Gleeo Health’s Privacy Policy
Effective
Date: March 28, 2021
1. Introduction
1.
We commit to safeguarding the privacy of our
website visitors and users of the Gleeo Health™
products and services (collectively “Services”).
2.
This policy applies where we are acting as a
“Data Controller” with respect to the personal data processed through the use
of our Services; in other words, where we determine the purposes and means of
the processing of that personal data as part of our offering.
3.
We have establishments in India (Gleeo Health Pvt Ltd.) .
4.
For data processing for the Gleeo Health™ services (www.Gleeohealth.com and associated Gleeo Health™ products) and all other services
provided by Gleeo Health Pvt
Ltd., Gleeo Health Pvt Ltd.
is the Data Controller.
5.
By using our website from any access point,
you consent to our use of cookies in accordance with the terms of this policy.
6.
In this policy, “we”, “us” and “our” refer to
Gleeo Health.
7.
In this policy, “you” and “your” may refer to
you or to the data subjects for which you are processing personal data,
depending on the nature of the context.
2. How we use your personal
data
In this Section we have included:
a) the general categories of personal data that we may
process;
b) in the case of personal data that we did not obtain
directly from you, the source and specific categories of that data;
c) the purposes for which we may process personal data; and
d) the legal bases
of the processing.
1.
We may process your personal data provided in
the course of the use of our Services (“Service Data”). The Service Data may
include name, email address, gender, date of birth, biometric data and health
data and any other submitted or uploaded information. The source of the Service
Data is you or your healthcare provider including device, activity or health
data you share with our Services. The Service Data may be processed for the
purposes of providing our Services, analyzing the use of our Services for
product development, informing you about product news, informing you about
product issues, providing information we believe is of interest to you and
communicating with you. If you are a private person signing up directly to our
Services, the legal basis is your consent. If you are a data controller
representing data subjects, the legal basis for our processing is legitimate
interest.
2.
We may process personally identifiable data
about your use of our website and Services (“Usage Data”). The Usage
Data may include your IP address, geographical location, browser type and
version, device make and model, operating system, referral source, length of
visit, page views and navigation paths, as well as information about the
timing, frequency and pattern of your service use. Usage Data is captured by
our analytics tracking systems, which includes the use of cookies (see Sections
14-16). Usage Data may be processed for the purposes of analyzing the use and
troubleshooting of the website and Services. The legal basis for this
processing is our legitimate interests, namely monitoring and improving our
website and Services.
3.
We may process personally identifiable data
in our monitoring of network traffic of our website and Services (“Traffic
Data”). The Traffic Data may include your IP address, browser type and
version, operating system, and referral source. Traffic Data may be processed
for the purposes of analyzing the use and troubleshooting of the website and
Services. The legal basis for this processing is our legitimate interests,
namely monitoring and improving our website and Services.
4.
We may process access information (“Audit
Log Data”) regarding who has accessed and processed your Service Data and
any access or processing you have made to other people’s Service Data. The
Audit Log Data may include identification of the data subject, who has accessed
the Service Data, when it was accessed, how it was accessed, and changes to
Service Data. Audit Log Data may be processed for the purposes of allowing
investigations to be performed regarding who has accessed your and other
people’s personal data. The legal basis for this processing is legal
requirements, which includes but is not limited to the guidelines defined by MoHFW (India) and Health Insurance Portability and
Accountability Act of 1996 (HIPAA) (USA).
5. We may process
your business related account data (“Business Account Data”). Business Account
Data may include your name, email address and any other submitted information.
The source of the Business Account Data is you, your employer or an industry
partner of yours. The Business Account Data may be processed for the purposes
of operating our website, providing our Services, ensuring the security of our
website and Services, maintaining back-ups of our databases and communicating
with you. If the processing is performed by contract between you (or your
employer) and us and/or taking steps, at your request, to enter into such a
contract, the legal basis for this processing is performance of contract. If
the processing is performed to establish or maintain a business relationship,
the legal basis for this processing is legitimate interest.
6. We may process information
contained in any inquiry you submit to us regarding our goods and/or Services
(“Inquiry Data”) via our website or Services. Inquiry Data may be processed for
the purposes of offering, marketing and selling relevant goods and/or services
to you. The legal basis for this processing is legitimate interest to fulfil your inquiry.
