Sucheta Swastham Private Limited Privacy Notice

We, Sucheta Swastham Private Limited (“Swastham”, “Company”, “we”, “us”, “our”) are the owners of the website swastham.life (“Website”) and the mobile and web-based application available at swastham.life (“Application”). The Website offers a wide range of fitness and wellness courses and programs to support your health and wellness goals. Individuals can also schedule personalized one one-on-one sessions with qualified professionals to receive tailored guidance and support on their fitness and wellness journey. (the “Services”). The Website and the Application are collectively referred to as “Platform”.

We respect data privacy rights and are committed to protecting Personal Data collected on the Platform. This Privacy Notice (“Privacy Notice”) sets forth how we collect, use and protect the personal data collected on the Platforms.

PLEASE READ THIS PRIVACY NOTICE CAREFULLY. BY CLICKING THE CONSENT CHECKBOX AND PROVIDING US YOUR CONSENT, YOU CONSENT TO OUR USE OF YOUR PERSONAL DATA IN ACCORDANCE WITH THE TERMS OF THIS PRIVACY NOTICE. IF YOU DO NOT AGREE TO THE TERMS OF THIS PRIVACY NOTICE, YOU MAY WITHDRAW YOUR CONSENT OR ALTERNATIVELY CHOOSE NOT TO PROVIDE YOUR PERSONAL DATA ON THE PLATFORM. SUCH AN INTIMATION TO WITHDRAW YOUR CONSENT CAN BE PROVIDED BY EMAIL TO privacy@swastham.life

IF YOU ARE ACCESSING THE PLATFORM ON BEHALF OF A THIRD PARTY, YOU REPRESENT THAT YOU HAVE THE AUTHORITY TO BIND SUCH THIRD-PARTY TO THE TERMS AND CONDITIONS OF THIS PRIVACY NOTICE AND, IN SUCH AN EVENT YOUR USE OF THE PLATFORM SHALL REFER TO USE BY SUCH THIRD PARTY. IF YOU DO NOT HAVE SUCH AN AUTHORITY (TO PROVIDE ANY PERSONAL DATA OF A THIRD PARTY) OR DO NOT AGREE TO THE TERMS OF THIS PRIVACY NOTICE, THEN YOU SHOULD REFRAIN FROM USING THE PLATFORMS.

This Privacy Notice is an electronic record in the form of an electronic contract being compliant and construed in accordance with data protection laws of India.

1. DEFINITIONS
   1. “User(s)”, “you”, “yours” shall mean individuals that use/access/s the Website and/or avails/subscribes to our Services through the Application.
   2. Customer” shall mean an entity, organizer, individual which avails our Services.
   3. “Personal Data” shall mean and include any data about an individual who is identifiable by or in relation to such data. This may include but not be limited to, your name, email address, contact number, company name, designation, postal address​, location​ etc.
   4. “Controller” or “Data Fiduciary” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data;
   5. “Processor” means a natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller.
2. WHAT PERSONAL DATA IS COLLECTED BY US? 

   For purposes of this Privacy Notice, we may collect your Personal Data in the following cases:

   1. Personal Data collected through website:

      You may provide Personal Data when you visit our Website or contact us through the ‘Contact us’ page on our Website. We may collect your Personal Data, including but not limited to your full name, email address, contact information, your query and any other information that you provide us.

   2. Account creation:

      When you create an account on our Platform in order to avail the Services, you may provide us your Personal Data, including but not limited to, full name, email address, mobile number (what’s App) profession, language preference, age, photo and any other information you may provide.

   3. Online Identifiers and Log Data:

      When you use or access our Platform, we may collect information about your operating device such as software, IP address, domain names, access times, operating system, browser type, web log data, and referring website addresses.

   4. Career Opportunities:

      If you apply for an employment/consultant position, we may collect your information including but not limited to first name, last name email address, CV, contact information, position you are applying for, information obtained during interviews and any other information you choose to provide.

   5. Social media platforms:

      We may receive your Personal Data when you access our social media pages or interact with us on social media platforms including Facebook, X (Twitter), YouTube and/or Instagram. Such Personal Data may include your social media handles, name, any Personal Data you share via direct messages, details about your profile, or any other Personal Data that you may share with us.

   6. Communications:

      We may collect information about you when you when you use the Website, contact us for enquiry or support or subscribe to our newsletters, you may provide us your Personal Data, including but not limited to your name, email address, contact number and company name and any other information you provide to us.

