Updated July 03, 2023

Human Edge Advisory Services Private Limited (“Human Edge”, “Our”, “We”, “Us”) is committed to safeguarding the privacy expectations of its Users (“You”, or “Your”, or “Yourself”). Accordingly, We have put in place this policy (“Privacy Policy”), which outlines Our data protection practices, including how We collect, use, disclose and protect Your Personal Information on our website (www.humanedge.co) (“Website”), and other online and offline sources as well as Your rights with respect to Your Personal Information.

The Website primarily offers lifestyle recommendations. We respect Your privacy and are committed to protect the privacy and security of Your personal data. We encourage You to read the Privacy Policy carefully. By using the Website You hereby indicate that You agree with this Privacy Policy without any exceptions. This Privacy Policy has been published in compliance with the Information Technology Act, 2000 and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal information) Rules, 2011. If You have any questions regarding Our use of Your personal data, please feel free to contact us over the channels provided below.

THE INFORMATION WE COLLECT

We collect two types of information from Our Users:

I. Personal Information
The first type of information that We collect is information that identifies or may reasonably identify an individual (“Personal Information”). Personal Information that is being gathered may consist of the following:

1. First name
2. Last name
3. Address
4. Birth date
5. Mobile telephone number
6. Email address
7. Password
8. Payment modes information
9. Health information such as weight, height, blood glucose, blood ketones, biometric identifiers, exercise frequency, exercise duration and intensity resting heart rate, heart rate variability, skin temperature, oxygen level, sleep information, OGTT, HbA1C, Triglyceride/HDL ratio, Total cholesterol, LDLC, HDLC, Total cholesterol/HDL ratio, Bilirubin total, ALT, AST, GGTP, ALP, Blood urea nitrogen, Uric acid, Total blood protein, hs-CRP, C reactive protein (CRP), Thyroid function, Liver function, or any other data points deemed necessary by our Consultants and Coaches.
10. Medical records, medical disease information, medications, lifestyle information regarding sleep, movement, fuel, environment and emotions, physical, psychological or mental health conditions; sexual orientation; biomarkers.
11. Financial information such as Bank account, debit card, credit card or other payment instrument details;

II. Non-Personal Information
The second type of information is un-identified and non-identifiable information pertaining to You, which may be made available or gathered via Your use of the Service (“Non-Personal information”). For avoidance of doubt, any Non-Personal Information connected or linked to any Personal Information shall be deemed as Personal Information as long as such connection or linkage exists. Types of Non-personal Information We collect from or about You:

1. Device and connection information: We collect information from the particular device You are using, for security and fraud detection and prevention purposes. For example, We may gather information with regard to other software which is running simultaneously with the App for detecting if You are using software which is associated with fraudulent activity (e.g.,
robots, malware, etc.) or checking if the connection You are using is via a VPN or proxy.

2. Analytics information: We collect information about Your use of the Services, such as App Usage, log files, User activity (e.g., pages viewed, the amount of time spent on particular pages, online browsing, clicks, actions, etc.), time stamps, alerts, etc. This information is collected for amongst other things troubleshooting errors and bugs as well as for research and analytics purposes about Your use of the Services.

3. Anonymous information: We may anonymise or de-identify the information collected by the Services or via other means so that the information cannot, on its own, personally identify You. Our use and disclosure of such aggregated or de-identified information is not subject to any restrictions under this Privacy Policy, and We may disclose it to others without
limitation and for any purpose, such as for advertising, marketing or research purposes.

4. Other information: We collect information on the User’s time zone.

CONDITIONS FOR PROCESSING PERSONAL INFORMATION

We will process Your Personal Information for a variety of reasons, each of which is prescribed by
relevant data protection laws:

I. Fulfilment of a Contract; Compliance with a Legal Obligation
It is necessary for Us to process Your Personal Information where it is necessary for the performance of a contract or in order for Us to comply with our various legal and/or regulatory responsibilities.

II. Legitimate Interests
We also process Your Personal Information where We deem such processing to be in our (or a third party’s) legitimate interests and provided always that such processing will not prejudice Your interests, rights and freedoms. Examples of Us processing in accordance with legitimate interests would include: (i) where We disclose Your Personal Information to any one or more of our associate/subsidiary companies following a restructure or for internal administrative purposes; (ii) processing for the purposes of ensuring network and information security, including preventing unauthorised access to our electronic communications network; (iii) safeguarding the integrity of our Services by combatting, reporting and sharing information related to suspicious betting patterns or fraudulent activities; (iv) adhering to regulatory and statutory requirements; (v) devising a tailored reward scheme for players; and (vi) sharing personal information with our advisers and professional services providers (such as auditors) for ensuring our compliance with regulatory requirements and industry best practices.

