- 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.
- The type of information collected from the Users, including Personal Information and Sensitive Personal Data or Information relating to an individual;
- The purpose, means and modes of collection, usage, processing, retention and destruction of such information; and
- How and to whom Solutine will disclose such information.
2.COLLECTION OF PERSONAL INFORMATION
Generally, some of the Services require us to know who you are so that we can best meet your needs. When you access the Services, or through any interaction with us via emails, telephone calls or other correspondence, we may ask you to voluntarily provide us with certain information that personally identifies you or could be used to personally identify you. You hereby consent to the collection of such information by Solutine. Without prejudice to the generality of the above, information collected by us from you may include (but is not limited to) the following:
- contact data (such as your email address and phone number);
- demographic data (such as your gender, your date of birth and your pin code);
- data regarding your usage of the services and history of the appointments made by or with you through the use of Services;
- other information that you voluntarily choose to provide to us (such as information shared by you with us through emails or letters.)
The information collected from you by Solutine may constitute ‘personal information’ or ‘sensitive personal data or information’ under the SPI Rules.
“Personal Information” is defined under the SPI Rules to mean any information that relates to a natural person, which, either directly or indirectly, in combination with other information available or likely to be available to a body corporate, is capable of identifying such a person.
The SPI Rules further define “Sensitive Personal Data or Information” of a person to mean personal information about that person relating to:
- financial information such as bank accounts, credit and debit card details or other payment instrument details;
- physical, physiological and mental health condition;
- sexual orientation;
- medical records and history;
- biometric information;
- information received by body corporate under lawful contract or otherwise;
Solutine will be free to use, collect and disclose information that is freely available in the public domain without your consent.
3.1 ALL USERS NOTE:
This section applies to all users.
3.1.3 All the information provided to Solutine by a User, including Personal Information or any Sensitive Personal Data or Information, is voluntary. You understand that Solutine may use certain information of yours, which has been designated as Personal Information or ‘Sensitive Personal Data or Information’ under the SPI Rules, (a) for the purpose of providing you the Services, (b) for commercial purposes and in an aggregated or non-personally identifiable form for research, statistical analysis and business intelligence purposes, (c) for sale or transfer of such research, statistical or intelligence data in an aggregated or non-personally identifiable form to third parties and affiliates (d) for communication purpose so as to provide You a better way of booking appointments and for obtaining feedback in relation to the Life Coaches and their practice, (e) debugging customer support related issues. (f) for 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. Solutine also reserves the right to use information provided by or about the End-User for the following purposes:
- Publishing such information on the Solutine App.
- Contacting End-Users for offering new products or services.
- Contacting End-Users for taking product and Service feedback.
- Analyzing software usage patterns for improving product design and utility.
- Analyzing anonymized practice information for commercial use.
- Processing payment instructions including those through independent third-party service providers such as payment gateways, banking and financial institutions, pre-paid instrument and wallet providers for processing of payment transactions or deferral of payment facilities.
If you have voluntarily provided your Personal Information to Solutine for any of the purposes stated above, you hereby consent to such collection and use of such information by Solutine. However, Solutine shall not contact You on Your telephone number(s) for any purpose including those mentioned in this sub-sec
3.1.5 Solutine does not control or endorse the content, messages or information found in any Services and, therefore, Solutine specifically disclaims any liability with regard to the Services and any actions resulting from your participation in any Services, and you agree that you waive any claims against Solutine relating to same, and to the extent such waiver may be ineffective, you agree to release any claims against Solutine relating to the same.
3.1.6 You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information provided as part of account registration. If your personal information changes, you may correct, delete inaccuracies, or amend information by making the change on our member information page or by contacting us through firstname.lastname@example.org.
We will make good faith efforts to make requested changes in our then active 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 Solutine has reasonable grounds to suspect that the information provided by you is untrue, inaccurate, out of date or incomplete, Solutine may, at its sole discretion, discontinue the provision of the Services to you. There may be circumstances where Solutine will not correct, delete or update your Personal Data, including (a) where the Personal Data is opinion data that is kept solely for evaluative purpose; and (b) the Personal Data is in documents related to a prosecution if all proceedings relating to the prosecution have not been completed.
3.1.7 If you wish to cancel your account or request that we no longer use your information to provide you Services, contact us through email@example.com. We will retain your information for as long as your account with the Services is active and as needed to provide you the Services. 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. After a period of time, your data may be anonymized and aggregated, and then may be 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. Please note that your withdrawal of consent, or cancellation of account may result in Solutine being unable to provide you with its Services or to terminate any existing relationship Solutine may have with you.
3.1.8 If you wish to opt-out of receiving non-essential communications such as promotional and marketing-related information regarding the Services, please send us an email at firstname.lastname@example.org.
