financial information such as bank account or credit card or debit card or other payment instrument details
physical, physiological and mental health conditions;
medical records and history;
any detail relating to the above sub-clauses or any other sensitive personal data or information you provide to us for providing the Services; and
any of the information received under the above sub-clauses by us under lawful contract or otherwise. However, any data / information relating to an individual that is freely available or accessible in public domain or furnished under any law shall not qualify as SPDI.
INFORMATION WE COLLECT:
The type of Information collected from you may vary based on your interaction with the Platform and preferred use of the Services. Since not all Services may be available to you in your country, Information collected from you will be as per the Services used by you in your country and our interactions with you.
Ultrahuman Digital: As defined in the Terms of Services and available across all major geographies.
Ultrahuman Cyborg: As defined in the Terms of Services and currently available only in India.
Advanced Biomarkers: As defined in the Terms of Services and currently available only in select Indian-cities.
Ultrahuman Digital, and Ultrahuman Cyborg (only available in India; not available in other countries): We collect information you voluntarily provide us in the following ways:
If you sign-up for the waitlist on the Website for Ultrahuman Cyborg, we collect certain information from you such as including your name, date of birth, email, Twitter handle, gender, country and city of residence, mobile number, phone OS (iOS/Android), if your phone is NFC compatible, and if you are using any Third-Party wearable device and if yes, its make and model.
When you purchase any subscription from us, we collect certain Information from you such as including your full name, email, mobile number and payment card details.
We collect your address if we have to deliver any shipment containing any physical products or devices such as CGM in our Ultrahuman Cyborg program. Please note, these details may be shared with our courier/delivery partners who help us deliver the physical products/devices to you.
When you register a user account (“
User Account") on the App to use the Services, we collect certain information from you such as including your full name and email. You may also register for a User Account using your existing Apple or Google account, or social media accounts (such as Facebook), and login credentials (your “Third-Party Site Accounts”). As part of the functionality of the Services, you may link your User Account with Third-Party Site Accounts, by either: (i) providing your Third-Party Site Account login information to us through the Services; or (ii) allowing us to access your Third-Party Site Account, as is permitted under the applicable terms and conditions that govern your use of each Third-Party Site Account. In the event you are registering for a User Account using your Third-Party Site Account, you represent that you are entitled to disclose your Third-Party Site Account login information to us and/or grant us access to your Third-Party Site Account (including, but not limited to, for the purposes described herein), without breach by you of any of the terms and conditions that govern your use of the applicable Third-Party Site Account.
For providing you personalized recommendations you may choose to provide us additional information such as your body weight, height, fitness activities (e.g., HIIT, Running, Strength Training, Yoga, Pilates), and certain SPDI such as including hip/lower back mobility issues, and neck/upper body mobility issues.
For tracking your glucose and evaluating your metabolic response, we collect certain information such as including your glucose data, time duration of events (e.g., sleep, activity, fasting), details of the meals eaten, stress, type of physical activity and other generic logs. This data may be shared with performance coaches to evaluate your metabolic response subject to your consent.
We collect subject to your permission Information such as including your location, distance, duration, and pace to track your runs.
We collect certain Information, with your explicit permission, from Third-Parties via integrations with such Third-Party platforms. Such Information includes the following:
your physical activity logs, sleep logs, number of steps, calories and heart rate from Google Fit.
mindful minutes, glucose, calories, distance (walking and running), heart rate, workout and sleep data from Apple Health.
your activity logs and sleep data from your Third-Party wearable devices such as including Fitbit, Garmin and Oura (via Terra who has partnerships with these Third-Parties to share their respective API’s with Terra who can then reshare with us and many other organizations). This integration feature is currently active on our Platform only in India.
The data read from such integrations will be used solely for measuring and improving the efficacy of your experience of our Services. The data synced from Apple Health, Google Fit, or any Third-Party platform that integrates with Apple Health or Google Fit, or collected from our integrations with Fitbit, Garmin, Oura is not collected, used or disclosed to any Third-Party for the purpose of marketing and advertising.
Advanced Biomarkers: For laboratory testing, evaluation of reports and consultation (only available in select Indian cities; not available in other countries):
We collect Information such as including your name, date of birth, gender, weight, height, past or current medical conditions, reports and records, prescriptions, biological samples. Any SPDI and biological samples are collected with your explicit consent. Any/all sample(s) and Information collected from you, is encrypted to ensure data anonymity. Your name and the analysis report(s)/result(s) are kept separated and under strict access control within our systems, our affiliates/partners’ systems and accredited laboratories. You are aware that the data collected by us may be analyzed, published and/or used, if necessary, for the purposes of improvement and development of new knowledge, quality and efficacy of our test/ examination/analysis/studies. In such cases, the samples and data are only retained and published in an anonymous form (without ability to link it to your identity). We reserve the right to use the sample(s) and data in an anonymous form for further scientific purposes and/or forward them to other companies or institutions in an anonymous form for this purpose. You always have the right to terminate your participation in future studies or research projects without giving reasons and to have the remaining samples destroyed. We reserve the right to contact you after completion of the study for a request for use of your data in a new trial or other medical or personal data or in the case of any additional use of your sample(s) and data, with your consent. However, you are not obliged to answer further questions or to give consent for any additional uses of your sample(s) and data.
