Privacy Policy

Svar Trifit Wellness Private Limited

This Privacy Policy (“Policy”) explains how Svar Trifit Wellness Private Limited
(hereinafter to be referred to as “Trifit”), and the Collaborators (identified in the Terms of
Use) collect, store, use, transfer and otherwise process your data (save and except
non-personal data / information), for providing you the Platform and/or the Services (defined
in the Terms of Use, available on the Platform) through the Platform, and shall be read with
“Trifit User Terms and Conditions” available on Trifit website.
IN ORDER TO FACILITATE AND PROVIDE YOU (AND CO-APPLICANTS,
MEMBERS, NOMINEES, APPOINTEES, IF ANY) WITH THE SERVICES
THROUGH THE PLATFORM, THE COMPANY, SVAR TRIFIT WELLNESS
PRIVATE LIMITED NEED TO COLLECT VARIOUS DATA AND INFORMATION,
BOTH PERSONAL AND SENSITIVE, FROM YOU WITH YOUR PRIOR AND
EXPLICIT CONSENT.

  1. ACCEPTANCE OF THE PRIVACY POLICY:
    Consent:
    By using this platform or its services/products, you are agreeing to our policy. This means
    you allow us and our partners to collect, keep, share, process, and store your personal and
    sensitive information as described in the policy. If you disagree with this policy, please do not
    proceed to use/access this platform or avail any services/products of the Trifit.
    When you create a Trifit account or give us access to your personal information, you are
    agreeing to let us collect, process, store, use, and share your information according to this
    policy.
    If you don’t provide your personal information or decide to withdraw your consent for us to
    use it, we or our partners may choose not to give you the benefits you were expecting. This
    could mean not allowing you to use our platform or service.
    If you withdraw your consent or delete your Trifit account, it will not change our or our
    collaborator’s rights and obligations under the law. You understand and agree that we and our
    collaborators will keep collecting, using, processing, and storing your personal data as the
    law requires.
    This policy applies only to your personal and sensitive personal data. Any non-personal
    information you provide to us, our collaborators, or our service providers, or that is collected
    by us, our collaborators, or our service providers, is not covered by this policy. Non-personal
    information will be used, shared, stored, and/or processed by us and/or our collaborators at
    our discretion, always subject to applicable laws. Non-personal data refers to information that
    does not directly identify you, is aggregated or de-personalized, and cannot establish an
    individual’s specific identity.
    The definitions in the “Trifit User Terms and Conditions” document will have the same
    meaning in this Privacy Policy whenever applicable.
    “Sensitive information” is defined as the following:
    ● Financial Information.
    ● Protected health information (PHI).
    ● Credential data.
    ● Customer information.
    ● Trade, proprietary information.
  1. PERSONAL INFORMATION PROVIDED BY YOU AND/OR COLLECTED BY US
    AND/OR OUR COLLABORATORS:

    We and the Collaborators will use the personal information including any sensitive personal
    data / information provided by You only in accordance with the purposes in this Policy or as
    per the requirements of the applicable laws.
    Except as provided herein or as clearly disclosed to You at the time of seeking or collection
    of sensitive personal data, we do not solicit any sensitive personal information about you.
    However, if you share such sensitive or personal information with us or the Collaborators
    voluntarily, we will not be liable for any actions, claims, costs, expenses or other liabilities
    that may arise because of any unauthorized use or misuse of such sensitive personal
    information. Any personal information including your sensitive personal information
    provided by you on the Platform or to us or to the Collaborators, will be deemed as an
    authorization given by you to us and the Collaborators to use, store, process, and share such
    personal information for the purpose as stated out on the Platform, the applicable laws.
    During your use of Platform, you may provide and/or we may collect and process such
    personal information from you, including but not limited to the below:
    i. Personal Information provided by You:
    You may provide the personal information to us or our collaborators:
    a) by filling in application forms or signing up for an account on the Platform at the time
    of the onboarding process or for availing any service on the Platform or any product
    thereto. This may include contact information such as name, email address, mailing
    address, phone number, KYC documents like Voter ID, PAN, Aadhaar card, Driving
    License, etc.
    b) voluntarily, when you call or write directly to us or to our collaborators (including by
    e-mail, feedback and/or surveys).
    c) You may be required to provide further information to us or the collaborators for the
    purposes of availing our services. Such additional information may include (without
    limitation) your health and lifestyle-related data as prompted on the relevant page.
