BLOOM APPLICATION PRIVACY POLICY

Effective Date: September 9, 2024

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Welcome to Bloom. This Application is managed and operated by AMVHT HEALTHCARE PRIVATE LIMITED (hereinafter referred to as “Company”) having its registered office at A403, Giriraj flat, Bhairavnath road, Sardar Patel School, Maninagar, Ahmedabad, Ahmedabad City, Gujarat, India, 380008. Your privacy is important to AMVHT HEALTHCARE PRIVATE LIMITED. This privacy policy (“Privacy Policy”) is in the context of and to govern the access and usage of the Bloom Application.

1. GENERAL

1.1. This Privacy Policy describes and determines how the Bloom Application (hereinafter referred to as “App” or “We/Us/Our”) handles and/ or deals with your (referred to as “You/Your” or “User”) personal and usage information in accordance with the applicable laws of India.

1.2. This document is an electronic record and is governed by the Information and Technology Act, 2000, and the rules made thereunder, along with the Digital Personal Data Protection Act, 2023 as may be applicable, including the amended provisions pertaining to electronic records in various Indian statutes. The Privacy Policy is generated by a computer system and does not require any physical or digital signatures.

1.3. The provisions of the Privacy Policy shall be applicable to the Users of the Bloom Application.

1.4. The Privacy Policy sets out the type of information collected from the Users, including the nature of the Sensitive Personal Data or Information, the purpose, means and modes of usage of such information, and how and to whom We shall disclose or transfer such information. You may at any time withdraw Your consent for collection and use of Your information, including Personal Information or Data and Sensitive Personal Data or Information. However, please note that if You withdraw Your consent, We may no longer be able to provide You with the corresponding Service for which You have withdrawn Your consent.

1.5. You are requested to familiarize yourself with Our Privacy Policy. If You do not agree with any provisions of the Terms & Conditions or this Privacy Policy, We advise You not to use or access the App.

1.6. We shall comply with the Users requests regarding access, correction, and/or deletion of the Personal Information or Data and Sensitive Personal Information or Data it stores in accordance with applicable law. You can write to Us at support@mybloom.in to assist You with Your request to correct and/or delete Your Personal Information or Data and Sensitive Personal Information or Data unless retention of the same is necessary for the specified purpose or for compliance with any law for the time being in force.

1.7. This Privacy Policy additionally governs Our data collection and storing practices in connection with “Bloom Saathi,” a feature in Bloom Application that enables Users to store and share their health data with doctors. The data collected under this Privacy Policy is hosted on servers located in India.

2. TYPE OF INFORMATION COLLECTED

2.1. When You access the App, You may provide, or We may collect information that may specifically identify You or any other individual. We may collect a variety of information from You, including but not limited to:

2.1.1. Personal Information: Your name, birth date, address, gender, mailing address, phone number, full face photograph, email address, and contact preferences, including any other usage and interaction details with Us or Our affiliates, any government number, including Aadhar, Voter’s Identity, Permanent Account Number (‘PAN’), Passport, Ration Card, and Below Poverty Line (‘BPL’) card. We may collect such information, which, when combined with other pieces of information available with Us, could reasonably allow You to be identified (“Personal Information or Data”).

2.1.2. Sensitive Personal Data or Information: We may also collect sensitive personal data or information consisting of information relating to:

However, any information that is freely available or accessible in the public domain or furnished under the Right to Information Act, 2005, or any other law for the time being in force shall not be regarded as Sensitive Personal Data or Information.

2.1.3. Health Information: This information includes health information We receive from You or, on Your behalf, such as information or records relating to Your medical or health history, health status, laboratory testing results, alternative medication, diagnostic results, surgical history, emergency events, allergies and/or other health-related information and any other information inferred therefrom.

2.1.4. Technical Information: Our servers automatically collect information when You access or use Our App and record it in log files. This log data may include the Internet Protocol (IP) address, the address of the web page visited before using the App, browser type and settings, the date and time the App was used, information about Your devices, language preferences, cookie data, device identifiers, and any technical and statistical data in relation to any events organised by Us. However, no attempt is being made to link these with the identity of individuals visiting the App unless an unlawful attempt to violate/infringe the App and Privacy Policy or provisions of the Information Technology Act, 2000, or under any law for the time being in force has been detected.

