PRIVACY POLICY

Introduction

1. The mobile application 'Dr. Morepen - Sync' (hereinafter referred to as 'App') is owned and operated by Morepen Laboratories Limited (hereinafter referred to as 'Company').

   
   

2. The Company is committed to the protection of your privacy and your personal information in accordance with applicable law.

   
   

3. This privacy policy ('Privacy Policy') discloses the Company's practices for the ‘App’ including the type of information being collected, the method of such information collection, use of such information and manner of sharing such information and can be accessed at - Privacy Policy. As per this Privacy Policy the Company protects personal information about the End-Users of the Services (as defined in the terms and conditions of use available at - T&C entered into between the Company and the End-User, hereinafter referred to as 'Terms and Conditions' ), the visitors of the App (are referred to as 'you' or 'User(s)' in this Privacy Policy).

   
   

4. The End-User's use of and access to the App is subject to this Privacy Policy and our Terms of Use. Any capitalized term used but not defined in this Privacy Policy shall have the meaning attributed to it in our Terms of Use.

   
   

5. By accessing or using the App, or by providing any information to us through the App, you confirm that you agree to the terms outlined in this Privacy Policy. You consent to the collection, use, and sharing of your information as described in the policy. We reserve the right to modify, add, or remove portions of this Privacy Policy at any time, and it is your responsibility to review it periodically. If you do not agree with the Privacy Policy, you should refrain from using the Services or providing any information. If you are using the App on behalf of someone else (e.g., a child) or an entity (e.g., an employer), you confirm that you are authorized to accept the Privacy Policy on their behalf.

   
   

6. By using the App and/or by providing your information, you consent to the collection and use of the information you disclose on the / App in accordance with this Privacy Policy.

1. WHAT DOES THE PRIVACY POLICY STATES?

   
   

   This Privacy Policy is published in compliance with, inter alia:

   
   

   1. Section 43A of the Information Technology Act, 2000;

   2. Regulation 4 of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011 (the 'SPDI Rules' ); and

   3. Information Technology (Intermediaries Guidelines) Rules, 2011.

      
      

      This Privacy Policy states the following:

      
      

      1. The type of information collected from the Users, including sensitive personal data or information;

      2. The purpose, means and modes of usage of such information;

      3. How and to whom such information will be disclosed; and

      4. How is the information collected going to be protected?

      
      

2. WHAT IS THE PERSONAL INFORMATION COLLECTED BY THE COMPANY?

   
   

   1. Information Collection: Users will be asked, via Dr. Morepen - Sync App or through other medium(s), to provide the Company information ('User Information'). User Information includes, among other things without limitation:

      
      

      1. Contact data (personally identifiable information, such as Your name, email address and phone number) of the End-Users, or Visitors.

         
         

      2. Demographic data (such as gender, date of birth, location, city, country);

         
         

      3. Health data (information about End-User's use of the Services including health readings and vitals, i.e. height, weight, blood sugar levels, blood pressure, caloric intake, fitness & activity, HbA1c readings, BMI data, and Other information that you voluntarily choose to provide on the App);

         
         

   2. Nature of Information: The information collected from you by the Company may constitute 'Personal Information' or 'Sensitive Personal Data or Information' under the SPDI Rules. 'Personal Information' is defined under the SPDI Rules to mean any information that relates to a natural person, which, either directly or indirectly, in combination with other information available or likely to be available with a body corporate, is capable of identifying such person.

      
      

      'Sensitive Personal Data or Information' is defined under the SPDI Rules to mean Personal Information about that person relating to:

      
      

      1. passwords;

      2. financial information such as bank accounts, credit and debit card details or other payment instrument details;

      3. physical, physiological and mental health condition;

      4. sexual orientation;

      5. medical records and history;

      6. biometric information;

      7. information received by body corporate under lawful contract or otherwise;

      8. visitor details as provided at the time of registration or thereafter; and

      9. call data records.

         
         

         Information that is freely available in the public domain or accessible under the Right to Information Act, 2005 or any other law will not be regarded as Personal Information or sensitive personal data or information.

