1. Introduction

We, at thirty2brain.com PRIVATE LIMITED (hereinafter referred to as “thirty2brain.com”), are committed to respecting your online privacy and recognize the need for appropriate protection and management of any personally identifiable information you share with us. This Privacy Policy (“Policy”) describes how thirty2brain.com collects, uses, discloses and transfers personal information of users through its websites and applications, including through thirty2brain.com, mobile applications and online services (collectively, the “Platform”). This policy applies to those who visit the Platform, or whose information thirty2brain.com otherwise receives in connection with its services (such as contact information of individuals associated with thirty2brain.com including partners) (hereinafter collectively referred to as “Users”). For the purposes of the Privacy Policy, “You” or “Your” shall mean the person who is accessing the Platform.

This Privacy Policy is published in compliance with, inter alia: Section 43A of the Information Technology Act, 2000; Regulation 4 of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011 (the “SPI Rules”); Regulation 3(1) of the Information Technology (Intermediaries Guidelines) Rules, 2011.

2. Types of Personal Information collected by thirty2brain.com

“Personal information” (PI) – means any information relating to an identified or identifiable natural person including common identifiers such as a name, an identification number, location data, an online identifier or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person and any other information that is so categorized by applicable laws. We collect information about you and/or your usage to provide better services and offerings.

The Personal Information that we collect, and how we collect it, depends upon how you interact with us. We collect the following categories of Sensitive Personal Information in the following ways:

• A. When your register with us we collect your name, contact data (such as your email address and phone number); demographic data (such as your gender, your date of birth and your pin code); medical history data regarding your usage of the services and history of the appointments made by or with you through the use of our Services; medical insurance data (such as your insurance carrier and insurance plan); other information that you voluntarily choose to provide to us (such as information shared by you with us through emails or letters.)
• B. The information collected from you by thirty2brain.com may constitute ‘personal information’ or ‘sensitive personal data or information’ under the SPI Rules. The SPI Rules further define “Sensitive Personal Data or Information” of a person to mean personal information about that person relating to:
  • passwords; financial information such as bank accounts, credit and debit card details or other payment instrument details; physical, physiological and mental health condition; sexual orientation; medical records and history; biometric information; information received by body corporate under lawful contract or otherwise; visitor details as provided at the time of registration or thereafter; and call data records.
• C. thirty2brain.com will be free to use, collect and disclose information that is freely available in the public domain without your consent.
• D. information about the services that you use and how you use them, including log information and location information, when you are a user of the services through the Platform;
• E. we may collect your Personal Information such as name, age, contact details, preferences, etc. through surveys and forms, when you choose to participate in these surveys etc.;
• F. when you communicate with thirty2brain.com, we collect information about your communication and any information you choose to provide;
• G. when you visit the Platform, we use cookies to automatically collect, store and use technical information about your system and interaction with our Platform;
• H. when you use a device to access the Platform, thirty2brain.com may collect technical or other related information from the device as well as the device location;

To the extent permitted by law, thirty2brain.com may record and monitor your communications with us to ensure compliance with our legal and regulatory obligations and our internal policies. This may include the recording of telephone conversations;

3. How thirty2brain.com may use your Personal Information

We will only use your personal data in a fair and reasonable manner, and where we have a lawful reason to do so.

Our use of your personal data depends on the purpose for which you interact with us. We may process your Personal Information for the following purposes:

• A. Providing our services and products to you including to send you related alerts, calendar alerts, relevant search results and other recommendations facilities;
• B. Protecting our Users and providing you with customer support;
• C. We use information collected from cookies and other technologies, to improve your user experience and the overall quality of our services (for more information please refer to paragraph 4 below). When showing you tailored ads, we will not associate an identifier from cookies or similar technologies with sensitive categories, such as those based on race, religion, sexual orientation or health.
• D. Improving the Platform and its content to provide better features and services.
• E. Conducting market research and surveys with the aim of improving our products and services.
• F. Sending you information about our products and services for marketing purposes and promotions;
• G. Preventing, detecting, investigating and taking action against crimes (including but not limited to fraud and other financial crimes), any other illegal activities, suspected fraud, or violations of thirty2brain.com Terms of Use in any jurisdiction.
• H. To the extent required for identity verification, government sanctions screening and due diligence checks.
• I. Establishing, exercising or defending legal rights in connection with legal proceedings (including any prospective legal proceedings) and seeking professional or legal advice in relation to such legal proceedings.

4. Cookies and Other Tracking Technologies

Some of our web pages utilize “cookies” and other tracking technologies. A “cookie” is a small text file that may be used, for example, to collect information about web-site activity. Some cookies and other technologies may serve to recall Personal Information previously indicated by a user. Most browsers allow you to control cookies, including whether or not to accept them and how to remove them.

You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser, but please note that if you choose to erase or block your cookies, you will need to re-enter your original user ID and password to gain access to certain parts of the Platform.

