1. INTRODUCTION

• EU's General Data Protection Regulation (GDPR)
• California's Consumer Privacy Act (CCPA) / California Privacy Rights Act (CPRA) and California Online Privacy Protection Act (CalOPPA)

2. SCOPE OF THE POLICY

3. PROCESSING ACTIVITIES

• Make use of Our application and services as an authorized user;
• Visit any of Our websites that link to this Privacy Statement; or
• Receive any communication from Us including newsletters, emails, calls, or texts/SMS

4. DEFINITIONS

• “GDPR” means General Data Protection Regulation 2016;
• “CCPA” means California Consumer Privacy Act 2018;
• “Applicable Law(s)” means all statutes, enactments, acts of legislature or parliament, ordinances, rules, bye-laws, regulations, notifications, policies, directions, directives, and orders as such are in effect as of the date hereof or as may be amended, modified, enacted or revoked from time-to-time hereafter or other governmental restrictions or any similar form of decision of, or determination by any government, statutory authority, tribunal, board, court having jurisdiction over the matter in question in EU or California;
• “Business Partner(sf)” shall mean such entities that We have a business partnership with, as updated from time to time;
• “Consent” shall mean as per Clause (V) of the Privacy Policy;
• “Database” shall mean an organized collection of structured information, or data, that is stored electronically in Our computer systems.
• “Log Data” shall include internet protocol address, browser type, browser language, referring URL, files accessed, errors generated, time zone, operating system, and other visitor details collected in Our log files, the pages of our Website or that You visit, the time and date of Your visit, the time spent on those pages/ and other statistics;
• “Purpose” includes:
  a) To provide and maintain our Service;
  b) To notify You about changes to our Service;
  c) To allow You to participate in interactive features of our Service when You choose to do so;
  d) To provide customer support;
  e) To gather analysis or valuable information so that We can improve our Service;
  f) To monitor the usage of Our Service;
  g) To detect, prevent, and address technical issues; And
  h) To provide You with news, special offers, and general information about other goods, services, and events that We offer that are similar to those that You have already purchased or enquired about unless You have opted not to receive such information;
• “Personal Information” shall mean information such as (a) Name of the User; (b) Email Address, as provided by the User; (c) Contact Number, (d) Gender, € Agre, (f) Location of the User, as provider by the User, (g) financial information, and (h) such other information of the User, as and when collected;
• “Privacy Policy” shall mean this document that governs usage of data by Us;
• “User”, “You”, or “Your” shall refer to any person or a person representing an entity under the laws of the European Union and California that accesses the Website;
• “User Data” shall mean the cumulative data obtained by Us, from User activity on the Website;
• “Site” shall mean the web services of ProcDNA made available on the world wide web, “www” and bearing domain names ‘procdna.com’, mobile applications, platforms and other online solutions, software applications, media, solutions, features, websites, webpages and subdomains, content including underlying data, and/or functionality that are owned, provided, and operated by Us.

5. CONSENT OF USER

6. POINTS OF DATA COLLECTION

• We receive information only when the Users enter their Personal Information on the Site.
• We collect information from Users when Users access Our Site. Further, in cases where You are looking to avail Our Services, we may ask You to provide Your Personal Information such as a phone number for verification and other information about health-related aspects. In case You are providing information to Us, on behalf of another person, You should only do so, if You are duly authorized by them under Applicable Laws.
• We may also request Personal information during the course of the provision of Our Services, to provide You with other Services.

