PRIVACY POLICY MITRAMCARES
Last updated: 23-Oct-2024
This Privacy Notice describes Our (“Swavalambanam MitramCares Private Limited (“MitramCares”)”) policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You. By visiting the MitramCares website or Mobile App, providing your information or availing our product/services, you expressly agree to be bound by this Privacy Policy and the applicable service/product terms and conditions of use. We value the trust you place in us and respect your privacy, maintaining the highest standards for secure transactions and protection of your personal information.
ABOUT MITRAMCARES
The MitramCares App aims to facilitate a meeting and an interaction between its Users and the Artificial-Intelligence(“AI”) enabled system which intends to in-take the Users requirements and learn the patterns in the queries and the conversations of the Users therein so as to assist the counsellors and the trained psychologists to provide requisite suggestions to the Users. MitramCares aims to provide an intelligent, digital assistant to the Users that is capable of learning and assisting the Users through pattern recognition from the conversations and interactions between the Users and the MitramCares App
FOR USERS IN INDIA
This privacy policy is published and shall be construed in accordance with the provisions of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 under the Information Technology Act, 2000 and the Digital Personal Data Protection Act, 2023; that require publishing of the privacy policy for collection, use, storage, transfer, disclosure of Personal Information (means and includes all information that can be linked to a specific individual) including Sensitive Personal Information (all Personal Information which requires heightened data protection measures due to its sensitive and personal nature) (both, hereinafter referred to as “Personal Information”), excluding any information that is freely available or accessible in public domain. If you do not agree with this privacy policy, please do not use or access our Platform.
INTERPRETATIONS AND DEFINITIONS
Interpretation
The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.
Definitions
For the purposes of this Privacy Policy:
“Affiliate” means an entity that controls, is controlled by or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
“Company” (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to “Swavalambanam MitramCares Private Limited (“MitramCares”)”.
“Cookies” are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
“Device” means any device that can access the Service such as a computer, a cellphone or a digital tablet.
“MitramCares Entities” - shall mean group, affiliates, associates and subsidiaries of MitramCares.
‘MitramCares Platform” - Refers to any platform owned/subscribed/used by Swavalambanam MitramCares Private Limited (“MitramCares”) or any other MitramCares Entities not limited to websites, mobile applications, devices, URLs/links, notifications, chatbot, or any other communication medium used by MitramCares Entities to provide its services to its Users.
“MitramCares Services” - shall include all services extended / to be extended by MitramCares and MitramCares entity as a group.
“MitramCares System” – The Artificial Intelligence System that is used in the Mobile App, which is trained to recognize patterns in conversations, among other aspects, and suggest recommendations based on preferences or perform other activities as defined within the scope of services vis-à-vis a User’s preference.
“Personal Data” is any information that relates to an identified or identifiable individual.
“Platform” refers to the Website and all and any touch points of the Company with the Users
“Service” refers to the Company’s Website and Mobile Application.
“Service Provider” means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
“Usage Data” refers to data collected automatically, either generated by the use of the Service (Application form etc.) or from the Service infrastructure itself (for example, the duration of a page visit).
“Website” refers to MITRAMCARES website and Mobile Application, accessible from www.mitramcares.com and mitramcares mobile App
“You” means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.
DATA FIDUCIARY
For the purpose of the DPDP ACT, 2023 Swavalambanam MitramCares Private Limited (“MitramCares”) is the data controller of your information. This means that we are responsible for deciding how we hold and use your personal data. We are required under Data Protection Legislation to notify you of the information contained in this Privacy Notice.
DATA PROTECTION OFFICER
We have appointed a Data Protection Officer (DPO) to oversee compliance with this Privacy Notice. If you have any questions about this Privacy Notice or how we handle your personal data, please contact the DPO at the contact details set out below- The Data Protection Officer, Geeta DESAI.
DATA AND INFORMATION COLLECTION
We may collect your Personal Information when you use our services or Platform or otherwise interact with us during the course of our relationship. We collect Personal Information which is relevant and absolutely necessary for providing the services requested by you and to continually improve the MitramCares Platform.
Personal and Sensitive Personal Information collected includes but not limited to:
Name
Address
Phone number / Mobile number
E-mail id
Location, etc.
