PRIVACY POLICY

Please read the following Privacy Policy applicable to the services made available on https://www.marrow.com or the equivalent Marrow Mobile Application available on Google Play Store or Apple Store (“Services”) (“Marrow App”/ “Website”). The Marrow App or Website on which the Services are availed may together be referred to for convenience as the “Platform”.

For the purpose of these privacy policies, wherever the context so requires “Your”, “You" or "User" shall mean any natural or legal person who browses the Platform or has agreed to become a subscriber to the Services on the Platform by providing login credentials by registering on our website as a Subscribed User. The term "We", "Us", "Our" shall mean Neuroglia Health Private Limited (“Marrow”) and Our affiliated entities.

Please ensure that this Privacy Policy is perused by You before availing any Services from Us. This Privacy Policy shall be updated from time to time and to stay abreast with our methods of using Your information and protecting Your privacy, please keep reviewing this Policy. If we decide to change our Privacy Policy, We will post those changes on this page so that You are always aware of what information We collect, how We use it, and under what circumstances We disclose it. If You do not agree for the foregoing, please do not continue to use or access our Website. In the event You discontinue Your consent for sharing any Information as required herein or retract Your consent at a subsequent date, We reserve the right to, at our sole discretion, discontinue or restrict Your access to the Marrow Platform, and in such event We will not be liable for any payment or refund on such account. We may review and change this Policy from time to time to reflect changes in the law, our business practices, processes or structure. This Policy is not a contract, nor does it suggest any obligation on our part with another party.

By viewing the Marrow Platform, you agree to be bound by the terms of this Privacy Policy.

By using the Marrow Platform and/or by providing Your information, You consent to the collection and use of the information You disclose on our Website in accordance with this Privacy Policy, including but not limited to your consent for sharing your information as per this Privacy Policy.

Any questions about this Privacy Policy may be directed to support@marrowmed.com. You may also contact Our Grievance Officer by writing to Marrow support at support@marrowmed.com.

This Privacy Policy is not intended for Our employees as they are subject to other policies specifically applicable and notified to them.

