PRIVACY POLICY

This privacy policy (“Privacy Policy”), as on 05/03/2025, summaries how Health Galaxy Technologies Private Limited, a private limited company duly incorporated and existing in accordance of the Companies Act, 2013 and having its registered office at 44, Backary Portion, 2nd Floor, Regal Building, New Delhi G.P.O., New Delhi, India, 110001 (“Us”, “We”, “Company” or “Our”), together with its affiliates, Processes (defined below), collects, stores, gathers, shares, and uses your  personal data and information made available to the Company by You and/or any person authorized by You and/or any information automatically collected and stored by Us, based on your interaction with Us and the products and/or services (“Services”) availed by You on the website https://healthgalaxy.org/ or mobile application currently named ’Health Galaxy’ or in each instance any pages thereof  (collectively “Platform”), either in the capacity of a visitor and/or in the capacity of a registered user. This Privacy Policy may be revised by the Company from time to time. If we make any changes to this Privacy Policy, We will notify you by posting the updated version on Our Platform or through other appropriate channels, as deem fit by the Company. We strongly advise You to read the Privacy Policy fully and periodically. Your continued use of the Services after any changes are posted will be considered your acceptance of the updated Privacy Policy and its terms.

For the purposes of this Privacy Policy, the terms "You", "you", "Your", "your", or "User" shall refer to (i) any individual who visits, uses, or accesses the Platform, (ii) end-customers who sign up on the Platform to inter alia use the Company’s Services in order to access information offered on the Platform, and (iii) a lawful guardian for and on behalf of any person with disability.

Please note that a person with disability, may only use or access the Platform and its Services with the consent of a lawful guardian and provided that lawful guardian has accepted and consented to this Privacy Policy for and on behalf of such User. If You are under 18 (eighteen) years of age, You shall not use the Platform and/or any Services on the Platform.

For the purposes of this Privacy Policy, the term “Processes/Processing/Process” shall refer to in relation to personal data, means a wholly or partly automated operation or set of operations performed on digital personal data, and includes operations such as collection, recording, organisation, structuring, storage, adaptation, retrieval, use, alignment or combination, indexing, sharing, disclosure by transmission, dissemination or otherwise making available, restriction, erasure or destruction. 

The Services can be accessed, used, and obtained in accordance with our Terms of Use, available at https://healthgalaxy.org/ ("Terms of Use"). If you do not agree with the Policy, we would advise you to not visit/use the Platform and/or avail any Services of the Company.

By accessing Our Platform or using Our Services, you acknowledge and consent to the data Processing practices described in this Privacy Policy, our Terms and Conditions, and any other relevant documents or pages. We are committed to safeguarding your Personal Information with the highest level of care and security. As detailed below, your Personal Information may be collected and used by the Company, or shared with third parties working on our behalf. This Privacy Policy should be considered a valid Notice under The Digital Personal Data Protection Act, 2023 (“DPDP Act”). 

I. COLLECTION OF DATA

Basis your usage of the Platform, Company may collect the following data:

1. For any unregistered user, Company may inter alia collect Your IP address, your location, how you behave on the Platform (what pages you land on, how much time you spend, etc.); what device you use to access the Platform and its details (model, operating system, etc.); cookies and web bugs data; any information received about You from other sources; any information provided by You to Company or received by Company including as per part of survey forms;  information about You provided by through chat bots of the Company.

2. For any registered user, in addition to the information collected under (a), Company may inter alia collect: (i) Your name, age, gender, phone number, e-mail address, mailing address, residential address, PAN details, marital status, date of birth, date of marriage anniversary (if applicable), blood groups, medical records (if any) (including but not limited to medical/fitness parameters) received from You and/or any third party partners and/or laboratories, lab reports, height, weight, lifestyle, medical conditions (if any), food preferences, health goals or fitness regimes; (ii) Your ethnicity, genetics, health or sexual orientation; (iii) username or other relevant unique identifier such as alpha numeric or numeric identifier  ; (iv) credit card/debit card/other payment mode information to facilitate payments for our Services; (v) all health data and parameters through the integration with and/or received from  third party applications/websites/services (for e.g., Google Health Connect, Fitbit, Apple Watch) including your heart rate, number of steps taken, medical test reports, etc.; (vi) Your  reviews, user experiences; (vii) Your pictures, voice recordings; (viii) information available on WhatsApp groups for specific Users, as determined by the Company.

