Privacy Policy

1Interpretation and Definitions

1.1Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

1.2Definitions

For the purposes of this Policy:

Affiliate means an entity that controls, is controlled by or is under common control with a party, where “control” means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.

Biometric Data means Personal Data resulting from processing using a specific technology related to the physical, physiological or behavioral characteristics of the data subject, which allows the identification or confirmation of the unique identification of the data subject, such as facial images or fingerprints.

Health Data means health-related information that You voluntarily input, such as exercise routines, dietary habits, weight, sleep patterns and health goals.

Personal Data or Information means any data related to a specific natural person, or related to a natural person that can be identified directly or indirectly by linking the data, through the use of identification elements.

Public Data refers to information that is publicly accessible or publicly available. This may include information that You have chosen to make publicly visible through the Platform or other websites, platforms and applications, such as user-generated content in forums or public profiles, or any information that is freely available or accessible in public domains.

Sensitive Personal Data or Information means any data which directly or indirectly reveals a natural person’s family, ethnic origin, political or philosophical opinions, religious beliefs, criminal record, biometric data, or any data relating to such person’s health and physical, psychological or mental condition. This may also include financial information such as bank account or other payment instrument details.

Service Provider means any natural or legal person who processes the data on behalf of Us. It refers to third-party companies or individuals employed by Us to facilitate the Platform, to provide the service on behalf of Us, to perform services related to the service, or to assist Us in analyzing how the service is used.

User Account means a unique account created for You to access Our Service or parts of Our Platform.

Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself.

Throughout this Policy, the term “Data” refers to either all or some of the types of information defined under this Policy herein.

2What Data We Collect

We may ask You to provide Us with some of Your Data defined above, including but not limited to Your Sensitive Personal Data or Information, during the use of Our Platform and while availing the services listed on the Platform. We are committed to protecting the privacy, confidentiality, accuracy and security of the Data that the Platform collects, uses, retains and discloses in accordance with the Terms and this Policy.

Other than the Usage Data described below, which is collected automatically when You use the Platform, We do not collect any Data or information without Your prior consent. You provide this consent voluntarily by registering with the Platform or using specific features or services available on Our Platform. You will be notified whenever a specific type of Data requires additional consent. You have the right to either consent to or reject this request. Please note that rejecting consent may result in Your inability to use the Platform or certain features or services available on the Platform.

You shall be solely responsible for providing and keeping Your Data accurate and up to date. All the services and products provided through Our Platform work in conjunction with a “User Account” which is created by You on the Platform.

We may already hold Data pertaining to You that was collected in relation to an existing or past Watch Your Health product or service. We will not transfer, copy or link any such Data to Your Rahi App User Account unless You expressly opt in to it. Where such Data exists, We will present You with a clear, separate notice within the Platform identifying the product or service the Data originated from and the categories of Data concerned, and will import it only after You give Your affirmative consent to that specific request. Consent to such an import is entirely optional and is not a condition of creating a User Account or of using the Platform.

You may withdraw this consent at any time through Your User Account settings or by writing to Us at the contact details set out under “Contact Us” below. On withdrawal, We will cease any further import of such Data and will delete the previously imported Data from Your User Account, save where We are required to retain it under a legal obligation. Withdrawal of consent will not affect the lawfulness of any processing carried out before the withdrawal.

We collect Personal Information that You voluntarily provide to Us when You register with the Platform, such as Your name, mobile number, date of birth and gender. This information may be necessary to create Your user profile and to provide personalized health-related services. We do not collect or store Your email address.

Where You use the mood tracker, or another feature that displays Your images within a report, We collect the image You capture or select and store it in Your User Account on Our servers. Where that image contains a face, We also derive and store a mood indicator from the facial expression in it. This processing requires Your separate consent and is described in full in Clauses 14.7 to 14.13.

