WHY THIS PRIVACY POLICY?

This Privacy Policy states the following:
- The type of information collected from the Users, including Personal Information (as defined in paragraph 2 below) and Sensitive Personal Data or Information (as defined in paragraph 2 below) relating to an individual.
- The purpose, means and modes of collection, usage, processing, retention and destruction of such information, and
- How and to whom Acko will disclose such information.

1. Information Collected:
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- We shall collect personal information of the User, by which he/ she/ it, as a person can be identified, including without limitation, name, gender, age, date of birth, height, weight, mobile number, business name, date of incorporation, address, email address, any identity proof number, phone number, health and fitness related information, your diagnostic test reports that you share with us or request third party service providers to share with us, etc (“Personal Data” or “Personal Information”, or “Sensitive Personal Data or Information”, as the case may be). It is hereby clarified that :
- Such shall include:
       - physical, nutritional, fitness, medical, and other information, including without limitation, physiological factors such as weight, sleep patterns, stress, diet and exercise, various health symptoms, as may be required for the effective use of the Platform.
       - information that does not reveal the identity of the User in any way, including without limitation, the details of the User’s browser and operating system, time spent using Platform, other webpages visited by the User, unique identifiers of the Device, information of WiFi connectivity, etc..
       - GPS signals, device sensors, Wi-Fi access points, and cell tower IDs for displaying the User’s location on a map.
       - credit card or other payment account information solely for processing payments (“Payment Information”). Provided further that the User’s Payment Information shall not be stored on the Platform, except for:
       - (a). the name and address of the card holder, the expiry date and the last four digits of the credit card number.
       - (b). processing future payments, subject to the User’s prior consent. Where necessary Payment Information of the User may be stored, by reputed payment gateway service provider/s engaged by Us. Such payment gateway service provider/s shall treat such information in accordance with their respective privacy policies, available on their respective websites.
       - While some Personal Information of User has to be mandatorily provided, others are optional and certain portions of the information shall remain private and some shall be displayed to other Users;
       - Additional information may be gathered during subsequent use of the Platform by the User, whenever the User  chooses to provide it.
- Certain mandatory information shall be collected at the time of registration on the Platform which is required to enable the User to login to the Platform and for Us to verify the User’s identity; and to safeguard against illegal activities like fraud, cheating, misappropriation, etc. as may be determined by Us; and/or our banking and service  partners.
- In order to use the facilities and services available on the Platform, the User may be required, from time to time, to provide certain additional Personal Information after registration on the Platform, which information shall be collected only upon receiving the User’s express consent.
- After obtaining the User’s specific consent to allow the Platform to access the User’s SMS inbox, we may collect relevant information from text messages (SMS) received by the Users from providers of services and/or products (including but not limited to retail outlets, financial institutions, mobile carriers and utility companies), that shall enable us to provide better services and products to the Users. We shall only access business messages that originate from alphanumeric senders.
- In order to enhance our ability to provide valuable services and experiences to the User, We may:
       - Automatically receive, collect and analyse your location information which may be accessed through a variety of methods including, inter alia, GPS, IP address, and cell tower location, and
       - Collect information pertaining to your Device and your usage thereof, including, inter alia, the names of the other applications on your mobile Device and how you use them, information about your Device, and information about your use of features or functions on your Device.
       - By providing us your Personal Information, and Sensitive Personal Data or Information, you provide your express consent to us to collect, store, process, transfer (including outside India) and disclose to third parties your Personal Information and Sensitive Personal Data or Information in accordance with the terms of this Privacy Policy.
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2. Method And Manner Of Use Of User Personal Information
- We shall also use the User Personal Information to enable activities and transactions that need to occur during the process of lending, such as:
       - Generating and maintaining User profiles on the Platform;Provide personalized features, offers, discounts, services, etc;
       - Maintaining regular communications with the User;Modifying the Platform from time to time to cater to the User’s interests;
       - Providing the Platform and the functions and features therein, efficiently;Making charts and comparisons;
       - Personalizing the fitness statistics;Calculating the average to determine the Users’ fitness assessment reports;
       - Software verification or administering software upgrades;
       - Allowing the Users to participate in surveys regarding services on the Platform;
       - Improving Users’ experience;Offering new services;
       - Providing custom, personalized content and information;
       - Monitoring the effectiveness of marketing campaigns by Us;
       - Monitoring aggregated metrics such as total number of visitors and traffic;
       - Maintaining the quality of services on the Platform and providing general statistics regarding their use;
       - Sharing email notifications, confirmations, technical notices, updates, security alerts, and support and administrative messages that the Users may request;
       - Maintaining archival or backup of the Platform;
       - Altering the User about updated information and such other new or updated services that may be offered by Us;
       - Allowing access to exclusive features or functionality of the Platform;
       - Co-ordinating and Collecting Blood Samples from the User;
       - Co-ordinating for attachment of Continuous Glucose Monitoring Devices (“CGMS”);
       - Sharing of test reports and other Personal Information or Sensitive Personal Data or Information with third party registered medical practitioners upon specific request by the User;
       - Arranging of expert consultations;
       - to monitor our infrastructure and screen for potential risk and fraud (in particular, User’s IP address), and more generally to improve and optimise our Platform (for example, by generating analytics about how our users browse and interact with the Platform, and to assess the success of our marketing and advertising campaigns);
       - to comply with applicable law;
       - and for any other purposes that are permissible under applicable law.
- You acknowledge that you are licensing Us to use, modify, display, distribute and create new material from the information you provide through the Platform to render certain services on the Platform. By providing such information, you automatically agree, or promise that the owner of such information has expressly agreed to allow or license, as the case may be, Us to use the information in the manner set out in this Privacy Policy, without the payment of any fees. We may, to the extent permitted by law, also use, licence, reproduce, distribute, disclose, and aggregate, non-personally identifiable information that is derived through your use of the Platform and you hereby provide consent for the same.

