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PRIVACY POLICY

1. Scope

This Privacy Notice (“Notice”) describes how Walnut (Polowings HealthTech Private Limited) (“Walnut”, “we”, “us” and “our”) collect, use, share, secure, and eventually dispose of (collectively “process”) your personal data. Personal data is any information that does, or could, identify you. Your rights over your personal data are set out in Section 9 – Your Rights and Choices.

This Notice applies to personal data collected by our websites, apps, and products (collectively “product”), and in the course of routine offline business contact with you.

This Notice is addressed primarily to our customers, service users (including visitors to our sites and trial users), sales prospects and individuals whose professional data is included in our product.

2. About Walnut

Walnut is India's 1st social health platform or a virtual health club, comprising of a blend of verified doctors, organic users, social media feed, posts, health communities & health content.

-‘A LinkedIn for Health’; Walnut is a Coterie (Community) platform with different health domains connecting people to discuss among themselves, engage with health experts follow & get health updates from their friends & family, & collaboratively work towards a healthy lifestyle !

The platform also features personalised Artificial Intelligence based health care solutions/services for its users, in the domain of mental health, fitness and chronic disease management.

 

3. Changes to this notice

We will update this Notice from time to time and will communicate material changes to you through an appropriate channel (for example, by e-mail or via a notice on our website and in our product).

4. Personal data collected

Sources of personal data 

We collect personal data directly from you:

  • When you use our product, e.g. when you purchase or have access to our product, we may collect your professional profile details. We may also collect and other information that you choose to enter into our product. We will also store your log-in credentials to our product.

  • When you interact with us, e.g. when you fill in a form online, we collect the information that you include in those forms or when you seek help with technical issues, you may share information about your devices with us, such as their operating system and installed programs.

  • Through cookies and similar technologies included in our product, e.g. when you access our product, we collect device and information relating to your usage of our product. 

  • We might collect personal data about you from third parties:

  • The organization(s) to which you belong or person(s) who have arranged your access to our product, e.g. your employer or the institution you are affiliated with may provide us with contact information so that we can set up your login.

  • Our partners and service providers, e.g. technology providers in connection with your use of our product.

  • Publicly available sources like academic publications, patent offices, and regulatory agencies, e.g. if you are an academic author or researcher, a patent holder, clinical trials investigator or are otherwise an author of, or contributor to, reports, analysis, articles or other materials available in the public domain, your professional data such as your name, work contact details, and specialization may be included as content in our product. If you have questions about this use of your data, contact us at ceo@walnuthealth.club

  • Other public or paid-for sources, e.g. we may acquire marketing lists from third parties to identify prospects for our product (see Section 9  – Your Rights and Choices for information on managing your marketing preferences).

Types of personal data we collect

How you interact with us and the different product that we offer determine what personal data we collect about you.

The personal data we collect may consist of the following:

  • Name and contact details, e.g. name, e-mail address, postal address, telephone number

  • Log-in Credentials, e.g. security and credentialing information required to access our product

  • User inputted content, e.g. content you provide to us when you use our product (for instance, if you contact our customer service team or any information you choose to include about yourself in our product)

  • Device related information, e.g. information about your computer or other device, such as IP address, location or provider

  • Usage information, e.g. information about your use of our product, such as date and time of visits, the pages viewed, time spent at one of our websites.

  • Purchase history, e.g. purchases you have made, when your subscriptions expire or renew

  • Demographic information, e.g. your country and preferred language

  • Billing information, e.g. credit card number and payment details if you make a payment through our product.

Sensitive personal data or information: We do not knowingly or intentionally process personal data about race or ethnicity; political opinions, or religious or philosophical beliefs; trade union membership; or genetic, biometric, health, or sex-life information (“special categories of personal data” as defined by the European Union General Data Protection Regulation) and sensitive personal data or information which consists of  password, financial information such as bank account or credit card or debit card or other payment instrument details, physical, physiological and mental health condition, sexual orientation, medical records and history, biometric information, any detail relating to the above clauses as provided to body corporate for providing services, and any information mentioned above by body corporate for processing, stored or processed under lawful contract or otherwise(as defined in the Information Technology act, 2000) unless you actively provide or indicate such information in a user-controlled area of our product, for example a professional profile. We may occasionally collect personal data that are subject to enhanced security requirements, such as requiring a credit card or government-issued ID to complete a transaction you have requested. 

 

5. Our legitimate interests

Our legitimate interests in processing your personal data are mainly customer and product administration, provision, improvement and development of our product, protection of legal rights and marketing. More detailed information about these legitimate interests is set out below.