• When You sign up for a User Account, You are required to provide Your Full Name, Mobile Number, OTP and other such details sought from You. Eligibility to use the Platform is set out in Clause 16.
• To benefit fully from the Platform, You are required to add additional personal details to Your User Account such as Your Height, Weight, Gender, Age, etc.
• With Your explicit consent, the Platform may read Your step count, physical activity and sleep data from Android Health Connect on Android devices, or from the Apple Health App on Apple devices. Connecting either source is optional and at Your own discretion. If You do not connect one, the Platform will not have that data. These integrations are described in Clauses 14.2 and 14.4.
• Data read from those sources is used on Your device, together with Your other User Account input data, to generate a health score card for You with ‘call to action’ interventions. This calculation is performed locally on Your device; Your Health Data is not transmitted to Our servers for this purpose.
• Information (if any) sent from Your current or past Watch Your Health product(s) or service(s) to the Platform is also stored in Your User Account.
• Additional information that You add manually to the Platform is also stored in Your User Account.

We will further collect industry-standard Usage Data, which may include information such as the browser and the operating system You are using, the address of the external or internal page that referred You, Your IP address at the time of User Account creation, and a log of the pages that You visit on the Platform in association with Your IP address. We may also collect the IP address associated with the device running Our Platform each time You sync.

The Platform does not collect Your location. We do not request precise or approximate location permissions, We do not use location services, and We do not derive Your location from any other Data We hold.

Use of stateless APIs — For Data other than Health Data, the Platform may use stateless APIs to send Data for calculations and receive results without storing the Data in the database. Such Data will only be stored on the server if You consent through the Platform. The fitness and wellness metrics described in Clause 14.6 are excluded from this process and are not sent to Our servers. The mood tracker and other image-based report features are an exception to this Clause and are described in Clauses 14.7 to 14.13.

3How We Use Your Data

The Data provided to Us by You may be subsequently used for purposes such as processing Your application(s), the assessment and processing of request(s), administrative purposes relevant to any products or services provided to You by Watch Your Health, and for any other purposes duly permitted by applicable laws. We will not use Your Personal Information for purposes other than those listed in this Policy unless We obtain Your prior consent for any such additional purposes.

Health Data is used to provide personalized health tips, recommendations and insights to help You improve Your overall well-being. This processing is performed locally on Your device, as described in Clause 14.6.

We may additionally use Your Personal Information to:

• Provide You access to the Platform and maintain the Platform’s functionality, including User Account management, authentication and personalized content delivery;
• Analyze the Platform’s usage and improve it;
• Manage Your registration as a user of the Platform. The Data You provide can give You access to different functionalities of the Platform that are available to You as a registered user;
• Deliver to You any administrative notices and communications relevant to Your use of the Platform’s product(s) and service(s), provide technical support, and send important notices regarding changes to Our terms, conditions and policies;
• Provide You with updates regarding Watch Your Health’s product(s) and service(s);
• Perform internal market research, project planning and troubleshooting of problems, and to detect and protect against error, fraud or other criminal activity;
• Perform data analysis, identify usage trends, and evaluate and improve Our Platform, products, services, marketing and Your experience;
• Comply with legal obligations and enforce the Platform’s Terms and this Policy.

4Disclosure of Your Data

We may share Your Data for the purpose of providing Our product(s) and service(s) and related activities, or for any other purposes permitted by law.

Additionally, We may share Your Personal Information in the following situations:

• With Service Providers: We may share Your Data with Service Providers to monitor and analyze the use of Our Platform.
• With Affiliates: We may share Your Data with Our affiliates, in which case We will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
• With Your consent: We may disclose Your Data for any other purpose with Your consent.

We do not sell Your Data. We do not share Your Data with business partners, advertisers, data brokers or any other third party for advertising or marketing purposes. The only recipients of Your Data are the Service Providers, Affiliates and other parties expressly identified in this Policy, each for the limited purpose stated.

Where You link Your User Account with a third-party service, any Data shared between the Platform and that third party, and that third party’s use of such Data, shall be governed by that third party’s privacy policy. Your Watch Your Health User Account shall continue to be governed by this Policy.

