Privacy Policy.

www.trifit.life

Effective Date: 19th July 2025

This Privacy Policy (“Policy”) describes how Svar TriFit Wellness Private Limited (“TriFit” , “we” , “us” , or “our”) collects, uses, stores, shares, and protects personal information obtained from users (“you” or “User”) of its website located at https://www.trifit.life (“Website”), mobile application (“App”), and associated devices and services (collectively, the “Services”).

If you do not agree with this Policy, please refrain from using our Services.

1. Data Controller and Contact Information

Svar TriFit Wellness Private Limited acts as the Data Fiduciary under India’s Digital

Personal Data Protection Act, 2023 (DPDP Act) and as the Data Controller under the

General Data Protection Regulation (GDPR) for users in the EEA.

Email (privacy & data requests): contact@trifitindia.com

Address: New No 59, Old No 120, Residency Road, Richmond Town, Bengaluru, Karnataka, 560025, India

2. Types of Personal Data Collected

We may collect the following categories of personal data, either directly from you, through your use of the Services, or via integrated wearables:

(a) Identity & Contact Information

• Name, email address, phone number, postal address, gender, date of birth.

(b) Account & Transaction Data

• Username, login credentials (hashed), device purchase history, subscription details, transaction receipts.

(c) Health & Wellness Data (optional)

• Heart rate, steps, activity logs, sleep patterns, food intake, mood, weight, fitness goals, biometric metrics you choose to record.

(d) AI Interaction Data

• Conversations and preferences shared with the in-app AI Coach.

(e) Technical & Usage Data

• IP address, device type, browser, OS, app version, crash reports, approximate location (if enabled), cookies and similar identifiers.

(f) Communication Records

• Support tickets, feedback, in-app chat, and customer service transcripts.

3. Legal Basis for Processing (for GDPR Users)

For users in the EEA, we process your data under one or more of the following legal bases:

Performance of a Contract (to deliver the Services you subscribe to or purchase)

Consent (for health data, marketing, and optional features)

Legitimate Interests (to improve user experience, prevent fraud, and conduct analytics)

Legal Obligation (where required by applicable law or authorities)

4. Purposes of Data Collection

We process personal data to:

• Create and maintain your TriFit Account

• Fulfil purchases, subscriptions, deliveries, returns, and support

• Provide personalized health and wellness insights you opt into

• Facilitate AI-driven coaching and wellness tracking (see Section 6)

• Respond to customer support and technical inquiries

• Improve functionality, safety, and performance of the Services

• Comply with legal obligations and enforce our Terms

5. Data from Wearable Devices

TriFit-certified devices connected to your Account may automatically collect and transmit data such as heart rate, step count, body temperature (device-reported), and movement, which we use to:

• Power your dashboard and trends

• Enable AI personalization (if you opt in)

• Provide visual reports and progress tracking

This data is stored securely, used with your consent, and encrypted in transit and at rest.

6. Use of AI and Automated Processing

TriFit’s in-app AI Coach uses OpenAI GPT-5 to generate personalized wellness suggestions.

What we send to OpenAI GPT-5:

• Your prompt/message and the minimum necessary context (e.g., selected goals or recent summaries you choose to include) for generating a reply.

• We do not send payment data or identity documents to OpenAI.

Why we process AI data:

• Interpret goals and habits you share

• Provide contextual health guidance in-app

• Improve TriFit features using anonymized/aggregated insights (no personal identification)

We do not use AI outputs to make automated decisions that produce legal or similarly significant effects. AI guidance is advisory only. You can request deletion of AI chat history at any time (see Section 11).

7. Cookies and Tracking Technologies

We use cookies/SDKs to:

• Recognize returning users and maintain sessions

• Keep accounts secure

• Analyze traffic and usage trends

You can control cookies via your browser or device settings. Essential cookies are required for basic operation and cannot be disabled.