III. Consent
Our processing of Your Personal Information will primarily be necessary for Us to provide You with the Services. However, if You provide Your consent to receive marketing, We will on certain occasions provide marketing information (such as promotions and marketing material). If You have agreed to receive marketing, You can opt out at a later date. If You no longer wish to be contacted for marketing purposes, please update Your account preferences within the App.

USING THE COLLECTED INFORMATION

We may use Your Personal Information for the purposes listed below:

1. To set up, manage and update Your account.
2. To provide and operate the Services.
3. To communicate with You and to keep You informed of our latest service updates.
4. To market our Services (see more below under “Marketing”), as well as to serve You advertisements, including behavioural advertising.
5. To conduct analytics, statistical and research purposes, in order to improve and customise the Services to Your needs and interests (such as by compiling aggregated reports about the Usage of certain features of our Services).
6. For customer relationship management purposes, and to support and troubleshoot the Services and to respond to Your queries.
7. To enable Us to further develop, customise and improve the Services based on Your common preferences and uses.
8. To communicate with You and to process any of Your requests to exercise Your User rights.
9. To identify and authenticate Your access to certain features of the Services.
10. To detect and prevent fraudulent and illegal activity or any other type of activity that may jeopardise or negatively affect the integrity of the Services, including by identifying risks associated with Your activity on the Website.
11. To investigate violations of our policies and the Terms as well as enforce our policies and the Terms.
12. To investigate and resolve disputes in connection with Your use of the Services.
13. To assist Us with meeting our regulatory obligations or as required by law or regulation, including for the purpose of ascertaining Your source of funds or income, or as required by other governmental authorities, or to comply with any legal process or respond to a government request.

In addition, We use Your Personal Information upon Your specific and informed consent, such as for certain marketing and promotional activities.
Where You have not consented (or have withdrawn Your consent) to the processing of Your Personal Information by Us, We may continue to process Your Personal Information (a) where processing is required for the performance of the contract (i.e. the Terms) between You and Us; and/or (b) where processing is necessary for compliance with a legal obligation to which We are subject; (c) where processing is necessary for the purposes of a legitimate interest of the Company.

MARKETING

Subject to Your express consent, We will use Your Personal Information, such as Your name, home address, email address, telephone number etc., ourselves or by using our third party subcontractors for the purpose of providing You with promotional materials, concerning the Services as well as products, services, Websites and applications which relate to the Services (“Marketing Affiliates”), which We believe may interest You. If You have consented to receiving marketing offers, You may at any time decline receiving further marketing offers from Us or from Marketing Affiliates by updating Your account preferences.

SHARING INFORMATION

We do not share Your Personal Information with third parties (“Recipients”) except as described in this Privacy Policy. The Personal Information will be disclosed to Recipients only to the extent required for the specific purposes, as stipulated in this Privacy Policy.
We may share Personal Information with any of the following recipients:

1. Any replacement service provider that We engage with to operate the Website.
2. Companies within our group and other affiliated companies.
3. Subcontractors and third-party service providers, as well as their subcontractors, which by way of example include (but is not limited to) cloud computing companies, marketing affiliates, identity verification and fraud prevention services, and other data verifiers.
4. Payment service providers, payment processors and banks.
5. Any third parties who investigate, detect or prevent fraudulent or illegal activity or enable Us to enforce our policies, including in order to ascertain Your source of income or funds (e.g., governmental authorities, law enforcement bodies, banks and other investigatory bodies).
6. Licensing authorities, governmental and regulatory bodies, in accordance with applicable laws and regulations.
7. Potential purchasers, successors or investors in Us, or in the event of a corporate transaction (e.g., sale of a substantial part of our business, merger, reorganization, bankruptcy, consolidation or asset sale of an asset or transfer in the operation thereof) in relation to Us (in such event, the acquiring company or transferee will assume the rights and obligations as described in this Privacy Policy).

In addition to the purposes listed in this Privacy Policy, We share Personal Information with those Recipients for any of the following purposes:

1. Storing such information on our behalf, for example by using cloud computing service providers.
2. Processing such information to assist Us with our business operations (e.g., to process payments and Your deposits; authenticate Your access; auditing our operations; detect and prevent fraudulent or illegal activity, etc.).
3. Performing research, technical diagnostics or analytics.
   Communicating targeted advertising, as well as promotional and informational materials, in accordance with our marketing policy (see above, in the section titled “Marketing”).

Whenever We believe in good faith that disclosure is necessary to protect our rights or legal claims, enforce our policies (including our Terms), protect Your safety or the safety of others, as well as to investigate or prevent any fraud, for security reasons or to help Us with any other related technical issue.

