1. DATA PRIVACY STATEMENT
1.1. Fitlife Natural Private Limited (d/b/a Jaagruk Bharat) (hereinafter referred to as “the
Company”, “we” or “us”) operates the ‘Jaagruk Bharat’ website, instant
messaging/WhatsApp bot and mobile application (together, the “Platform”) and provides
various services through the Platform and otherwise (“Services”). This policy outlines the
manner in which Personal Data is collected, the kinds of Personal Data which will be
collected, the purpose for which such Personal Data is collected, third parties to whom such
Personal Data may be disclosed and details of how to request for correction of Personal
Data, withdrawal of consent, period of retention of Personal Data and grievance redressal
etc.
1.2. By accessing our Platform and/or using our Services, each user / service recipient (“you”,
“your” or “individual”) freely, specifically, in an informed manner, unambiguously and
unconditionally agrees to the collection, storage, use and disclosure of your Personal Data in
accordance with this policy. You may, at your sole discretion, choose to withdraw this
consent by intimating us of such withdrawal in writing to the contact details set out herein
below or by such other mechanism that the Company will notify from time to time.
However, you acknowledge that if you opt out, we may not be able to provide you the
relevant Service(s).
1.3. This policy does not apply to the Personal Data that you may share with third parties (who
are not engaged by the Company, including as data processors), through external links or
websites provided on our Platform. In the event you visit such third-party websites or access
such links, you shall be governed by their respective privacy policies, and we will not be
responsible or liable in connection with the collection, processing, storage or disclosure of
such information.
1.4. For the purposes of this policy, “Personal Data” means any information that relates to an
individual, which either directly, or indirectly in combination with other information we have
or likely to have or have access to, could be used for identifying such person.
2. INFORMATION WE MAY COLLECT FROM YOU
2.1. Your access to the Platform and/or use of the Services may result in collection and
processing of your Personal Data by us. We collect the data either directly from you when
you provide it to us on the Platform (or otherwise) and/or automatically from your
navigation through the Platform (by means of cookies, web beacons or other tracking
technologies). The data that we may collect pursuant to our Platform and/or Services
includes, but is not limited to:
-
information you provide while creating a profile / account on our Platform or
accessing tools on the Platform, such as your full name, postal address, e-mail
address, age, gender, caste, marital status, educational information, income details,
and such other information as may be required from time to time;
-
information in respect of government registration(s) held by you as may be required
from you to provide the Services, which may include information in respect of your
Aadhar, permanent account number, ration card, passport, voter identification card,
goods and services tax registration and such other document issued by the government or such other
information which may be required for provision of our
Services;
-
health related information, such as blood group, medical history, details of any
disability, etc.
-
financial and transactional information, such as details of your bank account or
credit card or debit card or other payment instrument details, billing information
and one-time passwords strictly for the provision of the Services. This information
may be shared with third parties which assist in processing and fulfilling your
requests, including PCI compliant payment gateway processors;
-
any other information you provide while using our Services and information that is
generated while using our Services;
-
any information contained in your communications that you send us by e-mail,
telecom messaging or application messengers such as WhatsApp etc.
-
information in relation to your computer or mobile device including your IP address,
geographical location, browsers, browsing information, search queries, email
address, page views, website navigation etc.
-
Any detail relating to the above clauses as provided to enable us to provide products
and/or services; and
-
Any of the information received under any of the above clauses: (a) by the Company
for processing of data; and/or (b) stored or processed under a lawful contract or
otherwise.
2.2. We may also collect, use and share aggregated data such as statistical or demographic data
which is not Personal Data as it does not directly (or indirectly) reveal your identity. For
example, we may aggregate individuals’ usage data to calculate the percentage of users
accessing a specific Platform feature in order to analyze general trends in how users are
interacting with our Platform to help improve the Platform and our Services offering.
2.3. Unless you confirm otherwise (in writing), you represent and warrant that: (a) all the
information furnished by you is accurate and authentic; (b) you are not impersonating any
other individual; (c) you are above the age of 18 (eighteen) years; and (d) you have not
suppressed material information and have only furnished (and will only furnish) information
that is verifiably authentic. The Company does not take the responsibility to authenticate
the information provided by you.
3. PURPOSE OF DATA COLLECTION OR PROCESSING OR USE
3.1. We collect and use your Personal Data and other information for the following purposes:
-
to verify your identity;
-
to assess your eligibility for the requested services and/or assessing and preparing
the scope of work and fee estimate for the requested services;
-
to provide the Services you have chosen to avail from us;
-
to process and respond to your queries;
etc.;
-
to send you communications that you have requested or that may be of interest to
you by way of emails, or telephone calls, or any other mode of communication;
-
to carry out our primary business functions and activities, including but not limited
to, project planning, market research etc.;
-
to ensure compliance with a legal or contractual obligation;
-
for analytics regarding usage of the Platform and improvement of the
Platform/Services and user experience;
-
to provide you customer support;
-
to provide offers and other services, that may interest you;
-
for purposes otherwise set forth in this Privacy Policy; or
-
in any other way we may describe when you provide the information for which you
have provided your specific consent.