1. Collection of Personally Identifiable Information
   1. When You interact with Us, for example by visiting Our offices, corresponding with Us by email, post or telephone, or registering on Our Platform, We collect personal information about you (such as Name; Telephone Number; Email Address; Service Address; Other information about the service address which You give Us; Your IP address; Information about your device; Network information; College/ Institution Details and location; User uploaded photo and ids; Demographic information such as postcode, preferences and interests; Any other personal information which you give Us while booking a service or is relevant to customer surveys and/or offers) to help us serve You better. We do not intend to collect your sensitive personal data or information (“SPDI”) (such as passwords, financial information, biometric information, sexual orientation, medical records and history or information about physical, physiological and mental health condition) during our interactions with you; however we may require You to provide SPDI in the form of Your live video or live selfie photo as may be sought in our sole discretion for verification purposes. We may also collect other related information such as the date and time of contact with You for the said verification. The information collected in the course of Your verification shall solely be used for completing the verification and authenticating Your transactions on the Marrow Platform. However, if we are required to collect your SPDI, we will process it only in accordance with the data protection laws of India (including obtaining express written consent, where required).
   2. We are committed to protecting your privacy and will take the relevant measures to safeguard Your personal information (including SPDI) in accordance with the Information Technology Act, 2000 (the "IT Act") and The Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (the “SPDI Rules”) and other applicable laws (collectively referred to as the “Data Protection Laws”). This Policy sets out how We use and protect the personal information (including SPDI) You give Us.
   3. To create a profile and use this Website and Services, You may be asked to provide the following information: your name, your username, password, email address, the speciality in which you practice or intend to practice (selected from a drop-down menu if applicable), year of graduation or year of joining undergraduate medical program and the name of your college or university. You may also choose to provide a picture to be associated with Your profile.
   4. We may collect and process your personal data from third parties, our business partners or from publicly-available sources.
   5. We also provide an option to register using Facebook. If you select this option, You allow us to access Your Facebook profile information including the list of Your friends on Facebook. Please note that if You register to the Platform through Facebook, You shall be subject to the Terms & Conditions and Privacy Policy of Facebook.
   6. We will store Your username, country and specialty on an unencrypted server. Your password is cryptographically hashed and Your email address is encrypted. These information elements are referred to collectively as Your “Personal User Information.” We collect and hold this information for the purpose of administering Your use of the Platform and the Services.
   7. You are and shall remain solely responsible for:
   1. maintaining the strict confidentiality of your Personal User Information;
   2. not allowing another person to use Your Personal User Information to access the Services,
   3. any and all damages or losses that may be incurred or suffered as a result of any activities that occur in Your Account;
   4. ensuring that the information submitted by You complies with Our terms and conditions; and
   5. ensuring that the information provided by You is correct and updated from time to time.
   8. You agree to immediately notify Marrow in writing by email to support@marrowmed.com of any unauthorized use of Your Personal User Information or any other breach of security. Marrow is not and shall not be liable for any harm arising from or relating to the theft of Your Personal User Information that is under Your control, Your disclosure of Your Personal User Information, or the use of Your Personal User Information by another person or entity.
   9. On receiving personal information (including SPDI) about You, You no longer remain anonymous to Us. We may use this information to do internal research on demographics, interests, and behaviour to better understand, protect and serve our customers. This information is compiled and analysed on an aggregated basis. We indicate fields that are mandatorily required to be filled and fields that are optional. You may decide whether or not to provide such information to Us.
   10. You may choose not to provide us with any personal information or information as required to provide any Services. If We do not receive information required, We may choose not to provide You with such Services.
   11. You can browse Our Website without telling Us who You are or revealing any personal information about Yourself. We may automatically track certain information about You based on Your behaviour on our Website. This information may include the URL that You just came from (whether this URL is on our Website or not), which URL You next go to (whether this URL is on our Website or not), Your browser information, and Your IP address.
   12. On our Website, We use data collection devices such as "cookies" on certain pages to help analyse Our web page flow, measure promotional effectiveness, and promote trust and safety. "Cookies" are small files placed on Your hard drive that assist Us in providing our services. We offer certain features that are only available through the use of a "cookie". You are always free to decline our cookies if Your browser permits, although in that case You may not be able to use certain features on the Website. Additionally, You may encounter "Cookies" or other similar devices on certain pages of the Website that are placed by third parties. We do not control the use of cookies by third parties.
   13. As part of the registration process for the paid subscription, every user shall have to mandatorily submit one valid identity address proof issued by the Government of India i.e., Voter's ID, Passport, MCI card, Aadhar Card etc., which shall be used to confirm the identity of each Pro User. In respect of the identification information provided by the Pro user, We confirm that We shall -
   1. Collect, store, use and disclose the identification information provided by the Pro User only for the identity verification process as part of the pro subscription;
   2. Encrypt the identification information provided by the Pro User on receipt and decrypt it at the time of verification. After the completion of the verification process, the identification information will be encrypted again and stored on Our servers; and
   3. Comply with all reasonable security practices and procedures to ensure the security of the identification information provided.