         
         

         Since Sensitive Personal Data or Information means a particular kind of Personal Information., any references to Personal Information in this Privacy Policy should be construed to include a reference to Sensitive Personal Data or Information.

         
         

   3. Voluntary: By using the App, you voluntarily provide all information, including any Sensitive Personal Data or Information, and consent to its collection as outlined under the SPDI Rules. The collection of such data requires your express consent, and by agreeing to this Privacy Policy, you give that consent as per applicable laws. If you choose not to provide consent, our Services may not be available to you. You also have the right to withdraw your information at any time, as per the Terms of Use and Privacy Policy, by sending a written request to the Company. All users are expected to review and understand this Privacy Policy. Additionally, you consent to the storage of your information on the Company’s servers, even if those servers are located outside of India.

      
      

   4. Accuracy: You are solely responsible for maintaining the accuracy of the information you submit to the App, including, but not limited to, the contact information provided during Account registration. In the event that your Personal Information changes, or if you have inadvertently submitted inaccurate or incomplete information without reviewing the Privacy Policy, you may correct, update, or delete such inaccuracies by making the necessary changes within the Application or by contacting us via email. You may request confirmation from the Company regarding the possession of your personal data and, if desired, request the deletion and destruction of such data by contacting us at the relevant email address. The Company will make reasonable efforts to update its records and make the requested changes as soon as practicable. In the event that any information you provide is found to be false, inaccurate, outdated, or incomplete, or if the Company has reasonable grounds to suspect such information, the Company reserves the right, at its sole discretion, to suspend or discontinue the provision of its Services, including those provided to End-Users.

      
      

   5. Collection for lawful purpose: The company confirms that the collection of user information is for a lawful purpose and is connected to and necessary for the functions and activities of the Company which include providing the Services in the manner set out in the Terms of Use.

      
      

3. HOW IS THE INFORMATION COLLECTED GOING TO BE USED?

   
   

   1. General: The Company displays such information on its Application on an 'as-is' basis making no representation or warranty on the accuracy or completeness of the information. The Company will, however, take reasonable steps to ensure the accuracy and completeness of this information.

      
      

   2. Commercial: We may also draw upon this Personal Information for strategic purposes and in an aggregated or non-personally identifiable form for medical research, advertising including advertising by third parties, statistical analysis and business intelligence purposes, for sale or transfer of such research, statistical or intelligence data in an aggregated or non-personally identifiable form to third parties and affiliates.

      
      

      Information that is freely available in the public domain or accessible under the Right to Information Act, 2005 or any other law will not be regarded as Personal Information or sensitive personal data or information.

      
      

      Since Sensitive Personal Data or Information means a particular kind of Personal Information., any references to Personal Information in this Privacy Policy should be construed to include a reference to Sensitive Personal Data or Information.

      
      

   3. Additional Use: App also reserves the right to use the User Information provided by or about the User for the following purposes:

      1. For the purpose of providing the Products and Services to the User;

      2. Contacting Users for offering new products, features or services;

      3. Contacting Users for taking service feedback;

      4. For commercial purposes and in a non-personally identifiable form for research, statistical analysis and business intelligence purposes;

      5. For the purpose of contacting the User to complete any transaction if the User do not complete a transaction after having provided the Company with the User Information in the course of completing such steps that are designed for completion of the transaction;

      6. Analyzing software usage patterns for improving product design and utility;

      7. Analyzing anonymized practice information for commercial use;

      8. Monitoring and improving the content and usage of App;

      9. Customizing the advertising and content you see; and

      10. any other purpose for which the information was collected including medical research and analysis on chronic conditions.

          
          

          Information that does not personally identify the Users as an individual, is collected by the Company from Users, stored in a non-personally identifiable aggregated form (such as, patterns of utilization described above) and is exclusively owned by the Company.

          
          

          You hereby consent to such use of such information by the Company.

