2. Information Collected by Us
2.1 We collect Personal Information in the following ways: (i) when You register to become a member on the Platform; and (ii) when You access the Platform and provide Information in connection with Your use of the Platform, or otherwise utilize certain aspects of the Platform as described below:
a. Your name, password, mobile number and email address. Additionally you may also opt to add the following details in your profile: profile image, address, professional information and a brief introduction about yourself . You share this information with us when You create an account on the Platform, sign-up to receive communications or materials from us, or otherwise submit a form to us.
b. Information that You submit when using the Platform, this Information includes, for example, the Information You provide while using any service available on the Platform, Information provided by You while participating in activities, which may include activity postings, survey responses, assessment responses, and any other data You generate, and Information You submit while using support services including third party partner support services.
c. Usage metrics and other device and technical data are collected when You use the Platform. This may include Information such as the number of times that You visit the Platform, the specific services accessed, as well as the frequency and duration along with device identifiers, device Information (such as OS type or browser type), cookie IDs, etc.
d. Location Information when You visit the Platform, either provided by a mobile device or associated with Your Internet Protocol (IP) address.
e. In case of companies, partnership firms, and proprietorship concerns, we may also collect relevant business details such as details pertaining to owners, promoters, shareholders, officers’ names, employees, and their contact details.
2.2 We may also collect non-personally identifiable Information. We may use both Personal Information and non-personally identifiable Information to create aggregate Information.
3. How We Use the Information Collected From You
a. To enable You to use the Platform.
b. To contact You with relevant Information pertaining to the content on the Platform and for other promotional and marketing activities. We will not share, trade, or sell Your Information to any third parties for use beyond providing the Services to You, except when You give us explicit permission and You may at any time opt-out of having Your Personal Information shared.
c. To improve our Platform and to personalize Your experience on the Platform.
d. To keep a record or monitor Your communications with us/our support team to help resolve any issues You might be facing and have complained about and, also for the purpose of monitoring quality, security, and training.
e. To inform You about our improved or additional services, such as letting You know about upcoming changes or improvements as well as to send You marketing communications, promotional offers, and deals that we think You may be interested in.
4. Storage of Information
5. Security Measures
5.1 The security of Your Personal Information is important to us. We follow generally accepted industry standards to protect Your information, both during transmission and once it is received. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security. While no security system is completely secure, we and our service providers take appropriate security measures to protect against unauthorized access or disclosure of the information collected by us. We review our security measures periodically and are committed fully to securing Your Information and protecting Your privacy.
5.2 The safety and security of Your Information also depends on You. Where we have given You (or where You have chosen) a password for accessing the Platform or certain functions therein, You are responsible for keeping this password confidential. We ask You not to share Your password with anyone.
7. Information We May Disclose and To Whom We May Disclose Information
We may only disclose the Information we collect as mentioned below. The other organizations to whom we disclose Information are obligated to use such Information only for the purposes stated below. You give Your explicit consent towards the following disclosures:
a. Disclosures to Partners
We may disclose the Personal Information we collect to our partners so that they are better able to prepare the content which is made available by us from time to time for Your best user experience. In all cases, we will require our partners to whom we provide Personal Information to comply with our instructions and policies and to use the Information solely for the purposes for which we have retained them. Disclosure of Personal Information to these service providers is done to help us serve You better.
b. Disclosures to Other Affiliated Companies
We may disclose Personal Information, such as name, address, telephone number, and transaction or experience Information to our affiliates. We may disclose Personal Information to our affiliates for purposes such as and including but not limited to:
i. Fulfilling Your requests; and
ii. Offering You other products or services that we think may be of interest to You.
c. Other Disclosures Permitted by Law
We may make additional disclosures of Information as permitted or required by law. For example, we may disclose Information to law enforcement agencies or insurance regulators without seeking any further consent from You.
d. Third Parties
i. We do not sell, trade, or otherwise transfer to outside parties Your Personal Information. We may provide Your Personal Information to website hosting partners and other parties who assist us in operating our website, conducting our business, or serving our Users, so long as those parties agree to keep this Information confidential and adhere to our instructions and policies. We may, additionally, release Your Personal Information: (a) when we, in good faith, believe that it is necessary to protect our rights or property, (b) to any successor or purchaser in a merger, acquisition, liquidation, dissolution, or sale of assets, or internal restructuring, or (c) when we, in good faith, believe that access, use, preservation or disclosure of the Information is necessary to comply with any applicable law, legal process or enforceable governmental request, to enforce applicable Agreement, including investigation of potential violations, detect, prevent, or otherwise address fraud, security or technical issues or protect against harm to the rights, property or safety of our users or the public at large, as may be required or permitted by law. We also permit consultants and lawyers who may advise us in the course of litigation or arbitration concerning the Platform to have access to Your usage data and Personal Information, if required. Your consent will not be required for disclosure in these cases, but we will attempt to notify You, to do so. However, non-personally identifiable Information forming part of Your Personal Information may be provided to other parties for marketing, advertising, or other users without any prior intimation to You and/or Your express consent.