INTERNATIONAL TRANSFER OF INFORMATION

Personal Information We hold about You may be transferred to other countries outside India for any of the purposes described in this Privacy Policy. You expressly provide Your consent for transfer of such Personal Information outside India. Any Personal Information will be protected in accordance with this Privacy Policy as well as with adequate protections in accordance with applicable laws.

THIRD PARTY TRACKING TECHNOLOGIES

When You access our Services, We use (and authorize third parties to use) Web beacons, cookies, pixels, scripts, tags and other technologies (“Tracking Technologies”). The Tracking Technologies allow Us to automatically collect information about You and Your device (for example Your computer or mobile device), for different purposes, such as in order to enhance Your navigation on our Services, improve the performance of our Services and customize Your experience on our Services. We also use this information to collect statistics about the Usage of our Services, perform analytics, deliver content which is tailored to Your interests and administer services to our Users, advertisers, publishers, customers and partners.

THIRD PARTY SERVICES

While using the Services You may encounter links to third party Websites, services or applications. Please keep in mind that this Privacy Policy does not apply to any third-party Websites, services or applications, even if they are accessible, downloadable, or otherwise distributed through the Services.

RETENTION OF PERSONAL INFORMATION

If You have registered an account through our Services, We will retain Your Personal Information during the period Your account is active. In addition, We will retain Your Personal Information for additional periods, as strictly necessary to enable We to meet its legal obligations under applicable laws or regulations, as well as to meet our contractual obligations. In addition, the Group may retain Your Personal Information for longer periods, provided that retaining such information is strictly necessary for our legitimate interests, such as fraud prevention and record keeping, resolving or exercising claims regarding potential disputes, and where We are guided to do so by the applicable supervisory authority.

YOUR RIGHTS UNDER THE GDPR

The Company does not sell Your personal information to anyone. The Company may share the personal information with a third-party, if it is required for further processing or in connection to its business. Such personal information shall be shared in accordance with the confidentiality agreement with the third party, the applicable law and the intended purpose for which the information was collected.
We may release Your personal information when we believe release is required to comply with the Information Technology Act, the California Consumer Privacy Act of 2018 and the General Data protection Regulation. We may release personal information if, in our judgement after review, the release is compelled by law or regulation.

Rights to Your personal information

• Right to access: You have the right to ask for a copy of Your personal data and to verify how we are processing it.
• Right to rectification: If You believe we have inaccurate or incomplete information about You. You have the right to ask us to correct or update it.
• Right to be forgotten: In certain circumstances, You have the right to ask us to remove or erase Your personal data from our records.
• Right to object: You have the right to object to processing of Your personal data. You also have the right not to be subjected to any automated decision making or profiling.
• Right to restriction of processing: You have the right to ask us to restrict processing of Your personal data in cases where the data is inaccurate, or the processing of the data is unlawful. This does not restrict The Company from processing of Your personal data for legal and regulatory requirements.
• Right to withdraw consent: If we process Your personal data based on Your consent, You can withdraw Your consent at any point of time.
• Right to portability: You have the right to ask us to transfer Your data to You, or any other third party.
• Right to lodge a complaint with the competent supervisory authority: You have the right to contact the supervisory authority to complain about Human Edge Health’s personal data protection practices.
• Right to give instructions concerning the use of Your data after Your death: as required by applicable law, You may have the right to give Human Edge Health instructions concerning the use of Your personal data after Your death.
• Except as otherwise provided under applicable law, You have the rights to not receive discriminatory treatment for exercising Your access, data portability, opt-out, and deletion of information rights as set out in this Privacy Policy.

To exercise one or more of these rights, You can email grievances@humanedge.co. You may access Your personal data to modify or update at any time via an online account, or by emailing grievances@humanedge.co. We will respond to Your request in a reasonable timeframe in accordance with applicable law.

Please note that these rights are not absolute, and requests are subject to any applicable legal requirements, including legal and ethical reporting or document retention obligations. We may also rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion, in accordance with our internal policies.

HOW WE KEEP YOUR INFORMATION SECURED

We take great care in implementing and maintaining the security of the Services and Your information. We have put in place appropriate physical and technological safeguards to help prevent unauthorised access, to maintain data security, and to use the information correctly which we collect online. These safeguards vary based on the sensitivity of the information that We collect and store.

We conduct internal audits as well as external audits from independent auditors to ensure the safety of user information.

