This Privacy Policy sets out how Glassfrog Technologies Private Limited, (we, us, our, Glassfrog and Glassfrog) collects, holds, uses and protects your personal information. This Privacy Policy applies to your use of the Glassfrog.in website (the Website) and Glassfrog apps for android and apple devices (the Apps). You agree that using the Website or the Apps or clicking I Accept when signing up for a user account on the Website or the App implies your consent to the collection and use of your personal information in accordance with this Privacy Policy. This Privacy Policy is published in compliance with, inter alia: 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); and Regulation 3(1) of the Information Technology (Intermediaries Guidelines) Rules, 2011.

In the course of conducting our business, we collect personal information from you including, but not limited to:

• Your full name
• Your title
• Your contact details (including street address, postal address, email address and phone number)
• Your time zone
• Your gender
• Your date of birth
• Your next of kin
• Location information
• Transactional information including method of payment and your consultation dates and times
• Your reasons for using the Website or the App or any of our products and services
• Your preferences and opinions relating to the Website or any of our products and services
• Logs, which may include information such as your Internet Protocol (IP) address, browser type, browser version, clickstream data, the pages of the Website or the App that you visit, the features of the Website and the App, activities or actions you do while using the Website and the App, the time and date of your visit to the Website and the App, the time spent on any pages of the Website and the App, the number of consultations that you have, the duration of each consultation, the technical performance of your video calls, mic, uploaded documents and other log related information relating to your use of the Website and the App.

We may collect and store the clinical notes and / or clinical assessments of health care service providers (Providers) who are registered with us, which relate to your consultation with the Provider. The personal information we collect is reasonably necessary for the purposes of conducting and improving our business and our products and services. Given the nature of the products and services we offer, some of the information we collect may be sensitive information including health information. This information may be collected in a number of ways, including:

Personal information collected by us may include:

• Through the Website and the App
• Through our services
• Through our account creation process on the Website and the App
• From our users
• Through marketing research including surveys
• Through any of our other business activities or events
• Through a person seeking employment with us, having been employed or contracted by us or being employed or contracted by us and/or
• By otherwise having some form of contact with a person, such as by personal contact, mail, telephone, email, video teleconferencing, Internet or other forms of telecommunication.

We endeavor to only collect personal information about you from you, where it is reasonable and practical to do so.

Glassfrog (including its staff, contractors and volunteers) will use the personal information you provide in the provision of services to you. We may use personal information you provide for evaluating, improving, personalizing and developing our business, the Website, and the App our other products and services, and to protect our users. We may also use your personal information in the course of:

• improving the Website, and the App, our other products and services, and user satisfaction
• providing and delivering the Website and the App and our other products and services to you
• providing support to you (including technical support) with regard to use of the Website and the App and our other products and services
• promoting and delivering our Site and our other products to organizations and individuals
• our internal research and statistical purposes (including market segmentation and customer value analysis)
• enabling us to forward to you other information or material which we believe may be of interest to you, or which you have indicated you may be interested in receiving.

We automatically gather information to monitor the use of the Website and the App and our other products and services. Most of the data we collect is aggregated, and such aggregated information is effectively anonymous to us. Sometimes you will be asked to confirm that you agree to a particular activity, or the collection of your personal information for a specific purpose. Though we usually collect aggregate data, we will make it clear to you if any information is being collected in a way that could personally identify you.

We may use Google Analytics, and other third party analytics software to track your usage of the Website and the App. Google Analytics is a web analysis service provided by Google. Google utilizes the data collected to track and examine the use of our Site, to prepare reports on its activities and share them with other Google services.

In the course of conducting our business, we may also disclose your personal information to other entities including:

• Providers
• external service providers, so that they can provide products and services in connection with the operation and improvement of our business
• our affiliates, including but not limited to other organizations and businesses within our group of organizations

We will not use or disclose information about individuals for other purposes without consent, except in exceptional circumstances, such as if disclosure is required by law or is necessary to protect the rights or property of Glassfrog or any other individual, or to lessen a serious threat to a persons health or safety. This may include if we have concerns that there is a serious threat to your health or safety.

