Privacy Notice

Introduction

This Privacy Policy describes how Opwel Health and certain of its corporate affiliates (collectively, “Opwel,” “we,” “us” or “our”) process personal information that we collect or otherwise generate through our digital or online properties or services that link to this Privacy Policy (including as applicable, our website and social media pages) as well as our marketing activities, live events and other activities described in this Privacy Policy (collectively, the “Service”). Opwel may provide to individuals supplemental or separate privacy policies for specific products or services that we offer including those at the time we collect personal information (also known as “just-in-time” disclosures).

Opwel may process personal information that identifies your past, present, or future health or mental health status, or that otherwise constitutes “sensitive personal data or information” or equivalent terms as defined by applicable Indian laws (such as the Digital Personal Data Protection (DPDP) Act 2023 and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011) (“Health Data”).

How we handle Health Data specifically is set out below under Consumer Health Data, which forms part of this Privacy Policy. In the event of a conflict between that section and the rest of this Privacy Policy, that section applies to the extent that it is consistent with applicable law.

This Privacy Policy does not apply to personal information that we receive from and process on behalf of our enterprise customers while providing Opwel services to them. For example, to the extent that we receive your personal information from your employer related to your eligibility for our Service, our use of that personal information may be governed by our agreements with the relevant enterprise customer. If you have questions regarding your personal information that we process on behalf of an enterprise customer, please direct your questions to the relevant enterprise customer.

The personal information we collect may differ depending on your relationship with us. For example, if you are a representative of a prospective enterprise customer, we will collect limited personal information in comparison to if you were a Opwel member who obtains tests through Opwel. Please consider your relationship with us in the context of reading this Privacy Policy.

NOTICE TO INDIAN RESIDENTS: Please see the Indian Privacy Rights section of this Privacy Policy for additional information regarding your rights under the DPDP Act 2023.

Guiding Privacy Principles

We built Opwel for families, ourselves and you. Your privacy is one of our top priorities. We empower you to take control of your health and that includes having control of certain aspects of your personal information. We leverage measures designed to protect and process your personal information in accordance with our guiding privacy principles below and as otherwise stated in this Privacy Policy. Please read the Privacy Policy in full to understand our personal information practices.

• Your identity is not for sale for money. In the ordinary course of our daily operations, we do not disclose your personal information to third parties in exchange for money.
• We limit the information we collect and retain. We collect personal information to provide you with our products and Services. We retain your personal information for the period of time necessary to fulfill the purposes for which we collected it, including delivering requested products and Services, protecting the interests of our members, and for the period of time required by law.
• We limit the manners in which we share your test results with third parties. In order to deliver our product and Services to you, it may be necessary for us to provide certain information to our lab and other provider partners. We limit how such recipients may use your personal information.

How Opwel handles health information

Health information receives stricter handling than other personal information. It is accessible only to the clinicians and Care Team members supporting you, on a least privilege basis.

We do not send health information, health concerns or Health Assessment answers into analytics or advertising tools, and health context never appears in a URL.

We share information with accredited laboratories to carry out testing you have agreed to, and with service providers who process information on our behalf under contract. We do not sell your personal information, and we do not share health information with employers, insurers or advertisers.

Information is encrypted in transit and at rest. Access is controlled, logged and limited to what a role requires. We keep information only for as long as we need it for care, legal and regulatory purposes, according to a documented retention schedule.

Personal Information We Collect

Information you provide to us or that we generate about you. Depending on how you interact with the Service, the personal information you may provide to us through the Service or that we generate about you or otherwise may include:

