services, we may automatically process information about your computer and internet connection (including your unique device identifiers, IP address, operating system, browser type and domain name), your mobile carrier, device information (including device and application IDs), search terms, web pages that you view, the additional links you click on, cookie information, your activity on our App as well as information about the timing, frequency and pattern of your use of our Services, and information about to the transactions you make on our Services, such as the name of the recipient, your name, the amount and timestamp, your interactions with our customer support such as the date, time, and reason for contacting us, transcripts of any chat conversations, and if you call us, your phone number and call recordings, advertisement identifiers such as identifier for advertising, google advertising identifier, and data related to your interaction with the advertisements that are served on the App or Services (“Service Data”). The Service Data is processed for the purpose of providing our Services. We may generate reports and analysis based on the Service Data for internal analysis, monitoring and marketing decisions. The legal basis for this processing is the adequate performance of the contract between you and us, to enable us to comply with legal obligations and our legitimate interest in being able to provide and improve the functionalities of the Services.
We may also collect information about your activity on our Services which is not personally identifiable with you but may be linked to your account information including but not limited to, your username, health statistics, blood oxygen levels, heart rate calculations.
2.3.INFORMATION WE COLLECT FROM THIRD PARTIES.
From time to time, we may obtain information about you from third party sources as required or permitted by applicable law, such as public databases, credit bureaus, ID verification partners, resellers and channel partners, joint marketing partners, and social media platforms. ID verification partners use a combination of government records and publicly available information about you to verify your identity. We obtain such information to comply with our legal obligations, such as anti-money laundering laws and/or other applicable medical laws. The legal basis for the processing such data is compliance with legal obligations.
3.DISCLOSURE OF PERSONAL DATA
3.1.We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for us to provide you the best User experience while accessing our Services.
3.2.We may disclose Service Data to a variety of third-party service providers insofar as reasonably necessary to improve the functionalities of the Services and customise our user experience.
3.3.We may share aggregated data (information about our users that we combine together so that it no longer identifies or references an individual user) and other anonymized information for regulatory compliance, industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.
3.4.In the event of any dispute arising out of your use of the Services, we may disclose some of your Personal Data with the counterparty to such transaction to the extent we deem required, in our discretion, to resolve any dispute.
3.5.Further, we may disclose your personal data if we believe that it is reasonably necessary to comply with a law, regulation, legal process, or governmental request; or in order to protect your vital interests or the vital interests of another natural person; to protect the safety or integrity of the Services, or to explain why we have removed content or accounts from the Services; or to address fraud, security, or technical issues; or to protect our rights or property or the rights or property of those who use the Services.
3.6.We offer individuals the opportunity to choose (opt out) whether their personal information is (i) to be disclosed to a third party or (ii) to be used for a purpose that is materially different from the purpose(s) for which it was originally collected or subsequently authorized by the individuals. In order to opt out from disclosure of your personal information, please write to us at firstname.lastname@example.org.
4.2.Cookie and tracking information collected by us may be shared with third parties which directly support our advertising/promotional activities to deliver advertisements that relate to User’s interest, and are involved in development/ updating of our website.
4.3.Commonly used browsers are set up to automatically accept cookies however you can modify your device’s settings to either alert you when you receive cookies or block cookies. If you disable/ block cookies, it may affect the performance and functionality of our Services and may also restrict your experience. If you use different devices to access our Services, you would be required to modify each device’s settings individually to suit your cookie preferences.
5.TRANSFER OF PERSONAL DATA
5.1.We may need to transfer or share your personal data to third parties outside of India. In such circumstances where we may need to transfer or share your personal data to third parties outside of India (including our affiliates and subsidiaries), we will ensure that such transfers are compliant with the requirements under Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 and Global Data Protection Regulation (GDPR).
6.1.You shall not assign or transfer any right or obligation that has accrued to you under this Policy and any attempt by you to assign or transfer such rights and obligations, shall be null and void.