   When the Company receives information from its Customer, the Company acts as a Processor and shall process data as per the instructions received by the Data Controller. If you have any questions related to the handling of your Personal Data by the Company or to exercise your rights, you can contact us at privacy@swastham.life

   For Personal Data collected on behalf of the Customer please refer to Clause 3 of this Privacy Notice.

3. WHAT PERSONAL DATA DO WE PROCCESS ON BEHALF OF THE CUSTOMER?  

   This section concerns the Personal Data of the individuals collected by the Customer, and such collection may be facilitated by us.

   1. The Company as a Data Processor:

      The Customer sets the purpose and means of processing of such Personal Data. We process such Personal Data only on behalf of and on the instructions of the Customer and for the purpose of rendering our Services to the Customer.

   2. Customer Privacy Notice:

      If you are the user of the Services and your Personal Data was shared with us by the Customer, the privacy notice of the Customer, on whose behalf we collect and process the Personal Data, will apply. This means that any enquiry, request, objection or complaint that you as a user may have in connection with the collection and/or processing of Personal Data that forms part of your usage of Services should be addressed to and resolved by the Customer.

   3. Personal Data:

      Depending on the nature of Services and Customer requirements the Company processes Personal Data on behalf of Customer/s.

      The Customer has complete control over the Personal Data and the Company processes the Personal Data on the Customer’s behalf.

      Further, the Personal Data collected on behalf of the Customer may differ based on the specific requirements, the Company will remain the data processor, and the Customer will be responsible for providing adequate privacy notices.

   4. Customer Responsibility:

      The Customer represents that it has acquired all necessary consents and/or relies on other appropriate legal basis for the processing of Personal Data of end-users. The customer confirms that end-users have been informed that their Personal Data is transferred to the Company as a processor and other third parties used by the Company for the provision of Services.

      We will process the Personal Data for as long as we provide Services to the Customer and the Customer maintains active accounts.

4. COOKIES

   We use cookies and/or similar in-house and third-party tracking tools to track user traffic patterns. Tracking tools are also used are beacons, tags and scripts to collect and track information and to improve and analyse our Platform. You may choose to disable cookies through your browser settings. We also provide a cookie consent banner detailing the options and cookies on our Platform.

   We may use the Personal Data received through cookies to make your interaction with us faster and more secure.

   They may be used for the following purposes:

   1. Preferences Cookies allow the website to remember information that changes the way the site behaves or looks, such as your preferred language or the region you are in. Remembering your preferences enables us to personalize and display advertisements and other content for you.
   2. Security/Optimization: Cookies allow us to maintain security by authenticating users, preventing fraudulent use of login credentials and protecting user data from unauthorized parties. We may use certain types of cookies to allow us to block many types of attacks, such as attempts to steal content from the forms present on the Website.
   3. Processing Cookies enable the website to work efficiently. Basis such cookies, we are able to deliver services that a Website visitor expects, like navigating around web pages or accessing secure areas of the Website.
   4. Advertising We use cookies to make advertising more engaging to our Users. Some common applications of cookies are made to select advertising based on what’s relevant to you, to improve reporting on campaign performance and to avoid showing ads you would have already seen. Cookies capture information about how you interact with the Website, which includes the pages that you visit most.
   5. Communication We may use information collected via cookies to communicate with you, send newsletters, seek your opinion/feedback; provide you with services and promotional materials.
   6. Analytics and Research: We may use cookies to better understand how people use our products/services so that we can improve them.
5. ACCURACY OF DATA

   The User undertakes that he shall be solely responsible for the accuracy, correctness, or truthfulness of the Personal Data shared with us whether of its own or any third party. In the event the User is sharing any Personal Data on behalf of a third person, the User represents and warrants that he has the necessary authority to share such Personal Data with the Company, obtained a written consent from such third party and the Company shall not be responsible for verifying the same. The User understands and acknowledges that such Personal Data shall be subject to the terms and conditions of this Privacy Notice.

6. HOW WE USE YOUR PERSONAL DATA

   We use the Personal Data for the following purposes:

   1. to inform you about our Services and to respond to your requests;
   2. to provide you with a better experience when you access our Website and to improve the Services;
   3. to maintain and manage our relationship with Website visitors, Customers, Users, prospective customers and others effectively;
   4. Provide access to our Services we offer on our Platform including webinars, yoga sessions, wellness sessions, and users support;
   5. for marketing and advertising purposes, such as developing and providing promotional and advertising materials that may be relevant, valuable or otherwise of interest to you;
   6. to communicate with prospective customers, Users and Customers, including sending necessary service updates, promotional materials, and important announcements;
   7. to develop and provide relevant features, improve the performance and functionality of our Platform, and enhance the overall user experience;
   8. collect feedback, conduct surveys, and gain insights to enhance user satisfaction and refine our offerings;
   9. to maintain accurate and up-to-date internal records for organizational purposes;
   10. to comply with applicable legal, regulatory, and statutory obligations;
   11. to detect, prevent, and address fraudulent activities, unauthorized access, and other security threats;
7. DISCLOSURES

