PRIVACY POLICY

This privacy policy (“Policy”) was updated on _____ We, ORTHODOC Wellness Private Limited may occasionally make changes to the Policy. If we do, we shall notify either by sending you an e-mail or sending you a notification through our mobile application (“App”). Please make sure to read such notices carefully.

It must be noted that this Privacy Policy exclusively applies to the Orthodoc App and by signing up as a user or viewing the contents of the App as a visitor, you have expressly and willing consented to being subject to this Privacy Policy without any coercion.

We hold the sincere belief that you should always know what data we collect from you, the purposes for which such data is used, and that you should have the ability to make informed decisions about what data you want to share with us. We endeavour to comply with applicable privacy and data protection laws in the territory within which Orthodoc App operates. This Privacy Policy is only applicable for the information collected during the transaction of the Services and do not apply to unsolicited Information you may provide through our Platform or other third-party Platforms during the availing of Services. Such information shall constitute non-confidential data and shall not fall within the purview of this Privacy Policy.

We want to be fully transparent about: (i) how and why we collect, store, share and use your personal data through the various capacities in which you interact with us; and (ii) the rights that you have to determine the parameters of this interaction.

While we would strongly advise you to read the Policy in full, the following summary will give you a snapshot of the salient points covered herein:

• This Policy details the critical aspects governing your personal data relationship with ‘ORTHODOC’ which is owned and operated by ORTHODOC Wellness Private Limited, a company incorporated under the laws of India, and having its registered office at No. 30, 80 Feet Road, HAL 3^rd Stage, Indiranagar, Bengaluru- 560 075, Karnataka, India.
• Your personal data relationship with ORTHODOC varies based on the capacity in which you interact with us/avail of our products and services (“Services”). You could be: (i) a visitor to https://www.ORTHODOC.com (“Website”) or any pages thereof (“Visitor”); or (ii) a person who has an account with ORTHODOC to avail our Services (“Registered User”).
• Based on whether you are a Visitor or Registered User, the type of data we collect and the purpose for which we use it will differ and this Policy details such variations.
• This Policy applies to all the Services provided by ORTHODOC through the Website, App, or any other associated website of ORTHODOC.
• This Policy is a part of and should be read in conjunction with our Terms of Service; and
• This Policy will clarify the rights available to you vis-à-vis the personal data you share with us.

If you have any queries or concerns with this Policy, please contact our Grievance Officer. If you do not agree with the Policy, we would advise you to not visit/use the Website or the App.

1. INFORMATION WE COLLECT AND HOW WE USE IT

SPECIAL CATEGORIES OF PERSONAL DATA

We may collect and process ‘special categories of personal data’ such as ethnic origin, genetics, health, or sexual orientation, which are considered sensitive. We use this special category of personal data, for example to provide specialized diet plan and exercise routines. We require your explicit consent to collect and process special categories of personal data. A limited number of our personnel will have access to special categories of personal data provided by you. By agreeing to our terms and conditions and privacy policy, you are consenting to the dealing of such personal data.

We may use and/or disclose Protected Health Information in the same manner as Personal Information, described above, except our use and disclosure of Protected Health Information is further limited as provided by the administrative simplification provision of the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”),

WHAT ARE THE COOKIES AND WEB BEACONS REFERRED TO ABOVE?

A cookie is a small text file that we place on your mobile device to enable various features of the Website "Cookies" are used to store user preferences and to track user trends, so as to enhance your interactive experience and generally improve our Services to you. If you do accept a "cookie", you thereby agree to our use of any Personal Information collected by us using that, Cookie.

Usually, browsers have default setting to accept cookies until you change your browser settings. You can choose to reject and remove cookies from our website by changing your browser settings. If you reject or remove our cookies, it could affect how our website works.