Data may also be shared with the companies that provide services to Us such as information processing and rewards fulfillment.

Where You register with a mobile number issued outside India, We share that mobile number directly with Meta Platforms, which operates the WhatsApp Business Platform, solely in order to deliver Your one-time password as described in Clause 12. Meta Platforms acts as a Service Provider for that limited purpose. No intermediary or third-party messaging service provider is involved.

We may also disclose certain information about You to third parties if We determine that such disclosure is reasonably necessary to: (i) enforce this Policy and/or the Terms; (ii) protect Our operations or users; (iii) comply with any applicable law, rule, regulation, subpoena or any other statutory or regulatory process or directive; (iv) protect or defend Our rights, interests and property or that of Our associates and affiliates, or that of Our or Our affiliates’ employees, consultants, etc.; or (v) for fraud prevention purposes. In the event of a re-structuring exercise which includes reorganization, merger, etc., of Watch Your Health, We may transfer any and all of Your Data We have collected to the then relevant party or Our affiliate.

We shall not be liable under any circumstances for the disclosure of Your Data in accordance with this Policy, provided that such information was obtained and disclosed with Your consent and used in accordance with the terms herein.

5Use of Aggregated Anonymous User Data

We may disclose non-personally identifiable aggregated user data, such as aggregated gender, age, height, weight and Usage Data gathered from Our Platform, without the inclusion of Your name or other identifiable information, for the following purposes:

• To enable other users of the Platform to compare their personal health and well-being against that of the broader community; and
• To understand health trends among Platform users.
• This Clause applies only to the aggregated profile attributes and Usage Data listed above. It does not apply to the fitness and wellness metrics described in Clause 14.6, which are processed on Your device and are not aggregated or disclosed by Us.

6Contests, Surveys and Giveaways

While the activities You record through the Platform may earn You rewards in accordance with the eligibility and rewards criteria decided by Us from time to time, We may also offer You the opportunity to participate in contests, giveaways and other promotions. Any information submitted in connection with such activities will be treated in accordance with this Policy, unless specifically set forth in the terms and conditions or rules of those contests, giveaways or promotions. From time to time, We may also ask You to participate in surveys designed to help Us improve the Platform.

7Disclaimer for Products and Provision of Services

While using the Platform and availing the products and services made available to You therein, You are advised and informed that some products and services are being provided by third-party Service Providers and You are availing the same at Your own risk and volition. We disclaim any and all liability arising out of or related to such products and services in any manner whatsoever, and You confirm Your understanding of this.

8Third-Party Services and Links

While using the Platform and accessing the products and services provided therein, You are hereby notified that some products and services are offered by third-party Service Providers. Your access to these products and services is undertaken at Your own risk and discretion. We explicitly disclaim all liability arising from or related to such products and services in any manner whatsoever. By continuing to use the Platform, You acknowledge and agree to these terms.

Additionally, Our service may contain links to other websites that are not operated by Us. If You click on a third-party link, You will be directed to that third party’s site. We strongly advise You to review the privacy policy of every site You visit. We have no control over, and assume no responsibility for, the content, privacy policies or practices of any third-party sites or services.

9Data Security

We intend to use a combination of firewall barriers, encryption techniques and authentication procedures, among others, to maintain the security of Your Data and to protect Our User Accounts and systems from unauthorized access.

While We have taken reasonable security practices and procedures to protect Your Data in accordance with this Policy, please be aware that no method of transmission over the internet or method of electronic storage is completely secure. Hence, We do not give any further warranties as to the security of any Data provided by You other than what is mentioned in this Policy and under the applicable data protection laws of India.

It is important to understand that these precautions only apply to Our Platform. We exercise no control over how Your information is stored, maintained or displayed by third parties or on third-party sites.

10Retention of Your Data

We will retain Your Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Data to the extent necessary to comply with Our legal obligations (for example, if We are required to retain Your data to comply with applicable laws), resolve disputes, and enforce Our legal agreements and policies.