    You may also be required to provide this information to us or the collaborators via
    physical documents, e-mail, or other digital and offline methods.
    d) You agree to provide current, true, latest and correct information and documents at
    any and all times, including for KYC or other purposes. The said KYC details and
    other documents may be used by Us or the collaborators or our affiliates to perform
    KYC, health or other checks and extend the services to you. In the event of any
    changes to any personal information or KYC documents or health/lifestyle
    information in the KYC or other documents (as the case may be), you will promptly
    notify us via email and/or update the details under Your Account section immediately.
    e) You also consent to the use, disclosure, and sharing of personal information about
    You, including but not limited to information about your health, physical attributes,
    medical history, and lifestyle, etc. by Trifit Tech, the collaborators, Our affiliates
    and/or Our group companies. This will help You avoid repeat queries/tests, and also
    help You avail the additional products, services or other new offerings by Trifit Tech
    or collaborators , Our affiliates and/or Our group companies as per the terms of this
    Privacy Policy.
    f) In the event of any changes to any personal information or KYC documents or
    health/lifestyle information in the KYC or other documents (as the case may be), You
    will promptly notify us via email and/or update the details under “Your Account”
    section immediately.
    ii. Personal Information Collected from Third Parties:
    a) We and/or collaborators may also be working closely with third parties (including, for
    example, business partners, financial institutions, technical sub-contractors, analytics
    providers, etc.) and may lawfully receive information about you from such sources.
    Such personal data may be shared internally and combined with data collected on the
    Platform.
    b) We and /or collaborators may also use the content you have shared publicly, including
    on third party platforms or applications including any social media channel, to
    promote our Services and/or Our Platform and/or collaborators, or their
    services/platform (including by quoting your content, reviews and/ or
    recommendations, or displaying screenshots of your content, reviews and/ or
    recommendations).iii. Personal Information Collected by Us and/or the Collaborators:
    a) We and the collaborators collect user account data which includes both personal and
    non-personal data, including but not limited to the email address, IP address, and
    name to log in to the Platform. This information is required as part of the registration
    and on-boarding process to (i) create Your Trifit Account; (ii) provide our Service and
    Platform; (iii) enable the collaborators to provide you with products and/or services;
    (iv) perform verification and KYC checks on you; (and it is also used to auto-populate
    relevant fields when you apply for any product or service.
    b) We and the collaborators may also collect mobile numbers for verification to check
    the active SIM status on your device, uniquely identify you and prevent fraud and unauthorized access. When you grant us access to the address book on your mobile
    device, then we and the collaborators access the names and contact information from
    your address book to facilitate invitations and to assess your phone usage and habits.
    c) As part of your journey on the Platform, we access your phonebook contacts which
    includes their contact names, phone numbers, account types, favorites (starred) and
    contact labels to enrich your profile.
    d) We and the collaborators shall collect transaction information related to the use of our
    Services, the Platform and/or the products and services, including the type of Services
    requested, the date and time the Service was provided, and payment method.
    e) Additionally, if someone uses your promotion code, we or the collaborators may
    associate your name with that person and their usage of the Platform/ Services.
    f) If you call our call centers, we or the collaborators may record information provided
    by you to service you as per the Terms of Use and this Policy, including for quality
    and training purposes.
    g) When you grant us access to the SMSs on your mobile device, then we and our
    collaborators collect financial SMS data stored on your mobile or other device. We
    and the collaborators use this data to analyze your financial profile and enable the
    provisioning of the best offers by us and/or collaborators with respect to the Platform,
    Services and/or products offered by us.
    h) We may collect non-personal data as specified in the section below.
