Truworth Health Technologies Private Limited (“us”, “we”, or “Truworth”, which also includes its affiliates) is the author and publisher of the internet resource www.thewellnesscorner.com on the world wide web as well as the software and applications provided by Truworth, including but not limited to the mobile application ‘Thewellnesscorner’, and the software and applications of the brand names ‘Truworth’ (together with the Website, referred to as the “Services”).
- Section 43A of the Information Technology Act, 2000;
- Regulation 4 of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011 (the “SPI Rules”);
- Regulation 3(1) of the Information Technology (Intermediaries Guidelines) Rules, 2011.
- 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 Truworth will disclose such information.
2. PRIVACY STATEMENTS
2.1. ALL USERS NOTE:
This section applies to all users.
- All the information provided to Truworth by a User, including Personal Information or any Sensitive Personal Data or Information, is voluntary. You understand that Truworth may use certain information of yours, which has been designated as Personal Information or ‘Sensitive Personal Data or Information’ under the SPI Rules, (a) for the purpose of providing you the Services, (b) for commercial purposes and in an aggregated or non-personally identifiable form for research, statistical analysis and business intelligence purposes, (c) for sale or transfer of such research, statistical or intelligence data in an aggregated or non-personally identifiable form to third parties and affiliates (d) for communication purpose so as to provide You a better way of booking appointments and for obtaining feedback in relation to the Medical Experts and their practice, (e) debugging customer support related issues..
Truworth also reserves the right to use information provided by or about the End-User for the following purposes:
- Contacting End-Users for offering new products or services.
- Contacting End-Users for taking product and Service feedback.
- Analyzing software usage patterns for improving product design and utility.
- Analyzing anonymized practice information for commercial use.
If you have voluntarily provided your Personal Information to Truworth for any of the purposes stated above, you hereby consent to such collection and use of such information by Truworth. However, Truworth shall not contact You on Your telephone number(s) for any purpose including those mentioned in this sub-section 4.1(iii), if such telephone number is registered with the Do Not Call registry (“DNC Registry”) under the PDPA without your express, clear and un-ambiguous written consent.
- Truworth does not control or endorse the content, messages or information found in any Services and, therefore, Truworth specifically disclaims any liability with regard to the Services and any actions resulting from your participation in any Services, and you agree that you waive any claims against Truworth relating to same, and to the extent such waiver may be ineffective, you agree to release any claims against Truworth relating to the same.
- You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information provided as part of account registration. If your personal information changes, you may correct, delete inaccuracies, or amend information by making the change on our member information page or by contacting us through firstname.lastname@example.org. We will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable. If you provide any information that is untrue, inaccurate, out of date or incomplete (or becomes untrue, inaccurate, out of date or incomplete), or Truworth has reasonable grounds to suspect that the information provided by you is untrue, inaccurate, out of date or incomplete, Truworth may, at its sole discretion, discontinue the provision of the Services to you. There may be circumstances where Truworth will not correct, delete or update your Personal Data, including (a) where the Personal Data is opinion data that is kept solely for evaluative purpose; and (b) the Personal Data is in documents related to a prosecution if all proceedings relating to the prosecution have not been completed.
- If you wish to cancel your account or request that we no longer use your information to provide you Services, contact us through email@example.com. we will retain your information for as long as your account with the services is active and as needed to provide you the services. we shall not retain such information for longer than is required for the purposes for which the information may lawfully be used or is otherwise required under any other law for the time being in force. after a period of time, your data may be anonymized and aggregated, and then may be held by us as long as necessary for us to provide our services effectively, but our use of the anonymized data will be solely for analytic purposes. please note that your withdrawal of consent, or cancellation of account may result in truworth being unable to provide you with its services or to terminate any existing relationship truworth may have with you.
- If you wish to opt-out of receiving non-essential communications such as promotional and marketing-related information regarding the Services, please send us an email at firstname.lastname@example.org.
- Truworth may require the User to pay with a credit card, wire transfer, debit card or cheque for Services for which subscription amount(s) is/are payable. Truworth will 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. 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, Truworth provides you an option not to save your payment details. User is advised, however, that internet technology is not full proof safe and User should exercise discretion on using the same.
