PRIVACY NOTICE

Last Updated: 14^th February, 2023

Welcome to Gaze’s privacy policy (referred to as “Policy”).

At Gaze, we are committed to respecting your privacy and protecting your personal data. To provide our services, we have to collect and otherwise process certain data about you. This Policy applies to your use of https://shunyaapp.com, and any other websites, applications, or services provided by Gaze (collectively, the “Services”) and explains how we process and use data that we collect through the Services or personal data that we may have access to in relation to your use of the Services.

Please note that unless specifically defined in this Policy, capitalised terms shall have the same meaning ascribed to them in our Terms and Conditions, available at www.shunyaapp.com/terms/ (“Terms”). Please read this Policy in consonance with the Terms.

Please refer to Section 1 to understand how the terms of this Policy apply to you.

1. BACKGROUND AND KEY INFORMATION

(a)  About Us:

Gaze provides tailor-made content to support persons in fitness and holistic health. The terms “Gaze”, “we”, “us”, or “our” in this Policy refer to Gaze Health Private Limited and its affiliates. If you have any questions on this Policy or how we process or handle your personal data, please contact:

Name: Sadhna Upadhya

Designation: Director

Email: sadhna.upadhya@shunyaapp.com

(b)  How this Policy applies:

This Policy applies to individuals who access or use the Services or otherwise avail the Services. For the avoidance of doubt, references to “you” across this Policy are to an end user that uses the Services.

By using the Services, you consent to the collection, storage, usage, and disclosure of your personal data, as described in and collected by us in accordance with this Policy.

(c) Review and Updates:

We regularly review and update our Policy. We request you to regularly review this Policy. It is also important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

(d) Third-Party Links:

The Services may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave the Services, we encourage you to read the privacy policy of every website you visit.

2. DATA THAT WE COLLECT

• We collect different types of personal data about you. This includes, but is not limited to:
• Contact Data, such as your mailing or home address, location, email addresses, and mobile numbers.
• Identity and Profile Data, such as your name, username or similar identifiers, photographs, and gender.
• Marketing and Communications Data, such as your address, email address, information posted in service requests, offers, wants, feedback, comments, pictures and discussions in our blog and chat boxes, responses to user surveys and polls, your preferences in receiving marketing communications from us and our third parties, and your communication preferences. We also collect your chat and call records when you communicate with service professionals through the Services.
• Technical Data, which includes your IP address, browser type, internet service provider, details of operating system, access time, page views, device ID, device type, frequency of visiting our website and use of the Services, website and mobile application activity, clicks, date and time stamps, location data, and other technology on the devices that you use to access the Services.
• Transaction Data, such as details of the Services you have availed, a limited portion of your credit or debit card details for tracking transactions that are provided to us by payment processors, and for processing payments.
• Usage Data, which includes information about how you use the Services, your activity on the Services, booking history, user taps and clicks, user interests, time spent on the Services, details about user journey on the mobile application, and page views.
• We also collect, use, and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data under law as it does not directly or indirectly reveal your identity. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Policy.
• What happens if I refuse to provide my personal data?

Where we need to collect personal data by law, or under the terms of a contract (such as the Terms), and you fail to provide that data when requested, we may not be able to perform the contract (for example, to provide you with the Services). In this case, we may have to cancel or limit your access to the Services.

• We do not knowingly collect or process personal data of children through the Services.
• We do not collect any data about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, genetic or biometric data, or any information about criminal convictions and offences through the Services.

3. HOW DO WE COLLECT PERSONAL DATA?

We use different methods to collect personal data from and about you including through:

• Direct Interactions. You provide us your personal data when you interact with us. This includes personal data you provide when you:
• create an account or profile with us;
• use our Services or carry out other activities in connection with the Services;
• enter a promotion, user poll, or online surveys;
• request marketing communications to be sent to you; or
• report a problem with the our Services, give us feedback or contact us.
• Automated technologies or interactions. Each time you use the Services, we will automatically collect Technical Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies, web beacons, pixel tags, server logs, and other similar technologies. We may also receive Technical Data about you if you visit other websites or apps that employ our cookies.
• Third parties or publicly available sources. We will receive personal data about you from various third parties:
• Technical data from analytics providers such as Facebook and advertising networks;
• Identity and profile-related Data and Contact Data from service professionals, publicly available sources, etc.;
• Personal data about you from our affiliate entities.