3. Sensitive personal information: Company may collect and Process certain data such as ethnic origin, genetics, health or sexual orientation, which are considered sensitive.

(collectively “Personal Information”) 

II. USE OF PERSONAL INFORMATION

We may use Your Personal Information for the purposes including but not limited to (i) assist You in registering for and enabling the provision of Our Services and offering the Platform ; (ii) display age-appropriate content and advertisements; (iii) monitor and track Your nutrition, weight, and fitness activities; (iv) monitor and track Your smoking/vaping or any other activities that may lead to cardiovascular diseases; (v) create a personalized diet plan and training regimen for Your heart health; (vi) process payments for Our Services, working with a third-party payment provider; (vii) process Your requests, inquiries, complaints, and to provide customer support services; (viii) inform You about current or new offers, content, advertisements, surveys, key policies; (ix) provide You with informative features and services that We may develop periodically; (x) for analytics and reviews to help enhance, test, and improve Our Services including any prediction accuracies and improve personalisation; (xi) to fulfil any requirements under applicable law; (xii) analyse and identify your behaviour and enhance the interactions you have with the Platform; (xiii) send you e-mails/newsletters, re-target Company advertisements or re-market our Services using services from third-parties; (xiv) share with or disclose to any third party test laboratory, third-party medical practitioners or diagnostic labs to facilitate heart health solutions and reports; (xv) to provide functionality, fix bugs and errors, analyze performance, improve the usability, personalisation and effectiveness of Services; (xvi) to prevent and detect fraud and abuse in order to protect the security of Our Users; (xvii) for future analysis of Platform traffic. 

You hereby expressly and unambiguously consent to our collection, use, sharing, Processing and disclosure of your Personal Information as described herein and as may be required for Company to offer Services to you and as may be required for compliance with applicable laws, and you further agree to be bound by the terms of this Privacy Policy. 

III. DISCLOSURE OF PERSONAL DATA 

There might be certain situations in which We may disclose, or be required to disclose, Your Personal Information to third parties. These situations might include but not limited to (i) Our affiliates; (ii) Our service providers who collect and store data through forms submitted by Users of the Platform; (iii) Our sub-contractors, authorised designees that are required to offer Services and/or in connection with operation of Platform (iv) Our advertising and marketing teams, who help us deliver personalized ads to Your devices or contact you via email, phone, SMS, or other methods, where such consent will be provided by You; (v) public authorities as and when required under applicable law within or outside of India; (vi) any other third parties; (vii) Personal Information if necessary for enforcing any legal right or Claim; (viii) by any court or tribunal or any other body in India which is entrusted by law with the performance of any judicial or quasi-judicial or regulatory or supervisory function; (ix) in the interest of prevention, detection, investigation or prosecution of any offence or contravention of any law; (x) pursuant to any contract entered into with any person outside the territory of India by any person based in India; (xi) a scheme of compromise or arrangement or merger or amalgamation of two or more companies or by way of reconstruction or (xii) ascertaining the financial information and assets and liabilities of any person who has defaulted in payment due on account of a loan or advance taken from a financial institution demerger where You have provided explicit consent.

We engage, retain or might, as per requirement and business needs of the Company, employ, engage, contract with registered clinics, registered medical practitioners, diagnostic labs, third party advertisers, payment facilitators, IT support, independent contractors, and such other third party service professionals/providers to work on behalf of or with Us, in relation to the services provided by Us on the Platform and such third party may be given access to the Personal Information. 

We may share and disclose Your Personal Information with companies with whom we have formal agreements including any third party service providers, laboratories, nutritionists and coaches. These companies primarily provide services such as data storage, analytics, advertising, IT support, and other services necessary for the operation and improvement of our Services.

When You use Our Services, You may be redirected to other websites where Your Personal Information is not under Our control. The privacy policies of websites will govern the collection and use of Your Personal Information on those sites. 

