Vigo

Privacy Policy

Connected Care India Private Limited (“Connected Care”, “we”, “us”, “our” or “Vigo” a reference to which shall also include its affiliates) is a private limited company incorporated under the Indian Companies Act, 2013. Connected Care recognizes the importance of maintaining and respecting the privacy of its users (“User”, “you”, “your”, “yourself”) and the confidentiality of your information, in accordance with applicable law. We value the trust you place in us. That's why we insist upon the highest standards for secure transactions and User information privacy. Please read the following policy to learn about our information collecting, processing and dissemination practices and how you can exercise your privacy rights (“Privacy Policy”). The Privacy Policy can be easily accessible via a hyperlink at the bottom of each web page. The following Privacy Policy should be read along with our Terms of Use (https://vigocare.com/terms.html) , for a full understanding of Connected Care’s practices as well as the Users’ rights and responsibilities when interacting with the site www.vigocare.com, our mobile application ‘Vigo’ and the software, applications and devices of the brand name ‘Connected Care India or Vigo or Vigocare’ (together, “Website”) and the holter monitoring device bio-sensor patch and / or other devices (such as pulse oximeter, blood pressure monitors) (“Devices”) and remote monitoring services ((for monitoring heart activity, covid-19 symptoms, post-surgery recovery) you avail of (“Services”). This Privacy Policy specifies the manner in which personal data and sensitive personal data of Users is collected, received, stored, processed, disclosed, transferred, dealt with and handled by Connected Care. This Privacy Policy does not apply to information that Users provide to, or that is collected by, any third-party through the Website. Part A of this Privacy Policy is published in accordance with the provisions of the Indian Information Technology Act, 2000 and the rules made thereunder (“IT Act”), more specifically, the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011. All terms used in this Privacy Policy will have the same meaning and definitions assigned to them in the IT Act and the rules made thereunder, or in our Terms of Use. Part A of this Privacy Policy shall be applicable to all Users of the Website. Additionally, if you are a natural person based in the European Economic Area (“EEA”), the provisions of Part B of this Privacy Policy will apply to how we process your personal information. Part B of the Privacy Policy is published in accordance with, and in compliance of, the provisions of the European Union General Data Protection Regulation (“GDPR”). By visiting the Website, you agree to be bound by the terms and conditions of this Privacy Policy and the Terms of Use of the Website, as they apply to you. Please read this Privacy Policy carefully to understand how your personal information and your rights in this regard are handled. If you do not agree with any of the terms contained in this Privacy Policy or the Terms of Use, please do not use or access the Website. You must be aged 18 years or over to access our Website and avail of products and Services offered on the Website. If you are aged below 18 years, please ensure your use of the Website is consented to by your parent or legal guardian.