  2. NON- PERSONAL INFORMATION / DATA
    i. “Non-Personal Information” means and includes any information that does not reveal
    Your specific identity, such as, browser information, information collected through
    Cookies (as defined below), pixel tags and other technologies, demographic
    information etc. Our Platform gathers some information automatically when You visit
    the Platform or avail any Service and stores it in your log files.
    ii. We and the collaborators may collect certain non-personal information about Your
    computer or other electronic device through which you have accessed Platform or our
    Services or the products / services of collaborators to facilitate, evaluate, and verify
    your use of Platform or Your Trifit Account or your interactions/communications with
    the collaborators.
    iii. We and the collaborators collect non-personal data about the devices used to access
    our / their Services, including the hardware models, device IP address, operating
    systems and versions, software, preferred languages, unique device identifiers,
    advertising identifiers, serial numbers, device motion data, and mobile network data.iv. We collect non-personal data about how you interact with our Services, Platform
    and/or with the collaborators. This includes data such as access dates and times,
    features or pages viewed, Platform crashes and other system activity, type of browser,
    and third-party sites or services used before or in the course of interacting with our
    Services and/or the services/products.
    v. “Cookies” are small files that reside on Your computer’s/ electronic device hard drive
    and generally contain an anonymous unique identifier and are accessible only by
    Platform that placed them there and not any other sites. You may refuse to accept
    Cookies by activating the setting on Your browser which allows You to refuse the
    setting of Cookies. However, if You do not provide such information, you may be
    unable to access certain parts of the Platform. Unless You have adjusted Your browser
    setting so that it will refuse cookies, our system may issue Cookies when You log on
    to Platform. The use of Cookies by Our partners, advertisers or service providers is
    not covered by this Policy.
    vi. We collect the location data from you in two ways: (a) when you add the pin code as
    part of your account creation process; and (b) from your mobile device when enabled
    by you to do so.
    vii. We collect the data about your installed applications, including the applications that
    you have installed on and from the date you create your account on the Platform and
    the manner in which you use them.
    viii. IT IS REITERATED THAT THIS POLICY DOES NOT APPLY TO
    NON-PERSONAL DATA / INFORMATION INCLUDING PROCESSING OF ANY
    DATA IN ANONYMISED, AGGREGATED OR DE-IDENTIFIED FORM
    AVAILABLE WITH US OR COLLECTED BY US OR PROVIDED TO US / THE
    COLLABORATORS. THE USE OF SUCH NON-PERSONAL DATA /
    INFORMATION (INCLUDING RETENTION, SHARING, AND PROTECTION)
    SHALL BE AT OUR / THE COLLABORATORS SOLE DISCRETION AND
    REQUIREMENTS.
  3. How We / Our Collaborators Use Your Personal Information
    We and/or the collaborators may use, process, and share your personal information including
    any sensitive personal information/data for:
    i. Enabling the Platform and the Services offered by us and/or the collaborators,
    including:
    a) provide and improve the Platform and/or the Services.
    b) to enable the provisioning of products/services by the collaborators including but not
    limited to personalizing user experience and sending you information and updates
    about new products, your membership, your plan expiry dates, etc. This could include
    displaying appropriate content based on our / collaborators’ judgment and discretion.
    c) perform internal operations necessary to provide our Services or the Platform
    including enabling us to provide you with all the relevant details with respect to plans
    in an easy viewing format on Your Trifit Account, or to enable the collaborators to
    provide the products and/or services to you including updates on your plan through
    Your Trifit Account or otherwise, including to troubleshoot software bugs, operational
    problems or to conduct testing.
    d) providing details with respect to your plans on Your Trifit Account.
    e) the collaborators shall share your plan-related data with collaborators Tech to enable
    You to view and access the details with respect to your plans through Your Trifit
    Account, and you hereby provide your explicit consent for the same.
    f) to help avoid repeat tests or checks or questions to and by You, and to allow You to
    avail the additional products, services, or other new offerings by Us, the collaborators,
    our affiliates and/or our group companies.
    ii. to enable Us, Our affiliates and group companies to contact You or otherwise
    communicate with You to offer new products, services, facilities, features, and/or
    discounts as the case may be.
    iii. Enabling customer support including to help us / collaborators respond to your
    pre-sale and post-sale requests and support needs, efficiently and without delay,
    including through Your Trifit Account or otherwise.
    iv. Research, development, improvements and innovation including:
    a) to conduct research and analysis to develop new products/services, improve our /
    collaborators services, or to develop features and functionality to detect, prevent,
    mitigate, and investigate fraudulent or illegal activities.
    b) analyze how the Platform and/or the Services are used, diagnose service or technical
    problems, and maintain security for us and the collaborators.
