1. Definitions

• “Affiliates” in relation to Eldrly shall mean any Person that controls, is controlled by or is in common control of the ownership of Knowbility Media OPC Private Limited. For purposes of this definition, “Control” means the power to direct the management or policies of a Person, whether through the ownership of such Person or through contractual arrangements or otherwise;
• “Eldrly” refers to us and our company ‘Knowbility Media OPC Private Limited’, having its registered office at S-5 Sachdeva Arcade, Pocket-B LSC, Mayur Vihar Phase-2, Delhi 110091.  Eldrly can be addressed as Our and Us in this Privacy Policy;
• “Data” shall have the same meaning as assigned to it under Section 2 (1) (o) of the Information Technology Act, 2000;
• “Person” means and includes any natural person and legally recognised entity;
• “Personal Information” (PI) shall mean information related to any person, which, either directly or indirectly, in combination with other information available or likely to be available with a body corporate, is capable of identifying such person and shall include the following:

Relevant financial information, as and when required.

Information related to the documents as provided by the User/next of kin to Eldrly; and

IP Address;

Personal description and photo of the User;

Geo-location of the User;

User ID of the User;

Name, age, address, email ID, phone number of the next of kin;

Name, age, address, email ID, phone number of the User;

• “Sensitive Personal Information” of a person means such personal information which consists of information relating to:

Biometric information;

Medical records and history;

Sexual orientation;

Physical, physiological and mental health conditions;

Financial information such as Bank account or credit card or debit card or other payment instrument details;

Password

• “Third Party” shall mean and include any Person apart from the User who is agreeing to this Privacy Policy;
• “User” means and refers to the registered and unregistered users and their next of kin and any other third party visiting the website and availing of the services being offered by Eldrly. Words like ‘You and Your/s’ shall have reference to the User of the website;
• “Platform” refers to our website having the link ‘www.Eldrly.com’ or Eldrly Customer and Respondent Mobile Apps. This Website and Mobile App are owned and operated by Eldrly.

2. What do we do?

We provide holistic senior care solutions through our community, companionship, concierge, assistance and healthcare services.

3. Acceptance

• By accessing, using and/or registering on our platform, you explicitly accept, without limitation or qualification, the collection, use and transfer of the Information in the manner described in this Privacy Policy. If you do not accept the Privacy Policy stated herein or disagree with the way Eldrly collects and processes Information collected on its platform, please do not use our platform. Eldrly also sends promotional and administrative emails, notifications and pop-ups to its users to make them aware of the latest updates, offers and health-related blogs.
• You agree that we have an unconditional right to amend, modify and change the Privacy Policy at any time. The amended, modified, or changed Privacy Policy shall be effective from the date of its publication on our Website, with or without any specific notification regarding modification, amendment or change on our Website. You agree that your continued usage of our Website will be considered as acceptance of the modified, amended, or changed Privacy Policy.
• This Privacy Policy covers only such Data as is collected by Eldrly and does not include and is neither applicable on Third-Party Data collection, storage, retention or transferred. You are requested to read the Privacy Policy of the respective Third Party separately.

Information –

This Policy seeks to cover the personal information of the Users provided to Eldrly and also any other information collected by the Eldrly server from the Users browser. The (“Information”), i.e. any of the following:

• Personal/private information of the Users
• Sensitive personal data or information

Collection and Use:

