In this document, Clearcals Private Limited (CPL) shall mean to include the Company, its affiliates and associate companies and shall be referred to as “us”, “we”, or “Clearcals” who is the owner of the website and all software applications related thereto and a provider of the services mentioned thereon.

This Privacy Policy (“Policy”) complies with the

• Section 43A of the Information Technology Act, 2000;
• Regulation 4 of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011 (the “SPI Rules”);
• Regulation 3(1) of the Information Technology (Intermediaries Guidelines) Rules, 2011.
• General Data Protection Regulation (EU)
• Data Protection Act 2018 (UK)
• California Consumer Privacy Act (CCPA)

COVERAGE

This policy governs the collection, use, disclosure, and protection of the information we collect from and about the users of the services/ end users, Providers, and visitors, referred to as “you” or “Users” when you use our web-based platform and proprietary mobile application (the “Service”). We at Clearcals are committed to the obligations regarding your privacy and the protection of your information very seriously and we have made an effort to draft this Privacy Policy in a manner that is clear and easy for you to understand.

The policy intends you to have a clear understanding of the

• Type of information collected about an individual, ie. Personal information and Sensitive Personal Information as defined below.
• The purpose, means of collection, usage, processing, sharing, retention, disclosure to third parties, and deletion of such information by Clearcals.
• Your rights regarding the above.

1. “Personal Data" means data that relates to a natural person, which, either directly or indirectly, in combination with other information available or likely to be available with a body corporate, is capable of identifying such a person.

2. “Sensitive Personal Data" means such personal data, which may reveal (i) financial data such as bank accounts, credit, and debit card details, or other payment instrument details; (ii) physical, physiological, and mental health data; (iii) official identifier; (iv) sex status and sexual orientation; (v) medical records and history (vi) biometric data; (vii) genetic data (viii) caste or tribe; (ix) religious or political belief or affiliation; (x) any detail relating to the above clauses as provided to body corporate for providing service; and (xi) any of the information received under above clauses by body corporate for processing, stored or processed under lawful contract or otherwise: provided that, any information that is freely available or accessible in the public domain or furnished under the Right to Information Act, 2005 or any other law for the time being in force shall not be regarded as sensitive personal data or information for these rules.

INFORMATION COLLECTED

We collect personal information about you in two ways:

1. Manual Information Collection

   The personal information we collect includes information you give us, such as name, postal address, telephone number, e-mail address, date of birth, credit/debit card information, and personal preferences when you register on the Platform.

2. Automated Information Collection

   When you download or use apps created by us or our subsidiaries, we may receive information about your location, Platform usage, and your mobile device. We may use this information to provide you with location-based or other services.

USE OF PERSONAL INFORMATION

We use your personal information for a variety of purposes or “Services” which shall include but not be limited to the purposes as defined below:

1. Providing you with online video and audio consultation with Providers (to include but not limited to doctors, dietitians, therapists, alternative medicine practitioners, etc) in India and abroad.

2. To create a health data repository for use by you.

3. Anonymization of the information for use in research and statistical activities concerning various health conditions and medical advancements.

4. Anonymization and sharing for commercial purposes such as identification of the latest data trends and analyzing software usage patterns for improving the utility and product design.

5. Develop or inform you of new features of our services, improve our services, obtain your feedback, provide customer support, and offer you new products or services.

6. Evaluate and analyze your search preferences and Customize or personalize your experience with our Services.

7. Monitor, evaluate, or improve our Items, Services, systems, or networks.

YOUR RESPONSIBILITY

1. A User will have to register to access all features of the Clearcals web platform and Hint Mobile Application and by registering you expressly recognize and consent to share your Personal Data and Sensitive Personal Information( if any).

2. You are responsible for maintaining the accuracy of all the information shared by you with us. If your personal information changes, you may correct, delete inaccuracies, or amend information by making the change on our user information page or by contacting us through support@clearcals.com. We shall change the databases as soon as reasonably practicable. If you provide any information that is untrue, inaccurate, out of date, or incomplete (or becomes untrue, inaccurate, out of date, or incomplete), or if Clearcals has reasonable grounds to suspect that the information provided by you is untrue, inaccurate, out of date or incomplete, it may, at its sole discretion, discontinue the provision of the Services to you.

3. You can cancel your account or request that we no longer use your information to provide you Services, contact us through support@clearcals.com. We will retain your information for as long as your account with the Services is active and as needed to provide you with the Services. After a period of time, your data may be anonymized and aggregated, and then maybe held by us as long as necessary for us to provide our Services effectively, but our use of the anonymized data will be solely for analytic purposes.

