Privacy Policy

ASPIC Innovations Pvt. Ltd. (“ASPIC Innovations”, “us”, “we” or “our”) provides this Privacy Policy (“Policy”) to inform you of our policies and procedures regarding the collection, use and disclosure of personally identifiable information we receive when you, as a user –

• Visit ASPIC Innovations (including any subdomains of this website or other websites owned by us or operated on our behalf) (the “Website”);
• Download any of our Products, namely f-lambda / f-lambda Vita / f-lambda Vita-DX (the “Product”);
• Use any of our services via the Website or the Product (the “Services”);
• Visit or correspond with our offices at AC 133, Sector 1, Saltlake, Kolkata, West Bengal 700064, India or Module 402, Phase: I, Webel IT Park, DH Block, New Town, Kolkata – 700156, West Bengal, India
• Correspond with any of our Directors or Staff over their Corporate Email IDs.

It is clarified that this Policy refers to personally identifiable information we receive via any of our Services, thus not all of the Policy’s provisions necessary apply to both Website and Product.

Your privacy is important to ASPIC Innovations.

We wish to make sure you know how we collect, use, share and store your personal data when you use our Product.

By using our Product and Services, you provide consent to the privacy practices described in this Policy.

Our Services are for general audience and are neither designed nor intended to collect personally identifiable information from children or minors. We do not knowingly collect personally identifiable information of persons below the age of 18. If you become aware that someone under the age of 18 has provided us with personally identifiable information, please contact us.

This Policy covers our collection, use and disclosure of your information through the Product and the Website. It does not cover any collection, use or disclosure by third parties through any applications, web sites, products or services that we do not control or own or any third-party features or services made available via the Product or the Website.

Please note: If your use of the Product or any of the Services is pursuant to an invitation from, or subject to a license purchased by, a customer of ours which is an organization with which you are affiliated or connected (an “Organizational User”), the Organizational User is the Controller or Owner of your personally identifiable information. In such case, we are merely a processor of the personally identifiable information on behalf of the Organizational User. Your data as an end-user will still be collected and processed as described hereunder. However, in those cases, your information is under the responsibility of the Organizational User, and any inquiry or complaint regarding your personally identifiable information should be addressed directly to it.

 

Summary of The Policy

1. Information That We Collect
   In the course of using any of our Services, the following information may be collected and processed by us:
   • your personally identifiable information, including contact and registration information such as your name, your organization’s name, email address, phone number, as well as information such as gender, age, etc.,
   • payment details in order to process payments if you make any purchases,
   • personal demographic information like location of stay etc.,
   • personal lifestyle information related to fitness habits, healthcare habits, social habits etc.,
   • medical information including medical history including family cancer history, health symptoms, ailments and medical diagnostic reports and scans, prescriptions,
   • your contact info in the form of Email ID, Mobile No.,
   • technical information related to you, such as IP addresses, browser information, mobile device information etc.,
   • certain marketing or analytics or usage data, such as Cookies, Pixels, Web beacons, etc.,
   • aggregated information such as statistical or usage data for any purpose, which may be derived from your personally identifiable information,

2. How We Use Personally Identifiable Information ?
   We use personally identifiable information to deliver our services via our Product, improve and develop it, provide better support, improve your user experience, enforce terms, contact you or provide with information regarding our services, and protect us and the Product from misuse and law violations.

3. Information Sharing and Disclosure
   We share information when we use service providers, for example, our external consultants or to process payments or host the services. We may transfer information when we change our corporate structure, and we will also share information when required to do so by law enforcement or compliance requests. When your use of the Product is under an Organizational User, your personally identifiable information is shared with such Organization.

4. Your Choice
   You may opt-out of our mailing lists or SMS’s (except for operational emails and SMS’s) by writing to us.

5. Accessing Your Personally Identifiable Information
   At any time you can request to receive your personally identifiable information collected by us while using the Services via our Product.

6. Data Retention
   We retain data to provide the Services and for legitimate and lawful purposes.

7. Information Security
   Our Website, Systems and Product are hosted with reputed hosting and cloud service providers who, to the best of our knowledge, implement systems, applications and procedures to secure your personally identifiable information, to minimize the risks of theft, damage, loss of information, or unauthorized access or use of information. Within our Product, all your personally identifiable information is stored in an encrypted manner following HIPAA guidelines.

8. Our Policy Towards Children
   If you are under the age of 18, you do not have permission to use our Product.

9. Dispute Resolution
   Contact us at: contact@aspicinnovations.com or write to us for any request or complaint. We will make good-faith efforts to resolve any existing or potential dispute with you, but reserve all rights to handle disputes through courts and authorities of competent jurisdiction to which this Policy is subject.