4. RECIPIENTS OR CATEGORIES OF RECIPIENTS TO WHOM THE PERSONAL DATA
MAY BE DISCLOSED
4.1. We will not use or disclose your Personal Data to any other person (except our employees,
officers, professional advisors, third party contractors or service providers) otherwise than
for the purposes set out in this Privacy Policy, unless the disclosure is necessary for
compliance of a legal obligation or where it is agreed to in the specific consent by you for a
specific purpose not included in this policy.
4.2. Subject to what is permitted under law, we may disclose your Personal Data to the following
third parties, subject to confidentiality arrangements and on strict need-to-know basis:
-
agents, contractors, service providers and external advisers engaged by us, from
time to time to carry out, provide Services such as identity verification agencies,
application service providers, PAN/GST/Aadhar service providers etc.;
-
other related bodies corporate/affiliates of the Company or under common
ownership or control of the ultimate parent company;
-
regulatory bodies, government agencies, law enforcement bodies and court and/or
in connection with any on-going or prospective legal proceedings;
-
any person who we deem necessary for carrying out the instructions you provide us;
-
a buyer or other successor of the Company in the event of 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 the us about the users of our
Services are among the assets transferred;
-
If we believe disclosure is necessary or appropriate to protect the rights, property,
or safety of the Company, our customers or others. This includes exchanging
information with other companies and organizations for the purposes of fraud
protection etc.
5. DATA SUBJECT RIGHTS
5.1. Under the Digital Personal Data Protection Act, 2023 and the rules thereunder (“DPDP Act”),
you have the following rights (among other rights):
-
you have the right to withdraw your consent for processing of your Personal Data;
-
you have the right to request the Company for: (i) a summary of the Personal Data
processing and the processing activities undertaken by the Company; and (ii)
identities of all other data processors with whom your Personal Data has been
shared;
-
you have the right to request for correction, completion, updating or erasure of your
Personal Data;
5.2. If you wish to exercise any of the statutory rights above, please write to the Company’s
Grievance Officer with your specific request (along with the reasons) at contact details set
out in paragraph # 8 below.
5.3. If you are not satisfied with our redressal of your grievances / requests, or if you wish to
lodge a complaint against us, you can reach out to the Data Protection Board of India
(“Board”) through the mechanism that may be notified by the government from time to
time.
5.4. While exercising any of your statutory rights, please ensure that you:
-
comply with DPDP Act;
-
do not impersonate another person;
-
do not suppress any material information;
-
do not register any false or frivolous grievance or complaint with us or the Board;
and
-
furnish only such information which is verifiably authentic.
6. RETENTION OF PERSONAL DATA
6.1. Your Personal Data will be retained by the Company till the fulfilment of the purpose of the
processing of your data, unless you withdraw your consent herein or request for erasure of
your Personal Data.
6.2. However, irrespective of the above, we will retain your Personal Data, associated traffic data
and other logs of processing for such period of time as may be prescribed under the DPDP
Act and/or other applicable laws.
6.3. Your Personal Data will be deleted upon the earlier of: (a) you withdrawing your consent
herein or requesting for erasure of your Personal Data; (b) you signifying your rejection in
terms of availing our services – 30 (thirty) consecutive days of your inactivity in our
communications with respected to the requested services shall be deemed as your rejection
of such services; (c) where you are availing our services, upon fulfilment of the services; and
(d) when required to delete your Personal Data under applicable laws.
7. SECURITY
7.1. We will formulate and implement appropriate security practices and procedures (physical
electronic and managerial) to ensure that the information assets are adequately protected
as per the applicable industrial practice, standards and regulations. The safeguards take into
account the sensitivity of the information and the current state of technology. The Company
strives hard for ensuring that the Personal Data it holds is protected from misuse, loss and
unauthorized access, modification or disclosure, both during transmission and once we
receive it.
7.2.However, we do not assume any liability or responsibility for disclosure of your information
due to errors in the process of transmission, unauthorized access or disclosure by a third
party or other causes beyond our control.
8. QUERIES, GRIEVANCES ETC.
8.1. We have appointed the following individual as the Grievance Officer of the Company. If you
have any queries, issues or grievance, please contact our Grievance Officer at the details
below.
8.2. If we are unable to reasonably address your grievances, there are remedies available under
applicable law which can be availed by you, including approaching the Board. However, we
would appreciate the chance to deal with your concerns before you avail external remedies,
so please contact us in the first instance.
9. GOVERNING LAW AND JURISDICTION
9.1. This policy shall be governed by and construed in accordance with the laws of Republic of
India and the courts of New Delhi, India shall have the exclusive jurisdiction in relation to
any disputes arising out of or in connection with the Policy.
10. AMENDMENT
10.1. The Company may amend or modify this policy from time to time, at its sole discretion.