Certain services we provide and features on the Website and the App are open to any other account holders to view, including, but not limited to, our blog (if any), and certain aspects of your personal user profile. Any information you create or post in these locations may be available and accessible to other users of the Website. The Website and the App may also enable you to upload, post, transmit, display, perform or distribute content, information or other data, which may include your personal information. Any information that you choose to disclose by means of such features will become public information. We strongly urge you to exercise caution when deciding to disclose your personal information by such means. You agree to assume all responsibility for all personal information that you have made public.

We will use all reasonable endeavors to maintain the security of personal information we collect against misuse, interference, loss, unauthorized access, modification or disclosure. Data transmissions over the Internet cannot be guaranteed to be fully and absolutely secure. The Website and the App and our services have security measures in place designed to protect against the loss, misuse and alteration of the information under our control. The precautionary steps we take to protect personal information include:

• storing all our cloud information in India by way of a HIPAA and GDPR compliant server
• external messaging of data is not permitted
• adopting measures to protect our computer systems and networks for storing, processing and transmitting personal information
• adopting procedural and personnel measures for limiting access to personal information by our staff
• regularly reviewing our information collection, storage and processing practices
• secured encrypted servers, password protection for electronic files, multi-factor authentication procedures, securing paper files in locked cabinets and physical access restrictions.

We cannot ensure or warrant that your personal information will always be secure during transmission or protected from unauthorized access during storage therefore you provide your personal information to us at your own risk. Please contact us immediately if you become aware or have reason to believe there has been unauthorized use of your personal information in connection with the Website and the App.

Cookies are files with a small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your computers storage drive. Like many sites, we use cookies to collect information. You can instruct your browser to refuse all cookies, or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some of the features of the Website or our other products and services.

Web beacons (also known as clear gifs, pixel tags or web bugs) are tiny graphics with a unique identifier and are used to track the online movements of users or to access cookies. Unlike cookies which are stored on the users computer storage drive, web beacons are embedded invisibly on web pages (or in email). Web beacons may be used to deliver or communicate with cookies, to count users who have visited certain pages and to understand usage patterns. Like many sites, we use web beacons to collect information which is done in accordance with this Privacy Policy.

If you use a link to access a third-party website, you do so entirely at your own risk. You should always read the applicable privacy policies on the other website.

If you have established an account with us, you may access and amend your personal information through the Website after you log in. It is your responsibility to ensure that all of your personal information is accurate and kept up to date. If you wish to amend personal information that we hold that you are not able to amend through the Website and the App, please contact us by writing to our Privacy Officer at support@glassfrog.design. We will reasonably endeavor to respond to your request for access within 7 business days. You are responsible for advising us of any changes to your personal information. If you wish to delete your profile from the Website and the App please contact us by writing to our Privacy Officer at support@glassfrog.design. Please be aware there may be residual information left behind on our servers from your profile / personal information which is beyond our control. If applicable, any legal requirement on us to maintain certain records of your personal information shall prevail over any of your requests.

The Website and the App are controlled from our offices and group companies. This Privacy Policy will be governed and construed in accordance with the laws of Uttarakhand - India. You irrevocably and unconditionally submit to the exclusive jurisdiction of the courts of Dehradun India. If any provision of this Privacy Policy is found to be invalid or unenforceable by a court of law, such invalidity or unenforceability will not affect the remainder of this Privacy Policy which will continue in full force and effect.

The Privacy Policy is effective from 15.05.2020. We reserve the right to change this Privacy Policy from time to time without further notice to you. Any variations made will be updated on the Website and the App. Your use of the Website and the App following any such change to the Privacy Policy will confirm your acceptance of the changes.

For any further information about this Policy please contact us at support@glassfrog.design.

If you have any concerns about how we manage your personal information, you may write to our Privacy Officer at support@glassfrog.design. All complaints made will be dealt with in confidence. We will reasonably endeavor to provide a response within 30 days of receipt of your complaint.