- Due to the communications standards on the Internet, when a User or the End-User or anyone who visits the Website, Truworth automatically receives the URL of the site from which anyone visits. Truworth also receives the Internet Protocol (IP) address of each User’s computer (or the proxy server a User used to access the World Wide Web), User’s computer operating system and type of web browser the User is using, email patterns, as well as the name of User’s ISP. This information is used to analyze overall trends to help Truworth improve its Service. The linkage between User’s IP address and User’s personally identifiable information is not shared with or disclosed to third parties. Notwithstanding the above, Truworth may share and/or disclose some of the aggregate findings (not the specific data) in anonymized form (i.e., non-personally identifiable) with advertisers, sponsors, investors, strategic partners, and others in order to help grow its business.
- The Website uses temporary cookies to store certain (that is not sensitive personal data or information) that is used by Truworth and its service providers for the technical administration of the Website, research and development, and for User administration. In the course of serving advertisements or optimizing services to its Users, Truworth may allow authorized third parties to place or recognize a unique cookie on the User’s browser. The cookies however, do not store any Personal Information of the User. You may adjust your internet browser to disable cookies. If cookies are disabled you may still use the Website, but the Website may be limited in the use of some of the features.
- A User may have limited access to the Website without creating an account on the Website. In order to have access to all the features and benefits on our Website, a User must first create an account on our Website. To create an account, a User is required to provide the following information, which such User recognizes and expressly acknowledges is Personal Information allowing others, including Truworth, to identify the User: name, User ID, email address, country, ZIP/postal code, age, phone number, password chosen by the User and valid financial account information. Other information requested on the registration page, including the ability to receive promotional offers from Truworth, is optional. Truworth may, in future, include other optional requests for information from the User to help Truworth to customize the Website to deliver personalized information to the User.
- The Website may enable User to communicate with other Users or to post information to be accessed by others, whereupon other Users may collect such data. Such Users, including any moderators or administrators, are not authorized Truworth representatives or agents, and their opinions or statements do not necessarily reflect those of Truworth, and they are not authorized to bind Truworth to any contract. Truworth hereby expressly disclaims any liability for any reliance or misuse of such information that is made available by Users or visitors in such a manner.
- Truworth maintains a strict "No-Spam" policy, which means that Truworth does not intend to sell, rent or otherwise give your e-mail address to a third party without your consent.
- Truworth 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 unauthorized access, improper use or disclosure, unauthorized 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, Truworth shall not be held liable for any loss whatsoever incurred by the User.
- Truworth 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 Truworth’s business.
2.2 MEDICAL EXPERTS NOTE:
This section applies to all Medical Experts.
- As part of the registration as well as the application creation and submission process that is available to Medical Experts on Truworth, certain information, including Personal Information or Sensitive Personal Data or Information is collected from the Medical Experts.
- Medical Experts’ personally identifiable information, which they choose to provide to Truworth, is used to help the Medical Experts describe and identify themselves. This information is exclusively owned by Truworth You will be the owner of your information and you consent to Truworth collecting, using, processing and/or disclosing this information for the purposes hereinafter stated. Truworth may use such information for commercial purposes and in an aggregated or non-personally identifiable form for research, statistical analysis and business intelligence purposes, and may sell or otherwise transfer such research, statistical or intelligence data in an aggregated or non-personally identifiable form to third parties and affiliates.
Truworth also reserves the right to use information provided by or about the Practitioner for the following purposes:
- Publishing such information on the Website.
- Contacting Medical Experts for offering new products or services subject to the telephone number registered with the DNC Registry.
- Contacting Medical Experts for taking product feedback.
- Analyzing software usage patterns for improving product design and utility.
- Analyzing anonymized practice information including financial, and inventory information for commercial use.
- Truworth automatically enables the listing of Medical Experts’ information on its Website for every ‘Doctor’ or ‘Clinic’ added to a Practice using its software. The Practitioner information listed on Website is displayed when End-Users search for doctors on Website, and the Practitioner information listed on Website is used by End-Users to request for doctor appointments. Any personally identifiable information of the Medical Experts listed on the Website is not generated by Truworth and is provided to Truworth by Medical Experts who wish to enlist themselves on the Website, or is collected by Truworth from the public domain. Truworth displays such information on its Website on an as-is basis making no representation or warranty on the accuracy or completeness of the information. As such, we strongly encourage Medical Experts to check the accuracy and completeness of their information from time to time, and inform us immediately of any discrepancies, changes or updates to such information. Truworth will, however, take reasonable steps to ensure the accuracy and completeness of this information.
- Truworth may also display information for Medical Experts who have not signed up or registered for the Services, provided that the Medical Experts have consented to Truworth collecting, processing and/or disclosing their information on the Website. Such Medical Experts are verified by Truworth or its associates, and Truworth makes every effort to capture accurate information for such Medical Experts. However, Truworth does not undertake any liability for any incorrect or incomplete information appearing on the Website for such Medical Experts.