Tracking technologies may record information such as Internet domain and host names; Internet protocol (IP) addresses; browser software and operating system types; clickstream patterns; and dates and times that our site is accessed. Our use of cookies and other tracking technologies allows us to improve our Platform and the overall website experience. We may also analyse information that does not contain Personal Information for trends and statistics.

For more information about our use of cookies please refer to our Cookie Policy.

5. The Basis/ Grounds which we rely on for collection and processing of your Personal Information:

Your Personal Information is collected and processed by thirty2brain.com based on the following legal grounds depending upon the nature of Personal Information and the purposes for which it is processed.

Consent:

thirty2brain.com relies on your consent in order to process your Personal Information in certain situations. If thirty2brain.com requires your consent to collect and process certain Personal Information, as per the requirements under the applicable data protection laws, your consent is sought at the time of collection of your Personal Information and such processing will only be performed where consent is secured.

Compliance with a legal obligation:

Your Personal Information may be processed by thirty2brain.com, to the extent that such processing is necessary to allow thirty2brain.com to comply with a legal obligation. An example of this would be if thirty2brain.com is required to disclose your Personal Information to respond to a court order or if thirty2brain.com is required to retain specific records for a fixed period to comply with requirements under any applicable law.

6. Information Sharing and Disclosure

thirty2brain.com does not disclose, transfer or share your Personal Information with others except with:

Our affiliates and group companies to the extent required for our internal business and/or administrative purposes and/or general corporate operations and for provision of services aimed at helping you and improve our services;

Third parties including enforcement, regulatory and judicial authorities, if we determine that disclosure of your Personal Information is required to a) respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims; or b) investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of thirty2brain.com Terms of Use or as otherwise required by law;

In the event of a merger, acquisition, financing, or sale of assets or any other situation involving the transfer of some or all of thirty2brain.com business assets we may disclose Personal Information to those involved in the negotiation or transfer.

Third party service providers and marketing partners that thirty2brain.com engages to a) provide services over the Platform on thirty2brain.com behalf; b) maintain the Platform and mailing lists; or c) communicate with you on thirty2brain.com behalf about offers relating to its products and/or services. thirty2brain.com will take reasonable steps to ensure that these third-party service providers are obligated to protect your Personal Information and are also subject to appropriate confidentiality / non-disclosure obligations.

The Company does not provide any Personal Information to the advertiser when you interact with or view a targeted advertisement. However, if you interact with or view an advertisement, the advertiser may make certain assumptions and, in the process, learn certain Personal Information about you. For instance, if you view and click an advertisement that is targeted towards women in the age group 18- 24 from a specific geographic area, the advertiser may assume that you meet the relevant criteria.

thirty2brain.com does not intend to transfer Personal Information without your consent to third parties who are not bound to act on thirty2brain.com behalf unless such transfer is legally required.

If your Personal Information is transferred outside India, we take the necessary steps to protect your Personal Information in accordance with applicable data protection laws.

7. Third Party Content:

Please be aware that the Platform sometimes may contain links to other sites that are not governed by this Privacy Policy. Users may be directed to third-party sites for more information, such as advertisers, blogs, content sponsorships, vendor services, social networks, etc.

thirty2brain.com makes no representations or warranties regarding how your information is stored or used on third-party servers. We recommend that you review the applicable privacy statements and policies of each third-party site linked from the Platform to determine their use of your personal information.

8. Children Information

Use of our Platform is available only to persons who can form a legally binding contract under the Indian Contract Act, 1872. We do not knowingly solicit or collect personal information from children under the age of 18 years. If you have shared any personal information of children under the age of 18 years, you represent that you have the authority to do so and permit us to use the information in accordance with this Privacy Policy. If you are under the age of 18 or the age of majority in your jurisdiction, you must use the Platform under the supervision of your parent, legal guardian or responsible adult.

9. Retention of Personal Information

We retain your personal information in accordance with applicable laws, for a period no longer than is required for the purpose for which it was collected or as required under any applicable law. However, we may retain data related to you if we believe it may be necessary to prevent fraud or future abuse, to enable thirty2brain.com to exercise its legal rights and/or defend against legal claims or if required by law or for other legitimate purposes.

We may continue to retain your data in anonymised form for analytical and research purposes.

10. Controlling your personal information

You have the right to invoke your rights which are available to data principals or data subjects (as per applicable laws and regulations) in relation to your Personal Information which is being processed by thirty2brain.com.

thirty2brain.com provides you the ability to keep your Personal Information accurate and up-to-date. If at any time you would like to a) rectify, update or correct your Personal Information; b) obtain confirmation on whether or not your Personal Information is processed by it; c) access your Personal Information or exercise your right to data portability; or d) exercise your right to restrict the continuing disclosure of your Personal Information to any third party by  thirty2brain.com in certain circumstances, you are requested to contact us using the contact details mentions in paragraph 14 below. We will require you to provide a valid proof of your identity, in order to ensure that your rights are respected. For the exercise of certain rights, you may be required to approach the relevant authority / designated officer as per the provisions of the applicable data protection laws, thirty2brain.com may in accordance with the provisions of applicable data protection laws, charge a fee for fulfilling your request, in particular in case of excessive or manifestly unfounded request. Further you acknowledge that the above mentioned rights are not absolute and are subject to limitations as per the applicable data protection laws.