ii. In accordance with applicable Laws, we may share Your usage data, Personal Information, and/or non-personal information with third parties to (a) assist us and such concerned third parties in studying the user behavior and accordingly evaluating and improving the quality of the Services provided through the Platform; (b) determine Your preferences and/or the Platform to suit Your needs in a more targeted way, and (c) promote the Platform to third parties.
iii. For purposes of clarity, the usage data may be provided to anyone on an aggregate and anonymous basis for analytical purposes.
iv. We may permit our third-party agents, service providers, vendors, and sub-contractors (such as vendors and suppliers that provide us with technology, services, data analysis, research, advertising, and marketing assistance and/or content in connection with our operation and maintenance of the Platform) to access Your Personal Information, in connection with performing services for us and/or to operate the Platform. However, such third-party agents are not authorized to use that Personal Information for their benefit and are required to strictly adhere to our instructions and policies.
e. Third Parties for Users based in India
If you are a User of the Connect services, we may share Your usage data and Personal Information with Your healthcare provider to enable them to assess the efficacy of the Services offered on the Platform, if applicable. We, however, do not provide Your usage data or Personal Information to Your employer except where you give your explicit consent to share this information with Your employer based on the services you elect to receive.
8. Aggregate Data
We reserve the right to transfer and/or sell aggregate or group data about the Platform users (including usage data where the same is not linked to Personal Information) for lawful purposes. Aggregate or group data is data that describes the demographics, usage, or other characteristics of the Platform users as a group, without disclosing Personal Information. We may also share aggregate data with our partners– like publishers, advertisers, or connected applications. For example, we may share Information publicly to show trends about the general use of our services through the Platform.
9. Links to Other Websites
10. Information Retention
11. Your Rights
11.1 We value the confidentiality of Your Personal Information and will take all commercially reasonable efforts to ensure that You can exercise Your rights given to You under General Data Privacy Regulation (GDPR) and other applicable data privacy laws. You have the following rights in Your Information:
a. Right to access: You have the right to request access to the Personal Information we store and process about You.
b. Right to correct: You have the right to rectify Your inaccurate Personal Information including completion of incomplete Personal Information.
c. Right to erasure: You have the right to erase Your Personal Information unless data retention for said category of data has been stipulated for a mandatory minimum period of time as per existing law.
d. Right to object: You have the right to object at any time to our processing of Personal Information. For example, if Users have requested to receive Information from us, e.g., Newsletters, but do not wish to receive further Information, data subjects can easily opt out of receiving further Information from us.
e. Right to withdraw consent: As a rule, if the processing of Your Personal Information is based on Your consent at any time by unsubscribing from an email or sending us an email. Please note that this does not affect the processing of Your Personal Information before the withdrawal of Your consent.
f. Right to data portability: You have the right to receive Your Personal Information collected and stored by us in a structured, commonly used, and readable format. You have the right to transmit this Personal Information to a third party without hindrance from us, if technically feasible
12. Legal Basis For Processing Personal Information under GDPR
If You are a resident of the European Economic Area (“EEA”), our legal basis for collecting and using the Personal Information described above will depend on which Services are You use on the Platform. Our Legal Basis for collecting and processing Your Personal Information shall be as follows:
a. Consent: basis Your consent to process Your Personal Information
b. Contractual Obligation: You have entered into a contract with us, and we need to use Your Personal Information to provide You access to the Platform.
c. Legal Obligation: wherein we have to process Your data to comply with a legal obligation we are subjected to.
d. Vital Interests: where it is necessary to process Personal Information to protect the vital interests of a natural person.
e. Legitimate Interests: where it is necessary for the purposes our legitimate interests provided, they do not override Your rights in Your Personal Information.
13. “Opting Out” – Consumer Selections Regarding Information Sharing
While browsing the Roundglass website, or our web or mobile applications and/or using the Services, You will not be provided with the opportunity to opt-out of the sharing of Personal Information until You register on the Platform.
14. Children’s Data
15. Contacting Us
Name: Mannat Wadhera
Designation: Grievance and Privacy Officer
1756 114th Avenue SE
Bellevue, WA 98004
Roundglass Wellbeing Private Limited
9th Floor, Plot no. IT C-9,
IT Park, Sector 67, Mohali,