w.e.f. March 2019

DrLaBike Technologies Pvt. Ltd. respects the privacy of our users. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our mobile applications or web portals.

Please read this Privacy Policy carefully. IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY, PLEASE DO NOT ACCESS THE APPLICATIONS.

We reserve the right to make changes to this Privacy Policy at any time and for any reason. You are encouraged to periodically review this Privacy Policy to stay informed of updates. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised Privacy Policy by your continued use of the Applications after the date such revised Privacy Policy is posted.

This Privacy Policy does not apply to the third-party online/mobile store from which you install the Applications or make payments, including any in-game virtual items, which may also collect and use data about you. We are not responsible for any of the data collected by any such third party.

What Information we collect?

We may collect information about you in a variety of ways. The information we may collect via the Applications depends on the content and materials you use, and includes:

Personal Data
Demographic and other personally identifiable information (such as your name and email address) that you voluntarily give to us when choosing to participate in various activities related to the Applications, such as chat, posting messages in comment sections or in our forums, liking posts, sending feedback, and responding to surveys. If you choose to share data about yourself via your profile, online chat, or other interactive areas of the Applications, please be advised that all data you disclose in these areas is public and your data will be accessible to anyone who accesses the Applications.

Location Information
We may request access or permission to and track location-based information from your mobile device, either continuously or while you are using the Applications, to provide location-based services. If you wish to change our access or permissions, you may do so in your device’s settings.

Mobile Device Access
We may request access or permission to certain features from your mobile device, including your mobile device’s camera, contacts, microphone, reminders, sensors, social media accounts, storage and other features. If you wish to change our access or permissions, you may do so in your device’s settings.

Mobile Device Data
Device information such as your mobile device ID number, model, and manufacturer, version of your operating system, phone number, country, location, and any other data you choose to provide.

Push Notifications
We may request to send you push notifications regarding your account or the Applications. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings.

Third-Party Data
Information from third parties, such as personal information or network friends, if you connect your account to the third party and grant the Applications permission to access this information. 

How we use your information?

Having accurate information about you permits us to provide you with a smooth, efficient, and customized experience. Specifically, we may use information collected about you via the Applications to

• Maintain your health related data.
• Create and manage your account.
• To personalize user experience. We may use your Non- Personal Information to understand demographics, customer interest, and other trends among our users;
• To help develop our service. We may use Non- Personal Information to provide, maintain, improve and modify the Applications, Services and the Site and develop new services;
• Compile anonymous statistical data and analysis for use internally or with concerned pathologists for diagnosis purpose.
• Delivering targeted diagnosis results, customer support, camp locations, schedules and other related information regarding the Applications to you.
• Fulfill and manage purchases, orders, payments, and other transactions related to the Applications.
• Generate a personal profile about you to make future visits to the Applications more personalized.
• Increase the efficiency and operation of the Applications.
• Monitor and analyze usage and trends to improve your experience with the Applications.
• Notify you of updates to the Applications.
• Offer new products, services, mobile applications, and/or recommendations to you.
• Perform other business activities as needed.
• To further develop DrLaBike application business. We may use Non- Personal Information for promotion and marketing purposes
• Prevent fraudulent transactions, monitor against theft, and protect against criminal activity.
• Process payments and refunds.
• Request feedback and contact you about your use of the Applications.
• Respond to product and customer service requests.

DISCLOSURE OF YOUR INFORMATION

We may share information we have collected about you in certain situations. Your information may be disclosed as follows:

By Law or to Protect Rights
If we believe the release of information about you is necessary to respond to legal process, to investigate or remedy potential violations of our policies, or to protect the rights, property, and safety of others, we may share your information as permitted or required by any applicable law, rule, or regulation. This includes exchanging information with other entities for fraud protection and credit risk reduction.

Third-Party Service Providers
We may share your information with third parties that perform services for us or on our behalf, including payment processing, data analysis, email delivery, hosting services, customer service, and marketing assistance.

Marketing Communications
With your consent, or with an opportunity for you to withdraw consent, we may share your information with third parties for marketing purposes, as permitted by law.

Interactions with Other Users
If you interact with other users of the Applications, those users may see your name, profile photo, and descriptions of your activity, including sending invitations to other users, chatting with other users, liking posts, following blogs.

Online Postings
When you post comments, contributions or other content to the Applications, your posts may be viewed by all users and may be publicly distributed outside the Applications in perpetuity

Third-Party Advertisers
We may use third-party advertising companies to serve ads when you visit the Applications. These companies may use information about your visits to the Applications and other websites that are contained in web cookies in order to provide advertisements about goods and services of interest to you.

Affiliates
We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.

Business Partners
We may share your information with our business partners to offer you certain products, services or promotions.

Social Media Contacts
If you connect to the Applications through a social network, your contacts on the social network will see your name, profile photo, and descriptions of your activity.

Other Third Parties
We may share your information with advertisers and investors for the purpose of conducting general business analysis. We may also share your information with such third parties for marketing purposes, as permitted by law.

We are not responsible for the actions of third parties with whom you share personal or sensitive data, and we have no authority to manage or control third-party solicitations. If you no longer wish to receive correspondence, emails or other communications from third parties, you are responsible for contacting the third party directly.