INFORMATION FOR INDIVIDUALS IN CALIFORNIA

This section specifically applies to Users from the State of California and will apply only where we qualify as a business subject to California. Set out below is our procession of collection, use and disclosure of personal information. At the outset, please note that this section does not apply to the following:

• Any personal information reflecting a communication or a transaction between Us and a California resident acting as a representative of an organization that relates to the organization obtaining products or services from Us.
• Other personal information excluded or excepted from requirements of the California Consumer Privacy Act of 2018.
• California Personal Information We Collect

in the preceding 12 months we may have collected the following categories of California Personal Information:

• Identifiers such as Your name, phone number, email address. Including online identifiers such as IP address tied to Your browser. This information may be shared by us with our service providers.
• Geolocation data. This information may be shared by us with our service providers.
• Internet and other electronic activity information, which can include browsing behaviour and draw inferences from Your activity and interactions with our Services. This information may be shared by us with our service providers.
• Demographic information such as employment and education background. This information may be shared by us with our service providers.
• Biometric information. This information may be shared by us with our service providers, and such third parties as You may authorise.
• Intended Purpose of Use
  We may have in the preceding 12 months used and disclosed the California Personal Information with our service providers, with such third parties as You may authorise and with government entities or third parties to comply with applicable law. The use of California Personal Information collected is described in the section “Using the Collected Information” above.
  In the preceding 12 months, we have not sold California Personal Information. We do not sell California Personal Information, and we do not have actual knowledge that we sell California Personal Information of consumers under 18 years of age.
  The California Personal Information collected is not sold by Us and We will any information collected in the future without providing a right to opt out. Please note that Our advertising partners may collect certain Your electronic network activity to publish advertisements which targeted to Your interest. In order to opt out, You may use cookie preferences to disable ad trackers on the Platform. Additionally, You may limit Your device settings to restrict ad tracking through the mobile app.
  You may make a rights request by emailing us at [support@humanedge.co]. We will verify Your request by asking You to provide information that matches information we have on file about You. Consumers can also designate an authorized agent to exercise these rights on their behalf. Authorized agents should submit requests through the same channels, but we will require proof that the person is authorized to act on Your behalf and may also still ask You to verify Your identity with us directly.

INFORMATION FOR INDIVIDUALS IN THE EUROPEAN UNION

The sections below apply to You if You use our Services while in European Economic Area. Human Edge Advisory Services Private Limited is the data controller for personal data governed by this Privacy Policy.

• Processing of Personal Data
  Your personal information is only processed by Us in the following situations:
• As required to be processed by us by applicable laws;
• As required by Us to provide Services to You;
• For a legitimate interest which includes, increasing efficiency of our Services, communicate to You about changes to our Services and security purposes; and
• Where we have received Your consent.
• Retention of Personal Information The personal data received by Us is retained for no longer than is necessary for the purposes for which it is processed, unless otherwise required for a longer period of time under applicable law.
• Data Subject Requests
  Subject to certain limits and conditions provided under law, You have the following rights:
• Right to access personal data which we hold about You. You may request that such personal data be corrected, erased, or made available in a portable form.
• Right to object processing for data (for instance in case of direct marketing), or You may request that we restrict processing information in certain circumstances. We however may compel processing for legitimate grounds.
• Right to rectification: You have the right to obtain the rectification of any inaccurate personal data concerning You. You also have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
• Right to erasure: in some cases, You have the right to obtain the erasure of personal data concerning You. Upon request, Human Edge Health will permanently and irrevocably anonymize Your data such that it can never be reconstructed to identify You as an individual. However, this is not an absolute right and Human Edge Health may have legal or legitimate grounds for keeping such data
• When we ask for Your consent, You may withdraw that consent at any time.
  
  If You would like to exercise any of these rights and can’t do so directly via the Services or Your device, You may contact us as indicated below

CHANGES TO THE PRIVACY POLICY

We reserve the right to change this Privacy Policy at any time, so please revisit this page frequently. We will provide notice of substantial changes of this Privacy Policy on the App and/or We will send You an e-mail regarding such changes to the applicable e-mail address that You provided to Us. Such substantial changes will take effect no less than fourteen (14) days after such notice was provided. Otherwise, all other changes to this Privacy Policy are effective as of the stated “Last Revised” date, and Your continued use of the Services after the Last Revised date will constitute acceptance of, and agreement to be bound by, those changes.

GRIEVANCES

In accordance with the Information Technology Act, 2000 and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011, We have a Grievance Officer to address Your concerns regarding data safety, privacy, and the platform usage concerns including complaints You have against other users on the platform. We will resolve these issues raised by You within 30 (thirty) days from receiving them. You may contact the Grievance Officer at the following coordinates:
Name: Shoumitro Goswami
Address: 142 Persepolis, GD Somani Road, Cuffe Parade, Mumbai 400005
E-mail: grievences@humanedge.co
If at any time You become aware of the fact or believe that the Company or its employees/ members have not adhered to the principles of this Privacy Policy, please notify Us by e-mail at grievences@humanedge.co and We will use all commercially reasonable efforts to promptly determine and correct the problem.
If You are a resident of the European Economic Area You have the right to file a complaint regarding our data protection practices with a supervisory authority. You may use this directory for contact details: https://edpb.europa.eu/about-edpb/board/members_en.