7. We may process
information relating to transactions, including purchases of goods and Services, that you enter into with us and/or through our
website or Services (“Transaction Data”). Transaction Data may include your
contact details, your payment details and the transaction details. Transaction
Data may be processed for the purpose of supplying the purchased goods and
Services and keeping proper records of those transactions. The legal basis for
this processing is the performance of a contract between you and us and/or
taking steps, at your request, to enter into such a contract and legal
requirements for proper accounting.
8. We may process
information that you provide to us for the purpose of subscribing to our email
notifications and/or newsletters (“Notification Data”). Notification Data may
be processed for the purposes of sending you the relevant notifications and/or
newsletters. The legal basis for this processing is consent.
9. We may process
information contained in or relating to any communication that you send to us
(“Correspondence Data”). Correspondence Data may include the communication
content and metadata associated with the communication. Correspondence Data may
be processed for the purposes of communicating with you and record-keeping,
e.g. for technical support or accounting purposes. Further, when you seek
technical support from us, you understand and acknowledge that the
individual(s) providing you with support may need to access your Service Data
and Usage Data in order to diagnose the problem you are seeking support for; in
this case, this information will only be used to help provide you with support.
The legal basis for this processing is our legitimate interests, namely the
proper administration of our business and communications with users, which we
believe will benefit you.
10. We may process information about
you for keeping records of incidents or complaints (“Regulatory Data”). Regulatory
Data may be processed for the purposes of establishing internal reports and
records that may be made available to authorities upon their request. The legal
basis for this processing is legal requirements, for Medical Devices as advised
by MoHFW (India).
11.
We may process your personal data you provide to us when you submit
feedback to Gleeo Health about our services
(“Feedback Data”). The Feedback Data may include name, age and any information
uploaded by you. The source of the Feedback Data is you. Feedback Data may be
processed in marketing material and for publishing on our social channels such
as Facebook, LinkedIn, Twitter and Instagram. The legal basis for this processing is consent.
12. We may process any of
your personal data identified in this policy where necessary for the
establishment, exercise or defense of legal claims, whether in court
proceedings or in an administrative or out-of-court procedure. The legal basis
for this processing is our legitimate interests, namely the protection and
assertion of our legal rights, your legal rights and the legal rights of
others.
13. We may process any of
your personal data identified in this policy where necessary for the purposes
of the protection of yours or others’ personal data. The legal basis for this
processing is our legitimate interests, namely the protection and assertion of
our legal rights, your legal rights and the legal rights of others.
14. In addition to the
specific purposes for which we may process your personal data outlined in this
Section 2, we may also process any of your personal data where such processing
is necessary for compliance with a legal obligation to which we are subject, or
in order to protect your vital interests or the vital interests of another
natural person.
3. Automated
decision-making
1.
We or our Services may automate parts of
decision processes, but we will not use your personal data for the purposes of
automated decision-making.
2.
Decision processes may analyze your personal
data to determine whether or not you or your experience in the Services will be
subject to, but is not limited to, personalized reports, features, alerts,
notifications, and invites to product testing.
3.
Decision processes may analyze your personal
data to determine whether or not you will be subject to personalized marketing
of products, features, events and services that we believe may be of interest
to you.
4. Providing your personal
data to others
1.
Gleeo
Health’s policy is to avoid disclosing your personal data to others. We will
protect and consider your interests at all times. In some cases, listed below,
we may nevertheless disclose your personal data.
2.
We may disclose your personal data to any
member of our group of companies (this means our subsidiaries, our ultimate
holding company and all its subsidiaries) insofar as reasonably necessary for
the purposes, and on the legal bases, set out in this policy.
3.
We may disclose your Service Data to your
healthcare provider when your health devices are synced at your healthcare
provider’s office, during your appointments.
4.
We may disclose your personal data to our
suppliers or subcontractors insofar as reasonably necessary in order to provide
the Services. However, Service Data enjoys additional restrictions and may not
be disclosed to any such third party suppliers or contractors unless pseudonymized, e.g. encrypted by a security key managed by,
and only by, Gleeo Health. Please reach out to Gleeo Health to request a current list of Gleeo Health’s suppliers and subcontractors that process
your personal data.
5.
Financial transactions relating to our
Services are handled by our payment services providers. We will share
Transaction Data with our payment services providers only to the extent necessary
for the purposes of processing your payments, refunding such payments and
dealing with complaints and queries relating to such payments and refunds.