10. Changes to this Privacy Policy
    We may update our Policy from time to time and give you notice once it is completed.

11. Incorporation to the Terms of Use
    This Policy is also an integral part of the applicable ASPIC Innovations’ terms of use or any other agreement entered into between you (or the entity that you are acting on behalf of) and us with respect to your end-use of the Products.

Contact Us– Please contact us at: contact@aspicinnovations.com for further information.

ASPIC Innovations’ Privacy Policy

1.  Controller and Processor

Where you are a direct user of the Product, Website or Services, or contacting us directly, we process your personally identifiable information as the controller, meaning that legally, we deem as the owner of you personally identifiable information. In those cases, and for GDPR purposes, we assume the role of Data Controller, and any of our external supplier shall be deemed as Data Processor.

Where you use the Product or any of the Services as a member/user from an Organizational User, we merely process your personally identifiable information on behalf of the Organizational User which is the owner of your personally identifiable information. In those cases, and for GDPR purposes, the Organizational User is the Data Controller, and we assume the role of Data Processor. That means, that in those cases your personally identifiable information is being managed under the control and instructions of the Organizational User, which is responsible for the lawful basis for processing (the legal justification allowing the processing), including any consent or disclosure relevant.  Therefore, any inquiry or complaint regarding your personally identifiable information should be addressed directly to the Organizational User. With no prejudice to any of our legal obligations as a Processor, we are not responsible for the actions nor use by the Organizational User of your personally identifiable information.

 

2.  Information That We Collect

“Personally Identifiable Information” or “Personal Data” (“PII”) means any information about an individual from which that person can be identified.

As a condition to your use of the Product, we will ask you to provide us with certain PII that we can use to contact or identify you and administer your account. PII may include your name, gender, birthdate, age, weight, height, organization’s name, email address, telephone number, contact person details, lifestyle and social habits. Additionally, we collect, medical information, medical history (self and family in some cases), existing ailments or symptoms and medical diagnostic reprots and scans.

When you contact us, or when we contact you, we will receive and process any PII that you provide us.

When you use the Product, we may collect the following, as applicable:

• Information regarding your use of the Product and all information provided by you or recorded while you use the Product, including your preferences and other data relevant for customizing the Services for you;
• Information on your usage of the Product and download errors, as well as information related to your use of the Website that your browser sends whenever you visit the Website or use the Product (collectively “Log Data”). This Log Data could include, for example, your computer’s Internet Protocol address, browser type, mobile operating system, login information, the web page you were visiting before you came to the Website and information you search for on the Website;
• Aggregated Data, allowing us, inter alia, to analyze and better understand your use of the Services including the full website (uniform resource locators (URL)) clickstream (history) to, through and from our Website (including date and time) etc.;
• Products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks and mouse-overs), and methods used to browse away from the page.

When you use a widget or any other tool that may be offered by us, whether on the Website or on a third-party website, including a website owned or operated by you, we may record data related to that activity, the deployment of the widget or tool and any other account related data.

Links to Other Websites

Links to other websites are presented in a format that enables us to keep track of whether these links have been followed.

Third Party Sites

This Privacy Policy applies only to our Website, Products and Services. We do not exercise control over other websites that provide information, banners, advertisements, or links from within our Website or Products.

These other sites may place their own cookies or other files on your machines, collect data or solicit PII from you. Other websites follow different rules regarding the use or disclosure of the PII that you submit. We encourage you to read the privacy policies and other relevant terms of the other websites.

Job Applicants

If you are voluntarily making a job application or inquiry through our Website, you may provide us with a copy of your resume or other relevant information that contains your PII. We assume your consent to use and save the information that you provide in your job application and will use this information for the purpose of considering your application or inquiry. Except when you explicitly request otherwise, we may keep this information for future reference.

Market Research

If you participate in surveys through our Website or Products, we may use your PII to carry out market research and other relevant anaylsis. This research / analysis is conducted for our internal business and training purposes and will improve our understanding of our users’ demographics, interests and behavior apart from helping us improve our Products and Services.

Aggregated Data

We may also use subsets of information collected through the Product and our Website in aggregated non-identifying form (“Aggregated Data”) to compile statistical information and insights related to performance or use of the Product and/or Website, and use such statistical information and insights for improving our Products, developing new Products, generating reports, customizing Products and other uses specified in Section 2 (including without limitation for research purposes or public use in aggregated non identifying form). For further information on how we transfer and use such Aggregated Data, see the Transfer of Aggregated Data section in this Policy.