7. PERSONAL DATA WE MAY COLLECT

• In order to provide Our Services, We may collect the following types of information:
• User Information – When You use Our Site, We automatically receive and record information from Your device and applicable browser. Such information may include, the location of Your device, Your device storage, Your IP address, cookie information, software and hardware attributes, unique device ID, etc. Most of the information We collect during Your use of Our Site is Your device and hardware IDs and device type, and basic usage stats about Your device and general use of Our Services does not by itself identify You to Us, though it may be unique or consist of or contain information that You consider personal. Specifically, We collect, retain, and use information collected, retained, and shared through Google, according to the applicable terms and conditions of their privacy policies.
• Personal Information and Database – As You interact with our Site, We may automatically collect the following types of data (all as described above): Device Data about Your equipment, Usage Data about Your browsing actions and patterns, and Contact Data where tasks carried out via Our Site remain uncompleted, such as incomplete orders or abandoned baskets. We collect this data by using cookies, server logs, and other similar technologies. On the basis of Your usage of Our Site, we may also export Your Personal Information from Our Database to any other third -party as permitted under Applicable Law (collectively referred to as “User Data”).
• User history and preferences – We save Your query terms as well as Your statement of experience with Us. These may be associated with the unique registration ID of Your device. We also save Your recommendations and preferences for Our Services, as recorded through Your use of the Services, and use them for personalization features.
• Communications Data: Such as information You provide through Our online web forms, when You contact Us with questions, request support or marketing materials, or otherwise choose to provide when You correspond with Us online.
• Marketing Data: Such as Your preferences for receiving communications about Our activities, publications, and details about how You engage with Our communications.
• Social Media Information: We have pages on social media sites like Instagram®, Facebook®, X®, YouTube®, and LinkedIn® or other social channels. When We interact through Our social media pages, We collect personal data that You elect to provide to Us.

• Categories of Sources- We collect Personal Information directly and indirectly from the following categories of sources:
• Directly from You, and/or Your devices;
• Indirectly from your activities on Your devices, our Site, and/or Your interactions with Our Business Operations;
• From Our clients and business partners, such as commercial clients, corporate policyholders, insurers, reinsurers, brokers, network partners, employers, benefit plan sponsors, benefit plan administrators, health care providers, and service providers;
• From other third parties, such as social media sites, advertising networks, analytics partners, and other third parties that we interface with;
• From government authorities;
• From publicly available sources; and
• From background checks and screening tools such as industry fraud prevention and detection databases and credit agencies.

8. HOW WE MAY USE YOUR PERSONAL DATA

• We collect Personal Information primarily for the Purpose defined and to enable Us to provide Our Services to You or help you browse Our Website, seamlessly.
• We may share Your Personal Information in an anonymized form with any other third party as required under Applicable Law in order to perform Our Services. Any User Data that We have access to is never shared without Your consent.
• The Personal Information We collect allows Us to keep You posted on Our latest announcements, and upcoming events, including confirmations, security alerts, and support and administrative messages, that You have specifically requested for. It also helps Us to improve Our Services. If You do not want to be on Our mailing list, You can opt-out at any time by unsubscribing to Us, through the usage of Your mail ID.
• From time to time, We may use Your Personal Information to send important notices, such as communications and changes to Our Terms of Use or Privacy Policy. Since this information is important to Your interaction with Us, You may only opt out of the same, only after communicating with Us or choosing to delete Your profile with Us. We may also use Personal Information for internal purposes such as data analysis and research to improve Our Services, products, and customer communication.
• We collect Non-Personally Identifiable Information about Our Users generally to improve features and functionality of Our Website. We may analyze trends through aggregated demographic and psychographic offers to Users. We may also share this Non-Personally Identifiable Information with Our partners to allow them to assist Us in delivering tailored advertisements, promotions, deals, discounts, and other offers to You when You use the Services. We collect information from You when You use Our Website and decide to avail services provided by Us.
• We may also collect information about You through other methods, including research surveys or information We obtain from third parties, including verification services, data services, as well as public sources. We shall not be responsible for any breach of privacy, or any issues related to the accuracy of such third-party data or third-party information.
• Personal Information, personally identifiable information, and/or Financial Information shall be collected by the Website on an ongoing basis, without the need for further, separate consent from the User (aside from the acceptance of this Privacy Policy) for one or more of the Purposes mentioned under Clause 7.
• We may aggregate or de-identify personal data and use the aggregated information by excluding and removing data components (such as your name, email address, or linkable tracking ID) through obfuscation, or through other means so that the resulting dataset is no longer personally identifiable to You (“Aggregated Data”) to analyze the effectiveness of our Sites and/or Services, to improve and add features to our Sites and/or Services, to conduct research and for other similar purposes. In addition, from time to time, We may analyze the general behavior and characteristics of users of Our Services that do not identify a particular individual and share Aggregated Data like general user statistics with third parties, publish such Aggregated Data, or make such Aggregated Data generally available. We may collect Aggregated Data through the Services, through cookies, and through other means described in this Policy. We will maintain and use Aggregated Data in anonymous or de-identified form, and We will not attempt to reidentify the information.
• In connection with a job application or inquiry, whether advertised on the Site or otherwise, You may provide Us with information about Yourself, such as a resume. We may collect Your Personal Information in connection with Our HR operations, such as Your employee orientation, benefit enrolment, performance review, and compliance with applicable employment laws in Your jurisdiction. We may use this information throughout the Company to address Your inquiry and consider You for employment opportunities, and HR operations purposes.
• We may also use Your Personal Information to protect the rights or property of the Company, Our business partners, suppliers, clients, or others when We have reasonable grounds to believe that such rights or property have been or could be affected. In addition, We reserve the right to use Your Personal information as may be required or otherwise permitted by law, or when We believe that disclosure is necessary to protect Our rights, or the rights of others, or to comply with a judicial proceeding, court order, law enforcement, or legal process.
• We may use Your personal information for auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.
• We may use Your personal information for debugging to identify and repair errors that impair existing intended functionality.
  We may use Your personal Information for undertaking internal research for technological development and demonstration.
• We may use Your personal data for other purposes that are consistent with, related to, and/or ancillary to the purposes and uses described in this Policy, for which Your personal data was provided to Us.