PART A

1. Collection of your personal information and other identifiable information

  • When you use our Website, we collect and store your personal information about you, provided by you, from time to time.
  • Personal Information (“PI”) under the IT Act is defined to include any information that relates to a natural person, which, either directly or indirectly, in combination with other information available, or likely to be available, is capable of identifying such person by a body corporate. Further, we may also collect certain information classified as sensitive personal data and information which, under the IT Act and the rules made thereunder constitutes information relating to: (i) passwords; (ii) financial information, including but not limited to, credit card related information or other payment method data; (iii) physical, physiological and mental health conditions; (iv) sexual orientation; (v) medical records and history, including, but not limited to, past and present diseases, allergies, previous treatments, diagnostic reports, prescriptions and medication history; (vi) biometric information; (vii) any detail relating to the above, as provided to a body corporate for providing services; and (viii) any of the information received under the above by a body corporate, for processing or storing data under lawful contract, or otherwise (together “SPDI”). SPDI does not include any information that is freely available or accessible in the public domain, or that is furnished under any law. By using our Website, products, Devices and/or our Services, it is deemed that you have provided your consent to Connected Care for the collection, disclosure and transfer of your SPDI by your conduct.
  • Any third parties on our behalf, may collect and use the following PI and / or SPDI about you:
    • Your name, including your title;
    • Your contact number(s);
    • Your e-mail address;
    • Your postal address;
    • Your age;
    • Your gender;
    • Information provided when you correspond with us;
    • Updates to information you have already provided to us;
    • PI we obtain from third-party sources (e.g. APIs, URLs); and/or
    • Technical and behavioral information about you regarding your use of the Website.
  • We may also collect PI and SPDI for: (a) the purpose of providing you our Services, facilitating your seamless use of the Devices, and also facilitating provision of necessary healthcare by external healthcare providers, all through the Website (b) commercial purposes and in an accumulated or non-personally identifiable form for research, analysis and business intelligence purposes, (c) sale or transfer of such research, analysis or intelligence data in an accumulated or non-personally identifiable form to third parties and affiliates, (d) communication purpose so as to provide you better service and for obtaining feedback, (e) debugging customer support related issues, and (f) the purpose of contacting you to complete any transaction if you do not complete a transaction after having provided us with your contact information in the course of completing such steps that are designed for completion of the transaction. We will ensure this data is collected, stored, secured and processed in accordance with the IT Act and applicable law.
  • Our primary goal in doing so is to provide you with a safe, efficient, smooth and customized experience, which allows us to provide Services and features that strive to meet your needs and make your experience safer and easier. More importantly, while doing so we only collect PI and SPDI from you that we consider necessary for achieving this purpose and providing our Services. In general, you can browse the Website without providing us with information regarding who you are or without revealing any PI about yourself.
  • You agree and acknowledge that you provide us with your PI and SPDI voluntarily. Once you provide your PI and SPDI to us, either by signing up/registering on our Website or signing in through an associate API (such as Google or Facebook), you are no longer anonymous to us. Where possible, we indicate which fields are required and which fields are optional for you to fill in. You always have the option to not provide us with your information by choosing not to use a particular service or feature on the Website. We may, however, automatically track desensitized information about you based on your behavior on the Website. We use this information to do internal research on our User demographics, interests, and behavior to better understand, protect and serve our Users. This information is compiled and analyzed on an aggregated basis. This information may include the URL that you accessed our Website through (whether this URL is on our Website or not), which URL you next go to (whether this URL is on our Website or not) through our Website, your internet browser information, and your IP address.
  • We use data collection devices such as "cookies" on the Website to help analyze our webpage and mobile application flow, measure promotional effectiveness and promote trust and safety. By continuing to browse our Website, you are agreeing to our use of cookies. To know more on how cookies are used by us, please refer to Part C below.
  • If you choose to post messages on our message boards, chatrooms, other message areas or if you choose to leave feedback, we will collect that information you provide to us. We retain this information as necessary to resolve disputes, provide User support and troubleshoot problems, as may be necessary, and as is permitted under applicable law.
  • If you send us personal correspondence, such as e-mails or letters, or if other users or third parties send us correspondence about you and your activities or postings on the Website, we may collect such information into a file specific to you. If you reach out to our customer care representatives for resolving any issues that you may be facing in connection with the Services, or for the use of the Devices or the Website, we will collect such queries and/or communications received from you, through email or calls, in order to resolve disputes, provide User support, troubleshoot problems, and improve the quality of our Services.
  • We collect PI and SPDI from you when you set up an account with us/ register with us. We use the collected contact information to send you relevant information.
  • We also collect data concerning whether any communication you may have received from us have been accessed by you and if you have clicked on any links within such communication (i.e. email, text). This helps us ensure our communications are useful for you.
  • We also provide certain data to our medical partners, such as hospitals and physicians, to interact with you and send you relevant or required information of the type aforementioned, as well as to complete certain transactions and fulfill commitments. After your data is made accessible to a medical partner, the medical partner may use your data to send you information relevant to you. We will always ensure that our medical partners with whom we share information about our Users are subject to privacy and security obligations consistent with this Privacy Policy and applicable law.