FOR THE AVOIDANCE OF ANY DOUBT, WE SHOULD CLARIFY THAT IN THE EVENT WE ANONYMIZE AND AGGREGATE INFORMATION COLLECTED FROM YOU, WE WILL BE ENTITLED TO USE SUCH ANONYMIZED DATA FREELY, WITHOUT ANY RESTRICTIONS OTHER THAN THOSE SET OUT UNDER APPLICABLE LAW.

• By aggregating information:

Aggregated Personal Information does not personally identify you or any other user of the Service (for example, we may use Personal Information to calculate the percentage of our users who have chosen to receive messages by text messaging).

2. The Orthodoc app or website is not intended for European Union customers

3. PUBLISHED CONTENT

Any success stories, comments, messages, blogs, scribbles etc. posted/ uploaded/ conveyed/ communicated by you on the public sections of the Website/App becomes published content. We may publish such published content on our Website/App so long as you consent. You may request that such published content be taken down at any time and we shall remove such published content. However, we are not responsible for any actions taken by third parties with respect to such published content.

4. INFORMATION WE GET FROM OTHERS

We may receive data about you from other sources i.e., expert calls, smart watch, surveys, and such data may be added to our Website/App from time to time. Such data may include your behaviour towards various content posted on our Website/App from other sources. We use the data collected from other sources to prepare a specific diet plan and training regime for you. We also use this data for providing, testing, improving, or recommending the Services.

5. RETENTION OF PERSONAL INFORMATION

We will store any personal data we collect from you as long as it is necessary in order to facilitate your use of the Services and for ancillary legitimate and essential business purposes – these include, without limitation, for improving our Services, attending to technical issues, and dealing with disputes.

Your personal data will primarily be stored in electronic form. We may enter into agreement with third parties to collect, store, process your personal data but under full compliance with applicable laws. In the event, you have any telephonic interactions with our customer representatives, the call data is recorded and stored for training and quality purposes.

We may need to retain your personal data even if you seek deletion thereof, if it is needed to comply with our legal obligations, resolve disputes and enforce our agreements.

If you are a Registered User, please be advised that after you terminate your usage of a Service, we may, unless legally prohibited, delete all data provided or collected by you from our servers.

6. TRACKING BY OUR ADVERTISEMENT PARTNERS

Upon receiving your specific consent, we may share the data we collect from cookies or web beacons with our advertisement partners to track your visits, establish your non-personal identity and present you with targeted advertisements about our Services.

7.  Children’s online privacy in compliance with Digital Personal Data Protection Act, 2023As a business service, we neither knowingly collect or store nor use any personal data of any individuals under the age of 8. We do not target our Services towards individuals under the age of 18. Individuals under the age of 18 should seek the consent of their parents before providing any information about themselves, their parents, or other family members on our Website/App.

8. TRANSFER OF INFORMATION

In the ordinary course of business, we may employ other companies and people to assist us in providing certain components of our Services in compliance with the provisions of this Policy. To do so, we may need to share your data with them.

We may disclose Personal Information, including Protected Health Information as follows:

• if you are a user, to your medical advisor, coach, their Designees and Authorized persons without further authorization for purposes of treatment, payment, or operations; for other uses or disclosures permitted by law; or for purposes related to such uses or disclosures.
• to our third-party service providers who provide services such as website hosting, data analysis, payment processing, order fulfilment, infrastructure provision, IT services, customer service, email delivery services, credit card processing, backup, auditing services and other similar services.
• as we believe to be necessary or appropriate: (a) under applicable law,; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your state or country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

9. THIRD PARTY LINKS AND WEBSITES

We may display links to third-party websites or applications on our website or App for advertising or providing you with relevant content. We will not be responsible for such third-party websites or applications if you choose to access them. If you provide any data to such website/application, please ensure you read their policies given that you will no longer be bound by this Policy in doing so.

We may also tie-up with third parties, brand owners or other partners and make available certain offers, events, or special schemes. In such instances, your personal information may be shared with such third parties and/or may become available to them or be disclosed to them, such third parties may have their own applicable privacy rules and we shall not be liable for the use or misuse of your information by such third parties.