• Contact data, such as your first and last name, salutation, email address, billing and mailing addresses, and phone number.
• Demographic data, such as your city, state, country of residence, postal code, age, date of birth, gender or gender identity, racial or ethnic identity, assigned sex at birth, and sexual orientation.
• Account data, such as the username and password that you may set to establish an online account on the Service, date of birth, biographical details, photograph or picture, links to your profiles on social networks, preferences, information about your participation in our promotions or surveys, and any other information that you add to your account profile.
• Service-eligibility data, if you are accessing the Service as part of an enterprise customer-provided offering or benefit, you may provide us with relevant information such as your employer or other enterprise customer name, eligibility data, and relevant enterprise customer identification number.
• Health-related data, such as mental or physical history, conditions and diagnoses, treatments, medications, medical images, biomarkers, lab samples, lab results, clinical notes, and other physical or mental health information. This may include personal information that you provide directly to us when you complete electronic forms designed for you to self-report your physical or mental health status, upload medical records, or link a wearable or Internet of Things device to our Services.
• Genetic data, certain of the lab tests available through the Service may produce data that relates to inherited characteristics.
• Audiovisual recording data, such as video and audio recordings of you.
• Transactional data, such as information relating to or needed to complete your orders on or through the Service, including order numbers and transaction history. This includes purchase considerations, consumption history and purchase tendencies.
• Communications data based on our exchanges with you, including when you contact us through the Service, communicate with us via email, phone, chat features, social media, or otherwise.
• Relationship data, such as familial or other relationship to third parties whose personal information you may provide to us.
• Payment data needed to complete transactions, including payment card information or bank account number. We use a third-party vendor to directly collect and process your payment card information.
• Government-issued identification number data, such as an Aadhaar number, PAN card, voter ID, driver’s license, or other state ID number and an image of the relevant identification card. Where we ask for this, you provide it voluntarily and it is not used for Aadhaar-based e-KYC or authentication.
• Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
• User-generated content data, such as photos, images, music, videos, comments, reviews, questions, messages, and other content or information that you generate, transmit, or otherwise make available on the Service, as well as associated metadata.
• Derived data, such as inferences about you that we derive or otherwise infer from your personal information.
• Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Third-party sources. We may combine personal information we receive from you with personal information of the kinds identified above that we obtain from other sources, such as:

• Public sources, such as government agencies, public records, social media platforms, and other publicly available sources.
• Private sources, such as data providers and social media platforms.
• Linked third-party services, such as Google or other third-party service that you use to log into, or otherwise link to, your Service account.
• Linked third-party devices, such as wearable or Internet of Things devices that you link to your Service account.
• Lab and provider partners, including third party healthcare services providers, laboratory services providers, and other providers of medical and medical-adjacent services.
• Our enterprise customers, such as employers, gyms and other entities that may provide us with some of your personal information.
• Our corporate affiliates, including certain members of the Opwel Health group of companies.
• Marketing partners, such as joint marketing partners.
• Service providers that provide services on our behalf or help us operate the Service or our business.
• Third parties that you designate, such as lab providers with whom we do not have a contractual relationship.
• Business transaction partners. We may receive personal information in connection with an actual or prospective business transaction.

Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:

• Device data, such as your computer or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type, IP address, unique identifiers, language settings, mobile device carrier, radio/network information, and general location information.
• Precise geolocation data if you authorise the Service to access your device’s location.
• Online activity data, such as pages or screens you viewed, search history, how long you spent on a page or screen, navigation paths, access times and duration of access, and whether you have opened our emails or clicked links within them.
• Communication interaction data such as your interactions with our email, text or other communications.

Cookies and similar technologies. Some of the automatic collection described above is facilitated by the following technologies:

• Cookies, which are small text files that websites store on user devices.
• Local storage technologies, like HTML5.
• Web beacons, also known as pixel tags or clear GIFs.
• Chat technologies, that employ software code to operate the chat features that you can use to communicate with us.

How We Use Personal Information

We may use your personal information for the following purposes or as otherwise described at the time of collection:

Service delivery and operations. We may use your personal information to:

• provide, operate and improve the Service and our business;
• process your requests, orders and transactions;
• personalizing the service;
• establish and maintain your user profile on the Service;
• enable security features of the Service;
• communicate with you about the Service;
• understand your needs and interests, and personalize your experience; and
• provide support for the Service, and respond to your requests, questions and feedback.

Insights and development. We may use your personal information for:

• insights (including research, such as publishing research-related materials);
• to analyze your usage of the Service, help us understand user activity; and
• development purposes, including to analyze and improve the Service and our business and to develop new products and services.