2.1.5. Transaction information: This includes information regarding the date of the transaction, total amount, transaction history and preferences, and related details. 2.1.6. Data provided by Third-Parties: With Your explicit consent on Your device, We may access (read) or/and write (share) data related to Your activity with/from personal health medical devices as well as health applications like Apple Watch, Google Fit, and others. In some of the applications, You may decide to allow Us to read (receive) the following information from the Health applications, including but not limited to the step count, distance travelled, weight, dietary energy consumption, and any other data You select on the consent screen, as well as any additional Personal Information or Data stored within these apps. The specific data types covered by health applications will be presented to You by Apple or Google through their native pop-up screens, which are outside Our control.

2.1.7. Any other information that is collected or generated in the course of availing the Services and any other detail relating to the above as voluntarily provided to Us such as by You, for providing value added Services.

2.2. Personal Information or Data may also be collected incidentally by the App in the following instances, where the User:

2.2.1. Completes an online suggestions, complaints, or grievance redressal form by registering on the Grievance Portal at www.mybloom.in or emailing Us at grievance@mybloom.in.

2.2.2. The App may request access to, or permission for certain features from the mobile device of the User, including the camera, Bluetooth, location access, contact list, phone audio, and storage. If the User wishes to change the access or permissions, they may do so in the device's settings.

2.2.3. The camera feature has been added for the specific purpose of scanning a QR code, taking Your full-face photograph, capturing images of health records, documents, and other relevant items, etc., to confirm all details and share health-related, consent-based information/data in one click of the User. The camera shall not access any Personal Information or Data of the User.

2.2.4. The App uses the mobile devices’ internal and external storage to access files/documents. The App also uses the cache memory of the mobile device for the purpose of enabling the User to access medical and health records in the form of PDFs or any other format, which can also be downloaded/ uploaded by the User on mobile device.

2.2.5. The App may request that the User receive push notifications regarding their account or certain features of the App. If the User wishes to opt-out from receiving these types of communications, the User may turn them off in their device's settings.

3. USE OF INFORMATION COLLECTED

We use the information We collect in a variety of ways in order to provide the Services on the App and to operate Our business, including the following:

3.1. To create and manage User’s account;

3.2. For displaying the records to the User with consent;

3.3. To keep a record of registered Users;

3.4. To allow Us to customize Services based on Users’ preferences;

3.5. To contact Users to provide news or information regarding upcoming events;

3.6. For the purpose of data analysis, trend tracking, algorithm development, and database creation to support rating systems and recommendation engines;

3.7. To operate and improve the website and the App in order to foster a positive User experience and to improve Our business as a whole;

3.8. To provide You with marketing communications and advertising that the App believes may be of interest to You and contact Users for taking service feedback, surveys, etc;

3.9. For tasks such as generating visual representations of various health-related readings and assisting Users in sharing data with their healthcare providers;

3.10. To comply with applicable law;

3.11. For contacting Users for updates and resolution of queries;

3.12. To investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of Our Terms and Conditions, or as otherwise required by law;

3.13. To respond to any queries that You may have and to communicate information to You, including notifications of any promotions or alerts, any changes/updates to the App, changes to Our Terms & Conditions and Policies, and/or other administrative information, or the introduction of any future fees or charges that We may collect at the time provision of Our services to You;

3.14. To contact You by way of SMS, WhatsApp, email, and phone calls, from time to time for marketing purposes and /or to record Your valuable feedback on Our Services, as they currently stand, and/or any potential Services that may be offered in the future. For example, We may send You a notification to let You know about upcoming changes or improvements to Our Services or for any promotional event, invites, etc., and if You contact Us, We shall keep a record of Your request in order to help solve any issues You might be facing;

3.15. To use data for analytics to understand how Our services are used;

3.16. To share Your Personal Information or Data with entities and engage such entities to provide Services on Our behalf, such as software services, fulfilling customer requests, and communicating with You in relation to the App.

4. DISCLOSURE OF INFORMATION COLLECTED:

4.1. The Company does not share, sell, or lend out Your Personal Information or Data, which includes genetic information for underwriting and/or psychotherapy notes about You with other people (save with Your consent) or non-affiliated companies except to provide Services under the Terms and Conditions or this Privacy Policy or otherwise for the following uses:

4.1.1. To submit under a legal obligation of law of land in response to court orders, legal process, or to perform Our legal rights or defend against legal claims;

4.1.2. In the interest of public health or public intent;

4.1.3. To transfer/disclose Personal Information or Data about You to trusted partners, may or may not be for gain, to promote certain services for commercial purposes, without any prior notice to You;

4.1.4. To protect against harm to the rights, property, or safety of the application, other Users, or the public as required or permitted by law;

4.1.5. To detect, prevent, or otherwise address fraud, security, or technical issues, as well as investigate potential violations;

4.1.6. In the event of significant business changes, not limited to a merger, acquisition, or sale of assets, bankruptcy by giving a prior notice to You of any such transfer;

4.1.7. To effectively respond to medical emergencies that pose a threat to Your life, this limited data sharing is solely intended to facilitate prompt and appropriate medical intervention in critical situations to prioritize Your safety and well-being;

4.1.8. To safeguard Our company from loss of liability, such as corporate espionage, safeguard Our confidential trade secrets and intellectual property, and maintain the security of classified information.