8. Data Sharing and Third Parties

We do not sell your personal data. We may share data with:

Payment Processors – to complete transactions (RBI-regulated where applicable)

Logistics Providers – to fulfil hardware delivery

Service Providers – hosting, analytics, crash monitoring, customer support (bound by contract to use data only for us)

Practitioners – when you initiate a consultation or share data expressly

Regulators/Authorities – when required by law or lawful requests

All third parties are contractually obligated to protect your data and use it solely for the intended purpose.

9. Data Retention

We retain personal data only as long as necessary for the purposes in this Policy, or as required by law. Criteria include:

• Duration of your active account

• Statutory retention periods

• Ongoing disputes or enforcement obligations

Inactive accounts may be anonymized or deleted after 24 months of inactivity, subject to prior notice where required.

10. International Data Transfers

Your personal data may be transferred, processed, or stored in countries outside your

jurisdiction (e.g., India, the EU, or other locations where our service providers operate). We implement appropriate safeguards, including where applicable:

Standard Contractual Clauses (for EU data)

• Adequacy decisions (if available)

• Encryption and secure cloud infrastructure

11. Your Rights and Choices

Depending on your jurisdiction, you may have the right to:

Access your personal data

Correct inaccurate or incomplete data

Erase data where no legal basis for retention exists

Restrict certain processing

Port data in a machine-readable format

Object to processing based on legitimate interests or direct marketing

Withdraw Consent without affecting past lawful processing

How to exercise: email contact@trifitindia.com. We will respond within timelines required by applicable law.

You can also manage privacy settings in the App (e.g., delete activity logs, disconnect wearables, manage notifications, or close your account).

12. Data Security Measures

We maintain safeguards designed to protect your data, including:

• Encryption of data in transit and at rest• Access controls and monitoring

• Firewalls and intrusion-detection measures

• Regular reviews and staff training

No system is completely secure. Please use a strong, unique password and notify us at contact@trifitindia.com if you suspect unauthorized access.

13. Children’s Privacy

TriFit does not knowingly collect or process personal data from individuals under 18. If you believe a child has used our Services, contact contact@trifitindia.com and we will take appropriate steps to delete the data.

14. Withdrawal of Consent

Where processing is based on your consent (e.g., health data, AI insights, marketing), you may withdraw consent at any time via your Account settings or by emailing contact@trifitindia.com. Certain Services may become unavailable if essential consents are withdrawn.

15. User Controls and Settings

Within the App, you can:

• Toggle syncing with Devices

• Delete activity history or health logs

• Control notifications and in-app communication preferences

• Adjust AI interaction permissions

Review these settings periodically to keep them aligned with your preferences.

16. Grievance Redressal and Escalation (India)

Grievance Officer (DPDP Act): To be appointed

Email: contact@trifitindia.com

Response Time: within 7 working days of receipt

If unresolved, you may escalate to the Data Protection Board of India or, for EEA users, to your local data protection authority.

17. Marketing and Communication Preferences

We may send service notices, transaction alerts, and (with consent where required)

promotional messages. You can opt out of marketing anytime by:

• Clicking “Unsubscribe” in our emails, or

• Adjusting preferences in your Account, or

• Emailing contact@trifitindia.com

Transactional/legal notices will still be sent as necessary.

18. Automated Decision-Making

TriFit does not conduct automated decision-making or profiling that has legal or similarly significant effects. AI-based guidance is advisory and does not determine eligibility, pricing, or access to Services.

19. Changes to This Privacy Policy

We may update this Policy from time to time. When we make material changes, we will:

• Post the updated Policy on the Website/App

• Update the “Effective Date” above

• Provide an in-app or email notice where appropriate

Your continued use of the Services after such changes constitutes acceptance of the updated Policy.

20. Contact Information

Svar TriFit Wellness Private Limited

Email (privacy & support): contact@trifitindia.com

Address: New No 59, Old No 120, Residency Road, Richmond Town, Bengaluru,

Karnataka, 560025, India

Website: https://www.trifit.life

Google Play: https://play.google.com/store/apps/details?id=com.trifitx.authify.habit_tracker&pcampaignid=web_share

Apple App Store: https://apps.apple.com/in/app/trifit-life/id6740154473

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