3. Sharing Of Personal Information
- We shall not use Personal Information of User for any purpose other than as specified herein. 
- We shall not rent, sell or share  Personal Information of User and shall not disclose any of the User’s personally identifiable information to third parties, unless:
       - it is pursuant to obtaining the User’s permission.
       - it is in connection with the Services being rendered through the Platform.
       - it is to help investigate, prevent or take action regarding unlawful and illegal activities; suspected fraud, potential threat to the safety or security of any person, violations of the Company’s terms and conditions (“Terms of Use”), or as defence against legal claims.
       - it is a case of special circumstances such as compliance with court orders, requests/order, notices from legal authorities or law enforcement agencies compel us to make such disclosure.
       - it is in connection with matters relating to the usage of the Platform by User to help detect and prevent identity theft, fraud and other potentially illegal acts; correlated or multiple accounts to prevent abuse of services on the Platform.
       - it is to facilitate joint or co-branded services that the User requests, where such services are provided by more than one corporate entity other than the Company.
       - it is required to do so by law or regulation; to its legal counsel, law enforcement officers, governmental authorities who have asserted their lawful authority to obtain the information or where the Company has in good faith reasonable grounds to believe that such disclosure is reasonably necessary to enforce its Terms of Use or this Privacy Policy;
       - there is a merger with or transfer of business of the Company to another business entity, the Company shall transfer Personal Information of User(s) and such other information collected to the entity which acquires the business. In such cases, the Company shall require that the new business entity to follow this Privacy Policy with respect to the Personal Information; and
       - It forms part of the information We share with advertisers on an aggregate basis.
       - We or our affiliates use third-party service providers, consultants, coaches, etc to help us operate our business, the Platform, provide the Services or administer activities on our behalf, to you, such as sending out newsletters, surveys or questionnaires or other marketing activities with respect to our or our affiliates products / services. We may disclose Your information to third parties (including any foreign third parties) for the purposes mentioned under Section 2 above, inter alia, in order to perform checks, provide You with customer support facilities, to comply with Our legal obligations including prevention of money laundering or otherwise as prescribed under any applicable laws, to enforce Our Terms, to facilitate marketing and advertising activities for us and/or our affiliates, to conduct analysis, to provide You services, to facilitate services for You, to prevent, detect, mitigate, and investigate fraudulent or illegal activities related to Platform and to avail services from third parties for data analysis and market research. Some of these functionalities may include: Analysing customer behavior, conducting research into customer behavior and contacting the customers for the said purpose, and to automate our marketing and outreach efforts, etc.
       - With its affiliates to offer new products and services to you from time to time.
       - You will be able to avail the service offered / facilitated by Us and/or our affiliates. You may have interest or intention of availing such services or a general query with respect to the services available on Platform and through Platform or by our affiliates. Accordingly, You may contact us or we may contact you. By contacting Us in anyway and/or by providing us Your phone number and contact details and other details or showing interest in any product / service of the Company or its affiliates, You thereby give Us and/or affiliates the right to use the said personal details as per this Policy.
- Provided further that Acko shall ensure that the recipient of the User’s information maintains the same level of data protection that is adhered to by Acko as provided for under this Privacy Policy.