3.1.9 Solutine may require the User to pay with a credit card, wire transfer, debit card or cheque for Services for which subscription amount(s) is/are payable. Solutine will collect such User’s credit card number and/or other financial institution information such as bank account numbers and will use that information for the billing and payment processes, including but not limited to the use and disclosure of such credit card number and information to third parties as necessary to complete such billing operation. Verification of credit information, however, is accomplished solely by the User through the authentication process. User’s 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. However, Solutine provides you an option not to save your payment details. Users are advised, however, that internet technology is not full proof safe, and users should exercise discretion on using the same.
3.1.10 Solutine maintains a strict “No-Spam ” policy, which means that Solutine does not intend to sell, rent or otherwise give your email address to a third party without your consent.
3.1.11 Solutine has implemented best international market practices and security policies, rules and technical measures to protect the personal data that it has under its control from unauthorised access, improper use or disclosure, unauthorised modification and unlawful destruction or accidental loss. However, for any data loss or theft due to unauthorized access to the User’s electronic devices through which the User avails the Services, Solutine shall not be held liable for any loss whatsoever incurred by the User.
3.1.12 Solutine implements reasonable security practices and procedures and has a comprehensive documented information security programme and information security policies that contain managerial, technical, operational and physical security control measures that are commensurate with respect to the information being collected and the nature of Solutine’s business.
This section applies to all Life Coaches.
3.2.1 As part of the registration as well as the application creation and submission process that is available to Life Coaches in Solutine, certain information, including Personal Information or Sensitive Personal Data or Information is collected from the Life Coachess.
3.2.3 Life Coaches’ personally identifiable information, which they choose to provide to Solutine, is used to help the Life Coaches describe and identify themselves. This information is exclusively owned by Solutine You will be the owner of your information and you consent to Solutine collecting, using, processing and/or disclosing this information for the purposes hereinafter stated. Solutine may use such information for commercial purposes and in an aggregated or non-personally identifiable form for research, statistical analysis and business intelligence purposes, and may sell or otherwise transfer such research, statistical or intelligence data in an aggregated or non-personally identifiable form to third parties and affiliates. Solutine also reserves the right to use information provided by or about the Life Coaches for the following purposes:
- Publishing such information on the Solutine App.
- Contacting Life Coaches for offering new products or services subject to the telephone number registered with the DNC Registry.
- Contacting Life Coaches for taking product feedback.
- Analyzing software usage patterns for improving product design and utility.
- Analyzing anonymized practice information including financial, and inventory information for commercial use.
3.2.4 Solutine automatically enables the listing of Life Coaches’ information on its Solutine App for every ‘Life Coach’ added to a Service using its software. The Life Coaches information listed on Solutine App is displayed when End-Users search for Life Coaches in Solutine App, and the Life Coaches information listed on Solutine App is used by End-Users to request for Life Coaches appointments. Any personally identifiable information of the Life Coaches listed on the Solutine App is not generated by Solutine and is provided to Solutine by Life Coaches who wish to enlist themselves on the Solutine App or is collected by Solutine from the public domain. Solutine displays such information on its Solutine App on an as-is basis making no representation or warranty on the accuracy or completeness of the information. As such, we strongly encourage Life Coaches to check the accuracy and completeness of their information from time to time, and inform us immediately of any discrepancies, changes or updates to such information. Solutine will, however, take reasonable steps to ensure the accuracy and completeness of this information.3.3 END-USERS NOTE:
This section applies to all End-Users.
3.3.1 As part of the registration/application creation and submission process that is available to End-Users on this Solutine App, certain information, including Personal Information or Sensitive Personal Data or Information is collected from the End-Users.
3.3.3 If you have inadvertently submitted any such information to Solutine prior to reading the privacy statements set out herein, and you do not agree with the manner in which such information is collected, processed, stored, used or disclosed, then you may access, modify and delete such information by using options provided on the Solutine App. In addition, you can, by sending an email to privacy@Solutine.com, inquire whether Solutine is in possession of your personal data, and you may also require Solutine to delete and destroy all such information.
3.3.4 End-Users’ personally identifiable information, which they choose to provide on the Solutine App is used to help the End-Users describe/identify themselves. Other information that does not personally identify the End-Users as an individual, is collected by Solutine from End-Users (such as, patterns of utilization described above) and is exclusively owned by Solutine. Solutine may also use such information in an aggregated or non-personally identifiable form for research, statistical analysis and business intelligence purposes, and may sell or otherwise transfer such research, statistical or intelligence data in an aggregated or non-personally identifiable form to third parties and affiliates. In particular, Solutine reserves with it the right to use anonymized End-User demographics information and anonymized End-User health information for the following purposes:
- Analyzing software usage patterns for improving product design and utility.