2. Use of Demographic, Profile Data and Your Information

    • We use your personal information to provide you with the Services you choose to avail of. To the extent we use your personal information for direct marketing purposes, we will provide you with the ability to opt-out of such uses, if you do not wish to receive such communication. To opt-out of being on such call, SMS, e-mail and/or other communication lists, you may e-mail us at support@vigocare.com, and we will ensure you do not receive such communications in the future.
    • We may use your personal information to resolve disputes, troubleshoot problems, help promote a safe service, collect money either directly by us or through an authorized payment gateway facility, measure User-interests, inform you about updates, customize your experience, detect and protect us against error, fraud and other criminal activity, enforce our terms and conditions, and as otherwise described to you at the time of collection.
    • We will combine the information you give to us and information we automatically collect about you to maintain and improve the accuracy of the records we hold about you. We will also use the combined information about you to form a view on what products we think you, or others similar to you, may want or need to target our marketing closer to your interests.
    • In our efforts to continually improve our product and Services offerings, we collect and analyze demographic and user data about our Users' activity on our Website. We identify and use your IP address to help diagnose problems with our server, and to administer our Website. Your IP address is also used to help identify you and to gather broad demographic information related to you. In this regard, it is clarified that we reserve the right to use the data collected from your use of the Website for any analysis and development, and to improve the Website, our Services as well as the diagnostic outcomes.

3. Sharing your personal information

    • By providing us with your PI and SPDI, you consent to the information being shared with our group companies or third-party service providers, where it is in our legitimate interest to do so for administrative or business purposes (such as corporate strategy, auditing, monitoring, and quality assurance).
    • We will not share your SPDI with any third parties or disclose it to any person other than as required (a) to provide you with our Services; or (b) by applicable law.
    • We may share your PI and / or SPDI with our other corporate and/or associate entities and affiliates to (i) help detect and prevent identity theft, fraud and other potentially illegal acts and cyber security incidents, (ii) help and detect co-related/related or multiple accounts to prevent abuse of our Services, and (iii) facilitate joint or co-branded services that you request, where such services are provided by more than one associate entity. Those entities and affiliates will not directly market their products and/or services to you as a result of such sharing, unless you explicitly opt-in.
    • Any third parties we share your information with are limited by law and contract in their ability to use your PI and SPDI for any purpose, other than to provide Services for and in connection with us. We will always ensure that the third parties with whom we share information about our Users are subject to privacy and security obligations consistent with this Privacy Policy and applicable law.
    • We may disclose your PI and / or SPDI, if required to do so by law or in the good faith belief that such disclosure is reasonably necessary to respond to summons, court orders, or any other legal process. We may disclose your PI and / or SPDI to law enforcement offices, third party rights owners, or others as becomes necessary, in the good faith belief that such disclosure is reasonably necessary to: (i) enforce the Terms of Use or this Privacy Policy; (ii) respond to claims that a posting or other content violates the rights of a third party; or (iii) protect the rights, property or personal safety of our Users or the general public.
    • While transferring your PI and / or SPDI to another body corporate or natural person, for purposes necessary to perform contractual obligations to you, we will make sure that, as is required by applicable laws, the same level of data protection adhered to by us is adhered to by such entity to whom the data is being transferred.
    • In the event we (or our assets) plan to merge with, or be acquired by any business entity, or for purposes such as re-organization, amalgamation or restructuring of our business, by using the Website and consenting to these Terms of Use, you also consent to us, and our affiliates, using, sharing, parting with and allowing such resulting/other business entity to use the PI and SPDI provided by you to us. Should such a transaction occur, that other business entity (or the new combined entity), will be required to adhere to this Privacy Policy, with respect to your personal information.
    • Only if it is essential, we may also share your PI and / or SPDI with third parties in order to enforce or ensure application of our Terms of Use, other terms and conditions for Users, our policies, any other agreement in force, to respond to claims, to protect our rights or the rights of our employees and/or Users and/or a third party, to protect User safety or to prevent any illegal activity. This may include exchanging information with other organizations for fraud protection.
    • We may also disclose and use anonymized, aggregated reporting and statistics about Users of the Website and interaction with our products and Services for reporting purposes, or for marketing and promotion purposes. None of these reports or statistics will enable our Users to be personally identified.
    • Save as expressly stated above, we will never share, sell or rent any of your PI or SPDI to a third party without notifying you, and where necessary, obtaining your consent. If you have permitted us to use your PI or SPDI in a certain way, but later change your mind, you can contact our Grievance Officer and we will stop doing so.

4. Retaining your information

  • We keep your PI and SPDI for no longer than is necessary for the purposes that your PI/SPDI was collected and processed. The length of time for which we retain your PI or SPDI depends on the purpose for which we collect and use it, and/or as is required to comply with applicable law, and to establish, exercise or defend our legal rights.
  • Information provided by you to Connected Care is processed, stored and retained through our servers and web hosts.
  • Our web hosts and agency managing your information are compliant with IS/ISO/IEC27001 or an equivalent in standards of Security Techniques and Information Security Management System Requirements.