4. Information Security
- The information provided by the User is stored in access controlled facilities with restricted access. Personal Information of User transmitted over the internet is protected through the use of encryption.
- If a password is used to help protect User accounts and account information, it is the responsibility of the User to keep the password confidential. You have to ensure that You always log out, before sharing the device with a third party and it is advised that the User utilise a service to protect access to the User’s Device.
- We shall use generally accepted industry standards to protect the Personal Information of User(s) submitted to Us, both during transmission and upon receipt. However, please be advised that, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, even though We strive to use commercially acceptable means to protect Personal Information of User, We cannot guarantee its absolute security and your use of the Platform is at your sole risk and discretion. We also cannot warrant that such Personal Information of User may not be misused in the event our safeguards and protocols are breached by a malicious third-party. Further, We are not liable to nor can we fully control  the actions of other users with whom you may choose to share your information.
- The collection, usage, and sharing of User Personal Information by us shall be in compliance with the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 and other applicable laws.

5. Procedure For Removing User Name from the Records
- If and when a User is desirous of having his/her name and other details removed from our records, immediately upon receiving the User’s written request to that effect We shall, subject to the terms here of, remove and/delete all such information. Provided however that We shall retain such Personal Information as may be necessary to comply with our legal obligations, resolve disputes, and enforce any of its agreements with third parties.
- We reserve the right to close the User account if the User opts out of receiving certain crucial notices that are required by Us to perform the services through the Platform.
- It is hereby clarified that the Company shall retain such information as collected for registration for a period of one hundred and eighty days after any cancellation or withdrawal of the User’s registration, as the case may be or such longer period as prescribed under applicable laws.

6. Advertisements
- The Company contracts with its affiliates and other third parties to serve advertisements on its behalf across the internet and the Platform. The advertisers may collect information about Your visits to our Platform, and Your interaction with our products and services.
- The advertisers may also use information about Your visits to the Platform and other websites to target advertisements for goods and services. This information is collected through the use of a pixel tag, which is industry standard technology used by most major websites. Such third parties are not permitted to sell or share Your personally identifiable information as part of this process.
- Certain third-party vendors, advertising platforms, remarketing platforms, and customer query management platforms use cookies to serve advertisements based on the User's prior visits to our Platform.

7. Non- Personal Information / Data
a. “Non-Personal Information” means and includes any information that does not reveal Your specific identity, such as, browser information, information collected through Cookies (as defined below), pixel tags and other technologies, demographic information etc. Our Platform gathers some information automatically when You visit Platform or avail any Service and stores it in your log files.
b. We may collect certain information about Your computer or other electronic device through which You have accessed Platform or our Services to facilitate, evaluate and verify Your use of Platform.  
c. We collect data about how you interact with our Services or Platform. This includes data such as access dates and times, Platform features or pages viewed, Platform crashes and other system activity, type of browser, and third-party sites or services used before or in the course of interacting with our Services.
d. “Cookies” are small files that reside on Your computer's hard drive and generally contain an anonymous unique identifier and are accessible only by Platform that placed them there and not any other sites. You may refuse to accept Cookies by activating the setting on Your browser which allows You to refuse the setting of Cookies. However, if You do not provide such information, You may be unable to access certain parts of Platform. Unless You have adjusted Your browser setting so that it will refuse Cookies, Our system may issue Cookies when You log on to Platform. The use of Cookies by Our partners, affiliates, advertisers or service providers is not covered by the Policy.
e. We collect data about the devices used to access our Services, including the hardware models, device IP address, operating systems and versions, software, preferred languages, unique device identifiers, advertising identifiers, serial numbers, device motion data, and mobile network data.
f. We collect the location data from you in two ways: (i) when you add the pin code as part of your account creation process; and (ii) from your mobile device when enabled by you to do so. We use this data to assess servicing of Services or Platform to you. We collect the data about your installed applications, including the applications that you have installed on and from the date you create your Account on the Platform and the manner in which you use them.
g. IT IS REITERATED THAT THIS POLICY DOES NOT APPLY TO PROCESSING OF ANY DATA IN AN ANONYMISED, AGGREGATED OR DE-IDENTIFIED DATA AVAILABLE WITH US OR COLLECTED BY US OR PROVIDED TO US. THE USE OF SUCH NON-PERSONAL DATA / INFORMATION (INCLUDING RETENTION, SHARING AND PROTECTION) SHALL BE AT OUR SOLE DISCRETION AND REQUIREMENTS.

