PRIVACY POLICY

Last Updated: 21 February, 2025

App Name: HealCycle

We are HealCycle Wellness Private Limited (“HealCycle”, “we”, “us”). 

Thank you (“user”, “you”, “your”) for your interest in our HealCycle Mobile Application, designed for tracking and managing menstrual health symptoms, including but not limited to Premenstrual Syndrome, Premenstrual Dysphoric Disorder, and Premenstrual Exacerbation Syndrome.

This Privacy Policy defines how HealCycle collects, uses, shares, and protects the personal data/information disclosed by you and governs your access to and use of the HealCycle through all digital interface, including, website being https://www.healcycle.com, mobile application, communication tools like WhatsApp and other messaging services, any associated software applications, websites, media form (collectively “App”) offered by us, Accordingly, you are advised to read this Privacy Policy carefully before accessing the App. By downloading and/ or interacting with our App, you expressly consent and agree to be bound by the terms and conditions of this Privacy Policy as they apply to you. If you do not consent to or agree with any of the terms contained in this Privacy Policy, please do not download, use or access our App. Do note that the App description and further related details of the App may be provided to you at the time you access or engage with the App.

Your personal data and information are handled and processed in accordance with the provisions of Indian data protection laws relating to the collection, use, or processing of personal data, including the Information Technology Act, 2000, Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011, and the Digital Personal Data Protection Act, 2023, and rules, as updated, amended, superseded, or replaced from time to time.

HealCycle is committed to ensuring your privacy is protected. The information you provide during the usage of the App will only be used in accordance with this Privacy Policy, subject to limitations under applicable Indian data protection laws. 

The core objective of this Privacy Policy is to bring to your knowledge the nature of personal data collected by us, the purpose of collecting such data and its use, subsequent processing of such data and your rights pertaining to such personal data shared with us. 

This Privacy Policy may be updated from time to time for any reason. We will notify you of any changes to our Privacy Policy by posting the new Privacy Policy here. You are advised to consult this Privacy Policy regularly for any changes, as continued use is deemed approval of all changes. 

1. What Data We Collect

1. Personal data refers to any data about you by which you are identifiable or in relation to such data. Accordingly, we may collect the following personal data which you provide to us during the course of your usage of the App – 

1. Name;

2. Age;

3. Gender;

4. Telephone number;

5. E-mail address;

6. IP Address;

7. Device Information;

8. Health Data (including, but not limited to, menstrual cycle dates, mood, and symptoms)

2. We collect your personal data which you provide to us, inter alia, in scenarios such as:

1. by downloading and using the functionalities of the App; 

2. when registering for personalized services on the App; 

3. requesting information about our product or use of our services on the App or request for customer support etc.;

4. filing grievances, complaints, feedback, etc.

3. We may use a third-party service provider(s) to assist us with some features of the App. Our service provider(s) may receive your information on our behalf and such information will not be used for any other purpose than for necessarily achieving the specific purpose as indicated to you at the time of collection.

4. We automatically collect certain personal data from you when you access the App, including your IP address, location, other unique device identifiers, your browser type, language, the URL of any other website which you may have used prior to accessing the App, and any other diagnostic data.

5. We may also collect personal data from third parties such as our partners, service providers and publicly available websites, to offer services we think may be of interest and to help us maintain data accuracy, provide, and enhance the provision of our services and access to our App to you.

2. What We Do with the Information

1. In addition to the uses of your personal data we describe elsewhere in this Privacy Policy, we gather information to understand your needs and provide you with a better experience in relation to your usage of the App, and to do the following

1. Enable your access and use of the App;

2. To manage your account to give you access to the various functionalities of the App;

3. To manage your requests;

4. Internal record keeping;

5. To improve our products and services;

6. To periodically send promotional notifications about new products, special offers or other information which we think you may find interesting. HealCycle or its representatives may reach out to you using the phone number and/or email address provided by you.

7. From time to time, we may also use your information to contact you for market research purposes. We may contact you by email, phone or mail. We may also use this information to customize the App according to your interests.

8. To perform internal operations such as troubleshooting, data analysis, testing, research, statistical, internal training, and quality management purposes aimed at improving the App, such analysis is aggregated and does not pertain to any specific user; and

9. To enforce our App policies.  

3. Your Rights and Your Personal Data

We respect your right to access and control your information, and we will respond to requests for information and, where applicable, will correct, amend, or delete your personal data.