4.2. Further, You agree that We may share Your Personal Information or Data for the following categories of activities from time to time:

4.2.1. Advertisements: When You enter Personal Information or Data on any form of an advertiser, such information is simultaneously collected by the App and the advertiser. The Personal Information or Data is used by the App in accordance with the terms of this Privacy Policy and is used by the advertiser as per the advertiser's prevalent privacy policies. Because We do not control the privacy practices of these advertisers, You should evaluate their practices before deciding to provide the said information. We may also aggregate (gather up data across all Accounts) Personal Information or Data and disclose such information in a non- personally identifiable manner to advertisers and other third parties for other marketing and promotional purposes.

4.2.2. Other Corporate Entities: The Company shares much of the data, including Personal Information or Data about You, with its parent, affiliates, subsidiaries, and joint ventures, if any, that are committed to serving Your online needs and related Services throughout the world. To the extent that these entities have access to Your Personal Information or Data, they will treat it at least as protectively as they treat information they obtain from their other users. The Company's parent, affiliates, subsidiaries, and joint ventures, if any, follow privacy practices no less protective of all Users than Our practices described in this document, to the extent allowed by applicable law. The Company, its parent, affiliates, subsidiaries, its joint ventures, or any combination of such will share some or all of Your Personal Information or Data with another business entity should We plan to merge with or be acquired by that business entity.

4.3. The App strives hard to keep its records updated and accurate with Your latest information. You shall be responsible for ensuring that the Personal Information or Data that You provide from time to time is and shall be correct, current, and updated, and You have all the rights, permissions, and consents to provide such Personal Information or Data.

4.4. Notwithstanding the above, the App is not responsible for the confidentiality, security, or distribution of Your Personal Information or Data by Our partners and third parties outside the scope of Our agreement with such partners and third parties. Further, the App 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 the App, including acts of government, computer hacking, unauthorised access to computer data and storage device, computer crashes, breach of security and encryption, and poor quality of Internet service or telephone service of the User, etc.

SECURITY

5.1. The security of Your Personal Information is important to Us. We have implemented security policies, rules, and technical measures, as required under applicable law, including firewalls, transport layer security, and other physical and electronic security measures to protect the Personal Information or Data that the App has under its control from unauthorized access, improper use or disclosure, unauthorized modification, and unlawful destruction or accidental loss. When You submit Your information on the App, Your information is protected through Our security systems. We maintain electronic, physical, and procedural safeguards and implement reasonable security practices and measures, including certain managerial, technical, operational, and physical security control measures in connection with the collection, storage, and disclosure of Personal Information or Data (including Sensitive Personal Data or Information). Our security procedures may warrant that We may occasionally request proof of identity before We disclose personal information to You.

5.2. Your Personal Information, as well as Your Sensitive Personal Information or Data (from Your use of “Bloom Saathi”), is maintained by the App in electronic form on its equipment;

5.3. The App adopts the principles in relation to security standards and accountability. This includes:

5.3.1. data management protocols to be followed by data processors;

5.3.2. data protection impact assessments that must be carried out before undertaking any processing involving new technologies or any other processing that carries a significant risk of harm to Users;

5.3.3. maintenance of accurate and up-to-date records to document the important operations in the data lifecycle, including collection, transfers, and erasure of Personal Information or Data;

5.3.4. maintenance of a strict audit trail of all processing activities which have access to any Personal Information or Data at all times;

5.3.5. maintenance of a record of how such Personal Information or Data is processed by the App in a manner that enables the audit and review of any use of such Personal Information or Data.

6. PROTECTION OF MINORS' DATA

We are committed to safeguarding the privacy of minors (individuals under the age of 18 years). We collect, store, and process minor’s Personal Information or Data, as well as Sensitive Personal Information or Data, only with verifiable consent from a parent or legal guardian by providing valid ID proof along with the minor's identification for consent verification, as mandated by the applicable laws. Our data practices for minors adhere to strict safety standards, including data minimization and enhanced security. Parents and/or legal guardians have full rights to review, modify, or request deletion of the minor’s data at any time through Our App.