5. Links to Other Sites

  • Our Website links to other websites that may collect personally identifiable information about you. Such other websites are not operated by us, nor we do have any principal-agent relationship with such third-party websites; the same are only provided for your convenience.
  • The links available do not imply Connected Care’s endorsement of activities of such third-party websites or Connected Care’s association with its operators. This Privacy Policy applies only to PI or SPDI collected, or PI received from third party sources, by Connected Care. We are not responsible for PI and SPDI about you that is collected and stored by third parties.
  • Third party websites have their own terms and conditions for use and collection and processing of data. You should read the terms of use and privacy policies of these websites carefully before submitting your information to these websites.
  • Connected Care is not responsible for the privacy practices or the content of those linked websites and does not endorse or accept responsibility or liability for content of such third party websites or third party terms and conditions.

6. Security Precautions/ Security Breach

    • Our Website has stringent security measures in place, as required under law, to protect the loss, misuse, and alteration of the information under our control. Whenever you change or access your account information, we offer the use of a secure server. Once your information is in our possession, we adhere to strict security guidelines, protecting it against unauthorized access. Our web hosts, transaction affiliates etc., all use industry grade and standardized methods to protect your information from any misuse.
    • If any User has sufficient reason to believe their PI or SPDI, has been compromised, or there has been a breach of security due to a cyber security incident, you may write to our Grievance Officer immediately at the contact details mentioned below in, so that we may take suitable measures to either rectify such a breach and inform the concerned authorities of a cyber security incident.
    • To report an abuse on the Website, not being a cyber security incident, a User may write to the Grievance Officer and provide details of the abuse. Upon receiving such information, Connected Care will examine the abuse and take suitable and necessary steps to remedy it.
    • Where you have chosen a password, which enables you to access your account with Connected Care, you have the responsibility to ensure that your password remains confidential and only you have access to your account.
    • We endeavor to protect the privacy of your information (including PI and SPDI) we hold in our records by adhering to the maximum standards prescribed under law. However, we cannot, unfortunately, guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of User information at any time.

7. Your Consent

  • By using the Website and/or by providing your information, you consent to Connected Care’s collection, receiving, processing, using, disclosing, storing, dealing with, handling, transferring and/or sharing of the information you disclose on the Website in accordance with this Privacy Policy.
  • Connected Care shall, at its sole discretion, modify this Privacy Policy. If we decide to change our Privacy Policy, we will post those changes on this page immediately upon the revision of the Privacy Policy so that you are always aware of what information we collect, how we use it, and under what circumstances we disclose it.
  • Where material changes are made to this Privacy Policy, or where deemed appropriate by us, you will be notified of such material change through your registered mode of communication. Upon your first access to the Website post the revision of the Privacy Policy, you shall have the option to consent or revoke your consent to the revised Privacy Policy. We suggest that you read and understand the revised Privacy Policy, a link of which will be available where you would see the option to consent to the revised Privacy Policy. However, please note that denial of consent would lead to immediate termination of the Services we provide to you through the Website.
  • In spite of such notifications, the User should return to this Privacy Policy periodically to ensure familiarity with the most current version of the policy. The date on which this Privacy Policy is last updated is provided at the top of this page.

8. Representations and Warranties, and Limitation of Liability

  • The Website, all the products, Devices, materials, information and Services, included or otherwise made available to you through this Website are provided without any representation or warranties, express or implied except otherwise specified in writing.
  • We do not, either express or implied, warrant about the the absolute efficacy of the measures we undertake to safeguard your data collected as per this Privacy Policy.
  • We disclaim any liability that may arise due to acts and events beyond our control in relation to the security of the data collected as per this Privacy Policy.
  • Connected Care is not liable nor responsible for the compliance of applicable privacy laws including the IT Act by third parties that may obtain your data in accordance with this Privacy Policy. Accordingly, we disclaim any liability that may arise due to breach or consequences of such breach of IT Act by third parties.
  • Notwithstanding anything contained in this Privacy Policy or elsewhere, Connected Care shall not be held responsible for any loss, damage or misuse of the User Information, if such loss, damage or misuse is attributable to a Force Majeure Event. A " Force Majeure Event" means any event that is beyond the reasonable control of Connected Care and includes, without limitation, fire, flood, explosion, acts of God, civil commotion, strikes, lock outs or industrial action of any kind, riots, insurrection, war, acts of government, power failure, sabotage, computer hacking, unauthorized access to computer data and storage device, system failure, virus, attacks, bugs, computer crashes, breach of security and encryption.
  • You represent and warrant that any and all PI, SPDI and User Information are absolutely correct, accurate and complete in all aspects and may substantially impact the Services that we provide to you through the Website. You further undertake to immediately update Connected Care of any change or variation of your PI, SPDI and User Information.
  • Notwithstanding anything to the contrary contained herein, under no circumstance shall, the liability of Connected Care exceed the cost paid by you for the Devices.