Marketing and advertising. We, our service providers and our third-party advertising partners may collect and use certain of your personal information for marketing and advertising purposes:

• Direct marketing. We may send you direct marketing communications.
• Interest-based advertising. Our third-party advertising partners may use cookies, pixels and other technologies to collect information about your interaction with the Service to serve online ads. We do not use health-related information or genetic data for interest-based advertising.
• Testimonials. We may use your feedback to post comments about your experience with any Service on the website, in our marketing and promotional materials.

Promotions, contests, and events.

• We may use your personal information to administer promotions and contests.
• We may use your personal information to administer events.

Compliance and protection. We may use your personal information to:

• comply with applicable laws, lawful requests, and legal process;
• protect our, your or others’ rights, privacy, health, safety or property;
• audit our internal processes for compliance;
• enforce the terms and conditions that govern the Service; and
• prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity.

Data sharing in the context of corporate events, we may share certain personal information in the context of actual or prospective corporate events.

With your consent. In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.

To create aggregated, de-identified and/or anonymized data. We may create aggregated, de-identified and/or anonymized data from your personal information. We may use this data and share it with third parties for our lawful business purposes.

Sharing and Disclosure of Personal Information

We may share your personal information with the following parties and as otherwise described in this Privacy Policy:

• Affiliates. Such as our corporate parent, subsidiaries and affiliates, including certain members of the Opwel Health group of companies.
• Service providers. Third parties that provide services on our behalf or help us operate the Service or our business.
• Payment processors. Any payment card information you use to make a purchase on the Service is collected and processed directly by our payment processors.
• Research partners. We may share personal information with research partners to conduct research.
• Advertising partners and ad networks. Third-party advertising companies for the interest-based advertising purposes described above. We do not provide health-related information or genetic data to such advertising partners.
• Lab and provider partners. We may share your personal information with healthcare services providers, laboratory services providers, and other providers of medical and medical-adjacent services.
• Enterprise customers. We may share certain limited personal information with the relevant enterprise customers through which you received access to the Services. We do not provide health-related information or genetic data to enterprise customers.
• Third parties designated by you. We may share your personal information with other third parties where you have instructed us or provided your consent to do so.
• Business and marketing partners. Third parties with whom we jointly offer products or services.
• Linked third-party services or devices. If you log into the Service with a third-party service such as Google, or choose to link a wearable or Internet of Things device to your Service account, we may share your personal information with that third-party service.
• Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers.
• Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate.
• Business transferees and their advisors. We may disclose personal information in the context of actual or prospective business transactions (e.g., investments, public stock offerings, or the sale, transfer or merger of all or part of our business).
• Other users and the public. Certain user-generated content, including your health-related data and other data you submit to us may be visible to other users and the public, such as when you post comments in publicly accessible parts of the Service.

Data Retention

We generally retain personal information to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period for personal information, we may consider factors such as length of time we have an ongoing relationship with you and provide services to you; the amount, nature, and sensitivity of the personal information; the potential risk of harm from unauthorized use or disclosure of your personal information; the purposes for which we process your personal information and whether we can achieve those purposes through other means; whether there is a legal obligation to which we are subject; whether retention is advisable in light of our legal position; and applicable legal requirements.

When we no longer require the personal information we have collected about you, we may either delete it, anonymize it, de-identify it, or isolate it from further processing.

Children

The Service is not intended for use by anyone under 18 years of age. If you are a parent or guardian of a minor from whom you believe we have collected personal information in a manner prohibited by law, or if information was provided on your behalf when you were under 18, please contact us. If we learn that we have collected personal information through the Service from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.

Links To Other Websites

This Privacy Policy does not apply to third-party websites, applications, products, services or other properties even if they may link to our Service or we may refer you to such third parties as part of our Service. In addition, our content may be integrated into web pages or other online services that are not associated with us. We do not control websites, mobile applications or services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and services you use.

Social Sharing

If you log into the Service with a third-party social media service or choose to link your account, you may be able to use your settings in your account with that platform to limit the information we receive from it. Additionally, certain user-generated content you submit to us may be visible to other users and the public, such as when you post comments in publicly accessible parts of the Service. This information can be seen, collected and used by others.

Security

We employ technical, organizational and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.

International Users

We are headquartered in India and may use service providers that operate in other countries. Your personal information may be transferred to India or other locations where privacy laws may not be as protective as those in your state, province, or country. By using our Services, you consent to the transfer of information to countries outside your country of residence.