3.  The Purposes of Processing PII and Non-PII data

PII may be used for the following purposes:

• to provide you with any of our Services as a part of our Website or Products,
• to carry out analysis on information provided, including your medical records,
• to administer your use of the Product and any accounts you may have with us, to personalize your experience,
• to monitor and analyze your use of the Product or any of the Services,
• to improve your user experience,
• to provide to you Product announcements and notifications,
• to provide you recommendations related to our Services,
• to provide you with further information and offers from us or third parties that we believe you may find useful or interesting, such as products or services to purchase, newsletters, marketing or promotional materials,
• on behalf of and according to instructions of a third party, such as our advertising partners,
• to enforce our terms of use, including managing the licensing of the Product,
• to comply with court orders and warrants, and assist law enforcement agencies, to collect debts, prevent fraud, misappropriation, infringements, identity thefts and any other misuse of our Products, and to take any action in any legal dispute or proceeding.
• to improve our Website, Products and their accuracy,
• to contact you as per your request, manage our correspondence with you and provide you with customer service,
• as described in Section 4: Information Sharing and Disclosure.

We use information that is not personally identifiable (non-PII) for the above purposes and for:

• the technical administration of our Website and/or Products,
• collecting and analyzing the use of our Website and/or Products,
• improving our Website, the Product, and any of the Services,
• generating and deriving useful data and information concerning the interests, characteristic use behavior of our users,
• verifying that users of the Product meet the criteria required to process their requests, and
• Using the Aggregated Data as described herein.

Combined Information

We combine certain PII with non-PII in order to allow us to create information packages and services that are better tailored to your interests and preferences. Among other things, linking this information may allow us generally to improve and personalize our Website and Products. The combined information is always treated and handled by us as part of your PII, as it allows us to link the information to you.

Purchase of Products and Services

If you purchase or use our Product, we may use your PII, as applicable, and (where applicable) payment information for purposes which include but are not limited to:

• verifying your credentials;
• verifying your usage of the Product and/or Services in accordance with the terms and conditions of usage of our Products;
• providing training sessions for which you have registered;
• providing maintenance and technical support;
• providing information about product upgrades, updates and renewals;
• generating logs, statistics and reports on service usage and service performance;
• developing and enhancing products and services;
• processing orders and generating billing information.

We will use collected information in order to contact you if necessary, including, but not limited to, sending you reminders and notifications about our Products or Services, including in-app notificiations, sending commercial and marketing information about our Service, contacting you when you are using wrong paths to access our Website or are breaching restrictions on the use of our Website. Except for notificiations which are mandatorily a part of any of our Products you are using, if you decide at any time that you no longer wish to receive such announcements, information or offers, please follow the unsubscribe instructions provided in the communication. We may also use this information to block IP addresses where there is misuse of our Website.

4.  Information Sharing and Disclosure

We do not sell, rent or lease your PII. We may disclose your PII to third parties in a variety of circumstances in the ordinary course of operating our business, such as:

Service Providers
We may employ third party companies and individuals to facilitate the Product, to provide the Product on our behalf, deliver services hosted on the Products and to deliver services related to hosting or administration of the Product or our Website (including, without limitation, bill and credit card payment processing where and if relevant, maintenance, hosting and database management services and administration). These third parties have access to your PII only to perform the tasks for which they are retained or services you have subscribed to. In addition, in any such case we will take steps to ensure the security and privacy of your PII, and it will be subject to contractual terms ensuring the security and protection of any PII under any such sub-processor, under applicable law provisions;

YOU FURTHER ACKNOWLEDGE THAT WE DO NOT CONTROL OR OPERATE THE SERVICES OF OUR SERVICE PROVIDERS WHICH ARE NOT PART OF OUR ORGANIZATION (SUCH AS EXPERT CONSULTANCY ON DIFFERENT TOPICS OR HOSTING OR CLOUD SERVICE PROVIDERS OR PAYMENT PROCESSING SERVICES), NOR DO WE CONTROL ORGANIZATIONAL USERS. WE SHALL HAVE NO LIABILITY WHATSOEVER WITH RESPECT TO OR IN CONNECTION WITH THE USE, TRANSFER, OR RETENTION OF INFORMATION BY SUCH SERVICES PROVIDERS OR ORGANIZATIONAL USERS, OR THE FAILURE OF SUCH PARTIES TO COMPLY WITH THIS PRIVACY POLICY OR ANY LAW OR REGULATION.