9. HOW WE MAY SHARE AND DISCLOSE YOUR PERSONAL INFORMATION

• As a global organization with business processes, management structures, and technical systems that cross borders, We may share information about You within Our group of companies, and with certain service providers or third parties. We may transfer information about You to various countries in the world where We do business in connection with the purposes identified above and in accordance with this Policy. Our Policy and Our internal policies and practices are designed to provide a globally consistent level of protection for personal data all over the world. Even in countries where laws provide for less protection for Your information, We will still handle and protect Your information in the manner described in this Policy. We only share Personal Information with other companies or individuals in the following limited circumstances –
• We may share with third parties the location of Your device in order to improve and personalize Your experience of the Service.
• We may share with third-party certain pieces of non-personal information, such as the number of Users who are using Our Services, Users who clicked on a particular advertisement or who skipped a particular advertisement, as well as similar aggregated information. Such information does not identify You individually.
• We may share with third parties Your unique device ID. While such information does not by itself identify You to Us, it may be unique or consist of or contain information that You consider personal, however, such information does not identify You individually.
• We provide such information to trusted businesses or people for the purpose of processing Personal Information and or other information on Our behalf. We require that these parties agree to process such information based on Our instructions and in compliance with this Privacy Policy and any other appropriate confidentiality and security measures.
• Advertisers: We allow advertisers and/or merchant partners (“Advertisers”) to choose the demographic information of Users who will see their advertisements and/or promotional offers and You agree that We may provide any of the information We have collected from You in non-personally identifiable form to an Advertiser, in order for that Advertiser to select the appropriate audience for those advertisements and/or offers.
• Legal Requirement: We may use or disclose Your Personal Data in order to comply with a legal obligation, in connection with a request from a public or government authority, or in connection with court or tribunal proceedings, to prevent loss of life or injury, or to protect Our rights or property. Where possible and practical to do so, We will tell you in advance of such disclosure.
• Service Providers: We may share Your personal data with service providers, suppliers, and other alliance partners located in various countries to manage or support its business operations, provide professional services, deliver customer services and solutions, and otherwise process information on Our behalf. It is Our practice to require such service providers, suppliers, and alliance partners to handle Personal Information and other confidential information in a manner consistent with Our policies and applicable laws.
• Acquisitions and Similar Transactions: Circumstances may arise where, whether for strategic or other business reasons, We decide to sell, buy, merge, or otherwise reorganize businesses in some countries. Such a transaction may involve the disclosure of Personal Information to prospective or actual purchasers, or the receipt of such information from sellers. It is Our practice to seek appropriate protection for information from the prospective or actual purchaser in these types of transactions.

