PRIVACY POLICY

M/S USEKIWI WELLNESS SOLUTIONS PRIVATE LIMITED (“we”, “our”, “us’ or “the Company”) is committed to safeguard your personal information. This Privacy Policy outlines the types of personal data we collect through our Platform, the purposes for which such data is used, and the entities with whom it may be shared. It also explains the security measures we implement to protect your information, your rights regarding your personal data, and how you can reach out to us to understand or exercise those rights. Please review this Privacy Policy carefully prior to using or availing any of products and/or services listed on our Platform

1. DEFINITIONS

1.1. “Applicable Laws”

means all laws, brought into force and effect by the Government of India including rules, regulations and notifications made thereunder and judgments, decrees, injunctions, writs and orders of any court of record, as may be in force, from time to time.

1.2. “Brand/ Brand Partner”

means select third parties (individuals and/or entities) with whom we have contractual arrangement and are authorised by the Company to list, sell, distribute, and/or supply products and/or services through the Platform.

1.3. “Cookies”

means small text files placed on your device by our Platform when you visit or interact with certain features. Cookies typically enable a Platform to remember user actions or preferences over a period of time.

1.4. “Data”

includes personal information, sensitive or otherwise, and/or non-personal information that relates to you and, either directly or in combination with other information, may be used to identify you when you access our Platform.

1.5. “Data Protection Laws”

refers to any applicable legislation or regulation currently in force relating to the collection, processing, storage, or transfer of Data, including Digital Data Protection Act, 2023, Information Technology Act, 2000 & their respective extant rules and regulations.

1.6. “Platform/ E-Commerce Platform”

refers to the virtual e-commerce interface of “Swasthera”, enabling the sale/supply of the Brand’s Products and/or Services through the Company’s website https://swasth360.com and/or its mobile application.

1.7. “User” or “you”

refers to any individual or entity who accesses or uses our Platform, which also includes customers making a purchase of Products and/or Services on our Platform.

2. WHAT DATA DO WE COLLECT ABOUT YOU

We collect Data for various purposes outlined in this Privacy Policy. The types of Data we collect, includes but is not limited to the following:

• 2.1. Contact Information - Includes your first and last name, email address, postal address, country of residence, phone number, and other similar identifiers.
• 2.2. Financial Information - Includes details of your payment instruments, transaction history, payment preferences, mode and method of payment, spending trends, and related data.
• 2.3. Health-Related Information - Includes your medical and health history, treatment plans, medication details prescribed by registered medical practitioners (including dosage and frequency), laboratory testing results, alternative therapies, and information inferred from or related to healthcare services availed through the Platform.
• 2.4. Loyalty Programme Information - Includes loyalty programme identifiers, membership account details, login credentials, profile information, and any affiliation with frequent flyer or travel partner programmes.
• 2.5. Personal Information - Includes your age, gender, date of birth, marital status, nationality, occupation, ethnicity, religion, travel history, and any information contained in responses to surveys, questionnaires, or feedback forms.
• 2.6. Product and Service Information - Includes your membership and registration details, payment records, and information relevant to your participation in product or service offerings, promotional campaigns, or marketing programmes or when you request products and/or services directly from us.
• 2.7. Technical Information - Includes device and usage data relating to your interaction with our Platform, such as Internet Protocol (IP) address, browser type, operating system, and other data collected through cookies, pixels, and similar tracking technologies.
• 2.8. Transaction Information - Includes details relating to your purchases or service requests, including the transaction date, amount, product/service preferences, and history.
• 2.9. User Feedback and Opinions - Includes your reviews, comments, suggestions, complaints, or ratings in relation to products, services, or our Platform functionality.

3. HOW WE COLLECT DATA

We collect your Data through a variety of methods, including the following:

• 3.1. Information You Provide Voluntarily - We receive, collect and store any information entered by you on our Platform. For further details, please refer to the clause titled “Data Shared by You.”
• 3.2. Automatically Collected Information - We automatically gather certain types of information when you interact with our Platform using technologies such as cookies, pixels, and similar tracking tools. For more information, please refer to the clause titled “Data That is Collected Automatically.”
• 3.3. Email Communications - To help tailor our email content and enhance its relevance, we may receive confirmation (where supported by your device) when you open our emails or click on links within them. You may opt out of receiving marketing emails at any time by clicking the "unsubscribe" link provided in such communications.
• 3.4. Information Collected via Third-Party Websites/ Brand Partners - We may receive certain types of information when you interact with third-party websites/ Brand Partners that use our technology or with which we have a formal agreement. As this Data is processed on behalf of those websites/ service providers, its collection and use are governed by their respective privacy policies and not by this Privacy Policy.
• 3.5. Information from Other Sources - We may receive Data about you from other external sources. For instance, if you authorize a third-party service to connect with our Platform, we may obtain information shared by that third party for the purpose of account linkage or verification.