4. HOW DO WE USE PERSONAL DATA?

• We will only use your personal data when the law allows us to. We use your personal data for the following purposes:
• to verify your identity to register you as a user, and create your user account with us on the Services;
• to provide the Services to you;
• to monitor trends and personalise your experience;
• to improve the functionality of our Services based on the information and feedback we receive from you;
• to improve customer service to effectively respond to your requests and support needs;
• to track transactions and process payments;
• to send periodic notifications to manage our relationship with you including to notify you of changes to the Services, send you information and updates pertaining to the Services you have availed, and to receive occasional company news and updates related to us or the Services;
• ​​to assist with the facilitation of the Services offered to you, including to send you information and updates about the Services you have availed;
• to market and advertise the Services to you;
• to comply with legal obligations;
• to administer and protect our business and the Services , including for troubleshooting, data analysis, system testing, and performing internal operations;
• to improve our business and delivery models;
• to perform our obligations that arise out of the arrangement we are about to enter or have entered with you;
• to enforce our Terms; and
• to respond to court orders, establish or exercise our legal rights, or defend ourselves against legal claims.
• Where applicable laws permit us to, we rely on your consent as a ground to process your personal data.
• If you are based in the EU (or where applicable law does not permit us to rely on your consent to process personal data), we rely on the following legal bases for processing your personal data:
• Legitimate interest, which means our interest in conducting and managing our business to enable us to provide you with the best services, and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
• Performance of a contract, which means we process your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
• To comply with a legal obligation, which means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
• If you are based in the EU, we generally do not rely on consent as a legal basis for processing your personal data, although we will get your consent before sending third party direct marketing communications to you through email or text messages. You have the right to withdraw consent to marketing at any time by contacting us.
• We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your personal data.
• We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
• Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. COOKIES

• We use cookies to distinguish you from other users of our Services and remember your preferences. This helps us to provide you with a seamless user experience when you use our Services and also allows us to improve our Services.

For further information about the cookies we use, please refer to our Cookie Policy, available at www.shunyaapp.com/cookie-policy/.

6. DISCLOSURES OF YOUR PERSONAL DATA

• We may share your personal data with the parties set out below for the purposes set out in Section 3.
• Internal third parties, which are the other companies in the Gaze group.
• External third parties, such as:
• service providers who provide IT and system administration services.
• professional advisers including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance, and accounting services.
• regulators and other authorities.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the manner set out in this Policy.
• We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

7. CROSS BORDER TRANSFERS OF PERSONAL DATA

• The personal data that we process may be transferred to countries other than where you are based. For example, we transfer your personal data to Singapore, where some of our processors are located. Where applicable law permits such transfer, we rely on consent to transfer such data. If you are based in the EU, we rely on standard data protection clauses that are approved by the European Commission for the transfer of personal data outside the European Economic Area.
• You can find out more information about these transfer mechanisms by contacting us.

8. DATA SECURITY

• We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
• We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

9. DATA RETENTION

• We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
• In some circumstances, we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

10. YOUR LEGAL RIGHTS

• Under certain circumstances, you have rights under data protection laws in relation to your personal data.
• Subject to the data protection laws that apply to you, you have the right to:
• Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request confirmation as to whether or not your personal data is being processed.
• Request the correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request the erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
• If you want us to establish the data’s accuracy.
• Where our use of the data is unlawful but you do not want us to erase it.
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, and machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services through our Services to you. We will advise you if this is the case at the time you withdraw your consent.
• If you wish to exercise any of the rights set out above, please contact us at the details provided in Section 1(a).
• You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
• We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
• We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
• If you are based in the EU/EEA, and you are dissatisfied with the way in which we have handled your personal data or any privacy query or request that you have raised to us, you have a right to complain to the appropriate National Data Protection Authority (“DPA”). To find the contact details of the DPA in your country of residence, please visit https://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.