Please reach out to Gleeo Health to request a current
list of Gleeo Health’s payment services providers
that process your personal data.
6.
We may disclose your Inquiry Data to our
service providers for the purpose of enabling them to deliver services to us so
that we can offer, market and sell to you relevant goods and/or services.
7.
We may disclose your personal data to Third
Party applications such as the Apple HealthKit to
which you have chosen, at your sole discretion, to share your personal data. We
will not share this data to any Third Party applications without your consent.
Once your data has been shared at your discretion to a Third Party application,
we no longer control the use of, access to, or disclosure of that data from
that application, so you should understand the terms of use and privacy
policies for any Third Party applications prior to opting in and consenting to
share data with them.
8.
In addition to the specific disclosures of
personal data set out in this Section 4, we may disclose your personal data
where such disclosure is necessary for compliance with a legal obligation to
which we are subject, or in order to protect your vital interests or the vital
interests of another natural person. We may also disclose your personal data
where such disclosure is necessary for the establishment, exercise or defense
of legal claims, whether in court proceedings or in an administrative or
out-of-court procedure.
5. International transfers
of your personal data
1.
If you are using services provided by Gleeo Health Pvt Ltd. and you are
not located within India, your Service Data is stored in India and is protected
by the MoHFW (India) Health Insurance Portability and
Accountability Act of 1996 (HIPAA) (USA), in addition to any applicable local
and/or national jurisdiction of yours. In this Section 5, we provide information
about the circumstances in which your personal data may be transferred to
countries outside India. For the avoidance of doubt, this Section 5 is only
applicable if you are not located within India.
2.
We use service providers in order to deliver different
elements of the Services. Some of these service providers are located outside
of India. Any international transfers of personal data will be protected by
appropriate safeguards, namely the use of standard contractual clauses adopted
or approved by India, or Binding Corporate Rules, or your explicit consent.
6. Retaining and deleting
personal data
1.
This Section outlines our data retention
policies and procedures, which are designed to help ensure that we comply with
our legal obligations in relation to the retention and deletion of personal
data.
2.
Personal data that we process for any
purpose(s) shall not be kept for longer than is necessary for that purpose(s).
3.
We will retain your personal data as follows:
a) Service Data will be retained during the period for which
you have a valid Service account with us, and for a maximum period of 30 days
following termination of your Service account.
b) Usage Data will be retained during the period for which
you have a valid Service account with us, and for a maximum period of 30 days
following termination of your Service account.
c) Traffic Data will be retained for a maximum period of 30
days following the creation of such data.
d) Audit Log Data will be retained for a maximum period of
10 years following the creation of such data.
e) Business Account Data will be retained during the period
where there is an active business relationship between you and Gleeo Health, and for a maximum period of 12 months
following the termination of such business relationship.
f) Inquiry Data will be retained until the inquiry has been
resolved, and for a maximum period of 24 months following the resolution of the
most recent inquiry from you.
g) Transaction Data will be retained for a minimum of 7
years following the end of the year for which the transaction was performed,
and for a maximum period of 1 year following the end of said 7 year period.
h) Notification Data will be retained during the period for
which you have a valid Service account with us and/or you have elected to allow
such processing. Should you withdraw your consent and object to such
processing, Notification Data will be retained for a maximum period of 30 days
following the date of your request.
i) Correspondence Data will be retained until the inquiry
has been resolved, and for a maximum period of 24 months following the
resolution of the most recent inquiry from you, or following the end of our
relationship (e.g. service contract), whichever is latest.
j) Regulatory Data will be retained for 10 years after the
last production date of the product in question, and for a maximum period of 12
months following the end of said 10 year period.
4.
Notwithstanding the other provisions of this
Section, we may retain your personal data for a longer period where such
retention is necessary for compliance with a legal obligation to which we are
subject, or in order to protect your vital interests or the vital interests of
another natural person.
7. Security of personal
data
1.
We will take appropriate technical and
organizational precautions to secure your personal data and to prevent the
loss, misuse or alteration of your personal data.
2.
We will store all your personal data on
secure servers. Should personal data be provided to us in physical form, it
will be stored in secure manual record-keeping systems.
3.
All personal data stored electronically will
be stored by us in encrypted form.
4.
Transactions that are sent to and from your
client, e.g. computer or mobile app, are protected by encryption technology.
5.