          
          

   4. Cookies: A cookie is a small piece of non-Sensitive Personal Data sent from a web server to your browser / application and stored on your device's hard drive. It does not have the ability to read data from your hard drive or access cookie files created by other apps / websites. The use of cookies is not linked to any personally identifiable information while you are using the App. Once you close your browser / app, the cookie is terminated. For example, by setting a cookie, you may avoid the need to log in repeatedly, saving time while using the App. You have the option to accept or reject cookies by adjusting your app / browser settings. You may configure your browser / app to refuse all cookies or to alert you when a cookie is being sent. If you choose to reject cookies, you may still be able to use the App, but with limited functionality. Some of our business partners may also use cookies on the App; however, we do not have access to or control over these cookies. The Company and its affiliates or business partners may use cookies to enhance the personalization of content, banners, and promotions displayed on the App.

      
      

   5. Third Party Site: This Privacy Policy applies solely to services owned and operated by the Company. The Company does not control or take responsibility for the content or practices of external websites that appear as search results or links within its Services. These third-party sites may place their own cookies or other files on the Users' devices, collect data, or request Personal Information from Users, for which the Company has no responsibility or liability. Therefore, the Company makes no representations regarding the privacy practices or policies of these third parties, nor does it guarantee the accuracy, integrity, or quality of the information, data, text, software, images, videos, or other materials available on such sites. The inclusion of any third-party site or link does not imply endorsement by the Company of the site, its provider, or its content. If you choose to visit any third-party website linked to the App, you do so at your own risk. The Company encourages Users to review the privacy policies of those third-party sites.

4. WHAT IS THE MODE AND MANNER OF USING THE INFORMATION?

   
   

   1. The Company may require the User to pay with a credit card, wire transfer, debit card, cash on delivery or cheque for Services including but not limited to Services with respect to offering premium insights, and support or for conducting on demand diagnostic tests.

   2. The Company may collect such User's credit card number and/or other financial institution information such as bank account numbers and will use that information for the billing and payment processes, including but not limited to the use and disclosure of such credit card number and information to third parties as necessary to complete such billing operation.

   3. Verification of credit information, however, is accomplished solely by the User through the authentication process. User's credit-card/debit card details are transacted upon secure sites of approved payment gateways which are digitally under encryption, thereby providing the highest possible degree of care as per current technology. However, the Company provides you an option not to save your payment details. Users are advised, however, that internet technology is not full proof or safe and the User should exercise discretion on using the same.

   4. If you wish to request that we no longer use your information to provide you services or to cancel your End-User Account, you will be provided with options like “Deactivate Account” or “Erase My Health Data” in your App account settings. We shall not retain such information if you choose to Erase your health data saved on the App.

   5. Your data shall be completely anonymized and aggregated, and only then may be held by us as long as necessary for us to provide our Services effectively. As specified before, our use of the anonymized data will be towards betterment of science, and further possibly for strategic improvements in application or process, commercial interests and for analytical purposes.

   6. All the Company's employees and data processors, who have access to, and are associated with the processing of sensitive personal data or information, are obliged to respect the confidentiality of every End-Users' sensitive personal data and information.

      
      

5. HOW AND TO WHOM IS THE INFORMATION SHARED AND DISCLOSED?

   
   

   1. The Company may share User Information in an aggregated non-personally identifiable manner with its partners and third parties for the purposes set out in paragraph (ii) above.

      
      

   2. The Company may also disclose or transfer End-Users' personal and other information a User provides, to a third party as part of restructuring, reorganization or a sale of the assets of the Company or corporation division. Any third party to which the Company transfers or sells its assets to will have the right to continue to use the personal and other information that the Users provide to us, in accordance with the Terms of Use.

      
      

   3. To the extent necessary to provide End-Users with the Services, the Company may provide their Personal Information to third party contractors who work on behalf of or with the Company to provide End-Users with such Services, to help the Company communicate with End-Users or to maintain the Application and/or Generally these contractors do not have any independent right to share this information, however certain contractors who provide services on the Application, including the providers of online communications services, will have rights to use and disclose the Personal Information collected in connection with the provision of these Services in accordance with their own privacy policies.