- Analyzing such information for research and development of new technologies.
- Using analysis of such information in other commercial product offerings of Solutine.
- Sharing analysis of such information with third parties for commercial use.
3.3.5 Solutine will communicate with the End-Users through email, phone and notices posted on the Solutine App or through other means available through the service, including text and other forms of messaging. The End-Users can change their email and contact preferences at any time by logging into their “Account” at www.Solutine.com and changing the account settings.
3.3.6 At times, Solutine conducts a User survey to collect information about End-Users’ preferences. These surveys are optional and if End-Users choose to respond, their responses will be kept anonymous. Similarly, Solutine may offer contests to qualifying End-Users in which we ask for contact and demographic information such as name, email address and mailing address. The demographic information that Solutine collects in the registration process and through surveys is used to help Solutine improve its Services to meet the needs and preferences of End-Users.
3.3.7 Solutine may keep records of electronic communications and telephone calls received andmade for making appointments or other purposes for the purpose of administration of Services, customer support, research and development and for better listing of Life Coaches.
3.3.8 All Solutine employees and data processors, who have access to, and are associated with the processing of sensitive personal data or information, are obliged to respect the confidentiality of every End-Users’ Personal Information or Sensitive Personal Data and Information. Solutine has put in place procedures and technologies as per good industry practices and in accordance with the applicable laws, to maintain security of all personal data from the point of collection to the point of destruction. Any third-party data processor to which Solutine transfers Personal Data shall have to agree to comply with those procedures and policies or put in place adequate measures on their own.
3.3.10 To the extent necessary to provide End-Users with the Services, Solutine may provide their Personal Information to third party contractors who work on behalf of or with Solutine to provide End-Users with such Services, to help Solutine communicate with End-Users or to maintain the Solutine App or independent third-party service providers to process payment instructions including providing a payment deferral facility to End-Users in relation to the Services. These third-party service providers have access to information needed to process payments but may not use it for other purposes. Generally, these contractors do not have any independent right to share this information, however certain contractors who provide services on the Solutine App, including the providers of online communications services, may use and disclose the personal information collected in connection with the provision of these Services in accordance with their own privacy policies. In such circumstances, you consent to us disclosing your Personal Information to contractors, solely for the intended purposes only.
4.CONFIDENTIALITY AND SECURITY
4.1 Your Personal Information is maintained by Solutine in electronic form on its equipment, and on the equipment of its employees. Such information may also be converted to physical form from time to time. Solutine takes all necessary precautions to protect your personal information both online and off-line and implements reasonable security practices and measures including certain managerial, technical, operational and physical security control measures that are commensurate with respect to the information being collected and the nature of Solutine’s business.
4.2 No administrator at Solutine will have knowledge of your password. It is important for you to protect against unauthorized access to your password, your computer and your mobile phone. Be sure to log off from the Solutine App when finished. Solutine does not undertake any liability for any unauthorised use of your account and password. If you suspect any unauthorized use of your account, you must immediately notify Solutine by sending an email to email@example.com You shall be liable to indemnify Solutine due to any loss suffered by it due to such unauthorized use of your account and password.
4.3Solutine makes all User information accessible to its employees, agents or partners and third parties only on a need-to-know basis and binds only its employees to strict confidentiality obligations.
4.4 Part of the functionality of Solutine is assisting the Life Coaches to maintain and organise such information. Solutine may, therefore, retain and submit all such records to the appropriate authorities, or to Life Coaches who request access to such information.
4.5 Part of the functionality of the Solutine is assisting the clients to access information relating to them. Solutine may, therefore, retain and submit all such records to the relevant clients, or to their Life Coaches.
4.6 Notwithstanding the above, Solutine is not responsible for the 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. Further, Solutine shall not be responsible for any breach of security or for any actions of any third parties or events that are beyond the reasonable control of Solutine including but not limited to, acts of government, computer hacking, unauthorised access to computer data and storage device, computer crashes, breach of security and encryption, poor quality of Internet service or telephone service of the User etc.
If a User uses the Services or accesses the Solutine App after a notice of changes has been sent to such User or published on the Solutine App, such User hereby provides his/her/its consent to the changed terms.
6.CHILDREN’S AND MINOR’S PRIVACY
Solutine strongly encourages parents and guardians to supervise the online activities of their minor children and consider using parental control tools available from online services and software manufacturers to help provide a child-friendly online environment. These tools also can prevent minors from disclosing their name, address, and other personally identifiable information online without parental permission. Solutine respects the privacy of minors who may inadvertently use the internet or the mobile application.
7.CONSENT TO THIS POLICY