    c) help you efficiently use and access the Platform or the Services or any part thereof; or
    any products/services offered by the collaborators through Your Trifit Account.
    d) to assess the serviceability of services, products, or features offered by us or the
    collaborators or any other affiliate/group company of Trifit Tech, and to send you
    communications with respect to the same.
    e) to contact you for refund or cancellation or confirmation of a purchase or failed
    transaction on the Platform or with the collaborators including to display the status of
    your payments, applications, inquiries and/or plans on Your Trifit Account.
    f) to look at trends and customer interests with respect to our Services, and/or the
    products/services of the collaborators, whether offered now or in the future. We
    and/or the collaborators may combine the information we / collaborators receives
    from you, with the information we / collaborators gets from other third parties
    including any of the service providers.
    g) Enabling communications through Your Trifit Account or otherwise, including for
    enabling marketing and outreach activities including promotion of new products,
    services, and/or platforms offered by us or the collaborators or our group companies /
    other affiliates, and for automated/automating decisions. We and the collaborators will
    use and share your personal information to send you transactional communications.
    We or the collaborators may send you emails or SMS/es or other push notifications
    about Your Trifit Account or your expression of interest or purchases.
    h) Marketing and outreach including informing you about the new products offered by
    us, the plans or any other group company. You may have an interest or intention of
    availing services or a general query with respect to the services available on Platform
    and/or through Platform and/or by the collaborators. Accordingly, you may contact
    us; or we or the collaborators may contact you. By contacting us / the collaborators in
    anyway and/or by providing us / the collaborators your phone number and/or contact
    details and/or other details or by showing interest in any product/service of the
    Company or the collaborators or any other affiliate/group company, you thereby give
    us, the collaborators and/or other affiliates the unequivocal right and consent to use
    the said personal data as per this Policy.
    v. Ensure compliance under applicable laws including:
    a) to enable us or the collaborators to comply with any legal and regulatory obligations
    or requisition requests by any authority under the applicable laws including to enable
    us or the collaborators to proactively communicate with the authorities, or law
    enforcement agencies or any other government or judicial body in connection with
    any suspicious, illegal, fraudulent or unlawful activities.
    b) to enforce our / the collaborators legal or other rights against you including to comply
    with our / collaborators obligations to you.
  4. Sharing of Your Personal Information
    i. With Our other affiliates and/or our group companies: We may also share the personal
    information or details provided by you or collected by us with our other affiliates or
    members of our group companies for the purposes specified under Point 4 (How We
    Use Your Personal Data) of this Policy. We reserve the right to exchange, share or
    provide the personal information relating to your personal, financial details and other
    sensitive information with our affiliates and other group companies as required, and
    you will not hold us/our affiliates and/or our any other group companies and their
    agents liable for use, processing, retention or sharing of the personal information for
    use as per Point 4 (How We Use Your Personal Data) of this Policy. This right is in
    addition to the rights of the Trifit/ Collaborator to access, use, store, and share your
    personal data as per Point 4 (How We Use Your Personal Data).
    YOU UNDERSTAND AND AGREE THAT WE AND THE COLLABORATORS
    MAY DISCLOSE YOUR PERSONAL INFORMATION, TO ANY MEMBER OF
    OUR GROUP OR OUR AFFILIATES OR A RELATED PARTY, FOR THE
    PURPOSES SPECIFIED UNDER SECTION 4 (HOW WE USE YOUR PERSONAL
    DATA) TO THIS POLICY, AND YOU PROVIDE YOUR EXPRESS AND
    UNCONDITIONAL CONSENT FOR THE SAME.