2. Use of Personal Information
   1. The information (including SPDI) collected by Us through our Website is used by Us for various purposes to enable us to serve You better:
   1. Ensuring Our contacts and records are up-to-date;
   2. For the management of Our business;
   3. To carry out Our obligations arising from any contracts entered into between You and Us;
   4. Identifying opportunities to develop Our business;
   5. In accordance with internal compliance policies;
   6. To share with legal and professional advisors, in order to seek advice in relation to Our business;
   7. To investigate complaints and suspected suspicious transactions; and
   8. To share with regulators and law enforcement agencies, to respond to investigations, court orders, legal process, or to investigate, prevent or take action regarding illegal activities, suspected fraud, or situations involving potential threats to the physical safety of any person;
   9. To find third party service providers;
   10. To improve Our products and services;
   11. To send promotional emails or messages on the Website about new products, special offers or other information which We think You may find interesting using the email address which You have provided; and
   12. To customize the Website according to your interests
   2. We may use personal information (including SPDI) to resolve disputes that may arise with the use of Our Services, help promote a safe service to all the customers, measure consumer interest in Our services, customize Your experience, detect and protect Us against error, fraud and other criminal activity, and to enforce our terms and conditions.
   3. We identify and use Your IP address to help diagnose problems with Our server, and to administer Our Websites. Your IP address is also used to help identify You and to gather broad demographic information.
3. Sharing of Personal Information
   1. We may share Your information (including SPDI) with payment service providers, regulatory authorities, and third-party agencies including but not limited to analytics and technical partners, payment facilitators, commercial partners, lending partners etc. in the event of any request from such authorities or agencies.
   2. We may disclose Your personal information (including SPDI) if required to do so by law or in the good faith and belief that such disclosure is reasonably necessary to respond to subpoenas, court orders, or other legal process. We may disclose Your personal information (including SPDI) to law enforcement offices, third party rights owners, or others in the good faith belief that such disclosure is reasonably necessary to enforce Our Terms or Privacy Policy; respond to claims that an advertisement, posting or other content violates the rights of a third party; or protect the rights, property or personal safety of Our customers or the general public.
   3. We and Our affiliates will share some or all of the collected information with another business entity should We (or Our assets) plan to merge with, or be acquired by that business entity, or re-organization, amalgamation, restructuring of business. Should such a transaction occur, that other business entity (or the new combined entity) will be required to follow this Privacy Policy with respect to all the information collected. If We are involved in a merger, acquisition, or sale of all or a portion of Our assets, Your personal information (including SPDI) may be transferred to the acquiring person or entity.
   4. We do not disclose personal information (including SPDI) about identifiable individuals to advertisers, but We may provide them with aggregate and/or anonymised information about You to help advertisers reach the kind of audience they want to target. We may make use of the information We have collected from You to enable Us to comply with our advertisers' wishes by displaying their advertisement to that target audience.
4. Retention Period
   1. We will retain Your personal information (including SPDI) only as long as is necessary for the purpose for which We have collected it or as otherwise authorised, in accordance with Our internal data retention policies.
   2. If we no longer need to use Your personal information (including SPDI) for the purposes set out in paragraph 2 above and/or We are not legally required to retain Your personal information (including SPDI), We will take reasonable steps to destroy Your personal information (including SPDI) or render it anonymous.
5. Information Safety and Security
   1. All information is saved and stored on servers which are secured with passwords and pins to ensure no unauthorised person has access to it. Once Your information is in Our possession, We adhere to strict security guidelines, protecting it against unauthorized access.
   2. In case You want to delete Your account and/or the information linked to it, You can send Us an email at support@marrowmed.com requesting the same.
   3. We will take all reasonable precautions necessary to protect Your personal information (including SPDI) from:
   1. misuse, interference and loss; and
   2. unauthorised access, processing, modification or disclosure.
   4. We may use third party data storage providers (such as cloud service providers) to store personal information (including SPDI) electronically. We take reasonable steps to ensure this information is held as securely as information stored on Our own equipment.
   5. Please note that, unfortunately, there is always risk involved in sending information through any channel over the internet. Any information You send to Us over the internet is entirely at Your own risk. Although We will do Our best to protect Your personal information, We cannot guarantee the security of Your data transmitted over the internet and We do not warrant the security of any information, including personal data, which You transmit to Us over the internet.
   6. Where We transfer Your sensitive personal data (including SPDI) within or outside India, We will ensure that Your sensitive personal data (including SPDI) is transferred to only a person or body corporate that ensures the same level of data protection that is adhered to by Us and We will take reasonable steps to ensure that Your data (including SPDI) is treated securely and in accordance with this Policy.
6. Choice/Opt-Out
   1. We provide all customers with the opportunity to opt-out of receiving non-essential (promotional, marketing-related) communications from Us on behalf of Our partners, and from Us in general, after providing Us with personal information . If You want to remove Your contact information from all lists and newsletters, please write to support@marrowmed.com requesting the same.
7. Third Party Links
   1. We use third-party advertising companies to serve advertisements when You visit our Platforms. These companies may use information (not including Your name, address, email address, or telephone number) about Your visits to this and other Website in order to provide advertisements about services of interest to You.

All other terms and conditions as applicable under the Terms and Conditions of Use https://www.marrow.com will be applicable to You and will be read along with this Privacy Policy.