4. You have the option to opt out of receiving any promotional emails or messages from us. Please send an email to support@clearcals.com for the same as a request.

INFORMATION WE SHARE

1. We may collect the User’s credit card number, bank account number, and bank name and will use that information for the billing and payment processes. Verification of credit information, however, is accomplished solely by the User through the authentication process. Users’ credit card/debit card details are transacted upon secure sites of approved payment gateways which are digitally under encryption, thereby providing the highest possible degree of care as per current technology.

2. We may collect the providers’ practice details, qualifications, experience, and other data and may display them on our website and mobile application for viewing by the End-user.

3. When a User or the End-User or anyone who visits the Website, we shall automatically receive the URL of the site, the Internet Protocol (IP) address of each User’s computer (or the proxy server a User used to access the World Wide Web), User’s computer operating system and type of web browser the User is using, email patterns, as well as the name of User’s ISP. This is not shared with or disclosed to third parties. However, Clearcals may share and/or disclose some of the aggregate findings in an anonymized form with advertisers, sponsors, investors, strategic partners, and others to help grow its business.

4. We may share your information that is anonymized or in an aggregated form with third parties in countries other than India (cross-border transfer) only for the purposes mentioned herein.

5. We may share your information that is anonymized or in an aggregated form that does not directly identify you for use in research and statistical activities concerning various health conditions and medical advancements.

6. Anonymization and sharing for commercial purposes such as identification of the latest data trends and advertising.

7. We may share your data stored in the health data repository with Providers and online pharmacies.

8. We do not share information that identifies you personally with third parties.

9. We may access, monitor, use or disclose your personal information or communications to do things such as comply with the law or respond to lawful requests or legal processes or respond to emergencies.

10. We shall not retain such information for longer than is required for the purposes for which the information may lawfully be used or is otherwise required under any other law for the time being in force.

DATA PROTECTION AND CONFIDENTIALITY BY US

1. To protect against the loss, misuse, and alteration of the information under our control, we have in place appropriate physical, electronic, technical, operational, and managerial procedures in line with the best international market practices and security policies, rules, and technical regulations. This shall protect the personal data that it has under its control from unauthorized access, improper use or disclosure, unauthorized modification, and unlawful destruction or accidental loss.

2. Our servers are accessible only to authorized personnel and your information is shared with respective personnel to complete the transaction and to provide the Services requested by you.

3. Although we will endeavor to safeguard the confidentiality of your information, transmissions made by means of the Internet cannot be made absolutely secure. No such measures are competent enough to safeguard your information completely and 100% way. Hence, you are also encouraged to take steps to prevent your information from being misused by logging off after using a shared computer, choosing a robust password, not sharing the password with anyone, and changing it periodically. We in no way are to be held responsible for the unauthorized use of your information or any suspicious activity on your account. By using our Platform, you agree that we will have no liability for disclosure of your information due to errors in transmission or unauthorized acts of third parties.

4. Other than as stated in this Privacy policy we will only disclose your Personal information only if required by law, rule, regulation, law enforcement agency, governmental official, or legal authority

5. Notwithstanding the above, we disclaim any liability for any breach of confidentiality, security, or distribution of your Personal Information by our partners and third parties outside the scope of our agreement with such partners and third parties or events beyond the reasonable control of Clearcals.

INFORMATION ABOUT THE USE OF COOKIES

1. Our Platform uses your Cookies to distinguish you from other users of our Platform. This helps Us to provide you with a good experience when you browse our Platform and allows Us to improve the Platform. By using our Platform, you agree to our use of cookies as more specifically set out below.

2. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.

3. Please note that third parties affiliates may also use cookies, over which We have no control.

4. By using our site or allowing your browser to “accept cookies”, you consent to the use of cookies for your device.

5. You may block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of the Platform. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies as soon as you visit our Platform.

CHILDREN'S PRIVACY POLICY

Clearcals doesn’t intend to target children or persons under eighteen years of age to use its website and the Hint App. If any user provides any personal information relating to a child or children as a guardian if you use the Service on behalf of any child or children, you represent that you are authorized to:

1. Provide such personal information on behalf of such a child or children.

2. Accept this Privacy Policy on such child or children’s behalf.

3. Consent on behalf of such child or children to our collection, use, and disclosure of such information..

YOUR CONSENT AND DECLARATION

By using our services or by giving us your information, on this web-based platform and proprietary mobile application, it is deemed that as the providers, end-users, or visitors you have read, understood, and agreed to the practices and policies mentioned herein

YOU HEREBY EXPRESSLY CONSENT TO OUR ONLINE PRIVACY POLICY and declare that:

1. You understand and have the knowledge that information is being collected.

2. The sharing of the Information by you is Voluntary and expressly consent for the same.

3. You understand and have the knowledge of the purpose for which my information is being collected.

4. You understand and have the knowledge of the indented recipients of the information.

5. You understand that You have the option not to provide the data or information sought to be collected by the Company.

6. You understand that you also have an option (while availing the Services) to withdraw your consent given earlier to Company and understand and accept that such withdrawal of the consent shall be sent in writing and in such case, Company shall have the option not to provide the Services for which the said information was sought.