IV. DISCLAIMER

BY USING AND ACCESSING THE PLATFORM, AVAILING OF THE SERVICES, OR OTHERWISE PROVIDING US WITH YOUR PERSONAL INFORMATION, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, AND AGREED TO THE PRACTICES AND POLICIES OUTLINED IN THIS PRIVACY POLICY. YOU HEREBY EXPRESSLY CONSENT TO OUR COLLECTION, USE, SHARING, PROCESSING AND DISCLOSURE OF YOUR PERSONAL INFORMATION AS DESCRIBED HEREIN AND AS MAY BE REQUIRED FOR COMPANY TO OFFER SERVICES TO YOU AND AS MAY BE REQUIRED FOR COMPLIANCE WITH APPLICABLE LAWS, AND YOU FURTHER AGREE TO BE BOUND BY THE TERMS OF THIS PRIVACY POLICY.WE RESERVE THE RIGHT TO MODIFY, UPDATE, OR DELETE PORTIONS OF THIS PRIVACY POLICY AT OUR SOLE DISCRETION AT ANY TIME. IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY AT ANY POINT, YOU SHOULD REFRAIN FROM USING THE SERVICES OR PROVIDING US WITH ANY PERSONAL INFORMATION.IF YOU ARE USING THE SERVICES ON BEHALF OF OR FOR THE BENEFIT OF ANOTHER INDIVIDUAL OR ENTITY, YOU REPRESENT THAT YOU ARE AUTHORIZED TO (I) ACCEPT THIS PRIVACY POLICY ON THEIR BEHALF, AND (II) CONSENT TO OUR COLLECTION, USE, AND DISCLOSURE OF THEIR PERSONAL INFORMATION ON THEIR BEHALF.PLEASE NOTE THAT THIS PRIVACY POLICY IS BASED ON APPLICABLE LAWS IN INDIA AND BEST DATA PRIVACY PRACTICES FOLLOWED IN THE COUNTRY, AND IT MAY NOT MEET THE SPECIFIC PRIVACY LAWS OF OTHER COUNTRIES. 

V. COOKIES

You have the option to delete or block these cookies at any time. Additionally, You can configure Your browser to notify You when we attempt to send a cookie, giving You have the choice to accept or decline it. Please note that if you disable cookies, certain features of the website or application may not be accessible.

The data collected by cookies may be used by third parties to Process and analyse information in order to enhance or support Our Services. This includes providing services on Our behalf, as well as Platform-related services such as maintenance, fraud detection, database management, web analytics, monitoring, and evaluation. 

VI. RETENTION OF PERSONAL DATA

Your Personal Information is not retained by Us for longer than is required for Processing. This encompasses, for instance, the goals of carrying out legal work, establishing or defending legal claims, and meeting any legal, regulatory, financial, or reporting obligations. For research or statistical purposes, we may combine and anonymize your personal data (such that it can no longer be linked to you). In such a scenario, we may use this data indefinitely without providing you with any additional notice. 

VII. DATA PROTECTION

The Users under DPDP Act are granted specific rights in relation to their Personal Information.

You have the following rights, subject to the DPDP Act and the restrictions of applicable law:

1. Right to Access information about Personal Data: Without limiting the  Company’s right under Clause III of this Privacy Policy, You will the right to obtain following: (a) a summary of the Personal Information which is being Processed by Us and the Processing activities undertaken by Us; (b) identifies of third party with whom Personal Information along with a description if Personal Information shared; and (c) any other information related to Your Personal Information and its processing. 

2. Right to correction and erasure of Personal Information: You may request in writing by sending an email on info@healthgalaxy.org or using the editing option on user profile page of the Platform (if any), the correction, completion, updating and erasure of Your Personal Information. Upon receipt of Your request, Company will make the changes requested and in case of request for erasure, erase the Personal Information, unless retention of the same is necessary for: (a) compliance with any applicable law; (b) any medical parameter trends, fitness trends and lifestyle insights inferred or used in Company’s algorithms for statistical training on an anonymised basis ; (c) creating ‘persona’ trends for anonymization and storage at population level algorithms.