Organizational Users

When your use of the Product is pursuant to an invitation from, or subject to a license purchased by an Organizational User, the Organizational User will have access to all or parts of the information related to you, including without limitation PII, provided by you or collected through the applicable Product. When you use a Product pursuant to such license or invitation, we understand that you have provided the Organizational User with your consent for sharing your information. While we require of our Organizational Users to abide by requirements substantially similar to these terms and by applicable law, we cannot (and do not) ensure such compliance, and under no circumstances we will be held responsible for the actions of Organizational Users.

Compliance with Laws and Law Enforcement

We cooperate with government and law enforcement officials and private parties in response to lawful requests and to comply with the law. We will disclose any information about you to government or law enforcement officials or private parties if we believe it necessary:

• to respond to lawful requests by public authorities, including to meet law enforcement or national security requirements, claims or legal processes (including but not limited to subpoenas);
• to protect our or a third party’s property rights;
• to protect the safety of the public or any person;
• to prevent or stop any activity we may consider to be posing a risk of being illegal, unethical, inappropriate or legally actionable.

Business Transfers

We may sell, transfer or otherwise share some or all of our assets, including among others your PII and Log Data, in connection with a merger, acquisition, reorganization or sale of all or substantially all of our applicable assets, or in the event of our bankruptcy.

Transfer of Aggregated Data
We may share Aggregated Data generated as a result of your use of our Products, that includes non-PII, anonymized aggregated personal information and/or Log Data, with third parties for industry analysis, demographic profiling, other commercial purposes and to deliver targeted advertising about other products and services.

We use standard, commonly used analytics tools and we may use additional or other analytics tools, from time to time, to learn about how you and other users use the Services, in support of our Services-related activities and operations. The privacy practices of these tools are subject to their own privacy policies.

It is clarified that any Aggregated Date shared in these contexts is based on anonymous, statistical or aggregated information and we share it with our partners only for legitimate business purposes. It does not contain PII and it has no effect on your privacy, because there is no reasonable way to extract data from the aggregated information that we or others can associate specifically to your PII.

5.  Your Choice

At any time, you can unsubscribe from our mailing lists (except for operational emails) by sending us an opt-out request to: contact@aspicinnovations.com.

Note that if one of our customers uploaded content to our Services with your PII, then you can contact our customer who uploaded that content and request to remove your PII.

At any time, you can exercise your following opt-out options:

• object to the disclosure of your PII to a third party, other than (a) to third parties providing services which you have purchased or shown interest in, (b) medical professionals to whom you have agreed to share your medical data and records, (c) to third parties who act as our agents to perform tasks on our behalf and under our instructions, (d) when your use of the Product pursuant to the invitation from, or subject to a license purchased by, an Organizational User, in which case your information will be shared with the Organizational User so long as you use the Product as aforementioned; or
• object to the use by us of your PII for a purpose that is materially different from the purposes for which we originally collected such information, pursuant to this Policy, or you subsequently authorized such use.

You can exercise your choice by contacting us at: contact@aspicinnovations.com. We request and collect PII that we need for the purposes that we describe in this Policy. Following the termination or expiration of the Services, we will stop collecting any PII from or about you. However, we will store and continue using or making available your PII according with our data retention section in this Policy. Web browsers offer a “Do Not Track” (“DNT”) signal. A DNT signal is a HTTP header field indicating your preference for tracking your activities on a service or through cross-site user tracking. Our Services do not respond to DNT signals.

6.  Accessing Your PII

If you find that the information on your account is not accurate, complete or up-to-date, please provide us the necessary information to correct it. At any time, you can contact us at: contact@aspicinnovations.com and request to access the PII that we keep about you. We will ask you to provide us certain credentials to make sure that you are who you claim to be and to the extent required under the applicable law, will make good-faith efforts to locate your PII that you request to access. If you are eligible for the right of access under the applicable law, you can obtain confirmation from us of whether we are processing PII about you, and receive a copy of that data, so that you can –

• verify its accuracy and the lawfulness of its processing;
• request the correction, amendment or deletion of your PII if it is inaccurate or if you believe that the processing of your PII is in violation of the applicable law.

We will use judgement and due care to redact from the data which we will make available to you, PII related to others.

7.  Data Retention

We retain different types of information for different periods, depending on the purposes for processing the information, our legitimate business purposes as well as pursuant to legal requirements under the applicable law. We retain PII as part of our Services, to provide our customers with the Services as part of our Products and as needed to perform our business activities. We may maintain contact details, to help us stay in contact with you.