2.3 END-USERS NOTE:
This section applies to all End-Users.
- As part of the registration/application creation and submission process that is available to End-Users on this Website, certain information, including Personal Information or Sensitive Personal Data or Information is collected from the End-Users.
- If you have inadvertently submitted any such information to Truworth prior to reading the privacy statements set out herein, and you do not agree with the manner in which such information is collected, processed, stored, used or disclosed, then you may access, modify and delete such information by using options provided on the Website. In addition, you can, by sending an email to email@example.com, inquire whether Truworth is in possession of your personal data, and you may also require Truworth to delete and destroy all such information.
- End-Users’ personally identifiable information, which they choose to provide on the Website is used to help the End-Users describe/identify themselves. Other information that does not personally identify the End-Users as an individual, is collected by Truworth from End-Users (such as, patterns of utilization described above) and is exclusively owned by Truworth. Truworth may also use such information in an aggregated or non-personally identifiable form for research, statistical analysis and business intelligence purposes, and may sell or otherwise transfer such research, statistical or intelligence data in an aggregated or non-personally identifiable form to third parties and affiliates.
In particular, Truworth reserves with it the right to use anonymized End-User demographics information and anonymized End-User health information for the following purposes:
- Analyzing software usage patterns for improving product design and utility.
- Analyzing such information for research and development of new technologies.
- Using analysis of such information in other commercial product offerings of Truworth.
- Sharing analysis of such information with third parties for commercial use.
- Truworth will communicate with the End-Users through email, phone and notices posted on the Website or through other means available through the service, including text and other forms of messaging. The End-Users can change their e-mail and contact preferences at any time by logging into their "Account" at www.Truworth.com and changing the account settings.
- At times, Truworth conducts a User survey to collect information about End-Users' preferences. These surveys are optional and if End-Users choose to respond, their responses will be kept anonymous. Similarly, Truworth may offer contests to qualifying End-Users in which we ask for contact and demographic information such as name, email address and mailing address. The demographic information that Truworth collects in the registration process and through surveys is used to help Truworth improve its Services to meet the needs and preferences of End-Users.
- Truworth may keep records of electronic communications and telephone calls received and made for making appointments or other purposes for the purpose of administration of Services, customer support, research and development and for better listing of Medical Experts.
- All Truworth 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’ Personal Information or Sensitive Personal Data and Information. Truworth has put in place procedures and technologies as per good industry practices and in accordance with the applicable laws, to maintain security of all personal data from the point of collection to the point of destruction. Any third-party data processor to which Truworth transfers Personal Data shall have to agree to comply with those procedures and policies, or put in place adequate measures on their own.
- To the extent necessary to provide End-Users with the Services, Truworth may provide their Personal Information to third party contractors who work on behalf of or with Truworth to provide End-Users with such Services, to help Truworth communicate with End-Users or to maintain the Website. Generally, these contractors do not have any independent right to share this information, however certain contractors who provide services on the Website, including the providers of online communications services, may use and disclose the personal information collected in connection with the provision of these Services in accordance with their own privacy policies. In such circumstances, you consent to us disclosing your Personal Information to contractors, solely for the intended purposes only.
2.4 CASUAL VISITORS NOTE:
- No sensitive personal data or information is automatically collected by Truworth from any casual visitors of this website, who are merely perusing the Website.
- If you, as a casual visitor, have inadvertently browsed any other page of this Website prior to reading the privacy statements set out herein, and you do not agree with the manner in which such information is obtained, collected, processed, stored, used, disclosed or retained, merely quitting this browser application should ordinarily clear all temporary cookies installed by Truworth. All visitors, however, are encouraged to use the “clear cookies” functionality of their browsers to ensure such clearing / deletion, as Truworth cannot guarantee, predict or provide for the behaviour of the equipment of all the visitors of the Website.
INFORMATION WE COLLECT
When you interact with us through the Platform and Services, we may collect Personal Data and other information from you, as further described below:
The kind of Personal data that we collect may include such as your full name, email address, password, gender, profile picture, contact details, address, date of birth, height, weight, diet and digestive information, fitness and exercise details, medical history and conditions and medication details
When you interact with Truworth through the Platform, we receive and store certain personally non-identifiable information. Such information, which is collected passively using various technologies, cannot presently be used to specifically identify you. Consequently, we do not adjust or alter our Platform’s automatic tracking and data collection in response to a Do Not Track signal or request. Truworth may store such non-identifiable information itself or such information may be included in databases owned and maintained by Truworth affiliates, agents or service providers. This Platform may use such information and pool it with other information to track, for example, the total number of visitors to our Platform, the number of visitors to each page of our Platform, and the domain names of our visitors' Internet service providers. It is important to note that no Personal Data is available or used in this process.