• We collect information from you through your use of our Website.
• We operate only within the geographical territory of India and do not conduct operations in other countries and hence do not transfer your Information to other countries, however, the service provider of the servers may transfer the server content to other countries for maintenance of backup or such other general practices. You agree to such cross-border transfers of Information and the risk associated with it.
• From time to time, we may use the information for new and unanticipated uses not previously disclosed in our Privacy Policy. If our information practices change regarding information previously collected, we shall make reasonable efforts to provide notice and obtain the consent of any such uses as may be required by law
• Our Platform users can voluntarily choose to electronically forward a link, page, or document to someone else. To do so, the user must provide his or her email address, as well as the email address of the recipient. The user’s email address is used only in the case of transmission errors and, of course, to let the recipient know who sent the email. The information is not used for any other purpose
• We summarize information about your usage and combine it with that of others to convert it into statistical information which is then utilized by Eldrly, its associates, business partners and service partners independently or in combination with Third-party data to understand your requirements and to enhance your experience in using our Platform. All the Data collected by Eldrly ensures the de-identification of any information that may directly reveal the identity of an individual.
• We use the information to periodically send promotional emails about new products, special offers or other information which we think may improve your experience with our Platform.
• We also use your Information in fraud prevention efforts.
• We use the Information to contact you via email, telephone, facsimile or mail, or, where requested, by text message, to deliver certain services or information you have requested.
• We use the Information for internal record keeping, data analysis (without revealing your identity), improving our services, providing you great services like offers, improving user experience and user interface, verifying your identity and authority to use our Services, and otherwise enable you to use our Platform and our Services, to process billing and payment, including sharing with third-party payment gateways in connection with Platform and/or our and Services, to resolve disputes, to protect ourselves and other users of our Platform and Services, and to enforce our Terms of Service;
• We also collect information such as the name of the domain and host from which you access the internet; the Internet Protocol (IP) address of the computer you are using; the date and time of your access.

Storage, Retention and Transfer

• Your Information is stored on the servers by Eldrly. Eldrly shall endeavour to maintain adequate security to ensure that the data is stored in a reasonably encrypted, secured form and only authorised persons are allowed to access the data. Eldrly shall endeavour to avoid unauthorized access, loss, misuse, disclosure, alteration, and destruction of Data and Information.
• We shall be bound to share the Information with any Third Party by an order under the law for the time being in force.
• We do not share, sell, trade or rent your Information to Third Parties for unknown reasons. To the best of our ability, we retain complete anonymity in all analytics.
• We collect Information from you along with your username and password registered by you on our Platform. Some portions, but not all, may be shared by us with Third Parties under the terms and conditions of our contractual obligation towards them.
• Information not treated as Personal or Sensitive Information
• The information shared by the Users and/or Service Providers in feedback, surveys and chatrooms is not Personal or Sensitive Information and hence is not treated by Eldrly as Information. Such information is non-confidential and is treated as publicly available information by Eldrly. Eldrly to the best of its ability takes care that Information is transferred in the encrypted, secured form and is accessible by authorised persons only.
• Request for correction, updating, or deletion of Information: If you wish to correct, update, or delete Information, you may do so by accessing your account on the Platform.
• The Information is retained by Eldrly for till the time the user account is active, post which Eldrly ensures proper destruction of the information in a de-identified manner.
• Deletion of account or registration with us does not guarantee automatic destruction of the Information.
• Eldrly doesn’t intend to infringe the privacy of any person or entity and hereby declares that Information collected by it shall remain the property of the truthful owner, possessor, or holder of the Information and that Eldrly shall not use Information for any purpose, other than the one mentioned in clause 4.1, without providing an intimation in this regard.

Collection and Storage of Information from Social Networking sites

• We provide a facility for logging into our Website through your Gmail or other social media accounts. We ask you to grant us permission to access and collect your basic information from the social media account (this includes your name, profile picture, gender, networks, user IDs, list of friends, date of birth, email address, and any other information you have set to public on your account). If you allow us to have access to this information, then we will have access to this information even if you have chosen not to make that information public. We store the information that we receive from social media accounts with other information that we collect from you or receive about you.
• Google or any other social media account manager controls the information it collects from you. For information about how Google or other social media account may use and disclose your information, including any information you make public, please consult Google’s or other social media accounts’ privacy policy. We have no control over how any third-party site uses or discloses the information it collects about you.

Privacy of Third Party data

Eldrly doesn’t intend to infringe the privacy of any person or entity and hereby declares that Third-Party data collected by it shall remain the property of the truthful owner, possessor, and holder of the Third Party data and that Eldrly does not use this Third Party data, for any purpose which would reveal the specific Information of the said Third Party, without providing an intimation in this regard to that Third Party.