We collect details such as including your name, address, phone number and email for delivery of sample collection kits for Lab testing and evaluation, and thereafter home collection of samples. These details may also be shared with our delivery/courier partners.
Automatic Collection of Information: If you access the features of the Platform, we may automatically gather and store certain Information about your visit such as the type of browser and operating system used to access our Website, the date and time you accessed our Website, and if you were linked to our Website from another website, the address of that website, as well as additional information related to your visit may be collected
Voluntary Collection of Information: We collect Personal Data and SPDI only voluntarily and knowingly provided by you. In order to assess and customize your experience, we may collect other information from you as our Services are further developed. You can choose not to provide us with certain information, in which case you may not be able to register with us or to take advantage of some of our features / Services.
Billing & Payment Related Information: You may also be required to make a digital or offline payment to subscribe to our Services, as per our policies. In order to collect the subscription fee from you to access and use the premium Services, our authorized Third-Party payment processors (such as including Chargebee and Simpl) assist us in processing your payment information securely. We may share your relevant Information with our authorized Third-Party service providers who help us in payment processing.
Aggregated Personal Data: In an ongoing effort to better understand and serve you our Services, we may conduct research on our customer demographics and behaviour based on the Information provided to us. This research may be compiled and analysed on an aggregate basis, and we may share this aggregate data with our affiliates, agents and business partners. This aggregate information does not identify you personally. We may also disclose aggregated user statistics in order to describe our Services to current and prospective business partners, and to other third parties for other lawful purposes.
We also collect any Information that you voluntarily choose to provide to us through Platform, email, during interaction with us on call or chat and other modes of communication.
We may also collect Information you have provided to any company or its affiliates, associates, subsidiary, holding company to whom you have given consent for sharing of such Information.
PURPOSE OF COLLECTION:
We use your Information for purposes that include the following:
Deliver Services to you;
Your Registration Information for the purpose of receiving our Services, identification, communication, notification and for fulfillment of the Terms of Services;
Addressing your requests, queries and complaints, if any, pertaining to our Services; taking feedback, assisting you with completion of transactions or other issues relating to the use of Services and other customer care related activities;
Diagnose technical glitches;
Creating insights for corporate / business strategy and marketing operations of Ultrahuman;
Developing machine learning algorithms and tools to improve targeting of Services, and other products and services;
Contacting you to provide information on existing or new Services, features, products, special promotions or offers, both of Ultrahuman and affiliates as well as third-party offers or products with whom we have a tie-up and which are relevant to use of the Services;
Technical administration and customization of Platform, and other general administrative and business purposes;
Research, analysis, case studies for the development and improvement of products and Services;
Disclosure as required to government authorities in compliance with applicable law;
Investigating, enforcing and resolving any disputes or grievances;
Create your unified profile with analytics and insights generated through processing your Personal Data;
Processing any orders/requests and fulfil any orders you may place using our Services;
For providing recommendations to customize or tailor your experience of the Services;
Offering you personalized Services and targeted advertisements of our healthcare and wellness plans and offering you customised health insights
For providing any other services to users with their consent;
To present, operate or improve the Services;
To push transactional, marketing, and other product and service related notifications;
For performing data analysis and testing, processing of statistics for advertising, affiliate marketing, analytics
We may periodically send emails (including marketing emails) about upgrades to our existing products and services, or other similar products and services, special offers, or other information which we reasonably believe you may find relevant and interesting using the email address which you have provided. You may choose to opt-out of receiving promotional emails via the “Unsubscribe” link in every such promotional email communication. Once you unsubscribe, we will no longer send you promotional/marketing emails however you will continue to receive servicing and transactional emails;
To investigate fraud or abuse;
To use statistical information in any way permitted under law, including from Third-Parties in connection with commercial and marketing efforts;
To comply with the law and respond to legal requests;
In any other way that we specify at the time of seeking information from the users.
PRINCIPLES OF PROCESSING:
We will not process Information in a way that is incompatible with the purposes for which it has been collected or subsequently authorized by you or collect any Information that is not needed for the mentioned purposes. For any new purpose, we will ask your separate explicit consent. We also undertake to collect only such Information that is strictly needed for the mentioned purposes.
