Gleeo Health’s Privacy Policy

Effective Date: March 28, 2021

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.

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.

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.

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.

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.

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.

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).

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.

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.

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.

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.

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.

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.

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.

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.

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 ;

f) Edge: https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy.

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.

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 support@Gleeohealth.com.

1. Our data protection officer can be reached at support@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.