Health habits
Hobbies
Daily activities
Any KYC related information and your business-related information as required by the Company or mandated under Law
LAWFUL GROUNDS FOR USING YOUR INFORMATION
We are permitted to process your personal data in compliance with Data Protection Legislation by relying on one or more of the following lawful grounds:
You have explicitly agreed to us processing such information for a specific reason.
The processing is necessary to perform the agreement we have with you or to take steps to enter into an agreement with you.
The processing is necessary for compliance with a legal obligation we have.
The processing is necessary for the purposes of a legitimate interest pursued by us, which might be:
to provide services to you;
to ensure that our customer/User accounts are well-managed;
to protect our business interests;
to ensure that complaints are investigated;
to evaluate, develop or improve our services; or
to provide more focused and targeted service to you; and
to keep our Users informed about relevant services, unless you have indicated at any time that you do not wish us to do so.
PURPOSES OF PROCESSING
Specifically, we may use your information for the following purposes and under the following legal bases:
To provide better responses and suggestions from the A.I. based MitramCares System
where necessary for the performance of our agreement to provide you with the best targeted service tailored to your preference
To provide reminders for better health management
where necessary for the performance of our agreement to provide you with the best targeted service tailored to your preference
To provide insights to the trained relationship manager and the certified counsellor
where necessary for the performance of our agreement to provide you with the best targeted service tailored to your preference
To provide and manage your queries, and our relationship with you
Where necessary for the performance of our agreement or to take steps to enter into an agreement with you,
Where the law requires this
Where it's in our legitimate interests to ensure that our customers query data and enquires are well-managed, so that our customers are provided with a high standard of service, to protect our business interests and the interests of our customers
To handle enquiries and complaints
Where necessary for the performance of our agreement or to take steps to enter into an agreement with you
Where the law requires this
Where it's in our legitimate interests to ensure that complaints are investigated, for example, so that our customers receive a high standard of reply and delivery service and so that we can prevent complaints from occurring in future
To provide our services to you
Where necessary for the performance of our agreement or to take steps to enter into an agreement with you
Where the law requires this
For assessment, testing and analysis, and market research. We compile these reports from information about you and our other customers and users. The information in these reports is never personal and you will never be identifiable from them
Where the law requires this
Where it's in our legitimate interests to develop, build, implement and run business models and systems which protect our business interests and provide our customers/users with a high standard of service
To protect our business interests and to develop our business strategies
Where it's in our legitimate interests to protect our people, business and property and to develop our strategies
Where necessary for the performance of our agreement or to take steps to enter into an agreement with you
Where the law requires this
To meet our regulatory compliance and reporting obligations
Where the law requires this
Where such processing is a contractual requirement of the services
To share your information with our partners and service providers
Where necessary for the performance of our agreement
Where we have a legitimate interest in using third parties to provide some services for us or on our behalf
Usage Data
Usage Data is collected automatically when using the Service.
Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.
We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.
Information Collected while Using the Website or Mobile App
While using Our Website or Mobile App, in order to provide features of Our Application, We may collect, with Your prior permission:
Information regarding your location
Information regarding your device
We use this information to provide features of Our Service, to improve and customize Our Service. The information may be uploaded to the Company's servers and/or a Service Provider's server or it may be simply stored on Your device.
USE OF YOUR PERSONAL DATA
The Company may use Personal Data for the following purposes:
To provide and maintain our Service, including to monitor the usage of our Service.
For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
To provide You with more targeted and focused suggestions and reminders, news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
To manage Your requests: To attend and manage Your requests to Us.
For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.
For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.
To conduct the KYC compliance process as a mandatory prerequisite as per the requirements of various regulatory bodies
We may share Your personal information in the following situations:
With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, to contact You. We also share Your personal information with third patty service providers for conducting identity verification services.
For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.
With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside. If You interact with other users or register through a Third-Party Social Media Service, Your contacts on the Third-Party Social Media Service may see Your name, profile, pictures and description of Your activity. Similarly, other users will be able to view descriptions of Your activity, communicate with You and view Your profile.
With Your consent: We may disclose Your personal information for any other purpose with Your consent.
CONVERSATIONAL DATA WITH A.I. SYSTEM
The MitramCares System, empowered by AI, encourages the Users to communicate with it in a conversational tone, basis which it offers non-sensitive and non-prescriptive solutions to the Users. The conversational patterns between the Users and the MitramCares System allows the system to personalise suggestions and recommendations to the particular User. Basis the conversational patterns, the MitramCares system recommends and interacts with the Users to provide daily task reminders, health care management reminders and lifestyle convenience recommendations.