3. Right to Withdraw Consent: You may withdraw Your consent granted under this Privacy Policy by sending an email on info@healthgalaxy.org to the Company. Such withdrawal will not affect the lawfulness of processing based on consent before it was withdrawn.

4. Right to lodge a complaint with the Data Protection Board of India: While we encourage You to reach out to us with any concerns or complaints regarding our Processing of Personal Information, You also have the right to directly contact the Data Protection Board of India.

VIII. DUTIES OF THE USER

The User shall perform the following duties:

1. Comply with all applicable laws;

2. Ensure they do not impersonate another individual when providing their personal data for a specified purpose;

3. Ensure they do not withhold any material information when submitting personal data for any document, unique identifier, proof of identity, or proof of address issued by the State or its agencies;

4. Ensure they do not file a false or frivolous grievance or complaint with the Company or the Board; and

5. Provide only verifiably authentic information when exercising the right to correction or erasure under this Act or its associated rules.

IX. INFORMATION SECURITY

We recognize the importance of data security and take comprehensive measures to protect your Personal Information. We implement robust technical and legal safeguards to ensure your data remains secure. While we take all reasonable steps to protect your personal data, we cannot guarantee absolute security. By using or logging into our platform, you acknowledge this limitation and agree not to hold us liable for any data breach.

Please note that no platform administrator will have access to your password. It is essential that you take precautions to prevent unauthorized access to your password, computer, and mobile device. Always log off from the platform when you are done. We are not responsible for any unauthorized use of your account and password. If you suspect any unauthorized activity, please notify us immediately at info@healthgalaxy.org. You will be liable to indemnify us for any loss we incur as a result of unauthorized use of your account or password. We share user information with our employees, agents, partners, and third parties on a need-to-know basis only. However, we are not responsible for the confidentiality, security, or use of your personal data by third parties, including service providers outside the scope of our agreement with them.

In the event of a security breach, we will promptly notify you as required by law, either via email or by posting a notice on the platform, unless it conflicts with law enforcement requirements or necessary measures to understand the breach and protect data integrity.

X. GOVERNING LAWS AND JURISDICTION 

This Privacy Policy shall be governed under the laws of India. The courts and tribunals of New Delhi, India have exclusive jurisdiction to settle any dispute arising out of or in connection with this Privacy Policy (including any disputes regarding the existence, validity or termination of this Privacy Policy).

XI. COMPLAINT REDRESSAL 

Please contact us at info@healthgalaxy.org if you have any questions, concerns, or grievances about how your personal data is processed or about our privacy policy. Our team will be glad in assisting you. 

XII. GRIEVANCE OFFICER

The Company is committed to addressing any concerns raised by User(s). If a User feels their issue has not been adequately resolved, they may contact our grievance officer, who will make every effort to address the concern. User(s) should escalate their concern to the grievance officer only after they have raised their complaint as per XII (Complaint Redressal) above and is dissatisfied with the resolution or if their issue remains unresolved after 30 days from the date of complaint registration.

In compliance of the Information Technology Act, 2000 and rules made thereunder the name and contact details of the Grievance Officer are herein as under:

Name

Dhruv Bathla 

Address:

44, Backary Portion, 2nd Floor, Regal Building, New Delhi G.P.O., New Delhi, India, 110001  

Telephone:

+91 9266485959 

Email:

info@healthgalaxy.org 

XIII. MISCELLANEOUS

1. COMPLIANCE WITH LAW: All Users shall comply with all the applicable laws (including without limitation Foreign Exchange Management Act, 1999, Information and Technology Act, 2000, Prevention of Money Laundering Act, 2002, Foreign Contribution Regulation Act, 2010, Income Tax Act, 1961) as applicable to them respectively while using the Platform and for the Purpose. 

2. SEVERABILITY: If any provision of this Agreement is determined to be invalid or unenforceable in whole or in part, such invalidity or unenforceability shall attach only to such provision or part of such provision and the remaining part of such provision, and all other provisions of this Agreement shall continue to be in full force and effect.