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PRIVACY POLICY

We are aware that you take the security and privacy of your data seriously. We have you covered, possibly to a greater extent than you had anticipated. This streamlined guide is for you if you've ever questioned what personal information we gather from you and how we gather, utilize, and share that personal information.

SYNOPSIS
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You own your data and control our usage of your data. We will never sell your data to third-parties.
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You may exercise any of the following rights at any time in respect of your data in accordance with the terms of this privacy policy:
(a) request details of your information collected by us;
(b) request reasons for collection;
(c) correct your information;
(d) request deletion of your information;
(e) request restricted processing of your information;
(f) the category of entities with whom we have shared your data and the reason for any disclosure;
(g) request a portable copy of the information you have provided;
(h) object to processing of your information, such as for direct marketing; and
(i) where we obtain your consent, you may withdraw such consent at any time.
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We will not process your information in a way that is incompatible with or outside of the purpose(s) for which it has been collected or subsequently authorised by you. For any new purpose, we will always ask you for your separate consent.
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We keep your information only as long as necessary to provide you with our Products and Services or as may be required under any applicable law.

Your Acceptance To The Privacy Policy
Please read this Privacy Policy very carefully. By accessing or using the Modulus App, Website, our various products and services, you agree and consent to be bound by this Privacy Policy. If you do not agree to be bound by or abide by the terms of this Privacy Policy, you are not authorised to use or access our App, Website, various products and services. If you have any questions, feel free to ask us anytime at admin@modulushealth.in

INTRODUCTION

Modulus is a full-stack proactive healthcare solution, which tracks health data and provides healthcare services proactively, to make healthcare more simplified and accessible to users.
Currently our portfolio includes a mobile app (software platform) that helps users understand their health better, by collecting and analyzing their behavioral data. The app also includes healthcare services like scheduling consultations with doctors & specialists, OPD and IPD health covers, etc.

DEFINING DATA

Lets begin with understanding what is data/personal information before we delve deeper into some advanced stuff.
Your data essentially falls into either of the 3 (three) buckets, mentioned below, depending on your interaction with the Modulus app.
Personal Data or Information
Any data that can identify you.
E.g. Name, Email, Address, Phone number, etc.
Non-Personal Data
Any data that does not identify you personally and cannot be linked back to you unless you identify yourself.
E.g. browser name, the type of computer and technical information, the operating system, the internet service providers utilized, etc.
Sensitive Personal Data or Information (’SPDI’)
Personal information which consists of information relating to a person's passwords; financial information such as bank account or credit card or debit card or other payment instrument details; physical, physiological and mental health conditions; sexual orientation; medical records and history; biometric information; any detail relating to the above sub-clauses or any other sensitive personal data or information you provide to us for providing the Products and Services; and any of the information received under the above sub-clauses by us under lawful contract or otherwise.
It is noteworthy, any information that is freely available or accessible in the public domain, is exempted from privacy protection.
Now that you understand the categories of data, let us give you a detailed break-up of our data collection and processing practices.

PERSONAL INFORMATION WE COLLECT

We collect personal information when you provide it to us, when you use our Platform or Products and Services, and when other sources provide it to us, as further described below.

Information You Provide Us


🧑Account Creation
When you create an account or otherwise use the Products and Services, we collect information such as your name, email address, phone number, or other contact information.

📞Your Communications with Us
We collect personal information from you such as email address, phone number when you log in to our app.

🤝Third-Party Integrations
With your permission, we collect certain information from third-parties via integrations with such third-party platforms, such as:
Google Fit
The data read from such integrations will be used solely for measuring and improving the efficacy of your experience of our Products and Services.

Data Collected Automatically


Automatic Data Collection
When you access the features of the Platform, we may automatically gather and store certain information about your visit such as the type of browser and operating system used to access our Website, the date and time you accessed our Website, and if you were linked to our Website from another website, the address of that website, as well as additional information related to your visit may be collected. Similarly, we do automatically collect information from your use of our App such as location, phone’s name and model, operating software, IP carrier, and other in-app activities.

Analytics
We may also use third-party service providers to collect and process analytics and other information on our Website or Services. These third-party service providers may use cookies, pixel tags, web beacons or other storage technology to collect and store analytics and other information. They have their own privacy policies addressing how they use the analytics and other information and we do not have access to, nor control over, third parties’ use of cookies or other tracking technologies.

Other Sources

Cookies
We use cookies and other technologies to automatically collect information through the Website or Services. [Please note there are no cookies on the App.] These technologies are essentially small data files placed on your devices that allow us and our partners to record certain pieces of information whenever you visit or interact with our Services. This information may be used to, among other things, analyse and track data, determine the popularity of certain content and better understand your online activity.

Third-Party Services
We may obtain information about you from other sources, including through third-party services and organisations. For example, if you access our Website or Products and Services through a third-party application, such as a social networking site, we may collect information about you from that third party that you have made available via your privacy settings.
Third-Party entities
We may also collect information you may have provided to any company or its affiliates, associates, subsidiary, holding company to whom you have given consent for sharing of such Information with us.