You acknowledge and consent to the use of Your conversational data, to enable the AI-based MitramCares System to recognize the patterns of your preferences from the conversation and thus suggest and offer enabling and reminder services accordingly. The conversational data shall be stored only for a limited period of time.
TRACKING TECHNOLOGIES AND COOKIES
We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts (confirm if any additional cookies used too) to collect and track information and to improve and analyze Our Service. The technologies We use may include:
Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service. Unless you have adjusted Your browser setting so that it will refuse Cookies, our Service may use Cookies.
Flash Cookies. Certain features of our Service may use local stored objects (or Flash Cookies) to collect and store information about Your preferences or Your activity on our Service. Flash Cookies are not managed by the same browser settings as those used for Browser Cookies.
Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).
Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser.
We use both Session and Persistent Cookies for the purposes set out below:
Necessary / Essential Cookies
Type: Session Cookies
Administered by: Us
Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.
Cookies Policy / Notice Acceptance Cookies
Type: Persistent Cookies
Administered by: Us
Purpose: These Cookies identify if users have accepted the use of cookies on the Website.
Functionality Cookies
Type: Persistent Cookies
Administered by: Us
Purpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.
RETENTION OF YOUR PERSONAL DATA
The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.
After 15 days, we begin the process of deleting your conversational data with the MitramCares System and the personal information from our systems shall remain in our systems as long as Your account is active and for a period of 90 or days after the deletion of your account, subject to any changes or requirements of law.
TRANSFER OF YOUR PERSONAL DATA
Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.
Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.
The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.
AUTOMATED DECISION MAKING
We do not currently use any automated systems in our decision making process whilst servicing or choosing to service a client. Our automated communication systems are only limited to sharing communication on acknowledgement of any requests received or serviced.
DISCLOSURE OF YOUR PERSONAL DATA
Business Transactions
If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.
Law enforcement
Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
Other legal requirements
The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:
Comply with a legal obligation
Protect and defend the rights or property of the Company
Prevent or investigate possible wrongdoing in connection with the Service
Protect the personal safety of Users of the Service or the public
Protect against legal liability
SECURITY OF YOUR PERSONAL DATA
The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet,or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.
CHOICE/OPT-OUT
We provide all users with the opportunity to opt-out of receiving any of our services or non-essential (promotional, marketing-related) communications from us, after setting up an account. If you want to remove your contact information from all our lists and newsletters or discontinue any our services, please click on the unsubscribe button on the emailers.
RIGHTS OVER YOUR PERSONAL DATA
Under certain circumstances, by law you have the right to:
Be informed about the processing of your personal data (i.e. for what purposes, what types, to what recipients it is disclosed, storage periods, any third party sources from which it was obtained, confirmation of whether we undertake automated decision-making, including profiling, and the logic, significance and envisaged consequences).
Object to your personal data being processed for a particular purpose or to request that we stop using your information.
Request not to be subject to a decision based on automated processing and to have safeguards put in place if you are being profiled based on your personal data.
Ask us to transfer a copy of your personal data to you or to another service provider or third party where technically feasible and otherwise required by applicable regulations.
Withdraw, at any time, any consent that you have previously given to us for our use of your personal data.
Ask us to stop or start sending you marketing messages at any time.
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your working relationship with us.
Request the erasure of your personal data. This enables you to ask us to delete or remove personal data where you think that we do not have the right to process it.
Any request for access to or a copy of your personal data must be in writing and we will endeavour to respond within a reasonable period and in any event within one month in compliance with Data Protection Legislation. We will provide this information free of charge unless the request is manifestly unfounded or excessive. We will comply with our legal obligations as regards any individual’s rights as a data subject.
If you would like to contact us in relation to any of the rights set out above, please contact us using the following contact details. https://wa.me/917756933846. To protect your privacy and security, we may take reasonable steps to verify your identity before providing you with the details.
CHANGES TO POLICY
We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page. We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
CONTACT US
In case you have any questions or concerns regarding the processing of your Personal Information or this Privacy Policy you may write to us using this link https://wa.me/917756933846. We are committed to answer your questions within the reasonable time limit. Any delay in the resolution time shall be proactively communicated to you.
GREIVANCE REDRESSAL
For any grievance reporting procedure, please read our terms and conditions statement, which can be found here. Your query shall be responded to within 48 business hours.