9. Grievance Officer

  • In accordance with IT Act and the rules made thereunder, we have appointed a Grievance Officer to handle any arising concerns are grievances. We will ensure that the Grievance Officer will redress the grievances expeditiously but within one month from the date of receipt of grievance. The contact details of the Grievance Officer are provided below:
    • Name: Mr. Ratish Bhat
    • Address: 3rd floor, Plot no 288, Road no 6, Kakatiya Hills, Guttalabegumpet, Hyderabad-500033
    • E-mail: ratish.bhat@vigocare.com
    • Time: Mon – Sat (09:00hrs – 18:00hrs)

10. Governing Law and Jurisdiction

  • This Privacy Policy, along with the Terms of Use, is governed by laws prevailing in India.
  • Only the courts in Hyderabad, India will have jurisdiction with regard to disputes arising from this Privacy Policy.

Part B

11. Additional provisions applicable to EU residents only

  • The terms and conditions contained herein are only applicable to Users of the Website located and residing in the EEA (“EU Users”) and are in addition to the terms mentioned in Part A above. This section is not applicable to Connected Care’s Users located and residing in India or any other jurisdiction apart from EEA.
  • We consider that the legal basis for using your personal information, after you have provided your consent, as set out in this Privacy Policy is as follows: :
    • Our use of your personal information is necessary to perform our obligations under any contract with you; or
    • Our use of your personal information is necessary to comply with our legal obligations.
  • We will retain your data for such period of time as may be reasonably necessary to fulfill the purposes set out in the Privacy Policy and, if relevant, to deal with any claim or dispute that might arise in connection with any Services which you avail of via our website.
  • With respect to the personal information you provide us with, you have certain rights that you may exercise:
    • Right of access: you have the right to access personal information we hold about you.
    • Right to update: you have the right update information you may have provided to us that is out of date or incorrect.
    • Right to delete: you have the right to ask us to delete any information we hold pertaining to you in specific circumstances.
    • Right to restrict use of your information: you have the right to ask us to restrict how we process your personal information in certain circumstances.
    • Right to stop marketing: you have the right to restrict us from using your personal information for direct marketing purposes.
    • Right to data portability: you have the right to ask us to provide your personal information to a third party provider of services.
    • Right to object: you may ask us to consider any valid objections which you have to use of your personal information where we process your personal information on the basis of our, or another person’s legitimate interest.
  • If you would like to actively exercise any of your rights, or require more information regarding the steps we take to protect your personal information, you may contact our Grievance Officer. We will consider all your requests and provide our response to you within a reasonable period of time.
  • Your personal information is used, stored and accessed by staff operating and servers located outside the EEA. We may share personal information with our group entities and with third parties in accordance with the GDPR. Appropriate measures will be taken to ensure your personal information is protected adequately in accordance with this Privacy Policy.

PART C

12. Cookie Policy

  • We use data collection devices such as “cookies” which are small text files on your device that allows us to recognize you as a user. Cookies help us analyze how your device has interacted with our website, including the pages accessed and links clicked, websites visited before or after our website, products viewed or searched for and the length of visits to certain pages. We collect this data to tailor our webpage flow, measure promotional effectiveness and to promote trust and safety. We use cookies to offer you a more tailored experience in the future, by understanding and remembering your browser preferences. Certain features offered on our Website can only be fully realized through using “cookies”.
  • Where we use cookies on our Website, and where your internet browser permits, you may block them at any time. However, if you use your browser settings to block all cookies, you may not be able to fully access parts of our Website or realize full functionality of the Services we offer.
  • We do not control the use of cookies by third parties.

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