Grievances Officer: In terms of the Information Technology (Intermediaries Guidelines) Rules, 2011 and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, any grievance or complaint may be intimated to the following:

GRIEVANCE OFFICER

Please find below the details of the grievance officer:

Name:

Designation: Grievance officer

e-mail PDF:

Fax:

NODAL OFFICER

Please find below the details of the Nodal Officer:

Nodal Officer:

Name:

Designation:

e-mail PDF:

COMPLIANCE OFFICER

Please find below the details of the Compliance officer:

Compliance officer:

Name:

Designation: Compliance officer

e-mail PDF:

Fax:

Address:

Fax:

Third-Party Advertisements

• You agree and authorize Eldrly to use and share your information with its contractors and other third parties, in so far as required for joint marketing purposes/offering various services/report generations and/or to similar services to provide you with various value-added services, in association with the Services selected by you or otherwise. You agree to receive communications through emails, telephone and/or SMS, Eldrly’s contractors or its third-party vendors regarding the Services/ancillary services updates, information/promotional emails and/or product announcements. In this context, you agree and consent to receive all communications at the mobile number provided, even if this mobile number is registered under DND/NCPR list under TRAI regulations, and for such purpose, you further authorize Eldrly to share/disclose the information to its contractors or any Third-Party service provider
• Under contractual obligation, we allow Third Parties to serve advertisements and/or collect a certain portion of Personal Information in non-identifiable and statistical form from our Platform. These companies may use non-identifiable Personal Information to improve your experience regarding viewing advertisements about goods and services.

Links to other websites

Our Platform may contain a display of links and/or hyperlinks by clicking on which you could be directed outside our Platform and onto the Website or Mobile Applications of Third Parties. We do not control these links and hyperlinks and wish to make you aware that you shall be responsible for the results of clicking on any such links and hyperlinks; you are further advised to read the privacy practices and/or policies of any such other Website or Mobile Application. We are not responsible for any consequence of clicking on links and hyperlinks present on our Website.

Disclaimer

• Eldrly cannot ensure and provides no guarantee that the Information will never be disclosed in any way to any Third Party, Affiliates, or Government Authority in the manner otherwise than described in this Privacy Policy. You acknowledge that the entire part and parcel of your Information will not always remain private and you assume the risk associated with the use of the Platform, the internet generally and the documents you post or access and for your conduct on and off the Platform.

Disclosure for legal purposes; on account of change in the constitution of Eldrly

If an appropriate Government authority  requests or orders to disclose information or if we believe in good faith after considering your privacy interests and other factors that such action is necessary to:

• conform to legal requirements or comply with legal process;
• protect our rights or property or our Affiliates;
• prevent a crime or protect national security; or
• protect the personal safety of users or the public

We will disclose the entire or such portion of your Information.

If Eldrly’s constitution changes on account of merger, acquisition, transfer of business, conversion into another form of entity, incorporation of a subsidiary Company or in such other way and it is necessary to effect the change of the constitution to disclose such Information, then we will do so, after considering on best effort basis, your privacy interests and such other interests, to a Third Party, Government Authorities or to our Affiliates, as the case may be. Once the constitution has changed, the Information will become the property of the newly constituted entity.

Important Information

Security

• You are responsible for ensuring that your log-in credentials (your username and password) are kept confidential from Third Parties.
• We, on a best-effort basis, ensure that your log-in credentials are kept confidential and are shared with Third Parties under the same security as maintained by us.
• We also use cookies, web beacons, and Java Script to administer our Website and deliver a personalized experience. For additional detailed information on each of these, please see below.

Cookies and Other Tracking Technologies

• We use “cookies” and other tracking technologies on our Website to record information such as internet domain, host names, internet protocol addresses, clickstream patterns, dates and time of access, operating system types, browser software, etc. These cookies help us in improving our Website and user experience. Most browsers allow you to control cookies, including whether or not to accept them and how to remove them.
• Please note that if you choose to erase or block your cookies, you will need to re-enter your original user ID and password to gain access to certain parts of the Platform.