You should ensure that your password(s) of
our Services is not susceptible to being guessed, whether by a person or a
computer program. You are responsible for keeping the password you use for
accessing our Services confidential. We will not ask you for your password
(except when you log in to our Services).
8. Amendments
1.
We may update this policy from time to time
by publishing a new version on our website at Gleeo
Health https://gleeohealth.com/privacy.htm
2.
You should check this page occasionally to
ensure you are happy with any changes to this policy.
3.
We may notify you of changes to this policy
by email, through a (private or public) messaging system or on our website.
9. Your rights
1.
In this Section, we have summarized the
rights that you have under data protection laws. Some of the rights are
complex, and not all of the details have been included in our summary.
Accordingly, you should read the relevant laws and guidance from the regulatory
authorities for a full explanation of these rights.
2.
Your principal rights under data protection
law are:
a) the right to request access;
b) the right to request rectification;
c) the right to request erasure;
d) the right to request the restriction of the processing;
e) the right to object to processing;
f) the right to data portability;
g) the right to complain to a supervisory authority; and
h) the right to
withdraw consent.
3.
Access: You have the right to confirmation from us as to whether
or not we process your personal data and, where we do, access that personal
data, together with certain additional information. That additional information
includes details of the purposes of the processing, the categories of personal
data concerned and the recipients of the personal data. Providing that the
rights and freedoms of others are not affected, upon request, we will supply to
you a copy of your personal data. The first copy will be provided free of
charge, but additional copies may be subject to a reasonable fee. Provision of
such information will be subject to the supply of appropriate evidence of your
identity. You can access your Service Data by logging into our Services and we
may direct you there as a response to such request.
4.
Rectification: You have the right to have any inaccurate personal data
about you rectified and, taking into account the purposes of the processing, to
have any incomplete personal data about you completed.
5.
Erasure: In some circumstances you have the right to request the
erasure of your personal data without undue delay. Those circumstances include:
the personal data are no longer necessary in relation to the purposes for which
they were collected or otherwise processed; you withdraw consent to
consent-based processing; you object to the processing under certain rules of
applicable data protection law; the processing is for direct marketing
purposes; and the personal data have been unlawfully processed. However, there
are exclusions of the right to erasure. The general exclusions include where
processing is necessary: for exercising the right of freedom of expression and
information; for compliance with a legal or regulatory obligation; or for the
establishment, exercise or defense of legal claims.
6.
Restricted Processing: In some circumstances you have the right to request
the restriction of the processing of your personal data. Those circumstances
are: you contest the accuracy of the personal data; processing is unlawful but
you oppose erasure; we no longer need the personal data for the purposes of our
processing, but you require personal data for the establishment, exercise or
defense of legal claims; and you have objected to processing, pending the
verification of that objection. Where processing has been restricted on this
basis, we may continue to store your personal data. However, we will only
otherwise process it: with your consent; for the establishment, exercise or
defense of legal claims; for the protection of the rights of another natural or
legal person; or for reasons of important public interest.
7.
Objection to Processing: You have the right to object to our processing of
your personal data on grounds relating to your particular situation, but only
to the extent that the legal basis for the processing is that the processing is
necessary for any of the following: the performance of a task carried out in
the public interest or in the exercise of any official authority vested in us;
or the purposes of the legitimate interests pursued by us or by a third party.
If you make such an objection, we will cease to process the personal
information unless we can demonstrate compelling legitimate grounds for the
processing which override your interests, rights and freedoms, or the
processing is for the establishment, exercise or defense of legal claims.
8.
Direct Marketing: You have the right to object to our processing of your
personal data for direct marketing purposes (including profiling for direct
marketing purposes). If you make such an objection, we will cease to process
your personal data for this purpose.
9.
Data Portability: To the extent that the legal basis for our
processing of your personal data is:(a) consent; or
(b) that the processing is necessary for the performance of a contract to which
you are party or in order to take steps at your request prior to entering into
a contract, and such processing is carried out by automated means, you have the
right to receive your personal data from us in a structured, commonly used and
machine-readable format. However, this right does not apply where it would
adversely affect the rights and freedoms of others.
10. Complaints to a Supervisory Authority: If you consider that our processing of your personal
information infringes data protection laws, you have a legal right to lodge a
complaint with a supervisory authority responsible for data protection.