We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or where We are legally obligated to retain this data for longer time periods.

11Transfer of Your Data

Your information is processed at Our operating offices and in any other places where the parties involved in the processing are located. This means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of Your jurisdiction. However, any Personal Data or Biometric Data shall be stored only within the territory of India.

This does not apply to the delivery of one-time passwords to mobile numbers registered outside India. That process necessarily involves transmitting Your mobile number outside India, as described in Clause 12.

If You access the Platform from a country other than India, Your Data will be transferred to and stored in India, where the applicable data protection laws may differ from those of Your own country. By using the Platform, You consent to that transfer.

Your consent to this Privacy Policy, followed by Your submission of such information, represents Your agreement to that transfer.

We will take all steps reasonably necessary to ensure that Your Data is treated securely and in accordance with this Privacy Policy, and no transfer of Your Data will take place to an organization or a country unless there are adequate controls in place, including as to the security of Your Data.

12Registration and Password

When You register for the Platform, We shall seek a one-time password (“OTP”) from You for Your privacy and security. The OTP is sent to the mobile number registered with Us. The channel used to deliver it depends on the country of that mobile number:

• Mobile numbers registered in India. The OTP is delivered by SMS to Your mobile device.
• Mobile numbers registered outside India. The OTP is delivered through WhatsApp. We use the WhatsApp Business Platform operated by Meta Platforms directly, and We do not use any intermediary, aggregator or messaging service provider for this purpose. To deliver the OTP, We share Your mobile number with Meta Platforms, which processes it in accordance with its own privacy policy and may do so on infrastructure located outside India. We share Your mobile number with Meta Platforms for the sole purpose of delivering the OTP, and We share no other Data with Meta Platforms for this purpose.

This OTP is stored in an encrypted manner on Our systems.

You shall be solely responsible for maintaining the confidentiality of Your login information and OTP. You shall also be responsible for all uses of Your login information, whether or not authorized by You. You agree to immediately notify Us of any unauthorized use of Your login information, password or User Account. We cannot and do not assume any responsibility or liability for any information submitted by another person who has fraudulently accessed Your User Account, or for any third party’s fraudulent use or misuse of Your login information, password or User Account.

You represent and warrant that the information that You provide about Yourself, as requested in the Platform, is accurate and complete. You agree to update Your Data as necessary, including providing Us Your current mobile number, so that You may receive timely notifications and other account-related communications.

13Delete Your Data

You have the right to delete, or to request that We assist in deleting, the Data that We have collected about You.

Our Service may give You the ability to delete certain information about You from within the Service.

You may update, amend or delete Your information at any time by signing in to Your User Account, if You have one.

You may delete Your User Account from within the Platform, using the account deletion option in the Platform settings. Deleting Your User Account removes Your profile information and the Data associated with it, including any images You have provided and the mood indicators derived from them. If You are unable to access the Platform, You may request deletion of Your User Account by contacting Us using the details in Clause 19, and We will verify Your request and action it without undue delay.

Deleting a mood tracker entry deletes the image associated with that entry. Deleting Your User Account deletes all images You have provided through the Platform, together with the mood indicators derived from them.

Please note, however, that We may need to retain certain information where We have a legal obligation or lawful basis to do so.

14Platform-Specific Clauses

14.1For Android Users

If You are accessing and using the Platform on an Android device, please be aware that Google may collect and process Your information in accordance with their Privacy Policy. You should review Google’s Privacy Policy to understand how they handle Your data.

14.2Integration with Android Health Connect

The Platform may integrate with Android Health Connect, an open platform by Google that enables users to manage and control their fitness and wellness data. With Your explicit consent, the Platform will collect and process step count, physical activity and sleep data via the Health Connect SDK.