AGGREGATED PERSONAL DATA
In an ongoing effort to better understand and serve the users of Truworth Services, Truworth may conduct research on its customer demographics and behavior based on the Personal Data and other information provided to us. This research may be compiled and analyzed on an aggregate basis, and Truworth may share this aggregate data with its affiliates, agents and business partners. This aggregate information does not identify you personally. Truworth may also disclose aggregated user statistics in order to describe our services to current and prospective business partners, and to other third parties for other lawful purposes.
Our Service may collect and use your location information (for example, by requesting your location in your profile or by using the GPS on your mobile device or the TruworthApp) to provide certain functionality of our Service. We may use your location information in conjunction with your Personal Data or in an aggregate way, as described above in the “Aggregated Personal Data” section.
OUR USE OF YOUR PERSONAL DATA AND OTHER INFORMATION
In addition, if at any time, you wish not to receive any future communications whatsoever or you wish to have your name deleted from our mailing lists, please contact us at firstname.lastname@example.org.
AGENTS, CONSULTANTS AND RELATED THIRD PARTIES
Truworth, like many businesses, sometimes hires other companies to perform certain business-related functions. Examples of such functions include mailing information, maintaining databases and processing payments. When we employ another company to perform a function of this nature, we only provide them with the information that they need to perform their specific function.
Truworth may disclose your Personal Data, if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of Truworth, (iii) act in urgent circumstances to protect the personal safety of users of the Platform or the public, (iv) protect against legal liability.
OTHER THIRD PARTIES
We may also disclose your Personal Data with third party service providers such as Eco-System Partners, insurance companies, data analytics companies, marketing and research companies for use of such information including for offering additional services either bundled with, or in addition to the Services, or to assist Truworth in providing the Services to you. We will share such information with above mentioned partners/companies only when the customers have specifically authorized.
You can use the Platform without providing any Personal Data. If you choose not to provide any Personal Data, you may not be able to use certain Truworth Services.
THIRD PARTIES AND LINKS TO OTHER WEB SITES
You may also have the option of posting your Services activities to Social Media Services when you access content through the Services (for example, you may post to Facebook that you performed an activity on the Service); you acknowledge that if you choose to use this feature, your friends, followers and subscribers on any Social Media Services you have enabled will be able to view such activity.
Truworth takes reasonable steps to protect the Personal Data provided via the Platform and the Services from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. We have adopted reasonable security practices and procedure, as further described in our information security policy, available with our CIO to ensure that the Personal Data collected is secure. You agree that such measures are secure and adequate. While we will endeavor to take all reasonable and appropriate steps to keep secure any information which we hold about you and prevent unauthorized access, you acknowledge that, no Internet or e-mail transmission or security measure is ever fully secure or error free. In particular, e-mail sent to or from this Platform may not be secure. Therefore, you should take special care in deciding what information you send to us via e-mail. Please keep this in mind when disclosing any Personal Data to Truworth via the Internet. We will not be liable in any way in relation to any breach of security or unintended loss or disclosure of information caused by us in relation to your Personal Data.
OTHER TERMS AND CONDITIONS
Your access to and use of this Platform is subject to the Terms of Service.
ACCESS TO INFORMATION AND CONTACTING TRUWORTH
You may change or update information in your profile, or delete your account entirely. To keep your Personal Data accurate, current, and complete, please update your profile or contact us as specified below. We will take reasonable steps to update or correct Personal Data in our possession that you have previously submitted via this Platform or the Service.
WITHDRAWAL OF PERSONAL DATA
Further, you will have the option to not provide your consent, or withdraw any consent given earlier, provided that the decision to not provide consent / withdrawal of the consent is intimated to us in writing. If you do not provide us Personal Data or withdraw the consent to provide us with any of your Personal Data at any point in time, we shall have the option not to provide the benefits for the purpose of which the said Personal Data was sought.
WE MAY UPDATE THIS AGREEMENT
You may contact us as follows: email@example.com
We will endeavor to respond within an appropriate timeframe.
We can address any questions, comments and concerns about our online privacy practices and policy. Please write to our Privacy Team at firstname.lastname@example.org.