  • Customer and product administration: to provide you with our product and information that you requested or that you access through our product, create product accounts, provide user and technical support, enforce our terms of business, report product usage information to our customers and business partners, report to our content and technology providers, contact you about renewal of your subscriptions, and other related administrative tasks.

  • Product personalization: to deliver personalized functionality in our product, for instance we may retain your browsing and usage information to make your searches within our product more relevant. We also analyze product usage information to understand which content and tools are most useful for our users and to allow us to deliver and suggest tailored content, features and other Walnut product that we believe may interest you.

  • Product analysis and development: we may use information collected on our product, usually in aggregated form, to analyze the functionalities we offer and to improve the design and content of our product (including sharing your personal data across our group which allows us to make all our product more user-friendly). We may also provide information about your use of the product to a third party who has made the product available to you (for instance, your employer) or to a business partner whose content or technology you accessed through the product.

  • Marketing: to send you marketing messages for Walnut product that may interest you (see Section 9 – Your Rights and Choices for information on managing your marketing preferences). We do not disclose your contact information to third parties for their marketing purposes.

  • Product content: to organize and include information in our product we collect data from publicly available sources. We may also use personal data which you choose to make available in our product (for instance, you may wish to provide information to enable peer connection and related collaboration).

  • Security: to protect the security of our IT systems, architecture and networks as well as to prevent misuses of our product.

  • Legal rights: to exercise our rights and to the extent reasonably required, to assist third parties (such as your employee or our business partners) in exercising their rights, and to defend ourselves from claims and to comply with laws and regulations that apply to our group or third parties with whom we work.

  • Business restructuring or similar transactions: to participate in, or be the subject of, any sale, merger, acquisition, restructure, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock.

6. Recipients of the data

Your personal data will, depending on the purposes of processing, be disclosed to different individuals and organizations, including:

  • Employees and contractors of Walnut whose roles require access to your data. Our personnel are bound to confidentiality terms which cover their obligations to protect personal data.

  • The account administrator or the person providing you access to our product, in the case of corporate subscriptions.

  • Service providers who process personal data on our behalf (“processors”); for example Cloud computing providers and web analytics product like Google Analytics and credit card payment processors. Such vendors are contractually bound to protect your data to the same standard as set out in this Notice and, in the case of credit card payment processors, to meet the Payment Card Industry Data Security Standard (PCI DSS).

  • Business partners with whom we deliver co-branded product or host events; or whose content or technology we make available through our product.

  • Professional advisors such as legal counsel and information security professionals where reasonably required to protect our rights, users, systems and our product.

  • Prospective and actual buyers, sellers, advisers or partners in relation to any sale merger, acquisition, or similar corporate event involving Walnut.

  • Government agencies, law enforcement, courts and other public authorities where we have a duty to disclose your personal data by law.

  • Subscribers to our product. If your personal data is collected from public sources for inclusion in our product databases and any personal data you choose to provide to us for display in our product (for example, in profiles and when using online forums), your personal data will be accessed by users of our product.

  • Other third parties you have asked us to share information with, e.g. if you upload information into a public platform or forum that is publicly accessible.

7. Data security

Walnut maintains appropriate administrative, technical, and physical security measures to protect your personal data from accidental loss and unauthorized access or use. These measures may include encryption, firewalls, roles-based data access, intrusion-detection software, and physical access controls to data centers. However, we cannot guarantee that loss, misuse, unauthorized acquisition, or alteration of your data will never occur.

8. Data retention

We store your personal data throughout the period of your relationship with us and retain it for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying legal, accounting, or reporting obligations or to resolve disputes. .

9. Your rights and choices

You may at any time ask for access to the data that we hold about you, and request its correction or erasure, or that we cease to process it. 

Marketing: We may send you marketing communications, for example event invitations, white papers, and information about our product that may interest you. We will obtain your prior consent to do this when local law requires it.

You can opt out of our marketing communications at any time – all Walnut marketing e-mails contain an “unsubscribe” or “manage my preferences” link.

10. Links

Our product may contain links to third party sites. Walnut is not responsible for the privacy practices of such third-party sites. We encourage you to read the privacy statement of each and every site that you use that collects personal data about you.

11. Further privacy information relating to our product

This Notice only relates to our processing of personal data where we make decisions about how data is treated.

Where we need to give you additional information about how your personal information is used in relation to specific product, we will provide separate or additional privacy notices.

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