      
      

6. HOW IS THE USER INFORMATION PROTECTED?

   
   

   1. The Company has implemented best international market practices and security policies, rules and technical measures to protect the personal data that it has under its control from unauthorised access, improper use or disclosure, unauthorised modification and unlawful destruction or accidental loss. However, for any data loss or theft due to unauthorized access to the User's electronic devices through which the User avails the services including the Services listed in the Terms of Use, the Company shall not be held liable for any loss whatsoever incurred by the User.

      
      

   2. The Company implements reasonable security practices and procedures and has a comprehensive documented information security programme and information security policies that contain managerial, technical, operational and physical security control measures that are commensurate with respect to the information being collected and the nature of the Company's business. The reasonable security practices and procedures implemented by the Company include but are not limited to: encrypting data when it is on the move using industry standard practices, keeping all the data within private cloud, regularly changing production keys and password, secure and very limited access to all production servers, performing regular security updates on our servers and more.

      
      

   3. The Company takes your right to privacy very seriously and other than as specifically stated in this Privacy Policy, will only disclose your Personal Information in the event it is required to do so by law, rule, regulation, law enforcement agency, governmental official, legal authority or similar requirements or when the Company, in its sole discretion, deems it necessary in order to protect its rights or the rights of others, to prevent harm to persons or property, to fight fraud and credit risk, or to enforce or apply the Terms of Use.

      
      

   4. Your Personal Information is maintained by the Company in electronic form on its equipment, and on the equipment of its employees. Such information may also be converted to physical form from time to time. The Company takes all necessary precautions to protect your Personal Information both online and off-line, and implements reasonable security practices and measures including certain managerial, technical, operational and physical security control measures that are commensurate with respect to the information being collected and the nature of the Company's business.

      
      

   5. It is important for you to protect against unauthorized access to your password, your computer and your mobile phone. The Company does not undertake any liability for any unauthorised use of your login to App including Account and password. If you suspect any unauthorized use of your login to App including Account, you must immediately notify the Company by sending an email to devices.customercare@morepen.com. You shall be liable to indemnify the Company due to any loss suffered by it due to such unauthorized use of your login to App including Account and password.

      
      

   6. The Company makes all User information accessible to its employees, agents or partners and third parties only on a need-to-know basis, and binds all such employees to strict confidentiality obligations.

      
      

   7. Notwithstanding the above, the Company is not responsible for the confidentiality, security or distribution of your Personal Information by our partners and third parties outside the scope of our agreement with such partners and third parties. Further, the Company shall not be responsible for any breach of security or for any actions of any third parties or events that are beyond the reasonable control of the Company including, acts of government, computer hacking, unauthorised access to computer data and storage device, computer crashes, breach of security and encryption, poor quality of Internet service or telephone service of the User etc.

      
      

7. HOW CAN YOU CONSENT TO THIS POLICY?

   
   

   1. Consent: You acknowledge that this Privacy Policy is a part of the Terms of Use or other agreements with the Company, whichever applicable and you unconditionally agree that becoming a User of Dr. Morepen - Sync signifies your assent to this Privacy Policy and the use of the information including its disclosure in the manner provided above. Your visit to the Dr. Morepen - Sync and/or App, and use of the Services is subject to this Privacy Policy and the Terms of Use.

   2. Address for Privacy Questions: Should you have questions about this Privacy Policy or the Company's information collection, use and disclosure practices, you may contact us at the address: 409, 4th Floor, Antriksh Bhawan, 22, K.G. Marg, New Delhi – 110001. The Company will use reasonable efforts to respond promptly to any requests, questions or concerns, which you may have regarding our use of your Personal Information. If you have any grievance with respect to our use of your information, you may communicate such grievance to the Office of Vice President, Morepen Laboratories Limited, addressing:

      
      

      Mr. Amrit Ravi

      Vice President
      Morepen Laboratories Limited
      amrit.ravi@morepen.com

      
      

8. CHANGES TO THIS PRIVACY POLICY

   
   

   The Company reserves the right to update, change or modify this privacy policy at any time. Any update, change or modification in the privacy policy shall come to effect from the date of such update, change or modification.

   
   

9. GOVERNING LAW AND JURISDICTION

The governing law, jurisdiction and related matters with regards this Privacy Policy shall be in accordance with the Terms and Conditions.