For the purposes of this Policy
“Non-personal Information” refers to any non-personal information collected from End-Users pursuant to their use of the Services, including but not limited to the browser name, the type of device, computer, and technical information about End-Users means of connection to the Services such as the operating system, hardware model, the Internet service providers utilized, mobile carrier and other similar information.
“Personal Information” refers to any information that identifies or can be used to identify, contact or locate the person, to whom such information pertains including, but not limited to, when End-Users register, respond to a survey, fill out a form, and anything else in connection with the Services. Ultrahuman will collect Personal Information from End-Users only if they voluntarily submit such information to us.
Sensitive Personal Data or Information (“SPDI”) consists of information relating to the following:
“Third Party” refers to any person or entity other than you or us.
INFORMATION THAT WE COLLECT:
For the purposes of registering and creating a user-account (“User Account”) on the Platform to avail the Services, you may be required to disclose information including personal contact details such as your name, telephone number, profile photo, email address, residential/commercial address, birthday, SMS for OTP, and other information. In some situations, we may also require you to disclose demographic information including gender, age, and other information relevant to the provision of Services. We may collect some information about your friends, like their names, phone numbers, or email addresses, when you invite or refer them to the Services or import your contacts. If you opt for creating a User Account by providing your mobile number and signing in through OTP you receive via SMS, you agree that we may be able to retrieve your OTP from the SMS received on your registered mobile number and populate and submit the OTP for authentication and creation of User Account, and if we do so, you agree that we will only be acting as your technology intermediary to eliminate the need for you to manually enter your OTP.
If you access the Services without creating a User Account, we may still gather and store certain Non-Personal Information about your visit. This information does not identify you personally and cannot be linked back to you unless you decide to identify yourself. If you are accessing our Services, we may collect the following Non-Personal Information: IP address, the type of browser and operating system used to access our Platform, the date and time you accessed our Platform and if you were linked to our Platform from another website, the address of that website as well as additional information related to your visit may be collected. We may also collect certain information that our End-Users provide such as inter alia e-mail addresses of End-Users who communicate with us via e-mail and their country including IP addresses.
Ultrahuman collects SPDI such as weight, height, etc only voluntarily and knowingly provided by its End-Users. Ultrahuman undertakes to protect the SPDI provided by you in accordance with reasonable security practices and procedures and undertakes not to transfer or disclose your SPDI to a Third Party for any purpose without your prior consent.
You can choose not to provide us with certain information, but then you may not be able to register with us or to take advantage of some of our features / Services.
If you link your existing Instagram, Facebook, Snapchat, Apple or Google account with the User Account in order to avail the Services, we may collect such third-party site account details. Social media platforms and third-party apps may give us information about you. We may also collect information about you from other users. This might include your name, phone number, or email address if they invite or refer you to our Services or if they have linked their contacts to their User Account.
We may collect certain Information that our End-Users provide such as inter alia e-mail addresses of End-Users who communicate with us via e-mail, their country including IP addresses, the End-User specific URL used to host the session.
Our Services are currently free of charge for our End-Users. Since we do not charge any usage or subscription fee from our End-Users to access and use the Services, we do not collect debit/credit card information or other sensitive personal financial information of End-Users. However, it is important that if you detect any scam or fraudulent activity wherein any Third-Party tries to wrongfully gain access to your financial information in the garb of providing access to use our Services, please immediately report the matter to your local authorities and write to us at firstname.lastname@example.org.
PURPOSE OF COLLECTION:
We may receive, collect, and use the Information to deliver the Services, to identify and troubleshoot problems with the Services, and to improve the Services.
We make all efforts to ensure that we collect only such Information that we believe to be relevant in order to support and facilitate provision of Services, including but not limited to:
We are not in the business of selling Information to Third Parties for the above purposes, and all Information shared with Third Parties in relation to the above purposes, will be on a no-name aggregate basis.
PRINCIPLES OF PROCESSING:
We will not process Information in a way that is incompatible with the purposes for which it has been collected or subsequently authorized by you or collect any Information that is not needed for the mentioned purposes. For any new purpose of processing we will ask your separate explicit consent. To the extent necessary for those purposes, we take all reasonable steps to ensure that Information is reliable for its intended use, accurate, complete, and current. We also undertake to collect only such amounts and types of Information that is strictly needed for the mentioned purposes.
When you access and use the Services, some Personal Information may be disclosed to other users. For instance, when you attend or participate in a video chat or audio-visual conference session, your name, your image (still and moving), your online and offline status, your individual points or scores, your rank in the leaderboard, stats pertaining to your last or overall activity such as time spent, scores or points accumulated etc. may be visible to your connections or your contacts.
We may also disclose Information when we respond to valid legal processes. In the event we are required to respond to subpoenas, court orders or other legal process, your Information may be disclosed pursuant to such subpoena, court order or legal process, which may be without notice to you. We may also disclose Information when reasonably necessary to preserve our legal rights.