7. RIGHT TO NOMINATE

The Users shall have the right to nominate any other individual, who shall, in the event of death or incapacity of the User, exercise the rights of the User in accordance with the provisions of this Privacy Policy, the Terms and Conditions, and the applicable laws.

8. ACCOUNTABILITY

We are accountable for complying with measures, which give effect to the privacy principles while processing any Personal Information or Data by the App or on its behalf. In addition, Users should at all times have control and decision-making power over the manner in which Personal Information or Data associated with them is collected and further processed.

9. TRANSPARENCY

The App will notify the User, from time to time, of the important operations in the processing of any Personal Information or Data related to the User with Your consent. The information provided by the App will be in an intelligible form, using clear and plain language. All necessary steps shall be taken to implement practices, procedures, policies, and systems in a manner proportional to the scale, scope, and sensitivity of the Personal Information or Data to be collected in order to ensure compliance with the privacy principles.

10. CHOICE & CONSENT

The knowledge and consent of a User is required for the collection, use, or disclosure of Personal Information or Data. The App shall provide an option for the User to opt in/opt out of the App at any time or choose not to provide the information sought at any given time and/or withdraw consent. You have the right to access, review, modify, correct, or withdraw consent in relation to Your Personal Information or Data as well as Sensitive Personal Information or Data

11. COOKIES

The App uses temporary cookies to store certain data. We do not store Personal Information or Data in the cookies. Information collected by Us, by any means whatsoever that does not personally identify the User as an individual, is exclusively owned by Us and may be used by Us and third-party service providers for technical administration of the App, User administration, research, development, and other purposes. If You turn cookies off, some of the features that makes the App experience more efficient may not function properly.

12. OPT-OUT POLICY

12.1. The third-party service providers, with whom We may share information provided by You, are not permitted to market their own services, send promotional e-mails, or engage in promotional communication with You. We provide You with the opportunity to opt out of receiving non-essential, promotional, or marketing-related communication from itself or its partners.

12.2. If You wish to remove Your contact information from all Our mailing lists and newsletters, You can click on the "unsubscribe" link or follow the instructions in each e-mail message. Alternatively, You can contact Us at support@mybloom.in. We reserve the right to limit membership based on the availability of Personal Information or Data. All Users will be notified by email prior to any actions taken.

12.3. If You wish to unsubscribe or request that We no longer use Your information to provide You Services, contact Us through support. We will retain Your information for as long as Your account with the Services is active and as needed to provide You the Services, or You have chosen not to permanently delete the data. 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.

13. MODIFICATION

We reserve the right to amend this Privacy Policy at any time. The Privacy Policy, as and when modified, shall be updated on the App. We encourage You to review this Privacy Policy whenever You visit Our App to understand how Your Personal Information or Data is used.

14. AGE LIMITATIONS

To the extent prohibited by applicable law, We do not allow the use of the App by anyone younger than 18 years old. If You learn that someone younger than 18 has unlawfully provided Us with Personal information or Data, please contact Us, and We will take steps to delete such information.

15. SEVERABILITY

Whenever possible, each section of this Privacy Policy shall be interpreted in a manner so as to be valid under applicable law. However, in the event any provision is held to be prohibited or invalid, such provision shall be ineffective only to the extent of such prohibition or invalidity, without invalidating the remainder of such provision or other remaining provisions of this Privacy Policy

16. GRIEVANCE OFFICER

4.2. In accordance with the Information Technology Act, 2000, and rules made thereunder, as well as the provisions of the Digital Personal Data Protection Act, 2023, the name and contact details of the Grievance Officer who can be contacted with respect to any complaints or concerns, including those pertaining to breach of Our Terms & Conditions and other polices or questions are published as under:

Grievance Officer’s Name: Ajay Narula

Email address: grievance@mybloom.in

4.3. The details of the Grievance Officer may be changed by Us from time to time by updating this Privacy Policy.

17. GOVERNING LAW

The terms of this Privacy Policy shall be governed and construed in accordance with the laws of India. Any dispute regarding or arising out of this Privacy Policy shall be subject to the exclusive jurisdiction of the courts of Mumbai, India.

THE PRIVACY POLICY & TERMS AND CONDITIONS HEREINABOVE ARE ASSUMED TO BE READ, UNDERSTOOD AND AGREED BY YOU.