11. Withdrawal of Consent: To
the extent that the legal basis for our processing of your personal information
is consent, you have the right to withdraw that consent at any time. Withdrawal
will not affect the lawfulness of processing before the withdrawal.
12. You may exercise any of your rights in relation to your personal
data by written policy to us. See Section 20 for contact details.
10. Third party websites
1.
Our website and Services can include
hyperlinks to, and details of, third party websites.
2.
We have no control over, and are not
responsible for, the privacy policies and practices of third parties.
11. Personal data of children
1.
Our Services are targeted at persons of all
ages. For children younger than 16 years, a parent’s or legal guardian’s consent
is required in order to use our Services.
2.
If we have reason to believe that we hold
personal data of a person under the age of 16 in our databases without the
appropriate consents, we may delete that personal data.
12. Updating information
1.
For Service Data, you have the ability to
have your personal data corrected yourself by logging into our Services or
having your care provider do it for you.
13. Acting as a data processor
1.
In cases where we do not act as a data controller,
but instead we act as a data processor, this policy shall not apply. Our legal
obligations as a data processor are instead set out in the contract between us
and the relevant Data Controller.
14. About cookies
1.
A cookie is a file containing an identifier
(a string of letters and numbers) that is sent by a web server to a web browser
and is stored by the browser. The identifier is then sent back to the server
each time the browser requests a page from the server.
2.
Cookies may be either “persistent” cookies or
“session” cookies: a persistent cookie will be stored by a web browser and will
remain valid until its set expiry date, unless deleted by the user before the
expiry date; a session cookie, on the other hand, will expire at the end of the
user session, when the web browser is closed.
3.
Cookies do not typically contain any
information that personally identifies a user, but personal information that we
store about you may be linked to the information stored in and obtained from
cookies.
15. Cookies that we use
1.
We use cookies for the following purposes:
a) authentication – we use cookies to identify you when you
visit our website, as you navigate our website and use our Services;
b) status – we use cookies to help us to determine if you
are logged into our Services;
c) personalization – we use cookies to store information
about your preferences and to personalize our website and Services for you
(e.g. language selection);
d) security – we use cookies as an element of the security
measures used to protect user accounts, including preventing fraudulent use of
login credentials, and to protect our website and services generally;
e) analysis – we use cookies to help us to analyze the use
and performance of our website and services; and
f) cookie
consent – we use cookies to store your preferences in relation to the use of
cookies more generally.
16. Managing cookies
1.
Most browsers allow you to refuse to accept cookies
and to delete cookies. The methods for doing so vary from browser to browser,
and from version to version. You can however obtain up-to-date information
about blocking and deleting cookies via these links:
a) Chrome: https://support.google.com/chrome/answer/95647?hl=en ;
b) Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences ;
c) Opera: http://www.opera.com/help/tutorials/security/cookies/ ;
d) Internet Explorer: https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies ;
e) Safari: https://support.apple.com/guide/safari/manage-cookies-and-website-data-sfri11471/mac ; and
f) Edge: https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy.
2.
Blocking all cookies will have a negative
impact on the usability of many websites and our Services
3.
If you block cookies, you will not be able to
use all the features on our website and Services.
17. Gleeo Health’s
right to processing of anonymized data
1.
By submitting your personal data to us, we
may permanently anonymize the personal data and use
it for statistical analysis, clinical research, demographic analysis, profiling
of user behaviors within the application and characteristics and to measure
interest in and management of physical conditions and similar processing.
Permanently anonymized data does not constitute
personally identifiable information and is therefore not traceable back to you.
Permanently anonymized data may be exported to any
country in or outside India or elsewhere. Both anonymization
and tokenization may be used to anonymize data.
18. Our details
1.
We are registered in:
India as Gleeo Health Pvt Ltd. and the registered office is at 42, State Bank Colony,
Delhi, India and
2.
Our principal place of business is Gleeo Health Pvt Ltd.’s registered office.
3.
You can contact us:
a) by post, to the postal address given above;
b) using our website (available at www.Gleeohealth.com ) and Service
contact forms;
c) by telephone, on the contact number published on our
website from time to time; or
d) by email,
using the email address published on our website. For privacy related matters,
you may email privacy@Gleeohealth.com.
19. Data protection officer
1.
Our data protection officer can be reached at
privacy@Gleeohealth.com.
Thank you for taking the time to read our
Privacy policy. Should you have any questions or concerns, don’t hesitate to
contact us.