    ii. With Third Party Service Provider/s: We or the collaborators or our other affiliates
    may use third-party service providers to help us operate our business, perform KYC
    checks, manage the Platform, provide the Services or administer activities on our,
    collaborators / our other affiliates’ behalf, such as sending out newsletters, surveys or
    questionnaires or other marketing activities with respect to us, the collaborators or our
    other affiliates’ products / services, including any new offerings. We may disclose
    your personal information to third parties (including any foreign third parties to the
    extent permitted by the applicable laws) for the purposes mentioned under Section 4
    (How We Use Your Personal Data) to this Policy, inter alia, in order to perform KYC
    checks, provide You with customer support facilities, to comply with our /
    collaborators legal obligations including prevention of money laundering or otherwise
    as prescribed by the relevant authorities or under any applicable laws, to enforce the
    Terms of Use, to facilitate marketing and advertising activities for us, collaborators
    and/or our other affiliates, to conduct analysis, to provide You services, to facilitate
    services for You, to send notifications, reminders or to prevent, detect, mitigate, and
    investigate fraudulent or illegal activities related to Platform or the products/services
    of the collaborators and to avail services from third parties for data analysis and
    market research. Some of these functionalities may include Analysing customer
    behavior, conducting research into customer behavior and contacting the customers
    for the said purpose, and to automate our marketing and outreach efforts, Detection
    and flagging of fraud, Cloud services, Validating and authenticating your employment
    status, employment information and employment duration.
    iii. With Authorities or the Government: We may disclose or share your personal
    information if we are under a duty to comply with any legal obligation or an order
    from the government and/or a statutory authority, or in order to enforce or apply the
    Terms of Use or assign such personal information during corporate divestitures,
    mergers, or to protect the rights, property, or safety of the Company, the Users, or
    others. This includes exchanging personal information with other companies and
    organizations for the purposes of fraud protection and credit risk reduction.
    iv. For Business Requirements: In the event the Company is merged with or acquired by
    another company or in case of re-organization or re-structuring of business, we, the
    collaborators or our other affiliates may share your personal information, wholly or in
    part, with another business entity/ies.
  5. Retention Policy
    We and the collaborators collect, use, share and retain your personal information only for the
    purpose specified in the preceding sections above, including ensuring compliance with
    applicable laws. Subject to regulatory or law enforcement requirements or other obligations
    under applicable laws which may prescribe longer periods, we will retain your personal
    information in identifiable form until you withdraw your consent. To withdraw your consent,
    you may write to the grievance officer as per the details mentioned in the “Contact Us”
    section.
  6. How Trifit Protects Your Information
    We, at Trifit, have appropriate data collection, storage, and processing practices. Our and the
    collaborators’ security measures protect against unauthorized access, alteration, disclosure or
    destruction of your personal information. All kinds of private information exchange and
    transactions on the Platform happen through secured communication channels and are
    encrypted.
    We or the collaborators assume no liability for any disclosure of personal information due to
    errors in transmission, unauthorized third-party access, or other acts of third parties, or acts or
    omissions beyond our / collaborators’ reasonable control and you agree that you will not hold
    us / collaborators responsible for any breach of security or unauthorized disclosure. In using
    the Platform and/or availing the services or products of the collaborators, you accept the
    inherent security implications of data transmission over the internet, and the World Wide Web
    cannot always be guaranteed as completely secure. Therefore, your use of the Platform
    including availing any products/services offered by us/ the collaborators will be at your own
    risk.
  7. Third Party Websites
    While using the Platform, you may find content that contains links to other websites or
    portals on the internet. These sites and services may have their own privacy policies.
    Browsing on and interacting with any other website, including the websites which contain a
    link to our website, is subject to that website’s own terms and conditions.
  8. Changes in this Privacy Policy and Other Terms
    We and the collaborators have taken every effort to ensure that this Policy adheres to the
    applicable laws. The invalidity or unenforceability of any part of this Policy shall not
    prejudice or affect the validity or enforceability of the remainder of this Policy. This Policy
    does not apply to any information other than the personal including sensitive information and
    does not extend to any non-personal data provided by you or collected by us / our
    collaborators / other affiliates / by our service providers.
    This Policy shall be inapplicable to any unsolicited information you provide us through
    Platform or otherwise. This includes but is not limited to, information posted in any public
    areas of the Platform. All unsolicited information shall be deemed to be non-confidential, and
    the Company shall be free to use and/ or disclose such unsolicited information without any
    limitations. We and the collaborators reserve the right to update this Policy at any time, so
    you are advised to review this Policy statement frequently. Your access to or continued use of
    the Platform after the changes have been posted on this page shall confirm your equivocal
    acceptance of the revised privacy policy.
  9. Contact Us
    If you have any questions, comments, or grievances in relation to our privacy policy as
    outlined above, you may write to us at:
    Svar Trifit Wellness Private Limited,
    Email ID : nigel@trifitindia.com



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