DISCLOSURES


Modulus is not in the business of selling your information. We consider this information to be a vital part of our relationship with you.
There are, however, certain circumstances in which we may share your information with certain third-parties without further notice to you, as set forth below:

SERVICE PROVIDERS
We may share any information we collect about you with our third-party service providers. The categories of service providers to whom we entrust personal information include service providers for: (i) the provision of the Products and Services; (ii) the provision of information, products, and other services you have requested; (iii) marketing and advertising; (iv) payment and transaction processing; (v) customer service activities.
BUSINESS PARTNERS
We may provide personal information to business partners with whom we jointly offer products or services.
Also, where you have been referred to use our Products and Services by our business partners such as gyms and other B2B partners, we may share your data with them upon their request subject to informing you via email prior to sharing data with them.
Where we share your data with third-parties, they may use it for their business purposes and data in their possession will be governed by such third-party’s privacy policy.
BUSINESS AFFILIATES
We may share information with our affiliated entities.
ADVERTISING PARTNERS
We do not share your information to advertise any third party’s products or services via the Products and Services. We may use and share your information with third-party advertising partners to market our own Products and Services and grow our Products and Services’ user base, such as to provide targeted marketing about our own Products and Services via third-party services.
FOR LEGAL PURPOSES
We may access, preserve, and disclose any information we store in association with you to external parties if we, in good faith, believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) protect your, our, or others’ rights, property, or safety; (iii) enforce our policies or contracts; (iv) collect amounts owed to us; or (v) assist with an investigation and prosecution of suspected or actual illegal activity.
IN THE EVENT OF MERGER, SALE, OR OTHER ASSET TRANSFER
If we are involved in a merger, acquisition, financing due diligence, reorganisation, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.
SHARE CONTENT WITH FAMILY AND FRIENDS
Our Services may allow you to provide information about your family and friends, and may allow you to forward or share certain content with a family member, friend or colleague, such as an invitation email.
EXCLUSIONS
All Unsolicited/ Public Information shall be deemed to be non-confidential and we shall be free to reproduce, use, disclose, and distribute such Unsolicited/Public Information to others without limitation or attribution.
Anonymized, aggregated data may be shared with advertisers, research firms, and other partners.

DATA RETENTION

We keep your information only for as long as necessary to provide you with our App or as may be required under any applicable law. We store your information for lawful purposes only. We may keep de-identified data for research and statistical purposes for a longer period. If you close your User Account, we have no obligation to retain your data, and we may delete any or all of your data without liability. However, we may retain data related to you if we believe it may be necessary to prevent fraud or future abuse, or if required by law, or for other legitimate purposes. If you have elected to receive marketing communications from us, we will retain Information about your marketing preferences for a reasonable period of time, which will be determined by us based on the date you last expressed interest in our content, Platform, Products and Services.

SECURITY

Reasonable industry standard technical, administrative, and physical security safeguards and measures are in place to help protect against the loss, misuse and alteration of the information under our control. We promote safety and security on and off our Platform, Products and Services, such as by investigating suspicious activity or violations of this Privacy Policy and Terms of Use and to ensure our App is being used legally. If we do detect something risky that could compromise your privacy and security, we shall notify you by updating our respective policies and help guide you through steps to stay better protected.
We take complete measures to safeguard you and our App from unauthorised access, alteration, disclosure, or destruction of Information we hold, including:
a) Use of encryption to keep your information private while in transit
b) Timely review of our information collection, storage, and processing practices, including physical security measures, to prevent unauthorised access to our systems.
However, we cannot guarantee absolute security as no method of protection and transmission of information is completely secure. Therefore, while we strive to protect your information, you agree and acknowledge that
(i) there are security and privacy limitations of the internet which are beyond our control
(ii) the security, integrity, and privacy of any and all information and data exchanged between you and our Platform cannot be guaranteed
(iii) any such information and data may be viewed or tampered with in transit by a third-party, despite our best efforts.
We also have comprehensive internal policies in place to prevent unauthorised access to your data. We take steps to seek to ensure that third parties we share data with also adopt an adequate, reasonable level of security practices and procedures to ensure the privacy and security of your information. However, we are not responsible for any loss, unauthorised access, safety issue or any harm caused to you by any misuse of your information, unless it is a direct and foreseeable consequence of negligence and noncompliance on our part only. You hereby acknowledge that we are not responsible, in particular, for any third-party action or action on your part leading to loss, damage or harm to you or any other person. For any data loss or theft due to unauthorised access to your electronic devices through which you avail our Services, we shall not be held liable for any loss whatsoever incurred by you.

YOUR RIGHTS

We follow your instructions about your information we hold. You may request details of your information collected by us, request reasons for collection, correct your information, request deletion of your information, request restricted processing of your information, the category of entities with whom we have shared it and the reason for any disclosure, request a portable copy of the information you have provided, object to processing of your information, such as for direct marketing, and where we obtain your consent, you may withdraw such consent at any time.
You are free to not to share any medical or other information that you consider confidential and withdraw consent for us to use data that you have already provided. In the event that you refuse to share any information or withdraw consent to process information that you have previously given to us, we reserve the right to restrict or deny the provision of our Products and Services for which we consider such information to be necessary.

MODIFICATIONS TO THIS POLICY

We may modify the Privacy Policy from time to time at our sole discretion. If we do so, we will revise the date at the top of this Privacy Policy. It is important that you review our Privacy Policy from time to time because your continued use of the Platform, Products and Services after the effective date of any change to the Privacy Policy will be deemed to be your acceptance to the modified Privacy Policy. If you do not agree to be bound by the modified Privacy Policy, then you must not use the Platform, Products and Services anymore.

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