1.   Privacy Policy General

1.1 We (defined below) are committed to protecting your privacy and grant importance to the confidentiality of your data over internet. This privacy policy (“Privacy Policy”) read with the Terms of Use available at our website www.inuen.org (“Website”) applies to all services offered to persons using or visiting (“Users”, “You” or “Your”) the Website.

1.2 The Website is owned and operated by Ms. Payal Kothari who is an Integrative Nutrition Health Coach, philanthropist and transformation master. The terms “Coach”, “we“, “our” and “us” refer to Ms. Payal Kothari (“Coach”, “We”, “Our” or “Us”). We believe it is important for You to understand what information We collect from You, how it is used and who will have access to that information. This Privacy Policy sets forth the policy in relation to the collection and usage of personal information that you may provide to Us while using our Website and related services (collectively “Service”).

1.3 By visiting or using our Website and any other linked pages, features, content, or any other services We offer from time to time by in connection therewith, or by using the Services in any manner, You acknowledge that You accept the practices and policies outlined in this Privacy Policy, and You hereby consent[1] to Our collection, use and disclosure of Personal Information (as defined below) in accordance with this Privacy Policy. If you do not accept the Policies/Conditions of this Privacy Policy, PLEASE DO NOT USE OR ACCESS THE WESITE OR AVAIL OUR SERVICES.

1.4 If You are under 18 (eighteen) years of age, You are to access the Website or provide personal data under the supervision of a parent or guardian, as the case may be.

1.5 We collect, use, share, disclose and protect Your personal data provided while using the Services available on the Website. The data collected is used only to enhance the operation of the Website, allowing You to use all the listed features and allowing Us to respond to Your requests/queries in an efficient manner. The Personal Information is used strictly in line with Our business purposes and to provide You with useful features.

1.6 For purposes of this Policy, personal information shall mean any information relating to an identified or identifiable natural person, “Personal Information/data” shall mean information through which a User can be identified, directly or indirectly, in particular by reference to User, their name, email address, phone number, username, password, billing address, Internet Protocol (“IP”) address as well as any information associated with the foregoing (“Personal Information”). Personal Information does not include anonymized information that has been appropriately processed to make it non-identifiable in order to irreversibly prevent its identification.

1.7 User acknowledges that this Privacy Policy, together with terms of use, forms Our agreement with the User in relation to his or her use of the Website. Any capitalized term used but not defined in this Privacy Policy shall have the meaning attributed to it in our Terms of Use.

1.8 For any service that the User may use, We only collect the data that is strictly necessary (i) for the delivery of the services, (ii) for the performance of a contract for which User is a party, (iii) for which User has given consent for such processing of data[2], (iv) detect and prevent of happening and fraud, (v) personally communicate with you, (vi) improve user and learning experience, etc.

1.9 By using the Website or by otherwise giving us Your Personal Information, You will be deemed to have read, understood and agreed to the practices and policies outlined in this Privacy Policy and agree to be bound by the Privacy Policy. You hereby consent to Our collection, use and sharing, disclosure of Your Personal Information as described in this Privacy Policy. We reserve the right to change, modify, add or delete portions of the terms of this Privacy Policy, at Our sole discretion, at any time. You acknowledge and agree that it is your responsibility to review this Privacy Policy periodically and become aware of modifications, made, if any.

1.10 This Policy is applicable to all those who use the website including the registered or unregistered users and/or visitors, or anyone else related for that matter. The Users are also bound by the ‘terms of use’ available on the website. This Policy applies only to information we collect, process, and use through the website. This Policy does not apply to information that we collect through other channels, such as information that we collect offline, from other websites or from emails you send us. By using or visiting this Website, you consent to the Terms of our online Privacy Policy and to the processing of Personal Information for the purposes given under the Terms & Conditions and this Privacy Policy. We aim to follow the basic principles of protection that are core to the General Data Protection Regulation for data collection process. These are: Lawfulness, fair and transparency, limited use for the purpose, data minimization, accuracy, Integrity and confidentiality. We will make every possible effort to comply with these principles at all times in our information-handling practices.

2.  Information Collected

2.1 In the course of providing Services to You through the Website, We may collect the following:

    • Personal Identifiable Information including but not limited to Your name, phone number, username, password, e-mail address, height, weight when You register on the Website.

‘personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;

    • Processing of personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation. The sensitive personal data will be processed and used during the consultations and shall be stored for future or till the consultations go on.
    • With Your permission, at the time of registration, we may also collect information such as Your lifestyle and food preferences, medical conditions (if any), health goals or other fitness goals. By choosing to provide this information, You consent to Our processing of that information.
    • With Your permission, We may automatically collect some information about Your hardware devices when You access the Website. For example, when You utilize our Website, we may collect your IP address and the type of mobile device/computer/laptop You use and Your geographic location. We may also collect information about Your activity on the Website, such as information about Your account usage, as well as information about how You interact with the Website (collectively, “User Data”). We may combine this automatically gathered information with other information, including Personal Information we have collected about You.
    • If you permit cookies on Your browser, We may receive, and store certain types of information known as “cookies” when You access the Website.
    • Any communications between You and the Coach, or her representative

2.2  The information collected from You may constitute ‘personal information/data’ or ‘sensitive personal data or information’ as defined under the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011 (“SPI Rules”). The SPI Rules define “Sensitive Personal Data or Information” of a person to mean personal information about that person relating to:

    • financial information such as bank accounts, credit and debit card details or other payment instrument details;
    • physical, physiological and mental health condition;
    • sexual orientation;
    • medical records and history;
    • visitor details as provided at the time of registration or thereafter.

Some applications may ask you to identify your racial/ethnic origin or disabilities on a strictly voluntary basis and you may choose not to submit this information anytime.

2.3  We will be free to use, collect and disclose information that is freely available in the public domain without Your consent.

2.4  In order to provide Services through the Website, We may require the User to provide Us with certain information that personally identifies himself. Personal Information includes the following categories of information:

    • Contact details (such as email address, phone number and call recording); and
    • Data concerning health (Lifestyle preferences including food habits, sleep cycle, daily habits,  medical conditions (if any) etc.
    • Sensitive data-User ethnicity, genetics, sex life or sexual orientation;
    • Demographic data (such as time zone, postal address and location details); and
    • If the User communicates with Us, for example, via e-mail, registers with Us, any information provided in such communication may be collected by Us.
    • Financial data (such as account details, e-wallet details, bank account or credit or debit card details or other payment instrument details etc.) that User may have provided Us while using the Services provided by the Website.

2.5  All such information is stored or used for processing Services and under no circumstance are any of these details made available in the public domain. However, We may use this information to share with You additional and/ or upcoming information regarding the Services offered by the Website.

2.6  The Website may transmit User Data to the data servers, to ensure secure storage of data collected by Us. Thereby the User is also subject to the terms of data server’s policy. The Personal Information is immediately deleted once User deletes his account exclusively made on the Website, except to the extent it is necessary to store the same under applicable laws. We have implemented technical and organizational measures as well as we employ physical, electronic, and managerial measures to secure your personal information from accidental loss and from unauthorized access, use, alteration or disclosure. However, due to the inherent open nature of the internet and wireless communications, we cannot guarantee that Users personal information will be completely free from unauthorized access by third parties, such when transferred over or through systems not within our exclusive control.

2.7  Our Website may contain links to third party websites or applications. The User agrees and understands that privacy policies of these websites are not under Our control and the User understands that once he or she leaves Our servers, use of any information provided by the User shall be governed by the privacy policy of the operator of the site used by them.

2.8  Prior to any direct marketing or commercial operation (for example for sending the newsletters or commercial offers), We will first obtain User’s consent, either when creating account on the Website or later by indicating Your choice in account settings. User will always have the right to withdraw his or her consent at any time, directly by clicking on the unsubscribe link available on each email received, by modifying his account settings, or by contacting Us at the following email address [email protected] .

2.9  In accordance with the applicable laws, User has the right to access, to rectify and to object data concerning them. User can access and change their profile picture, display name and user profile password provided when account is created through the account page or by contacting Us.

2.10  We may disclose any information We may deem necessary, in Our sole discretion, to comply with any applicable law, regulation, legal process or governmental request, in order to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any personal or as otherwise required by law. Such transfer or disclosure shall be for lawful purposes only. Further, such transfer or disclosure of Your sensitive personal information to other third parties shall only be done once it is ensured that the third party receiving such information has implemented the same level of security practices as We have.

2.11  We take Your right to privacy very seriously and other than as specifically stated in this Privacy Policy, will only disclose Your Personal Information in the event it is required to do so by applicable law, rule, regulation, law enforcement agency, governmental official, legal authority or similar requirements or when we deems it necessary in order to protect its rights or the rights of others, to prevent harm to persons or property, to fight fraud and credit risk, or to enforce or apply the Terms of Use.

3. Use of Personal Inforamtion

 3.1 We (and third-party data processors, vendors and hosting partners who may be acting on Our behalf) may collect, store and process Your personal data/ information for the following reasons:

    • to make this Website customized, to provide content tailored to individual requirements; to understand Your needs and provide You with improved products and Services, newsletters and other communications;
    • to maintain any registered accounts that You may hold with Us and to provide You with updates or notifications of changes to Your account;
    • to track Your health, nutrition intake, weight and fitness regimes;
    • to prepare a specific diet plan and training regime for You;
    • with Your permission, to contact Our business partners’ promotions, products and Services or other information which We think You may find interesting, offers, or for customer satisfaction purposes;
    • for market research, analysis, testing, monitoring, risk management and administrative purposes (including diagnosing technology problems which may be reported to Us); and
    • for any purposes related to the above or where We have a legal right or duty to use or disclose Your personal data/ information (including for abuse, crime and fraud prevention and related purposes).
    • to better understand how Users access and use our Service, both on an aggregated and individualized basis;
    • to facilitate payments for the Services availed by the User;
    • User posted content may be reused by Us to aggregate data about a particular activity or location and include it in consolidated formats.

3.2  If We become aware that We have collected or been sent personal data/ information from a person who is under 18 (eighteen) years of age, without the supervision of the parent or guardian, We will deactivate the relevant account as soon as is reasonably practicable by Us.

3.3  Further, in an ongoing effort to better understand and serve the Users of Our Service, we also often conduct research on its customer demographics, interests and behavior based on the personal information and other information provided to Us. This research may be compiled and analyzed on an aggregate basis, and We may share this aggregate data with Our affiliates, agents, advertisers and business partners. This aggregate information does not identify You personally. We may also disclose aggregated User statistics in order to describe Our Service to current and prospective business partners and to other third parties for other lawful purposes (including providing advertising use cases to actual or potential advertisers).

4. Usage of Cookies

4.1 In some instances, Our service providers use cookies and other technology to automatically collect certain types of information collected through our website or via emails. The collection of this information allows Us to customize Your online experience, improve the performance, usability, and effectiveness of Our online presence, and to measure effectiveness of our marketing strategies. Users can also block advertising cookies in the dedicated “cookies” page.

5.  Security

5.1  The security of User Data and Personal Information is important to Us. We generally follow accepted industry standards to protect the User Data and Personal Information submitted to Us, both during transmission and once We receive it. All information gathered on Our Website is securely stored on the cloud server (DigitalOcean). The database is stored on servers secured behind a firewall; access to the servers is password-protected and is strictly limited. Such information may also be converted to physical form from time to time, if deemed necessary. We take all necessary precautions to protect Your Personal Information both online and offline, and implement reasonable security practices and measures including managerial, technical, operational and physical security control measures that are commensurate with respect to the information being collected and the nature of Our business.

5.2  Although We make best possible efforts to store Personal Information in a secure operating environment that is not open to the public, User must understand that there is no such thing as complete security, and We do not guarantee that there will be no unintended disclosures of Personal Information. If We become aware that Users Personal Information has been disclosed in a manner not in accordance with this Privacy Policy, We will use reasonable efforts to notify such User of the nature and extent of such disclosure as soon as reasonably possible and as permitted by law.

5.3  For security from Your part, You should:

    • if using a computer in a public location, always log out and close the website browser when You complete Your online session;
    • keep Your account details and passwords private;
    • frequently change Your password;
    • avoid using the same password for multiple online accounts.

5.4  We do not sell Users Personal Information to any advertisers or any third party. We use Users Personal Data to display relevant advertisements, based on their preferences. We make reports related to the advertisement campaigns, in particular statistics, without any reference or information related to the personal information of visitors or Users of the Website. [

5.5  Any purchase transaction data is only used as long as is necessary to complete the purchase transaction and after that is complete, Your purchase transaction information will not be saved. Our payment gateway adheres to the standards set by PCI-DSS as managed by the PCI Security Standards Council. PCI-DSS requirements helps ensure the secure handling of credit card information by Our Website and its service providers.

6.  Retention period

We will only retain your data for as long as is required in order to provide the services, or as required by law. However, depending on the processing, use and requirement of Personal Information, the data may be subject to a different storage period.

7.   Change to Privacy Policy

7.1  We may update this Privacy Policy at any time, with or without advance notice. In the event there are significant changes in the way We treat User’s personal information, or in the Privacy Policy itself, We will display a notice on the Website or send an email to the User’s, as provided for above, so that You may review the changed terms prior to continuing to use the services.

7.2  If You object to any of the changes to Our Privacy Policy, and You no longer wish to avail the services, You may contact Our Grievance Officer Minakshi Shawan having [email protected] deactivate Your account and for any other issues related to this Privacy Policy. Unless stated otherwise, Our current Privacy Policy applies to all information that We have about You and Your account.

7.3  If a User uses the Website, after a notice of changes published on the Website, such User hereby provides his/her/its consent to the changed terms.

7.4  This Privacy Policy is an electronic record in the form of an electronic contract formed under the Information Technology Act, 2000 and the rules made thereunder and the amended provisions pertaining to electronic documents/ records in various statutes as amended by the Information Technology Act, 2000. This Privacy Policy does not require any physical, electronic or digital signature and is a legally binding document between the User and Us.

8.   Terms of Use

Use of the curecast service is governed by, and subject to, the terms & conditions. this privacy policy is incorporated into such terms.

9.   Contact Us

If you have any questions or suggestions regarding this policy, please contact us at [email protected]

[1] ‘consent’ of the data subject means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

[2] ‘processing’ means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.