You have control over the Data you share with us. For instance, you may choose to access, update, or delete your personal information through our website or mobile application. Where Data is requested, you have the right to decline to provide it; however, doing so may limit your ability to access certain features or services.

4. DATA SHARED BY YOU

We collect Data that you provide while interacting with our Platform. Such Data may be collected in various circumstances, including but not limited to:

• When you register or sign up to access our products and/or services;
• When you initiate or complete a transaction at our Platform;
• When you participate in surveys or feedback exercises conducted by or on behalf of the company;
• When you subscribe to receive communications from us, including newsletters, promotional offers, or service updates;
• When Data is collected from your interactions during visits to our Platform, including usage patterns or preferences.

5. DATA THAT IS COLLECTED AUTOMATICALLY

1. When you visit our Platform, certain information is collected automatically to help us improve your user experience, optimize our content, and enhance site navigation.
2. Data that is collected automatically includes, but is not limited to: IP address, Browser type and version, Operating system and device information, Language preferences, Browsing activity and session details.
3. Our web servers and third-party service providers may collect and aggregate this information to assess metrics such as the number of visits, average time spent on the website, pages viewed, and navigation patterns. We use this data to monitor and enhance website performance, improve content relevance, and maintain the safety and security of the Platform.
4. We may also collect this Data through the use of cookies, pixels, and similar tracking technologies, consistent with your browser or device settings.

6. OUR USE OF DATA

We collect and use your Data for various legitimate purposes to provide our services, improve user experience, comply with legal obligations, and fulfil contractual requirements. All such processing is undertaken in accordance with Data Protection Laws. Specifically, your Data may be used for the following purposes:

6.1. Performance of Contractual Obligations:

• To fulfil our obligations under any agreement entered into between you and us.
• To facilitate the provision of products and/or services and to communicate with you in relation thereto.

6.2. Facilitating Third-Party Services and Affiliates

• To enable us and authorized Brand Partner to offer and communicate with you about their products and/or services.
• To disclose, transfer, or share your Data with Brand Partners or other third parties in accordance with a valid contract or for a lawful purpose under the Data Protection Laws.

6.3. Personalization and Service Enhancement

• To provide offers, targeted recommendations, and tailored user experiences.
• To operate, evaluate, and enhance our business, Platform, and overall service delivery.
• To generate insights from aggregated Data to better understand user preferences, patterns, and behaviour.

6.4. Marketing and Loyalty Programs

• To inform you about promotions, privileges, and marketing campaigns suited to your user profile.
• To administer loyalty and reward programmes operated by us.

6.5. Relationship and Support

• To respond to your inquiries, claims, complaints, and feedback.
• To improve your shopping experience and facilitate access to cross-brand offers and membership benefits.

6.6. Legal Compliance and Security

• To enforce our “Terms of Use” and other contractual conditions.
• To detect, prevent, or investigate fraud, security breaches, financial loss, or unlawful activities.
• To comply with obligations under applicable laws and lawful requests from regulatory or judicial authorities in accordance with the Data Protection laws.

6.7. Other Purposes

• For any other purpose for which we provide specific notice at the time of data collection, and is otherwise authorised or required by the applicable laws.

7. MINORS

Our Platform is not intended for use by minors. If you are under the age of 18, you may access or use our Platform only under the supervision and with the consent of a parent or legal guardian.

8. SHARING OF DATA

We may share your Data with and for the following purposes:

• 8.1. Brand Partners: Customer information related to transactions made (while purchasing products and /or services of a Brand), may be shared with the respective Brand Partner. These Brand Partners are required to maintain the security and confidentiality of your Data and handle it in accordance with this Privacy Policy and applicable laws.
• 8.2. Service Providers: We may share your Data with Service Providers for activities such as data storage and analysis, system security, customer service, search results, payment processing, credit analysis, profiling, and user analysis. These Service Providers are obligated to process Data strictly in accordance with our instructions and only as necessary for the purposes stated in this Privacy Policy. They must also protect the security and confidentiality of the Data through appropriate technical, organizational, and contractual safeguards.
• 8.3. Information from Other Sources: We may receive information about you from other sources, such as when you authorize a third-party website to interact directly with our platform. In such cases, we may receive Data from that third party to identify your account with them.
• 8.4. Protecting the Company: We may disclose Data where necessary to comply with applicable laws or legal processes, enforce our “Terms of Use” or other agreements, protect the company from harm or financial loss, safeguard individuals’ vital interests, or assist in investigating suspected or actual fraudulent or illegal activities. This may involve sharing information with other companies and organizations for fraud prevention, risk management, and dispute resolution. We do not sell or disclose users’ personal information for commercial purposes in violation of this Privacy Policy.
• 8.5. Business Transfers: In the event of a sale, purchase, or transfer of business units or subsidiaries, your Data may be transferred as part of such transactions. Any Data received from a third party through such transfers will be processed in accordance with this Privacy Policy and applicable laws.
• 8.6. Third Parties: We may also share your Data with other third parties in the following situations:
  • When you request or authorize us to do so;
  • When required to comply with applicable law or respond to valid legal processes; or
  • When necessary to operate and maintain the security of our website or mobile application, including preventing or stopping attacks on our systems or networks.
  These third parties are contractually bound to process sensitive personal Data only in accordance with our instructions and applicable laws, and to safeguard such Data through strict confidentiality, technical, and organizational measures.