Your Choices

In this section, we describe the rights and choices available to all users, particularly regarding their rights under the Digital Personal Data Protection (DPDP) Act 2023 of India.

• Access or update your information. If you have registered for an account with us through the Service, you may review and update certain account information by logging into the account and navigating to your account profile and settings.
• Opt-out of communications. You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. If you receive text messages from us, you may opt out of receiving further text messages from us by replying STOP to our message.
• Cookies. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings.
• Advertising choices. You may be able to limit use of your information for interest-based advertising through browser settings, privacy browsers/plug-ins, platform settings, or mobile settings.
• Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” signals.
• Mobile location data. You can disable our access to your device’s precise location in your browser or device settings.
• Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

Indian Privacy Rights Notice

Under the Digital Personal Data Protection (DPDP) Act 2023, residents of India have specific rights regarding their personal data:

• Right to Access: You have the right to request a summary of the personal data processed by us and the processing activities undertaken.
• Right to Correction and Erasure: You can ask us to correct inaccurate or misleading personal data, complete incomplete data, or update your data. You also have the right to request the erasure of your personal data when it is no longer needed for the purpose it was collected or if you withdraw your consent.
• Right to Revoke Consent: You have the right to withdraw your consent to our processing of your personal data at any time.
• Right of Grievance Redressal: You have the right to register a grievance with us regarding any act or omission pertaining to the performance of our obligations under the DPDP Act. If we do not resolve your grievance to your satisfaction, you can escalate it to the Data Protection Board of India, using the process the Board publishes for the purpose, you do not need our permission or involvement to do that.
• Right to Nominate: You have the right to nominate an individual to exercise your rights under the DPDP Act in the event of your death or incapacity.

To exercise any of these rights, write to us at [email protected]. We acknowledge every request within 7 days, and complete verified requests within 90 days at the outer limit set by the DPDP Rules. Most requests are handled faster. We may need to verify your identity before processing your request.

Grievance officer: Opwel’s designated grievance officer can be reached at [email protected], and we will route your request to them directly. This is the named contact point for any question, correction, deletion, or complaint relating to your personal data, whether or not you are making a formal request.

How to see who your data has been shared with

DPDP's Right to Access already covers this: the categories of personal information we collect and why are described above under *Personal Information We Collect* and *How We Use Personal Information*, and the parties we share them with are listed above under *Sharing and Disclosure of Personal Information*, itemised by category rather than repeated in a separate table. For a summary specific to your own data, including which named recipients your information has actually been shared with, exercise your Right to Access using the contact details below.

Consumer Health Data

This Consumer Health Data Privacy Policy (“Consumer Health Data Privacy Policy”) describes how Opwel Health and its corporate affiliates (collectively, “Opwel,” “we,” “us” or “our”) process consumer health data as applicable laws may define that term (“Consumer Health Data”), that we collect through our digital or online properties or services that link to this Consumer Health Data Privacy Policy (including as applicable, our website and social media pages) as well as our marketing activities, and other activities described in this Consumer Health Data Privacy Policy (collectively, the “Service”). This Consumer Health Data Privacy Policy applies to the extent required by applicable laws.

This section forms part of this Privacy Policy and applies specifically to Consumer Health Data. In the event of a conflict between this section and the rest of this Privacy Policy, this section applies to the extent that it is consistent with applicable law.

This Consumer Health Data Privacy Policy does not apply to Consumer Health Data that we process on behalf of our enterprise customers while providing Opwel services to them. For example, to the extent that we receive your Consumer Health Data from your employer related to your eligibility for our Service, our use of that Consumer Health Data may be governed by our agreements (including, as applicable, a business associate agreement) with the relevant enterprise customer. If you have questions regarding your Consumer Health Data that we process on behalf of an enterprise customer, please direct your questions to the relevant enterprise customer.