Ultrahuman is not in the business of selling your Information. We consider this Information to be a vital part of our relationship with you. There are, however, certain circumstances in which we may share your Information with certain Third Parties without further notice to you, as set forth below:
Disclosure for Legal Purposes: We may share information with law enforcement agencies pursuant to lawful requests for Information, and otherwise as required under any law applicable at the given time. We may also disclose Information if we determine in good faith that disclosure is reasonably necessary to protect our rights and pursue available legal remedies, enforce our terms and conditions, investigate fraud, or protect our operations or users.
Service Providers: We share Information with companies that provide Services on our behalf, such as website hosting, data storage, software services, email services, marketing, fulfilling customer orders, providing payment-related services including payment aggregation, data analytics, data mining, providing customer services, and conducting surveys, as permitted by applicable law. These companies may be located within or outside India, but in any case, they are obligated to protect your data.
Group Entities/Affiliates/Business Partners/Employees: We may also share Information with employees, data processors, consultants, business partners, and technology partners on a need-to-know basis. Such entities would be contractually obligated to maintain confidentiality in relation to your Information.
Business Affiliates: We may disclose or transfer some of your Information to Company group entities, affiliates, associates, subsidiary, holding company of the Company, associates and subsidiary of holding company of the Company including foreign entities, and in particular group companies and affiliates who are involved in the provision of Services, to the extent permitted by applicable law.
Business Re-organisation: In the event of a merger, reorganization, acquisition, joint venture, assignment, spin-off, transfer, asset sale, or sale or disposition of all or any portion of our business, including in connection with any bankruptcy or similar proceedings, we may transfer any and all Information to the relevant Third-Party with the same rights of access and use.
HOW WE PROTECT INFORMATION:
We are committed towards maintaining the privacy of the Information uploaded by you on the Platform and complying with the industry standard security safeguards for the purpose of securing the Platform and the information provided / uploaded by you. However, we cannot guarantee absolute security as no method of protection and transmission of Information is completely secure. Therefore, while we strive to protect your Information, you agree and acknowledge that (i) there are security and privacy limitations of the internet which are beyond our control; (ii) the security, integrity, and privacy of any and all Information and data exchanged between you and our Platform cannot be guaranteed; and (iii) any such Information and data may be viewed or tampered with in transit by a Third-Party, despite our best efforts.
We use reasonable technical, administrative, and physical security measures for the purpose of safeguarding all data you share with us. We also have comprehensive internal policies in place to prevent unauthorized access to your data. We take adequate steps to ensure that third parties we share data with also adopt reasonable level of security practices and procedures to ensure the privacy and security of your information.
However, we are not responsible for any loss, unauthorised access, safety issue or any harm caused to you by any misuse of your Information, unless it is a direct and foreseeable consequence of negligence and non-compliance on our part only. You hereby acknowledge that we are not responsible, in particular, for any Third-Party action or action on your part leading to loss, damage or harm to you or any other person.
For any data loss or theft due to unauthorized access to your electronic devices through which you avail our Services, we shall not be held liable for any loss whatsoever incurred by you. Further, you are liable to indemnify us as per the Terms of Services.
ACCESS TO THIRD-PARTY:
However, we may use certain standard advertising tools on our marketing sites which, provided you have allowed it in your cookie preferences, sends Information to the tool providers, such as Google. You can use the privacy setting and cookie preferences to opt-out of the use of these advertising tools. We may also offer electronic newsletters to which you may voluntarily subscribe at any time. You may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails or by contacting us. However, you will continue to receive essential service and transactional emails.
We may engage Third-Party processors to perform particular operations with your Information for us. Such Third-Party processors are companies that help us operate the Services, support our communication with you or perform other Services-related activities. They may process certain Information on our behalf to accomplish the goals related to the Service functions and associated activities. Third-Party processors act only in accordance with our instructions and process only such amount of Information as we instruct them to process. We undertake to execute formal data processing agreements with them to the extent required by applicable law.
We store your Information in accordance with applicable laws, which means we keep your data for as long as necessary to provide you with our Services or as may be required under any law. We shall store your Information for lawful purposes only. We keep de-identified data for research and statistical purposes for a longer period.
If you close your User Account, we have no obligation to retain your data, and we may delete any or all of your data without liability. However, we may retain data related to you if we believe it may be necessary to prevent fraud or future abuse, or if required by law, or for other legitimate purposes. We may continue to store your data in anonymised or de-identified form for analytical, research or other purposes for which your information is collected as previously indicated
If you have elected to receive marketing communications from us, we will retain Information about your marketing preferences for a reasonable period of time, which will be calculated based on the date you last expressed interest in our content, products, or Services.
We follow our users’ instructions about Information we hold for that user. You may access your Information collected by us, request reasons for collection, correct your Information, request deletion of your Information, request restricted processing of your Information, the category of entities with whom we have shared it and the reason for any disclosure, request a portable copy of the Information you have provided, object to processing of your Information, such as for direct marketing, and where we obtain your consent, you may withdraw such consent at any time.