6.2.We may assign, novate, or transfer any or all rights and obligations that accrued in our favour under the Policy, at our sole discretion, to our subsidiaries, affiliated entities, or any other third party, especially in order to comply with regulatory requirements in India, and for our users, to offer them a full suite of services in globally through our subsidiaries or affiliates.
7.1.We have implemented measures designed to secure your personal data from accidental loss and from unauthorized access, use, alteration, and disclosure. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of the Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
7.2.We use commercially reasonable security practices and procedures industry practices and procedures designed to help keep your personal information safe and secure. Although we strive to protect your personal information, we cannot guarantee the security of your data while it is being transmitted to our Service; any transmission is at your own risk. We will also ensure, on a commercially reasonable efforts basis, that any agent or third party that we employ complies with the same security standards as we do for the protection of your personal information.
7.3.Steps taken to ensure data security:
a)All the user information can only be accessed by authorized users;
b)Users need to authenticate themselves with a username-password combination; and
c)All data is hosted on AWS servers.
7.4.Unfortunately, the transmission of information via public networks such as the internet is not completely secure. Although we do our best to protect your personal data, we cannot guarantee or absolutely ensure the security of your personal data transmitted through the Services. Any transmission of personal data is at your own risk. We are not responsible for the circumvention of any privacy settings or security measures contained on the Services.
8.1.We retain your personal information as long as necessary for providing you the Services and as per the lawful basis of processing and to comply with our legal obligations. In particular, when determining how long we retain personal data, we take into account how long we need it to:
a)Maintain business records for analysis and/or audit purposes;
b)Comply with record retention requirements under the law;
c)Defend or bring any existing or potential legal claims; and
d)Deal with any complaints regarding the App and/or the Website for providing the Services.
8.2.At the end of the retention period your personal data will be anonymized.
8.3.If you no longer want us to use your information, then you can request that we erase your personal information and close your User account. Erasing your information will result in your subscription being terminated without any refunds. We may retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety. For example, if we suspend a User account for fraud or safety reasons, we may retain certain information from that account to prevent that User from opening a new account in the future.
8.4.We make no warranties and shall not be liable regarding non-availability or non-retention of any information and/or data provided by you beyond the deletion of your account.
9.YOUR RIGHTS WITH REGARDS TO PERSONAL DATA
9.1.You may deal with your personal data available with us in the following ways:
a)You may correct, amend, add, or update personal data from your account at any time by logging in to your account.
b)You are free to remove or delete your content from your account at any point in time, provided, however, SSPL may retain all or some of your data as per applicable law.
c)Copies of public content may be retained indefinitely in our systems, including in cached and archived pages of our App and/or Website, or if other users have copied or saved that information.
d)You may also, at any time while availing the Services or otherwise, withdraw the consent given earlier to SSPL provided that such withdrawal request is sent in writing to email@example.com. However, please note that in the event you withdraw the consent granted to us, we shall be unable to provide you with Services.
11.1.If you have queries about our data protection processes and practices or wish to request access to and/or make corrections to your personal data in our possession or under our control, or wish to withdraw your consent to our collection, use or disclosure of your personal data, please submit a written request (with supporting documents, (if any) to our Grievance Officer.
11.2.The name and contact details of the Grievance Officer are provided below:
Grievance Officer: Ankit Sachdev
Contact details: firstname.lastname@example.org
11.3.Our Grievance Officer shall endeavour to respond to you within 30 days of receiving your submission. Please note that if you withdraw your consent to any or all use or disclosure of your personal data, depending on the nature of your request, we may not be in a position to continue to provide our Services or products to you or administer any contractual relationship in place. Such withdrawal may also result in the termination of any agreement you may have with us. Our legal rights and remedies are expressly reserved in such event. We may charge you a fee for processing your request for access. Such a fee depends on the nature and complexity of your access request. Information on the processing fee will be made available to you.
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