Consumer Health Data we collect:

Consumer Health Data you may provide to us through the Service or otherwise includes:

• Contact data, such as your first and last name, salutation, email address, billing and mailing addresses, and phone number.
• Demographic data, such as your city, state, country of residence, postal code, age, date of birth, gender or gender identity, racial or ethnic identity, and sexual orientation.
• Account data, such as the username and password that you may set to establish an online account on the Service, date of birth, biographical details, photograph or picture, links to your profiles on social networks, preferences, information about your participation in our promotions or surveys, and any other information that you add to your account profile.
• Service-eligibility data, if you are accessing the Service as part of an enterprise customer-provided benefit, you may provide us with relevant information such as your employer or other enterprise customer name, eligibility data, and relevant enterprise customer identification number.
• Health-related data, such as mental or physical history, conditions and diagnoses, treatments, medications, medical images, biomarkers, lab samples, lab results, clinical notes, and other physical or mental health information. This may include personal information that you provide directly to us when you complete electronic forms designed for you to self-report your physical or mental health status, upload medical records, or link a wearable or Internet of Things device to our Services.
• Genetic data, certain of the lab tests available through the Service may produce data that relates to inherited characteristics.
• Audiovisual recording data, such as video and audio recordings of you.
• Transactional data, such as information relating to or needed to complete your orders on or through the Service, including order numbers and transaction history.
• Communications data based on our exchanges with you, including when you contact us through the Service, chat features, social media, or otherwise.
• Relationship data, such as familial or other relationship to third parties whose personal information you may provide to us.
• Payment data needed to complete transactions, including payment card information or bank account number.
• Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
• User-generated content data, such as photos, images, music, videos, comments, questions, messages, and other content or information that you generate, transmit, or otherwise make available on the Service, as well as associated metadata. Metadata includes information on how, when, where and by whom a piece of content was collected and how that content has been formatted or edited. Metadata also includes information that users can add or can have added to their content, such as keywords, geographical or location information, and other similar data.
• Other data not specifically listed here, which we will use as described in this Consumer Health Data Privacy Policy or as otherwise disclosed at the time of collection.

Consumer Health Data we collect automatically. When you use our services, we collect some information through certain technical tracking technologies that may be considered Consumer Health Data. For example:

• Device data, such as your computer or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.
• Precise geolocation data, if you authorise the Service to access your device’s location.
• Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.
• Communication interaction data such as your interactions with our email, text or other communications (e.g., whether you open and/or forward emails) – we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails.

Consumer Health Data we obtain from third-party sources. We also obtain the types of Consumer Health Data described above from third parties. These third-party sources may include, for example:

• Corporate affiliates. We may obtain your Consumer Health Data from our corporate affiliates.
• Lab and Provider Partners, including third party healthcare services providers, laboratory services providers, and other providers of medical and medical-adjacent services.
• Our enterprise customers, such as employers, gyms and other entities that may provide us with your personal information.
• Linked third-party services, such as Google or other third-party service that you use to log into, or otherwise link to, your Service account. This data may include your username, profile picture and other information associated with your account on that third-party service that is made available to us based on your account settings on that service.
• Linked third-party devices, such as wearable or Internet of Things devices that you link to your Service account. This data may include your username, profile picture and other information associated with your account on that third-party service that is made available to us based on your account settings on that service. This may include your device’s health app information historical data related to your use of the wearable device.
• Third parties that you designate such as lab providers with whom we do not have a contractual relationship.
• Service providers. Third parties that collect or provide Consumer Health Data in connection with work they do on our behalf.

Consumer Health Data we may create, infer or generate. We may create, infer or generate Consumer Health Data from other data we collect, including using automated means to generate information about your likely preferences or other characteristics. We may create aggregated, de-identified, and/or anonymized information from Consumer Health Data by removing certain data components (such as your name, email address, or linkable tracking ID) that makes the data identifiable, or through aggregation, obfuscation or other means. For example, we may de-identify any information and data provided and/or generated in connection with your use of our Services (including without limitation your health-related data), in compliance with applicable law. Except as required or permitted by applicable law, we will not attempt to re-identify any data that has been aggregated, de-identified, and/or anonymized. Subject to applicable law, our use of such aggregated, de-identified, and/or anonymized information is not Consumer Health Data.