10. CROSS BORDER INFORMATION FLOW

11. INFORMATION SECURITY

12. DATA RETENTION

13. ONLINE MARKETING

14. EXTERNAL LINKS

15. PURPOSE AND LEGAL BASIS FOR THE PROCESSING OF PERSONAL DATA

• To deliver your product or Service and performing a contract;
• Building a Safe and Secure Environment;
• To verify or authenticate Your identity;
• Investigating and preventing security incidents such as breaches, attacks, and hacks;
• Providing, developing, and improving our products and Services;
• Delivering, maintaining, and debugging our products and Services;
• Enabling You to access our Services and set up accounts;
• Providing You with technical and customer support;
• Organizing and delivering advertising and marketing;
• Sending You newsletters and other marketing communications about current and future products, programs and Services, events, competitions, surveys, and promotions held by Us or hosted on Our behalf;
• Organizing events or registering attendees and scheduling meetings for events;
• For research and development;
• To pursue Our legitimate interests;
• To comply with public interest where applicable;
• To communicate with You about the products and Services; and
• To comply with legal obligations.
  Where We process Your Personal Data to provide a product or Service, we do so because it is necessary to perform contractual obligations. All of the above processing is necessary in Our legitimate interests to provide products and services to maintain Our relationship with You and to protect Our business, for example, against fraud. Consent will be required to initiate Services with You. New consent will be required if any changes are made to the type of data collected. Within Our contract, if You fail to provide consent, some services may not be available to You.

16. CHILDREN’S PRIVACY

17. MECHANISM OF SHARING DATA WITH THIRD PARTIES

• endorse or make any representations about any information, products, or services reached on third-party sites;
• control the privacy practices of any third parties regarding their independent collection or use of Your Personal Information; and

18. PRINCIPLES FOR PROTECTION OF PRIVACY

• Commitment to Privacy: The Website is strongly committed to Users’ right to privacy and to keeping Users’ Personal Information and Financial Information secure. To earn Users’ trust and confidence, We are fully disclosing Our privacy practices. We encourage Users to read our Privacy Policy to understand what types of Personal Information We collect and how We use this information.
• Applicability: This Privacy Policy sets forth the reasonable security practices and procedures adopted by Us and shall apply to the use, disclosure, and sharing of Personal Information provided by the Users of the Website which is owned and operated by Us. This policy is equally applicable on the visiting the Website or using Our Services. The Privacy Policy outlines the various measures undertaken by Us to provide Users with a convenient and safe online/ experience, while maintaining and safeguarding the confidentiality, integrity, and security of Users’ Personal Information, during storage and transmission through the world wide web. This Privacy Policy explains how We protect Personal Information provided by Users through the Website and how We store and use that information, to deliver the Services.
• Choice: You may choose whether / not to provide Your Personal Information. If You choose not to provide the Personal Information the Website requests, You may still visit the Site, but You may be unable to access the Services. If You choose to avail Our Services, We will naturally continue to contact You in connection with the said Services. We neither collect nor store Your biometric information.
• Access/Accuracy: To the extent that You do provide Us with Personal Information, We wish to maintain accurate, true, and complete Personal Information. When We collect Personal Information from You, we aim to be able to reach out to You. You should keep Your information updated and correct. If for any reason Your information is inaccurate, You may send updates and corrections about Your Personal Information to Us, and We shall make reasonable efforts to incorporate the changes.
• Change in Policy: This Privacy Policy is subject to change at any time, and it is advised that Users review this Privacy Policy periodically. Any change to this Privacy Policy will become effective as soon as it is posted or linked to the revised Privacy Policy on the Website. Users shall receive a notification whenever there is a change in our Policy on Users’ registered email ID and the issuance of the notification shall constitute a fair amendment of the Privacy Policy.
• Retraction of User Consent: If at any time such changes are not agreeable to a User, then the User may terminate his/her registration with the Website, stop availing Our Services, and usage of the Website. Such termination and/or stopping of further use shall not result in any automatic deletion of Users’ Personal Information already stored with Us and We take no responsibility or make any representation that would imply otherwise. However, We can assure You that the User’s Personal Information will be deleted or cease to be retained by Us within a reasonable time as permitted under Applicable Laws.
• Users’ Responsibility: It shall be the responsibility of the Users to read and assess such changes in the Privacy Policy once such notifications have been sent to the Users’ registered email ID.