7. You have read and have understood these Terms and all other policies governing the usage of the Platform.

8. We shall not collect any sensitive personal data or information automatically from any casual visitors of this website, who are merely perusing the Website. However, certain provisions of this Privacy Policy apply to even such casual visitors, and such casual visitors are also required to read and understand the privacy statements set out herein, failing which they are required to leave this Website immediately.

YOUR RIGHTS REGARDING YOUR PERSONAL DATA

If you are a resident of the United Kingdom, the European Union, or the State of California, you have the following rights:

1. You have the right to request an accounting of all Personal Information that we have that pertains to you, and to be delivered copies of such information in electronic format (e.g., electronic copies of information attached to an email). We reserve the right to transmit information to you in a manner that complies with all applicable laws.

2. You have the right to request that we change any Personal Information that pertains to you that is inaccurate.

3. You have the right to request that we delete some or all Personal Information that pertains to you. We reserve the right to carry out such a request in a manner that complies with all applicable laws, such as laws concerning record retention. Note that fulfilling this request requires us to delete Personal Information in our possession, but that this right does not extend to Personal Information that has already been lawfully shared in accordance with this Policy.

4. You have the right to request that we cease processing any Personal Information that pertains to you. Note that fulfilling this request requires us to cease processing Personal Information that pertains to you in the future, but does not apply to lawful processing that has already occurred in accordance with this Policy.

5. You have the right to exercise all the rights afforded by this Policy without fear of retaliation or discrimination. This means that we treat Users who exercise any of the rights under this Policy the same as Users who do not.

To exercise any of the rights explained above, contact our Grievance Officer whose details are set out in the contact us section below. Once we have received notification that you withdraw your consent, we will no longer process your information for the purpose(s) to which you originally consented unless there are compelling legitimate grounds for further processing which override your interests, rights, and freedoms or for the establishment, exercise or defense of legal claims.

If you believe that we have misused your personal data, you also have a right to lodge a complaint with your local supervisory Authority.

THIRD-PARTY LINKS

1. This Privacy Policy applies to Services that are owned and operated by us. We do not exercise control over the sites displayed as search results or links from within its Services and are not responsible for the practices employed by websites linked to from within the Service nor for the information or content contained therein. Please remember that when you use a link to go from the Service to another website, our Privacy Policy is no longer in effect and your activities on that third-party website are subject to such third-party website’s own rules and policies.

2. The User may communicate with other Users or post information to be accessed by others, whereupon other Users may collect such data. Clearcals declares that such Users, including any moderators or administrators, are not authorized Clearcals representatives or agents and hereby expressly disclaims any liability arising out of such communication.

UPDATING AND ACCESSING PERSONAL INFORMATION

You may request access, correction or updation, and deletion of the data by contacting support@clearcals.com. You may note that the deletion of certain data or withdrawal of consent may lead to the cancellation of your registration with us or your access to our Services.

Based on technical feasibility, we will provide you with access to all your personal and sensitive personal data that we maintain about you. We will perform a verification before providing you access to this data.

You may opt out of our marketing emails by clicking on the ‘opt-out’ link provided in the emails. However, we may still send you non-marketing emails about your accounts or any other transactions with you.

CONTACTING US

In accordance with Information Technology Act 2000 and the rules made thereunder, the name and contact details of the Grievance Officer are provided below: Name: Susheel Athmakuri Email: susheel.athmakuri@clearcals.com Time: Mon – Fri (10:00 AM to 5:00 PM IST)

If you have any grievance, then you may intimate the same to the above e-mail address in the manner explained below: -

a. Sending a request in writing or through email signed with an electronic signature identifying the grievance;

b. Your contact information like address, telephone number, email address, etc. where you can be contacted.

Changes to our Privacy Policy If we decide to change our privacy policy, we will post those changes on this page, and/or update the Privacy Policy modification date below.

Date of the last update 05 June 2023.