   We will not sell, distribute or lease your Personal Data to third parties without your prior consent. Keeping this in mind, we may disclose your Personal Data in the following cases:

   1. Affiliates: We may provide your Personal Data to our affiliates to enable them to improve our services, provide feedback and respond to their queries.
   2. Service Providers: We may share your Personal Data with the service providers who work with us in connection with operating the Platform and/ or providing the service. All such service providers are subject to stringent confidentiality restrictions consistent with this Privacy Notice.
   3. Merger or Acquisition: We may transfer your Personal Data if we are acquired by another entity, or if we merge with another company or transfer a part of our business, including the Platform, to a third party. Any such third party or resultant entity that receives your Personal Data shall have the right to continue to use your Personal Data in line with the purposes set out herein. In the event of such a sale or transfer, we may notify you.
   4. Legal and Regulatory Authorities: We may disclose your Personal Data in order to comply with our legal obligations/ court orders/ requests by Govt. authorities.
8. DATA RETENTION

   We will retain a User’s Personal Data for as long as it is required to be retained for the purpose of provision of the Services on our Platform. We may retain and use User’s Personal Data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We only store your Personal Data for as long as necessary and we take measures to render the information irrecoverable once deleted.

9. HOW WE SECURE YOUR PERSONAL DATA

   We have implemented reasonable administrative, technical and physical security measures to protect your Personal Data against unauthorized access, destruction or alteration. Although we provide appropriate firewalls and protections, we cannot guarantee the security of Personal Data transmitted as these systems are not hack proof. Data pilferage due to unauthorized hacking, virus attacks, technical issues is possible, and we will take necessary measures to mitigate such events.

10. LINKS TO OTHER WEBSITES

    Our Platform may contain links to other websites/platforms/applications of your interest. Please note that we do not have any control over such other websites/platforms/applications, and Users will be accessing these websites/ platforms/applications at their own risk. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such websites/platforms/applications and those are not governed by this Privacy Notice. Users should exercise caution and look at the privacy policy/ notice applicable to such websites/platforms/applications.

11. YOUR RIGHTS

    You have the right to access Personal Data in our possession, right to have us rectify or modify any such Personal Data, right to have us erase/delete your Personal Data, right to restrict us from processing such Personal Data, right to object to our use of Personal Data, withdraw consent at any time where we are relying on consent to process Personal Data. Depending on the nature of the request, we may ask you to complete a Personal Data request form or seek certain details to verify the request. All requests for Personal Data will be handled within a reasonable period of time. If you would like to exercise ANY of these rights, please contact privacy@swastham.life

12. CHILDREN’S USE

    Our Platform and Services are available for children. We define “children” as anyone under 18 years old. If we learn we have collected or received personal information from a child without verification of parental consent, we will delete the information. If you believe we might have any information from or about a child, please contact at privacy@swastham.life

13. CHOICE AND OPT-OUT

    We may send you communications including but not limited to (a) notices about your use of our Website and/or Services, including those concerning violations of use, (b) updates, (c) promotional information regarding our Services, and (d) newsletters. You may opt out of receiving promotional emails and newsletters from us by following the unsubscribe instructions provided in those emails. Alternatively, you can opt-out, at any time, by emailing privacy@swastham.life

14. GOVERNING LAWS

    This Privacy Notice shall in all respects be governed by and construed and enforced in accordance with the laws of India and the courts in Pune, Maharashtra shall have an exclusive jurisdiction to adjudicate any subject matter under this Privacy Notice.

15. CHANGES TO THIS POLICY

    Please revisit this page periodically to stay aware of any changes to this Privacy Notice, which we may update from time to time. If we modify this Privacy Notice, we will make it available through the Website and indicate the date of the latest revision. If such modifications materially alter your rights or obligations hereunder, we will make reasonable efforts to notify you of the change through our Platform.

16. CONTACT US

    If you have any questions or concerns or grievances regarding this Privacy Notice or wish to withdraw your consent in relation to the processing of your Personal Data, you can reach out to our appointed grievance redressal officer, Rahul Deshpande and via email at rahul@swastham.life.

Company Address: Flt 306, sno. 39/4, Iris
Apartment, Opposite,
Deccan Gymkhana, Pune,
Pune City, Maharashtra,
India, 411004