19. EMAIL NOTIFICATIONS

20. PURGING OF PERSONAL INFORMATION

21. YOUR RIGHTS REGARDING PERSONAL DATA

• Right to Access (GDPR Article 15, CCPA/CPRA). You have the right to learn whether We are processing Your Personal Data and to request a copy of the Personal Data We are processing about You.
• Right to Rectification (GDPR Article 16, CPRA). You have the right to have incomplete or inaccurate Personal Data that We process about You rectified.

22. SPECIFIC PRIVACY RIGHTS FOR EU USERS

• Right to Restriction of Processing (GDPR Article 18) . You have the right to restrict Our processing of Your Personal Data under certain circumstances. In this case, We will not process Your Data for any purpose other than storing it.
• Right to Portability (GDPR Article 20). You have the right to obtain Personal Data we hold about You, in a structured, electronic format, and to transmit such Personal Data to another data controller, where this is (a) Personal Data which You have provided to Us, and (b) if We are processing that data on the basis of Your consent or to perform a contract with You or the third party that subscribes to ProcDNA LLC / ProcDNA Analytics Pvt. Ltd. services.
• Right to Objection (GDPR Article 21). Where the legal justification for our processing of Your Personal Data is Our legitimate interest, You have the right to object to such processing on grounds relating to Your particular situation. We will abide by Your request unless We have compelling legitimate grounds for processing which override Your interests and rights, or if We need to continue to process the Personal Data for the establishment, exercise, or defense of a legal claim.
• File a Complaint (GDPR Article 77). You have the right to bring a claim before their competent data protection authority. If You are based in the EEA, please visit this website (https://edpb.europa.eu/about-edpb/about-edpb/members_en) for a list of local data protection authorities.

23. SPECIFIC PRIVACY RIGHTS FOR CALIFORNIA USERS

• Right to Opt-Out (CPRA).You have the right to opt out of the processing of Your Personal Data for purposes of:
• Targeted advertising;
• The sale of Personal Data; and/or
• Profiling in furtherance of decisions that produce legal or similarly significant effects concerning You. Under CPRA, You have the right to opt out of the sharing of Your Personal Data with third parties and our use and disclosure of Your Sensitive Personal Data to uses necessary to provide the products and services reasonably expected by You.
• Nondiscrimination and nonretaliation (CCPA/CPRA).You have the right not to be denied service or have an altered experience for exercising Your rights.
  For Your own privacy and security, at Our discretion, We may require You to prove Your identity before providing the requested information.

24. RIGHT TO INJUNCTIVE RELIEF

25. LIMITATION OF LIABILITY

• any loss that Users may incur as a consequence of unauthorized use of User’s account or account information;
• Any interruption or non-availability of the website during periodic maintenance or for any other reason including but not limited to systemic failures and acts of God;
• Any inaccuracy, error, omission, interruption, completeness, deletion, defect, failure of performance, computer virus, communication line failure, alteration of, or any use of content herein, regardless of cause, for any damages resulting therefrom;
• Any loss of opportunity, goodwill, or reputation; or any indirect or consequential loss or damage arising howsoever;
  Accuracy, correctness, or originality of any data including all indices published on the website whether the same is third-party data or otherwise; or

26. HOW TO EXERCISE YOUR RIGHTS AND INFORM YOUR GRIEVANCES

27. INDEMNITY

28. DISCLAIMER

29. NOTIFICATION OF CHANGES

30. GOVERNING LAW AND DISPUTE RESOLUTION

31. INQUIRIES AND CONTACT