You are free to not to share any medical or other information that you consider confidential and withdraw consent for us to use data that you have already provided. In the event that you refuse to share any information or withdraw consent to process information that you have previously given to us, we reserve the right to restrict or deny the provision of our Services for which we consider such information to be necessary.
You also have the right to file a complaint with the supervisory authority in the EEA and in the UK you can file a complaint with the Information Commissioner’s Office. If you are an EEA or a UK resident, you may also write to our Data Protection Officer at the below address:Ametros Group Ltd
Lakeside Offices, Thorn Business Park
Rotherwas Industrial Estate
0330 223 2246
Further, please find below the details of our EEA and UK representative.
EEA UK Ametros Ltd
Unit 3D, North Point House
North Point Business Park
New Mallow Road
Ametros Group Ltd
Lakeside Offices, Thorn Business Park
Rotherwas Industrial Estate
England, HR2 6JT
0330 223 2246
If you are a California resident, you may also request Information that we may have collected about you in the previous twelve months, the reason we collected it, the category of entities with whom we have shared it and the reason for any disclosure, by writing to us. You can exercise these rights by raising a request to us at firstname.lastname@example.org.
DATA STORAGE AND TRANSFER:
You agree that Information collected may be stored and processed in any country where we rent servers, or where we or our affiliates, subsidiaries, or agents maintain facilities in order to provide Services, and by accessing, registering for, or using the Services, you consent to any such transfer of Information. We may transfer your Information to Third-Parties acting on our behalf, for the purposes of storage such as including AWS and MongoDB in the US. You authorize us to transfer, store, and use your Information in any country where we operate. Some of these countries may have different privacy and data protection laws and rules from those in the country where you live. If you do not agree to the transfer, storage and use of your information in any other country where we operate, please do not use the Platform or Services.
In the event we become aware that the security of the Site, or our Services has been compromised or your Personal Information has been disclosed to unrelated Third-Parties as a result of external activity, including, but not limited to, security attacks or fraud, we reserve the right to take reasonably appropriate measures, including, but not limited to, investigation and reporting, as well as notification to and cooperation with law enforcement authorities. In the event of a data breach, we will make reasonable efforts to notify affected individuals if we believe that there is a reasonable risk of harm to the user as a result of the breach or if notice is otherwise required by law. When we do, we will post a notice on the Website, and where required, send you an email. If for any reason, you have a reason to believe that your Information shared with us is no longer secure, you may contact us via our e-mail address at email@example.com.
You should not be a minor in your country to use (“Permissible Age”). We will not be responsible for any consequence that arises as a result of misuse of any kind of our Services that may occur by virtue of any person including a minor accessing and using the Services. By using the Services, you warrant that you are of the Permissible Age and thus eligible to access, register for, and use the Services. We reserve the right to refuse to provide you with access to the Services if it is discovered that you are under the Permissible Age. You acknowledge that Company does not have the responsibility to ensure that you conform to the aforesaid eligibility criteria. It shall be your sole responsibility to ensure that you meet the required qualification.
We shall take complete measures to safeguard you and our Services from unauthorized access, alteration, disclosure, or destruction of Information we hold, including:
Use of encryption to keep your Information private while in transit;
Timely review of our Information collection, storage, and processing practices, including physical security measures, to prevent unauthorized access to our systems;
ASSIGNMENT AND TRANSFER:
LAW AND PROTECTION:
MODIFICATIONS TO THIS POLICY:
Ultrahuman Healthcare Private Limited is located at 1st Floor, Gopalakrishna Complex #45/3, Residency Road Bangalore 560025, Karnataka, India.
Additionally, please note, not all Services may be available to you in your country due to legal and regulatory reasons. Please contact us at firstname.lastname@example.org if you wish to know more about availability of our Services in your country.
What is Personal Data?
“Personal Data” refers to any information that can be used to directly or indirectly identify you. It includes de-identified data that, when linked to other information available to us, would enable us to identify you. Personal data does not include data that has been irreversibly anonymized or aggregated so that we cannot identify you through it, even in conjunction with other information.
Sensitive Personal Data or Information (“SPDI”) includes information relating to the following:
What is Non-Personal Data?
“Non-Personal Data” refers to any non-personal information collected from you pursuant to your use of the Services, including but not limited to the browser name, the type of computer and technical information, means of connection to the Services such as the operating system, the internet service providers utilized and other similar information. This information does not identify you personally and cannot be linked back to you unless you identify yourself.
Personal Data, Non-Personal Data, and SPDI or any other information shall collectively be referred to as the ‘Information’.
“Third-Party” refers to any person or entity other than you or us.