We use Third-Party service providers to help us provide portions of the Services and give support. They only receive Information needed to provide their services. We have agreements with our service providers that say they cannot use any of this Information for their own purposes or for the purposes of another third party. We prohibit our service providers from selling Information they receive from us or receive on our behalf. We require service providers to use Information only in order to perform the services we have hired them to do (unless otherwise required by law).
We may also share Information for other reasons we may describe to you or as permitted under law.
HOW WE PROTECT INFORMATION:
We maintain appropriate administrative, technical, and physical safeguards to protect your Information from accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use and other unlawful forms of processing. We implement appropriate physical, electronic and managerial procedures to safeguard and help prevent unauthorized access and for the purposes of maintaining Information security.
ACCESS TO THIRD-PARTY:
We do not sell or share your Information to any Third Party i.e. marketing companies, agencies, advertisers or any similar companies in exchange of fees/payments. We also do not share or allow any Third-Party to use your Information stored with us for any other purpose except consented by you or if required under any legal obligations.
However, we may use certain standard advertising tools on our marketing sites which, provided you have allowed it in your cookie preferences, sends Information to the tool providers, such as Google. If we do so, we will provide a “Do Not Sell My Personal Information” link at the bottom of our marketing sites. You can use this link to change your Cookie Preferences and opt out of the use of these advertising tools. If you opt out, Information that was used by these tools will no longer be shared with Third Parties.
We may engage Third-Party processors to perform particular operations with your Information for us. Such Third-Party processors are companies that help us operate the Services, support our communication with you or perform other Services-related activities. They may process certain Information on our behalf to accomplish the goals related to the Service functions and associated activities. Third-Party processors act only in accordance with our instructions and process only such amount of Information as we instruct them to process. We remain fully liable for any acts or omissions of our Third-Party processors and undertake to execute formal data processing agreements with them to the extent required by applicable law.
We will only retain your Information for as long as necessary to fulfil the purposes described above. We may also retain your Information, if necessary, for our legitimate business interests, such as fraud prevention or to maintain the security of our users. 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 calculated based on the date you last expressed interest in our content, products, or Services.
We will take reasonable steps to accurately record the Information that you provide to us including any subsequent updates. You can review, update and amend the Information that we maintain about you, and you may request we delete Information about you that is inaccurate, incomplete or irrelevant for legitimate purposes, or is being processed in a way which infringes any applicable legal requirement.
DATA SUBJECT RIGHTS:
For the purposes of EU’s General Data Protection Regulation (“GDPR”) and California Consumer Privacy Act (“CCPA”), our End-User is the “Controller”, or decision maker, for the Information, and we are the “Processor”, acting as a “service provider” for, and at the direction of, our End-User. “Processing” just means doing something with the Information. We are typically required to follow an End- User’s instructions about Personal Information we hold for that user.
If you are an EEA, Swiss, or UK resident, you may have the right to access your Personal Information, the right to correct your Personal Information, the right to request deletion of your Personal Information, the right to request restricted processing of your Personal Information, the right to a portable copy of the Personal Information you have provided, and the right to object to processing of your Personal Information, such as for direct marketing. You may obtain more information on exercising these rights granted under the GDPR by writing to us at email@example.com.
If you are a California resident, you can request Personal Information that we may have collected about you in the previous twelve months, the reason we collected it, the category of entities with whom we have shared it and the reason for any disclosure, by writing to us at firstname.lastname@example.org.
We generally store Information closest to the End-User where they are located through our authorized Third-Party data centers available globally. We may transfer your Information to Third-Parties acting on our behalf, for the purposes of processing or storage. Our End-Users may choose to have their Information stored in their geographic vicinity.
Reasonable security 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 Services, such as by investigating suspicious activity or violations of our Terms of Services, Acceptable Use Policy, and to ensure our Services are being used legally. If we do detect something risky that would compromise on your privacy and security, we shall notify you by updating our terms and help guide you through steps to stay better protected.
We shall take complete measures to safeguard you and our Services from unauthorized access, alteration, disclosure, or destruction of Information we hold, including:
ASSIGNMENT AND TRANSFER:
LAW AND PROTECTION:
Only Indian courts shall have jurisdiction in connection to and the usage of the Services. We may collect, use, preserve, and share your Information if we have enough cause to believe that it is reasonably necessary to: Respond pursuant to applicable Indian laws or regulations, to legal process, or to government requests; Enforce our Terms of Services and any other applicable terms and policies, including for investigations of potential violations; Detect, investigate, prevent, and address fraud and other illegal activities, security, or technical issues; or Protect the rights, property, and safety of our users, Ultrahuman, its affiliates, or others.
MODIFICATIONS TO THIS POLICY:
Ultrahuman Healthcare Private Limited is located at 1st Floor, Gopalakrishna Complex #45/3, Residency Road Bangalore 560025, India.