SECURITY OF YOUR INFORMATION

We use administrative, technical, and physical security measures to help protect your personal information. While we have taken reasonable steps to secure the personal information you provide to us, please be aware that despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse. Any information disclosed online is vulnerable to interception and misuse by unauthorized parties. Therefore, we cannot guarantee complete security if you provide personal information.

OPTIONS REGARDING YOUR INFORMATION

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with legal requirements. If you no longer wish to receive correspondence, emails, or other communications from us, you may opt-out by contacting us using the contact information provided below. If you no longer wish to receive correspondence, emails, or other communications from third parties, you are responsible for contacting the third party directl

Personal and Sensitive User Data

Personal and sensitive user data includes, but isn’t limited to, personally identifiable information, financial and payment information, authentication information, phonebook, contacts, device location, SMS and call related data, inventory of other apps on the device, microphone, camera, and other sensitive device or usage data. If your app handles personal and sensitive user data, then you must:

• Limit your access, collection, use, and sharing of personal and sensitive user data acquired through the app to purposes directly related to providing and improving the features of the app (e.g., user anticipated functionality that is documented and promoted in the app’s description on Google Play). Sharing personal and sensitive user data includes using SDKs or other third party services that cause data to be transferred to a third party. Apps that extend usage of personal and sensitive user data for serving advertising must be in compliance with our Ads Policy.
• Handle all personal and sensitive user data securely, including transmitting it using modern cryptography (for example, over HTTPS).
• Use a runtime permissions request whenever available, prior to accessing data gated by Android permissions.
• Not sell personal and sensitive user data.

Prominent Disclosure & Consent Requirement

In cases where users may not reasonably expect that their personal and sensitive user data will be required to provide or improve the policy compliant features or functionality within your app (e.g., data collection occurs in the background of your app), you must meet the following requirements:

You must provide an in-app disclosure of your data access, collection, use, and sharing. The in-app disclosure:

• Must be within the app itself, not only in the app description or on a website;
• Must be displayed in the normal usage of the app and not require the user to navigate into a menu or settings;
• Must describe the data being accessed or collected;
• Must explain how the data will be used and/or shared;
• Cannot only be placed in a privacy policy or terms of service; and
• Cannot be included with other disclosures unrelated to personal and sensitive user data collection.

Your in-app disclosure must accompany and immediately precede a request for user consent and, where available, an associated runtime permission. You may not access or collect any personal and sensitive data until the user consents. The app’s request for consent:

• Must present the consent dialog clearly and unambiguously;
• Must require affirmative user action (e.g., tap to accept, tick a check-box);
• Must not interpret navigation away from the disclosure (including tapping away or pressing the back or home button) as consent; and
• Must not use auto-dismissing or expiring messages as a means of obtaining user consent.

To meet policy requirements, it’s recommended that you reference the following example format for Prominent Disclosure when it’s required:

• “[This app] collects/transmits/syncs/stores [type of data] to enable  [“feature”], [in what scenario].”
• Example: “Fitness Funds collects location data to enable fitness tracking even when the app is closed or not in use and is also used to support advertising.”
• Example: “Call buddy collects read and write call log data to enable contact organization even when the app is not in use.”

Data safety section

All developers must complete a clear and accurate Data safety section for  app detailing collection, use, and sharing of user data. The developer is responsible for the accuracy of the label and keeping this information up-to-date. Where relevant, the section must be consistent with the disclosures made in the app’s privacy policy.

Privacy Policy

DrLaBike apps must post a privacy policy link in the designated field within Play Console, and a privacy policy link or text within the app itself. The privacy policy must, together with any in-app disclosures, comprehensively disclose how your app accesses, collects, uses, and shares user data, not limited by the data disclosed in the privacy label. This must include:

• Developer information and a privacy point of contact or a mechanism to submit inquiries.
• Disclosing the types of personal and sensitive user data your app accesses, collects, uses, and shares; and any parties with which any personal or sensitive user data is shared.
• Secure data handling procedures for personal and sensitive user data.
• The developer’s data retention and deletion policy.
• Clear labeling as a privacy policy (for example, listed as “privacy policy” in title).

The entity (for example, developer, company) named in the app’s Google Play store listing must appear in the privacy policy or the app must be named in the privacy policy. Apps that do not access any personal and sensitive user data must still submit a privacy policy.

EU-U.S., Swiss Privacy Shield

If you access, use, or process personal information made available by Google then you must:

• Comply with all applicable privacy, data security, and data protection laws, directives, regulations, and rules;
• Access, use or process EU Personal Information only for purposes that are consistent with the consent obtained from the individual to whom the EU Personal Information relates;
• Implement appropriate organizational and technical measures to protect EU Personal Information against loss, misuse, and unauthorized or unlawful access, disclosure, alteration and destruction;

Usage of App Set ID

Android will introduce a new ID to support essential use cases such as analytics and fraud prevention. Terms for the use of this ID are below.

• Usage: App set ID must not be used for ads personalization and ads measurement.
• Association with personally-identifiable information or other identifiers: App set ID may not be connected to any Android identifiers (e.g., AAID) or any personal and sensitive data for advertising purposes.
• Transparency and consent: The collection and use of the app set ID and commitment to these terms must be disclosed to users in a legally adequate privacy notification, including your privacy policy. You must obtain users’ legally valid consent where required.