• Upon connection, users can view their step data in a visual format, and the Platform automatically imports this data onto Your device to provide activity insights.
• Data collection continues until the user disables the step-tracking feature, logs out, or uninstalls the Platform.
• Our use of information received from Google APIs, including Android Health Connect, adheres to the Google API Services User Data Policy, including its Limited Use requirements. We do not use Health Connect data for serving advertisements, We do not sell it, and We do not transfer it to others except as necessary to provide or improve the features You have enabled, to comply with applicable law, or as part of a merger or acquisition.

14.3For Apple Users

If You are accessing and using the Platform on an Apple device, Apple may collect and process information about Your use of the App Store and Your device in accordance with Apple’s own privacy policy. We do not control that processing. We do not share Your Data with Apple, and Apple does not receive the Health Data, facial images or mood indicators described in this Policy.

14.4Integration with Apple Health

The Platform may integrate with the Apple Health App, which enables users to manage and control their fitness and wellness data. With Your explicit consent, the Platform may read fitness and wellness data made available by the Apple Health App, such as step count, physical activity and sleep data.

We use that data solely to provide the health and fitness features You have enabled. We do not use it for advertising, marketing or data mining, We do not disclose it to third parties, and We do not store it in any cloud service.

14.5Collection and Usage of Health Data

The Platform prioritizes the privacy and security of Your Personal Information. The Platform requests permission to access step data solely to enhance Your experience and deliver personalized wellness features.

• This information is collected only with Your explicit consent.
• It is used exclusively for fitness tracking purposes.
• We do not sell, share or disclose Your health data to third parties without Your express authorization.

14.6Purpose of Health Data Access

The Health Data described in this Clause 14.6 — namely the fitness and wellness metrics obtained from Android Health Connect and the Apple Health App, such as steps, calories burned, heart rate and sleep cycles — is used to track and display Your daily wellness metrics.

• Processing of these metrics is performed locally on Your device.
• The Platform does not transmit these metrics to external servers or third-party platforms.
• This Clause does not apply to the mood tracker or to other features that display Your images within a report. Those features are described in Clauses 14.7 to 14.13 and do involve storage and processing on Our servers.

14.7Camera and Photo Usage

The Platform uses the device camera and, where You permit it, Your photo library for two separate purposes. Your data is treated differently in each case, and You may use either feature independently of the other.

• (a) Real-time health measurement. For features that calculate a health metric from the camera signal, the camera is used solely for real-time processing on Your device. No photo, video, facial image or biometric template is captured, stored, recorded or transmitted for this purpose. Any intermediate signals derived during processing (such as photoplethysmography-related values) exist only temporarily in device memory during active processing and are discarded immediately once the calculation is complete.
• (b) Mood tracker and image-based reports. For the mood tracker, and for any other feature that displays Your images back to You within a report, the image You capture or select is uploaded to and stored on Our servers so that it can be displayed in Your reports and associated with Your User Account. Where that image contains a face, Our servers analyze the facial expression in it in order to derive a mood indicator, which is stored alongside the image in Your User Account.

14.8Consent to Facial Image and Biometric Processing

The analysis of a facial image in order to infer mood constitutes processing of Biometric Data as defined in Clause 1. We collect and process such Biometric Data only where You have given Your specific, informed and affirmative consent to the mood tracker feature, obtained separately from Your general acceptance of this Policy.

This consent is optional. Declining it does not affect Your ability to create a User Account or to use the other features of the Platform. You may withdraw it at any time through the Platform settings or by contacting Us using the details in Clause 19. On withdrawal, We will cease further processing of Your facial images and delete the stored images and derived mood indicators, save where We are required to retain them under a legal obligation.

14.9Retention of Face Data

Facial images that You provide through the mood tracker or another image-based report feature are retained on Our servers for as long as You choose to keep them. They are deleted when You delete the relevant entry, when You delete Your User Account, or when You withdraw Your consent under Clause 14.8, whichever occurs first. We do not apply a separate expiry period; retention is controlled by You.

No facial images are retained in connection with the real-time camera measurement described in Clause 14.7(a).