8. Procedure For Correcting Inaccuracies In User Personal Information
- The User may correct or update any information online. In the event of loss of access details, the User may retrieve the same or receive new access details by sending an e-mail to our grievance redressal office as per the details provided in the Privacy Policy.

9. Delete targeting cookies
- Your interest profile can be removed by deleting your browser's cookies.
- Information stored on cookies.
The cookie information stored on the User's hard drive is: (i) User segment hits or information on a specific product, service, brand or model in which the User has shown interest during its visit to a certain website and (ii) time and date stamp of the latest update of the User profile.  If the cookie is deleted by the User, all profile data is removed. For the sake of clarity, no segments relating to information which Acko considers sensitive have been or will be created, such as segments relating to political opinions, religious beliefs, physical or mental health conditions or sexual life. Further, Acko is very sensitive to the issue of children's privacy and marketing directed to children. No segments are intended to be established for the profiling of children.

10. Grievance Officer
- In accordance with Information Technology Act 2000 and rules made thereunder, the name and contact details of the Grievance Officer are provided below:
             Name: Rakesh Shivran
             Email: rakesh@onecare.co.in
             Time: Monday - Friday 9AM - 6PM

             The Grievance Officer shall acknowledge the complaint within twenty four hours and dispose off such complaint within a period of fifteen days from the date of its receipt;
- The Company shall, within twenty-four hours from the receipt of a complaint made by a User, in relation to any content which is prima facie in the nature of any material which exposes the private area of such individual, shows such individual in full or partial nudity or shows or depicts such individual in any sexual act or conduct, or is in the nature of impersonation in an electronic form, including artificially morphed images of such individual, take all reasonable and practicable measures to remove or disable access to such content which is hosted, stored, published or transmitted by it.


11. CHILDREN'S AND MINOR'S PRIVACY
- Acko strongly encourages parents and guardians to supervise the online activities of their minor children and consider using parental control tools available from online services and software manufacturers to help provide a child-friendly online environment. These tools also can prevent minors from disclosing their name, address, and other personally identifiable information online without parental permission. Although the Acko Website and Services are not intended for use by minors, Acko respects the privacy of minors who may inadvertently use the internet or the mobile application.

12. DATA PROTECTION RIGHTS
- You have certain choices available to You when it comes to Your Personal Information. Subject to any exemptions provided by the applicable laws, You may have the following rights:
       - Rectifying, correcting, updating and removing Your information:
You can access, edit, modify and/or update Your Personal Information by logging into Your user profile or You can write to Us via email or other means of communication in case You want to exercise Your data protection rights in respect of Personal Information stored or processed by Us to access, rectify, delete, port or restrict processing of such Personal Information. Upon receipt of a request and upon verification, Acko will remove the Personal Information within thirty (30) days save and except such records or data as required to be maintained by it under Applicable Laws.
       - Accessing and updating or deleting Your information:Our Services and related documentation on Our Website provide You with the ability to access, update and delete certain Personal Information from Your account, if any. We will provide You with information about whether We hold any of your Personal Information upon request. We will respond to such requests within a reasonable timeframe. Please note, however, that We may need to retain certain information for record keeping purposes, to complete Our Services and related obligations to You or to comply with Our legal obligations.
       - Object or restrict processing of Your information:You have the right to: (i) object to Our processing of Your Personal Information; and/or (ii) request that We restrict the processing of Your Personal Information. You can log into Your user profile or You can write to Us via email or other means of communication in case You want to exercise any or all of these data protection rights.

- If You have made any request in order to exercise any or all of the above mentioned data protection rights, Acko, on best effort basis, shall respond to You within 30 (thirty) days.