9. SECURITY OF DATA

We employ appropriate technical and organisational safeguards to protect your Data and store it on secure servers. These safeguards include measures designed to detect, respond to, and manage any suspected data breaches. If you believe your Data has been misused, lost, or accessed without authorisation, please contact us immediately via the email address provided in clause 17 below.

10. DATA RETENTION

We retain your Data for as long as it is necessary for the use of products and/or services, to provide access to our Platform, or for other purposes such as fulfilling legal obligations, resolving disputes, and enforcing our agreements, when necessary, to the extent permitted under applicable law.

Retention periods may vary depending on the nature of the Data and the specific purpose for which it is processed. Even where Data is deleted pursuant to your rights under clause 11 below, it may continue to be stored on backup or archival systems for legal, regulatory, audit, or tax-related requirements.

11. YOUR RIGHTS AND CHOICES

You have the following rights with respect to your sensitive personal information, which you may exercise by submitting a request through the contact details provided in clause 17 below:

• You are entitled to access to the personal information we hold pertaining to you, and may seek to review or update it.
• You are entitled to request rectification of any inaccurate or incomplete personal information pertaining to you.
• Where processing of the personal information is based on your consent, you may withdraw it at any time without affecting the lawfulness of processing carried out prior to such withdrawal.

It is important that the Data we maintain is accurate and up to date. Please notify us promptly of any changes to your personal information during the period for which we retain it.

12. LOCATION OF DATA STORAGE

All Data collected pursuant to this Privacy Policy is stored on servers located within the territory of India.

13. PROCESSING OF YOUR DATA

We process all Data collected under this Privacy Policy in accordance with its terms and in compliance with applicable laws.

To safeguard your Data and ensure it is afforded a consistent level of protection, we have implemented appropriate contractual safeguards with whom your Data is shared. These agreements obligate such parties to handle your Data in a lawful, secure, and responsible manner, aligned with the standards set forth in this Privacy Policy and applicable legal requirements.

14. PERMISSIONS THAT WE CAPTURE

When you use our Platform, we may request access to certain device features and information to enable functionality, enhance user experience, and ensure the efficient delivery of services. These permissions may include, but are not limited to:

• Location: To provide location-specific content, enable delivery services, or enhance security.
• Camera: For scanning prescriptions, QR codes, or uploading profile images.
• Microphone: Where applicable, for voice search or support interactions.
• Storage: To read and write files necessary for the app’s operation (e.g., storing invoices, prescriptions).
• Contacts/SMS/Call Logs: Only with your express consent, and strictly for features that require such access (e.g., referral services, authentication).
• Phone: To detect device identity and ensure secure login or communication.

Permissions are requested during usage of relevant features of Platform. You have the option to grant or deny access through your device settings. Denial of certain permissions may limit access to some features of the Platform.

15. SEVERABILITY

If any provision of this Privacy Policy, or part thereof, is held to be invalid, unlawful, or unenforceable by a court or other competent authority, such provision or part shall be deemed severed from this Privacy Policy to the extent necessary. The remaining provisions shall continue in full force and effect and shall not be affected or impaired in any manner.

16. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our business practices, legal requirements, or technology. Any modifications will take effect immediately upon being posted on our Platform. By continuing to access or use our Platform after such changes are made, you will be deemed to have accepted the updated terms.

While we may, at our discretion, notify you of material changes via email or other means, we encourage you to review this Privacy Policy periodically to stay informed about how we collect, use, and protect your information.

17. HOW TO CONTACT US

If you wish to access, review, update, or withdraw your consent regarding your personal information, or if you have any questions or concerns related to this Privacy Policy, you may contact us by writing to:

Grievance.officer@affordplan.com

We will endeavour to respond to your request within 30 days from the date of receipt.

18. GRIEVANCE OFFICER

The contact details of our designated Grievance Officer are provided below: