PRIVACY POLICY

Version -1 [updated as on [25th June]

This document is subject to change, in whole or part, from time to time. Any such change shall become effective immediately upon posting to the Platform

This document is published in accordance with the provisions of Rule 3 (1) of the Information Technology (Intermediaries Guidelines) Rules, 2011 that require publishing the rules and regulations, privacy policy and terms for access or usage of www.feeljoy.in or the FeelJoy mobile software application (the "Platform").

The Platform is owned by Healr Private Limited (“Healr”), the parent company of FeelJoy Private Limited (“Company” or “FeelJoy”), a private limited company, incorporated under the provisions of the Companies Act, 2013 bearing CIN U74999DL2016PTC308244 and having its registered office at 3rd Floor, D-682, C.R Park, New Delhi, 110019. The expression ‘FeelJoy’ shall include reference to its Affiliates (as defined below) where the context permits.

FeelJoy has the right to access and operate the Platform for provision of its services through the Platform.

FeelJoy appreciates the trust and information entrusted upon it by you and seeks to protect such information to the best extent possible, and only use the information in a manner provided in this privacy policy (“Privacy Policy”). FeelJoy reserves the right to make changes, in whole or in part to this Privacy Policy at any time with no prior notice. Such changes will become effective immediately upon posting to the Platform unless stated otherwise, and you agree to periodically review the current version of the Privacy Policy as posted on the Platform. Your continued access or use of the Platform, shall be deemed to be an acceptance of the revised Privacy Policy.

The Privacy Policy is to be read along with and is also subject to the FeelJoy terms of use (“Terms and Conditions”) available at here.

This Privacy Policy shall come into effect from the date and time you register on the Platform, and accept the Terms and Conditions provided, for availing the services provided through the Platform (“Services”). By using the Platform, you have agreed to permit FeelJoy to collect, store, and use the personal information provided by you (including any changes thereto as provided by you) for any of the Services that FeelJoy offers.

This Privacy Policy intends to inform you of how FeelJoy collects, stores, secures, utilizes, and shares your information in relation to the services provided through the Platform, and your choice about the collection and use of your information by FeelJoy.

By using the Platform, you understand and accept this Privacy Policy, and thereby expressly consent to FeelJoy’s collection, storage, processing, use, disclosure, and/or transfer of the information, including your Personal Information (as defined below) in accordance with this Privacy Policy. By using the Platform, you understand and accept this Privacy Policy, and thereby expressly consent to FeelJoy’s collection, storage, processing, use, disclosure, and/or transfer of the information, including your Personal Information (as defined below) in accordance with this Privacy Policy.

  1. ELIGIBILITY
    1. By using this Platform, you represent and warrant that you are at least eighteen (18) years of age and are competent to contract and be bound by the Terms and Conditions of FeelJoy, and this Privacy Policy.
  2. COLLECTION OF INFORMATION
    1. In the course of providing the Services, FeelJoy may collect the following information (“Personal Information”);
      1. Information necessary for the purposes of registration with the Platform, including but not limited to your name, e-mail address, phone number, and emergency contact details;
      2. Your username, and password created for the access to, and use of the Platform;
      3. Demographic information, including your gender, date of birth, and pin code/country or residence;
      4. Billing information in case of Services which require payment, such as credit/debit card number, expiration date, billing address, and any other payment instrument information required for processing payments.
      5. Information collected from the responses, assessments, or the feedback provided by you.
      6. Any information provided by you in communications with FeelJoy by email, or phone.
    2. FeelJoy collects the Personal Information, so as to provide a comfortable, and efficient experience to you. This will enable you to establish an account and profile that can be used to interact with the Buddy, or Coach, as the case may be. You have the option to not provide any or all of the Personal Information by choosing to leave the information fields empty. You also have to option to change, remove, or update the information provided by you through the ‘My Account Profile Page’ page on the Platform.2.2. FeelJoy collects the Personal Information, so as to provide a comfortable, and efficient experience to you. This will enable you to establish an account and profile that can be used to interact with the Buddy, or Coach, as the case may be. You have the option to not provide any or all of the Personal Information by choosing to leave the information fields empty. You also have to option to change, remove, or update the information provided by you through the ‘My Account Profile Page’ page on the Platform.
    3. In the event, there is any change in your Personal Information other than the information available on your ‘My Account Profile Page’ page, or if you need to update or correct such Personal Information, or you have any grievance with respect to the processing or use of your Personal Information, for any reason, you may send updates and corrections to FeelJoy at [email protected] and FeelJoy will take all reasonable efforts to incorporate the changes within a reasonable period of time.
    4. Some Personal Information, such as your answers to online assessments, if any, cannot be updated or deleted once submitted. If you would like FeelJoy to remove your records from its system, please contact FeelJoy at [email protected] and all attempts will be undertaken to accommodate your request, to the extent that FeelJoy does not have any legal obligation to retain such information. Please note that FeelJoy is required to retain certain information by law for record maintaining purposes (including but not limited to payment history, feedback, etc.), and there may also be residual information that will remain within the databases and other records, which, irrespective of any efforts by FeelJoy to delete information, will not be removed from them.
    5. In addition to the Personal Information, FeelJoy may also collect the following information;
      1. Technical and network data, including service provider details, internet protocol (IP) address, operating system, browser type, cookies (as more detailed in Paragraph 3, below);
      2. Location data, hardware data, including the unique identification number for your device (in case the device is a mobile phone);
      3. Account activity, and any other manner of interaction with, and on the Platform.
  3. COOKIE POLICY
    1. FeelJoy also uses ‘cookies’ to collect information. Cookies are small data files made of alphanumeric identifiers that are transferred to your device's hard drive through your web browser to enable FeelJoy systems to recognize your browser and to provide Services.
    2. Cookies are used for several purposes;
      1. saving your user credentials for future logins to the services;
      2. enabling certain features of the Platform, to understand how you interact with the Platform, and to monitor aggregate usage by users of the Platform and web traffic routing on the Platform. These features are enabled only for the fixed time period while you are logged in on the Platform.
    3. FeelJoy may work with third parties that place or read cookies on your browser to improve your user experience. In such cases, by using the third-party services through the FeelJoy Platform, you consent to their privacy policy and terms of use and agree not to hold FeelJoy liable for any issues arising from such use.
    4. You may instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you may not be able to use all features or functionalities of the Platform.
  4. STORAGE AND RETENTION
    1. FeelJoy shall retain any and all of your information, including your Personal Information as long as your user account is active on the Platform. FeelJoy may, for the purposes of research, archive and anonymize any and all information that may have been uploaded, shared, and or disclosed by you.
    2. In addition to the above, FeelJoy will also retain any and all of your information as necessary to comply with legal obligations, resolve disputes and/or enforce agreements.
  5. USE
    1. Information collected by FeelJoy about you is used to:
      1. administer your account,
      2. provide access to particular tools and services,
      3. respond to your inquiries raised to FeelJoy, and to send you administrative communications about the Platform,
      4. obtain your feedback about the Services or our offerings,
      5. analyze user behavior and activity to improve our Services, for example FeelJoy may analyze how frequently portions of the Platform are visited and how many emails are received by you,
      6. provide you with more relevant content or advertising both on the Platform or on other websites that you visit through the Platform, with your consent, when required by the applicable law,
      7. conduct research and measurement activities, or
      8. undertake any additional activities in accordance with your authorization, for which FeelJoy shall provide specific notice at the time of collection of your Personal Information.
  6. SHARING AND TRANSFER
    1. FeelJoy will share your information, including Personal Information, information from cookies, log files, device identifiers, location data, and usage data with businesses that are legally part of the same group of companies that FeelJoy is part of, or that become part of that group (“Affiliates”). Affiliates may only use this information to help provide, understand, and improve the Services (including by providing analytics) and Affiliates’ own services (including by providing you with better and more relevant experiences).
    2. FeelJoy may also share your information, with third-party organizations that assist FeelJoy in providing the Services to you. Such information shall be shared, only to the extent necessary for the relevant third-party to assist in providing Services. Any and all third-parties assisting FeelJoy in the provision of Services shall be bound by a Non-disclosure Agreement entered into between FeelJoy and such third-party, to ensure adequate confidentiality of your information available with the third-party.
    3. Any information shared with third-parties by FeelJoy shall be anonymized prior to sharing, to ensure that such information cannot identify you. To ensure anonymity, FeelJoy may combine your information with other information in a way that it is no longer associated with you and cannot be traced back to you.
    4. Any information shared by you during your sessions with your Buddy or Coach, as the case may be, shall form part of Personal Information, as provided in Paragraph 2.1 above. However, such Personal Information shall not be collected/used in the same manner as other categories of Personal Information.
    5. Your Personal Information shall not be disclosed or shared by FeelJoy, its employees, its agents or any third-party contractors, including the Buddy or Coach; either orally or in writing; except only in the following circumstances:
      1. FeelJoy is of the opinion that there is a significant, real, and/or imminent threat or risk to your health, safety or life or to the health, safety or life of any other person or the public;
      2. FeelJoy is required to share such Personal Information to any authority by law; and
      3. If you have claimed a health care insurance and such Personal Information is required by the insurer.
  7. SECURITY OF INFORMATION
    1. The security of your Information is important to FeelJoy, and FeelJoy shall take all reasonable measures to protect the security of such information. However, there is always some risk that an unauthorized third party may access the FeelJoy systems or that transmissions of your information over the Internet may be intercepted, accessed, used, or released in a manner that is inconsistent with this policy. FeelJoy expressly disclaim any representation or warranty, whether express or implied, with respect to ensuring, guaranteeing, or otherwise offering any definitive promise of security in connection with your information, which may be intercepted by third-parties.
    2. In order to prevent any unauthorized access or disclosures, FeelJoy uses Amazon Web Services. Any texts, emails, or any other chat transcripts are not stored on the servers. Access to the information stored by FeelJoy is protected by multi-layered security controls including firewalls, role-based access controls, encryption and passwords. Such information, to the extent necessary, shall only be accessible to you and your Buddy, or Coach. These technologies help ensure that your information is safe, secure, and is displayed only to you and those to whom you have granted access including but not limited to your Buddy, or coach, as the case may be, and any other personnel of FeelJoy that require any information for work purposes.
    3. You shall be responsible for maintaining the secrecy of your user account at all times. For the safety and security of your information, FeelJoy has implemented procedures to will help protect the information that you provide. However, you are solely responsible for maintaining confidentiality of your user identification and password. You are responsible for all activities and transmission performed through your user account.
    4. Payments made for Services are through third-party payment processors, and the payment process shall be subject to the terms, conditions and privacy policies of such third-party payment processor. You understand, and agree that neither FeelJoy, nor any of its directors, shareholders or other representatives will be liable to you for any direct, indirect, punitive, incidental, special or consequential damages that result from or arise out of your use of the third-party payment processors, your payment through the payment processors or your ability or inability to complete the payment.
    5. As stated in Paragraph 6 above, FeelJoy does not sell, transfer or share your Personal Information to any third party (unless it is obliged to do so by legal authorities) except as stated in this Privacy Policy. In the event you access any third-party website from the Platform and leave the Platform, you will then, be governed by the terms, conditions and privacy policy of such third-party website. Any information you disclose to the third-party websites once you access these third-party websites is not subject to this Privacy Policy. FeelJoy does not endorse and shall not be responsible for the privacy practices of these third-party websites.
  8. EUROPEAN UNION VISITORS/USERS
    1. In addition to the terms set forth above, this portion of the document shall apply if your personal data is subject to protection under the European Union General Data Protection Regulations (“GDPR”).
    2. Healr Private Limited, and FeelJoy Private Limited shall be the data controllers for the purposes of the GDPR which means that both Healr and FeelJoy determine the purposes and means of processing of personal data which you have provided to us at various occasions.
    3. International Transfers of Personal Data
      1. FeelJoy may store or transfer your personal data to countries outside of the European Union, including to countries which may not provide the same level of data protection as your home country. In such circumstances, FeelJoy shall, however take appropriate steps to ensure that recipients of your personal data are bound by duties of confidentiality. FeelJoy will implement appropriate measures to ensure the protection of your personal data in accordance with this document. 8.3.1. FeelJoy may store or transfer your personal data to countries outside of the European Union, including to countries which may not provide the same level of data protection as your home country. In such circumstances, FeelJoy shall, however take appropriate steps to ensure that recipients of your personal data are bound by duties of confidentiality. FeelJoy will implement appropriate measures to ensure the protection of your personal data in accordance with this document.
    4. Your Rights
      1. You have the following data protection rights, which you can exercise at any time by contacting us using the contact details provided in this document:
        1. The right to access, correct, update or request deletion of your personal data.
        2. The right to object to processing of your personal information in connection with our business, and separately the right to object to direct marketing.
        3. The right to ask FeelJoy to restrict processing of your personal information or request portability of your personal information.
        4. iv. The right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us at [email protected]
        5. If you are aware of changes or inaccuracies in your information, you should inform us of such changes so that our records may be updated or corrected.