At any time, if you wish to delete your account on thirty2brain.com it can be initiated by raising a request with our call center and necessary action for deletion of user account will be taken by us.

11. Confidentiality and Security

The security and confidentiality of your Personal Information is important to us and thirty2brain.com has invested significant resources to protect the safekeeping and confidentiality of your personal data. When using external service providers acting as processors, we require that they adhere to the same standards as thirty2brain.com does. Regardless of where your Personal Information is transferred or stored, we take all steps reasonably necessary to ensure that personal data is kept secure.

We seek to ensure compliance with the requirements of the Information Technology Act, 2000 and Rules made there under to ensure the protection and preservation of your privacy. We have physical, electronic, and procedural safeguards that comply with the laws prevalent in India to protect your Personal Information. By accepting the terms of this Privacy Policy, you agree that the standards and practices being implemented by us, are reasonable and sufficient for the protection of your Personal Information.

Your Personal Information is maintained by thirty2brain.com in electronic form on its equipment, and on the equipment of its employees. Such information may also be converted to physical form from time to time. thirty2brain.com takes all necessary precautions to protect your personal information both online and off-line, and implements reasonable security practices and measures including certain managerial, technical, operational and physical security control measures that are commensurate with respect to the information being collected and the nature of thirty2brain.com business.

No administrator at thirty2brain.com will have knowledge of your password. It is important for you to protect against unauthorized access to your password, your computer and your mobile phone. Be sure to log off from the Website when finished. thirty2brain.com does not undertake any liability for any unauthorised use of your account and password. If you suspect any unauthorized use of your account, you must immediately notify thirty2brain.com by sending an email to info@thirty2brain.com You shall be liable to indemnify thirty2brain.com due to any loss suffered by it due to such unauthorized use of your account and password.

thirty2brain.com makes all User information accessible to its employees, agents or partners and third parties only on a need-to-know basis, and binds only its employees to strict confidentiality obligations.

Part of the functionality of thirty2brain.com is assisting the doctors to maintain and organise such information. thirty2brain.com may, therefore, retain and submit all such records to the appropriate authorities, or to doctors who request access to such information.

Part of the functionality of the thirty2brain.com is assisting the patients to access information relating to them. thirty2brain.commay, therefore, retain and submit all such records to the relevant patients, or to their doctors.

Notwithstanding the above, thirty2brain.com is not responsible for the confidentiality, security or distribution of your Personal Information by our partners and third parties outside the scope of our agreement with such partners and third parties. Further, thirty2brain.com shall not be responsible for any breach of security or for any actions of any third parties or events that are beyond the reasonable control of thirty2brain.com including but not limited to, acts of government, computer hacking, unauthorised access to computer data and storage device, computer crashes, breach of security and encryption, poor quality of Internet service or telephone service of the User etc.

12. Social Media

thirty2brain.com may operate channels, pages and accounts on some social media sites to inform, assist and engage with customers. thirty2brain.com monitors and records comments and posts made on these channels about itself in order to improve its products and services. Please note that you must not communicate the following information to thirty2brain.com through such social media sites:

– sensitive personal data including (i) special categories of personal data meaning any information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation and (ii) other sensitive personal data such as criminal convictions and offences and national identification number ; – Excessive, inappropriate, offensive or defamatory content. thirty2brain.com is not responsible for any information posted on those sites on its behalf thirty2brain.com is only responsible for its own use of the Personal Information received through such sites.

13. Changes to this Privacy Policy

thirty2brain.com reserves the right to update, change or modify this Privacy Policy at any time. The Privacy Policy shall come to effect from the date of publication of such update, change or modification.

14. Disclaimer

thirty2brain.com does not store any account related information or any credit / debit card details. thirty2brain.com shall not be liable for any loss or damage sustained by Users as a result of any disclosure (inadvertent or otherwise) of any information concerning the User’s account, credit cards or debit cards in the course of any online transactions or payments made for any products and/or services offered through the Platform.

In case any Personal Information is shared by you with thirty2brain.com which is not requested by thirty2brain.com during registration, (whether mandatorily or optionally), thirty2brain.com will not be liable for any information security breach or disclosure in relation to such information.

If you have any questions regarding this Privacy Policy or the protection of your Personal Information, please contact thirty2brain.com Data Protection Officer/ Grievance Officer at the following:

15. Data Protection Officer/ Grievance Officer

In case you have any complaints and/or grievances in relation to the processing of your Personal Information you can send your complaints via e-mail to our grievance officer:

Grievance Officer
Thirty2brain
Phone: +91 – 6280430890
Email: info@thirty2brain.com