1. The Right to Confirmation and Access to Information: At any point, you can contact us to request (a) confirmations on whether your personal data is being processed by us; and (b) brief summaries of your personal data processed or being processed by us. You may also request us for further information on the matters covered in the Privacy Policy. Once we have received your request, we will respond within one month. There are no fees or charges for the first request but additional requests for the same data may be subject to an administrative fee.

2. The Right to Correction, Withdrawal of Consent, and Erasure of Information: With regard to the personal data you have provided us, you have the right to correct inaccurate or misleading personal data, complete any incomplete personal data, and update the personal data. You may also request for the withdrawal of your consent for processing of your personal data as well as erasure of such personal data in a manner that is prescribed under law. We will take reasonable steps to notify all relevant persons to whom we have disclosed your personal data about any corrections, completion, or updates made to your personal data, as the case may be. If we do not agree to correct, complete or update your information, we will provide you with an adequate written justification for the same.  

3. The Right to Grievance Redressal: You have the right to a readily available means of grievance redressal. We have appointed a grievance officer to cater to any grievances, complaints, or queries raised by you in the course of the processing of your personal data by us. We have provided the officer’s name and contact details under Clause 9 of this Privacy Policy.

4. The Right to Nominate: You have the right to nominate an individual to exercise these rights in the event of any incapacity.

4. How Long Do We Keep Your Personal Data?

1. We retain your data/information for as long as is necessary to provide you with our services and access to the App; thereafter, we may retain your data/information to comply with our legal obligations, resolve disputes and enforce our agreements, and protect our legal rights, subject in each case to limitations under applicable law.

5. How We Share Your Personal Data

1. We store and share your data and information in accordance with the overall terms of this Policy. In certain instances, we may share your personal data and information with our associated entities, affiliates and third-party vendors, for the furtherance of providing you with an optimal experience in your usage of the App, and other associated purposes, who may store or process your data and information in jurisdictions other than India. These may include, third-party distributors, dealers, vendors, and service providers engaged by HealCycle as well as group entities of HealCycle, as the case may be. However, this is only done as per the permissible circumstances specified under applicable Indian data protection laws. Further, HealCycle will not disclose or share your personal data or information for any purpose other than those identified in this Policy, except with your consent.

2. We may share your data/information with various third parties who assist us in providing you with access to the App, and other associated purposes, including the following: 

1. Service providers, such as information technology service providers, Artificial Intelligence tool, etc. whose services may form a part of or may be necessary for the provision and functioning of the App; 

2. Cloud storage providers to store the data/information you provide and for disaster recovery services, as well as for the performance of any contract we enter into with you;

3. Analytics and search engine providers that assist us in the optimisation and improvement of the App.

3. We may share your data/information with law enforcement agencies, public authorities, or other organisations if legally required to do so or if such use is reasonably necessary to:

1. Comply with any applicable law, legal obligation, process, or request from government or judicial authorities;

2. Enforce our App policies, including investigation of any potential violation thereof;

3. Detect, prevent, or otherwise address security, fraud, or technical issues; or

4. Protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law.  

6. Security and Protection of your Personal Data

1. We use industry standard and legally mandated reasonable security safeguards to keep your personal data and information secure. These measures include periodic reviews of our data collection practices, storage and processing practices, cyber security measures such as encryption, and physical security measures to guard against unauthorised access to systems where we store your personal data. We have a comprehensive information security program and information security policies that contain managerial, technical, operational and physical security control measures adequate for the protection of personal data. Where applicable, our web hosts and any third parties managing and processing your personal data and information are compliant with IS/ISO/IEC27001 or an equivalent in standards of Security Techniques and Information Security Management System Requirements.

7. Personal Data of Children

1. The App is not intended or directed at anyone under the age of 18, and we do not knowingly collect or solicit any information from anyone under the age of 18. Upon learning that we have collected personal data from anyone under the age of 18, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under age 18, please contact our grievance officer in the manner provided in Clause 9 below. 

8. Links To Other Websites

1. Our App may contain links to third-party websites or services of interest. However, once you have used these links to leave our App, you should note that we do not have any control over such other third-party website or service. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this Privacy Policy. You should exercise caution and carefully review the privacy policy applicable to such third-party website or service.

9. Governing Law and Dispute Resolution

This Privacy Policy will be governed and construed in accordance with the laws of India, without regard to its ‘conflict of laws’ provisions. The competent courts in New Delhi shall have exclusive jurisdiction on all matters arising under this Privacy Policy. 

10. How to Contact Us

If you have any questions, about this Privacy Policy, or any concerns, requests, or grievances about the processing of your personal data by us or wish to exercise your rights, you may contact our grievance officer whose details are provided below: 

Name: Manish Grover

E-Mail Address: contact@healcycle.com