How we use your Consumer Health Data

We use Consumer Health Data for purposes described in this Consumer Health Data Privacy Policy or as otherwise disclosed to you. For example, we use Consumer Health Data for the following purposes:

How we share your Consumer Health Data

We may “share” (as the applicable law may define that term) Consumer Health Data with your consent or as we determine necessary to complete your transactions, provide the Service to you, or as otherwise permitted or required by law. For example, we may share your Consumer Health Data to:

• Corporate affiliates. We may share your Consumer Health Data with our corporate affiliates.
• Payment processors. Any payment card information you use to make a purchase on the Service is collected and processed directly by our payment processors. Our payment processor may use your payment data in accordance with its own privacy policy.
• Research partners. We may share Consumer Health Data with research partners to conduct research.
• Lab and Provider Partners. We will share your Consumer Health Data with healthcare services providers, laboratory services providers, and other providers of medical and medical-adjacent services.
• Linked third-party services or devices. If you log into the Service with a third-party service such as Google, or choose to link a wearable or Internet of Things device to your Service account, we may share your personal information with that third-party service. The third party’s use of the shared information will be governed by its privacy policy or other relevant terms and the settings associated with your account with the third-party service.
• Legal and law enforcement. We will access, share, and preserve Consumer Health Data when we believe that doing so is necessary to comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies. We will also share Consumer Health Data if we believe it is necessary to protect our customers and/or the rights or property of ourselves or others.

For more information on how we may otherwise disclose your Consumer Health Data, see *Sharing and Disclosure of Personal Information* above.

Your rights under the DPDP Act

Under India's Digital Personal Data Protection (DPDP) Act 2023, you have the following rights over your Consumer Health Data:

• Access. You have the right to request a summary of the Consumer Health Data we hold about you, how it is being processed, and who it has been shared with.
• Correction and erasure. You have the right to ask us to correct inaccurate or incomplete Consumer Health Data, or to delete it once it is no longer needed for the purpose it was collected for or you withdraw your consent.
• Withdraw consent. To the extent we rely on your consent to collect or share your Consumer Health Data, you have the right to withdraw that consent for any future collection or sharing at any time.
• Grievance redressal. You have the right to raise a complaint with us regarding any act or omission concerning your Consumer Health Data. If we do not resolve it to your satisfaction, you can escalate it to the Data Protection Board of India, using the process the Board publishes for the purpose, you do not need our permission or involvement to do that.
• Nominate. You have the right to nominate another individual to exercise these rights on your behalf in the event of your death or incapacity.

To exercise any of these rights, write to us at [email protected]. We may need to verify your identity in order to process your request. To confirm your identity, we may ask you to verify personal information we already have on file for you. If we cannot verify your identity based on the information we have on file, we may request additional information from you, which we will only use to verify your identity, and for security or fraud-prevention purposes. We acknowledge every request within 7 days, and complete verified requests within 90 days at the outer limit set by the DPDP Rules.

Declining to provide information. We need to collect Consumer Health Data to provide certain services. If you do not provide the information we identify as required or mandatory or if you request that any required Consumer Health Data be deleted or withdraw your consent for future collection or sharing of any required Consumer Health Data, we may not be able to provide those services.

Linked third-party platforms. If you log into the Service with a third-party service such as Google, or choose to link a wearable or Internet of Things device to your Service account, you may be able to use your settings in your account with that platform to limit the information we receive from it. If you revoke our ability to access information from such third-party platform, that choice will not apply to information that we have already received from that third party.

International and NRI users

This Consumer Health Data Privacy Policy and the DPDP Act apply to Consumer Health Data we process in connection with the Service regardless of where you access it from, including Non-Resident Indians and other users located outside India. If you access the Service from outside India, you remain responsible for complying with any additional laws that may apply to you in your own jurisdiction. You agree to indemnify and hold us harmless against claims arising from your use of the Service from a jurisdiction where such use is restricted, or where your access creates an obligation for us under a law other than Indian law.

Changes To The Privacy Policy

The “Last Updated” legend at the top of this Privacy Policy indicates when this Privacy Policy was last updated. We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service or other appropriate means. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acknowledging that the modified Privacy Policy applies to your interactions with the Service and our business.

Contact Us

If you have questions about our personal information practices or if you would like to exercise any privacy-related right that may be available to you, please contact us via the method listed below.

Email: [email protected]