14.10Reasons for Storing Face Data

Facial images are stored for two purposes: (i) to display them back to You within Your mood tracker entries and reports; and (ii) to derive the mood indicator associated with each entry.

They are not used to identify You, to build a facial recognition template for identification purposes, or for advertising or marketing.

14.11Duration of Storage and Justification

Facial images and their derived mood indicators are stored for the duration of Your User Account, or until You delete the entry or withdraw consent, as set out in Clause 14.9. The justification for this duration is that the mood tracker is a longitudinal record: its purpose is to let You review Your own entries over time, which requires that those entries persist until You choose to remove them.

The temporary signals described in Clause 14.7(a) are not stored for any length of time and are discarded immediately after each calculation.

14.12Sharing of Face Data with Third Parties

We do not share Your facial images, or the mood indicators derived from them, with any third party. The expression analysis is performed on Our own servers, and the images are not sent to any external vision, facial-analysis or machine-learning service. Facial images are not shared with business partners, advertisers or Affiliates, and are not sold or disclosed for any commercial purpose.

14.13Third-Party Storage of Face Data

Facial images are stored on infrastructure operated by Us or on Our behalf. Consistent with Clause 11, such images and the Biometric Data derived from them are stored only within the territory of India.

Where a hosting or infrastructure provider stores or processes such images on Our behalf, that provider acts as a Service Provider under this Policy, is bound to process the images only on Our documented instructions, and is not permitted to access, use or disclose them for its own purposes.

15User Consent

By using the Platform, You consent to the collection and processing of health-related Data for the features described in this Policy and within the Platform.

• Users retain full control of permissions.
• Permissions may be enabled or revoked at any time through the Platform settings.
• Consent to the processing of facial images, and of the Biometric Data derived from them, is obtained separately and explicitly under Clause 14.8. It is not covered by the general consent described in this Clause.

16Eligibility and Age Restriction

The Platform is intended solely for adults. You may use the Platform only if You are 18 years of age or older.

You are asked to confirm that You are at least 18 years of age at the point at which You access the features of the Platform, rather than at the time You create Your User Account. By accessing or using those features, You represent and warrant that You are at least 18 years of age.

We do not knowingly collect, use, store or otherwise process the Data of any person below 18 years of age. In particular, We do not knowingly collect or process the facial images, mood indicators or Health Data of any such person.

If We become aware that We have collected Data from a person below 18 years of age, We will delete that Data and close the associated User Account without undue delay. If You believe that a person below 18 years of age has provided Data to Us, please contact Us using the details in Clause 19 so that We can take appropriate action.

Because the Platform is not offered to children, We do not carry out any tracking or behavioural monitoring of children, and We do not direct any advertising at children, as prohibited by Section 9 of the Digital Personal Data Protection Act, 2023.

17Applicable Laws

We are established in India and Our processing of Your Data is governed by the applicable laws of India, including the Digital Personal Data Protection Act, 2023, the Information Technology Act, 2000 and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, each as amended from time to time.

The Platform is not offered only in India. Where You access the Platform from outside India, the data protection laws of Your country of residence may also apply to Our processing of Your Data, in addition to the laws referred to above. Nothing in this Policy is intended to limit, and shall not be read as limiting, any right You may have under the data protection laws applicable to You in Your own jurisdiction. Where those laws grant You a right that is broader than a right described in this Policy, We will honor the broader right.

Irrespective of the country from which You access the Platform, Your Data is stored on servers located in India, as described in Clause 11. Accessing the Platform from outside India therefore involves a transfer of Your Data to India.

The Terms of Service shall also govern this Policy.

18Amendments to the Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy.

As We do not collect Your email address, We will notify You by a prominent notice within the Platform prior to the change becoming effective, and will update the “Last updated” date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted or updated. Your continued use of Your User Account shall be deemed to be Your consent to such updated, amended or replaced Policy.

19Contact Us

If You have any questions about this Privacy Policy, or wish to exercise Your rights in respect of Your Data, You may contact Us at: