DEFINITIONS: In this Privacy Notice, the following definitions are used:

• Cookies: a small file placed on your device by our website or mobile application when you either visit or use certain features of our website or mobile application. A cookie generally allows a website to remember your actions or preference for a certain period of time.
• Data: includes non-personal information, personal information and sensitive personal information about you, which either directly or indirectly in combination with other information, could allow you to be identified when you visit the website/mobile application.
• Data Protection Laws:any applicable law for the time being in force relating to the processing of Data.
• Partners: select third parties with whom we have contracts for the businesses described in this Privacy Notice.
• Service Providers: includes entities to whom we will disclose your Data in order to process information for a specific purpose pursuant to written contract.
• Sparcolife: Sparcolife, a company incorporated in India whose registered office C/o. Foundation for Sandbox Startups, next to Airport, Gokul Road, Opposite Gokul Village Hubli Dharwad KA 580030 IN
• User or you:The institution or natural person who accesses our stores, website or mobile application.

TYPES OF DATA COLLECTED

Sparcolife collects Data for various purposes set out in this Privacy Notice. This Data includes, without limitation, the following categories:

• Contact information: It includes Name, Mobile number, Email Address, name of the spouse, spouse's mobile number.
• Financial information: Banking details
• Payment transaction information: Transaction ID
• Health related information: Medical, mental & family history, medical data, diagnostic reports, laboratory reports.
• Personal information: It includes preferred language, education level, size of the household, household income, employment status.

HOW WE COLLECT DATA

We collect Data in the following ways:

• Information You Give Us: Information that you submit on the website and the mobile application, is collected and stored by us.
• Automatic Information We Collect: Information that we receive using cookies, and other similar technologies, whenever you access our website or mobile application, are stored by us.
• Information collected during tele conversations and sessions as well.
• If you download, access, or use our Apps, we may receive and store certain information about you and your mobile device(s) automatically using automatic data collection technologies, including but not limited to first- and third-party Cookies, log files, Web Beacons, Pixels, dynamic tag management and other technical means. This information may include, without limitation:
  • The location of your mobile device;
  • Your mobile device ID and call information;
  • The type of mobile device and operating system you use to access our Apps;
  • Your IP address;
  • Information associated with your Internet or mobile service provider or your account with your Internet or mobile service provider;
  • Information associated with your Google Play accounts or any other account use to download or access the Apps
  • The specific Apps you use, content you view and/or download, search terms you enter, features you use, and the date and time of your visits;
  • Information about the web pages you visit from our Apps or before you came to or after you leave our Apps; and
  • Information collected by third-party advertisements on our Apps, from third-parties providing services to us, and from third-parties with whom we advertise.

PURPOSE OF DATA COLLECTION.

Any or all the above Data may be required by us from time to time to provide information relating to Sparcolife and to work on the experience when using our website or mobile application. Specifically, Data may be used by us for the following reasons:

• carry out our obligations arising from any contract entered into between you and us.
• provide services and communicate with you about services offered by us;
• processing, disclosing, transmitting, and/or sharing the data/information with other third parties which have business or contractual dealings with us;
• operate, evaluate and improve our business, website and mobile application;
• generate aggregated data to prepare insights to enable us to understand customer behavior, patterns and trends with a view to learning more about your preferences or other characteristics;
• provide privileges and benefits to you, marketing and promotional campaigns based on your profile;
• in connection with loyalty programs owned and operated by us;
• communicate with you (including to respond to your requests, questions, feedback, claims or disputes) and to customize and improve our services;
• enforce the terms of use of our website and mobile application;
• protect against and prevent fraud, illegal activity, harm, financial loss and other legal or information security risks; and
• serve other purposes for which we provide specific notice at the time of collection, and as otherwise authorized or required by applicable law.

As required under the applicable law, your personal information (including sensitive personal information) shall be used only with your consent, for a lawful purpose connected with the activities of Sparcolife.

DISCLOSURE OF DATA

We may share your Data with/ for:

1. Partners: We may share the data that we collect and store with our Partners in order to ensure smooth provision of our services. Such partners are also required to ensure that your data remains secure, and process it in accordance with this privacy policy.
2. Service Providers: Your data may be shared with technical service providers.
3. Protecting Sparcolife: Wherever, by law, Sparcolife is required to disclose data, your data will be disclosed to the appropriate authorities. Disclosure may also be made to protect Sparcolife from financial loss.
4. Third Parties: We may also share your Data with other third parties where:
   • You request or authorize us to do so;
   • We need to comply with applicable law or respond to valid legal process; or
   • We need to operate and maintain the security of our website or mobile application, including to prevent or stop an attack on our computer systems or networks.

Such third parties will be required to process the data according to the applicable law.

SECURITY OF DATA

Data obtained is secured using technical and organizational measures. We store your Data on secure servers. Technical and organizational measures include measures to deal with any suspected data breach. In case of any suspicion about misuse of or unauthorized access to your data, contact the grievance redressal officer at the email address given below.

RETENTION OF DATA

Retention of the collected data will be for as long as is permitted by law, and necessary for the provision of services, compliance with legal obligations, resolution of disputes, enforcement of agreements. Because these needs can vary for different data types and purposes, actual retention periods can vary significantly. Even if we delete your Data it may persist on backup or archival media for audit, legal, tax or regulatory purposes.

YOUR RIGHTS AND CHOICES

Even after we collect your data, you will have the following rights:

• Right to Access and Review the information collected.
• Right to Correct the information collected.
• Right to Withdraw Consent to the collection/storage/processing of information, and seek its erasure.

STORAGE OF DATA

Data collected under this Privacy Notice is hosted on servers located in India and outside as well.

PROCESSING YOUR DATA

We take steps to ensure that the Data we collect under this Privacy Notice is processed according to the provisions of this Privacy Notice and the requirements of applicable law.

SEVERABILITY

If any court or competent authority finds that any provision of this Privacy Notice (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this Privacy Notice will not be affected.

CHANGES TO THIS PRIVACY NOTICE

We reserve the right to make changes to our privacy policy. The privacy notice will be revised to incorporate any change made, and the revised notice uploaded on the website and the mobile application. The changes will be effective immediately upon being put up in the website and the mobile application. Your continued usage of the website/mobile application will amount to acceptance of the updated policy.

HOW TO CONTACT US

To request to access, review, update, or withdraw your consent for your personal information or to otherwise reach us, please submit a request by e-mailing us at support@vyli.health.

GRIEVANCE OFFICER

Please see below the details of our grievance officer:

Mr. Ashutosh Dwivedi

9620356777