We may need to keep the information about the payment transactions that you made for several years due to tax related requirements, for accounts settling, record keeping, archiving and legal issues.

We may keep aggregated non-identifiable information without limitation, and to the extent reasonable we will delete or de-identify potentially identifiable information, when we no longer need to process the information.

In any case, as long as you use our Products or Services, we will keep information about you, unless we are required by law to delete it, or if we decide to remove it at our discretion.

8.  Information Security

We are concerned with safeguarding your information. Our website, systems and products are hosted with reputed hosting and cloud service providers who, to the best of our knowledge, employ a variety of measures designed to protect your information from unauthorized access and disclosure. To the best of our knowledge, they implement systems, products and procedures to secure your PII, to minimize the risks of theft, damage, loss of information, or unauthorized access or use of information. To the best of our knowledge they take reasonable steps to maintain the security of the PII that we collect, including limiting access to the servers. However, we do not control or operate the services of our service providers which are not part of our organization (such as the hosting or cloud service providers or payment processing services) and no one can guarantee a completely secured data transmission over the Internet. Accordingly, we cannot ensure or warrant the security of any information that you transmit to us, so you do so at your own risk. If you have been given log-in details to provide you with access to certain parts of our Website or Product, you are responsible for keeping those details confidential.

We also understand that your health information is private and we take its protection very seriously. We are committed to complying with the Health Insurance Portability and Accountability Act (HIPAA) of 1996, which protects the privacy of personal health data. Firstly, your PII including any health information you share or store in our Product is stored in an encrypted form within our Product and all data transfer is done over secured channels. Secondly, we will only use and disclose your PII including your personal health information for the purposes of providing you with relevant Services as part of our Products and/or obtaining payment for those services. Wherever your health information has to be shared, we will also obtain your confirmation within the Product before sharing your health information for any purpose. You have the right to access, copy, and amend your health information maintained by us. You can also request a restriction on how we use or disclose your health information or other PII as well as request to receive confidential communications from us.

If you receive any email seeking or asking you to update your PII, do not reply and please contact us at contact@aspicinnovations.com.

9.  Our Policy Towards Children

If you are under the age of 18, you do not have permission to use our Products. If a parent or guardian becomes aware that his or her child has provided us with PII without their consent, he or she should contact us at contact@aspicinnovations.com. If we become aware that a minor has provided us with PII, we will delete such information from our files.

10.     Dispute Resolution, Governing Law and Venue

We do periodic assessments of our data processing and privacy practices, to make sure that we comply with this Policy, to update the Policy when we believe that we need to, and to verify that we display the Policy properly and in an accessible manner. If you have any concerns about the way we process your PII, you are welcome to contact us at: contact@aspicinnovations.com, or write to us. Our address is published on our website and, if applicable, is indicated in your subscription agreement with us.

We will look into your query and make good-faith efforts to resolve any existing or potential dispute with you, but reserve all rights to handle disputes through courts and authorities of the competent jurisdiction to which this Policy is subject.

Any disputes or claims arising out of or in connection with this Policy, will be governed by and construed in accordance with the laws of the territory specified in your applicable engagement agreement with us (aside from this Policy), and if none, then this Policy shall be construed and enforced in all respects in accordance with the laws of India, without reference to principles of conflict or choice of law and the courts located in Kolkata, India shall have exclusive jurisdiction over any dispute or matter in connection with this Policy. You irrevocably waive any and all claims and defenses you might otherwise have in any such action or proceeding in any of such courts based upon any alleged lack of personal jurisdiction, improper venue, forum non convenience or any similar claim or defense.

11.     Changes to the Privacy Policy

We will update this Policy from time to time. If we make any changes to this Policy, we will post a notice of these changes on our Product or our Website and in this Policy. If the updates have minor if any consequences, they will take effect 7 days after we post a notice on our Website. Substantial changes will be effective 30 days after we initially posted the notice. Continuing to use the Services after the new policy takes effect means that you agree to the new policy. Note that, despite the foregoing, if we need to adapt the Policy due to legal requirements, the new policy will become effective immediately or as required by law.

12.     Incorporation to the Terms of Use

This Policy is an integral part of the applicable ASPIC Innovations’ Terms of Use or any other agreement(s) entered into between you (or the entity that you are acting on behalf of) and us with respect to your end-use of the Products.

13.     Contact Us

Please contact our Privacy Compliance Team at: contact@aspicinnovations.com for further information.

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Last Updated on July 21, 2024.