We may receive data whenever you visit a third-party link through our Website/App which includes the date and time of your visit to the third-party website, the web address or URL, technical information about the IP address, browser and the operating system you use and, if you are logged into ORTHODOC, your username.

You also understand that for completion of the services and for interactions with the Resources you would get in touch with various other third-party platforms and payment gateways. As with third party sites, you acknowledge that the Privacy Policies/Terms and Conditions of these platforms are not within the Control of Orthodoc Wellness Private Limited and you agree that it is your responsibility to review the privacy policies of such third-party platforms to confirm that you agree with them. You also expressly agree and acknowledge that Orthodoc Wellness Private Limited are not responsible for the information you provide on above referred third party websites/Platforms and that this Privacy Policy is applicable only for the information that you share on our website/platform.

10. COMPELLED DISCLOSURE

In addition to the purposes set out in the Policy, we may disclose any data we collected or processed from you if it is required:

• under applicable law or to respond to a legal process, such as a search warrant, court order, or subpoena.
• to protect our safety, your safety, or the safety of others or in the legitimate interest of any party in the context of national security, law enforcement, litigation, criminal investigation or to prevent death or imminent bodily harm.
• to investigate fraud, credit risk or violation of our Acceptable Use Policy.
• in connection with legal proceedings brought against ORTHODOC, its officers, employees, affiliates, customers, or vendors.
• to establish, exercise, protect, defend, and enforce our legal rights; or
• when we do a business deal or negotiate a business deal, or our assets are merged or acquired by the other business entity, or during restructuring of business or re-organization, we may have to share information provided by you with the other business entities.

10. SECURITY OF YOUR PERSONAL INFORMATION

We implement industry-standard technical and organizational measures by using a variety of security technologies and procedures to help protect your data from unauthorized access, use, loss, destruction, or disclosure.

The collection, storage, usage, and sharing of your data by the Company shall be in compliance with the Digital Personal Data Protection Act, 2023and other applicable laws.

Your password is your first line of defence once you set up a ORTHODOC account, we recommend that you set a strong password which you never share with anyone.

We have taken appropriate steps for the security and protection of all our digital platforms including internal applications, however, we shall not be responsible for any breach of security or the disclosure of personal data for reasons outside our control, such as hacking, social engineering, cyber terrorism, espionage by third parties, or any events by way of force majeure such as sabotage, fire, flood, explosion, acts of God, civil commotion, strikes or industrial action of any kind, riots, insurrection, war or acts of government.

Also unfortunately, no data transmission over the Internet can be guaranteed to be absolutely secure. As a result, while we strive to protect your personal information and Orthododc cannot ensure or warrant the security of any information you transmit to us, and you do so at your own risk. In the event of a breach of the confidentiality or security of your personal information, we will notify you as necessary and to the extent possible so you can take appropriate protective steps. Unless you indicate otherwise, we may notify you under such circumstances using the email address you provided to us when you registered with our websites.

11. ACCESS, CORRECTION & DELETION

You may request access, correction or updation, and deletion of the data by contacting support@ORTHODOC.com You may note that deletion of certain data or withdrawal of consent may lead to cancellation of your registration with us or your access to our Services.

Based on technical feasibility, we will provide you with access to all your personal and sensitive personal data that we maintain about you within 30 days of such request. We will perform verification before providing you access to this data. However, in the event of ongoing Services, we reserve the right to retain all the Information until the Competition of such Services.

You may opt out of our marketing emails by clicking on the ‘opt-out’ link provided in the emails. However, we may still send you non-marketing emails about your accounts or any other transactions with you.

12.  TERMS OF SERVICE

Please also visit our Terms of Service section, establishing the use, disclaimers, and limitations of liability governing the use of our website, by clicking here.

13. GRIEVANCE OFFICER

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