Privacy Policy

OUR COMMITMENT

[ECI Services Pte Ltd] ("we", "us", “our”, “Company”) is strongly committed to the data subject's ("you", "your", "subscriber", "user") right to privacy and recognizes the need for appropriate protection and management of any personally identifiable information ("Personal Information") or information which is sensitive for the user (“Sensitive Information”), which is shared with us through [www.eldercare.international] (“Website”) or [Elder Care app] (“Mobile App”). To earn your trust and confidence in our commitment, we are fully disclosing our privacy practices. We encourage you to read our Privacy Policy to understand what types of personally identifiable information we collect and how we use this information. The reference to Website shall also include its applications.

This privacy policy describes the usage of information provided or collected on the sites and applications where this privacy policy is posted. We follow this privacy policy in accordance with applicable law in the regions where we operate. In some cases, we may provide additional data privacy notices specific to certain services or regions. Those terms are to be read in combination with this policy. 

Please keep in mind that when you provide information to us on a third-party site or platform (for example, via our applications like social media login) the information we collect is through those third-party sites linked with our applications and is covered by this privacy policy, and the information the third-party site or platform collects is subject to the third-party site or platform's privacy practices. Privacy choices you have made on the third-party site or platform will not apply to our use of the information we have collected directly through our sites or applications. Please also keep in observance that our sites and applications may contain links to other sites not owned or controlled by us and we are not responsible for the privacy practices of those sites. We encourage you to be aware when you leave our sites or applications and to read the privacy policies of other sites that may collect your personal information.

INTERPRETATION

Kindly note that the capitalised words used in this Privacy Policy but not defined herein, have to be read and understood in the manner described in the Terms & Conditions available at Terms and Conditions.

ABOUT THE PRIVACY POLICY

This Privacy Policy is created and published herein by Elder Care (CIN: 201925295M) having its registered office at [1, Scotts Road, #24-10, Shaw Centre Singapore, 228208], under the provisions of Rule 4 of Information Technology (Reasonable Security Practices & Procedures and Sensitive Personal Data or Information) Rules, 2011.

  1. USER CONSENT

    1. By accessing the Website or Mobile App, you irrevocably and unconditionally consented and acknowledged that you have read, understood and accepted the Privacy Policy. This Privacy Policy is a legally binding and enforceable agreement between you and the Company. If you do not agree to accept or understand any of the terms mentioned in the Privacy Policy, you are not entitled to access the Website or Mobile App.

    2. By using the Company’s services, you agree to our collection, use and sharing of your personal information as described in this policy. In some cases, particularly if you reside in a country governed by data protection regulations, we may ask you to provide explicit consent to access our services before proceeding for further operations. In case of any roaming user profile or if you are a traveller visiting various countries around the world and avail our services, then we will consider the country of registration as your primary country and the consents obtained at the time of registration will be valid for your processing of personal information. The privacy terms applicable as per the law of that country at the time of registration will be applicable to you.

    3. You should not access or use the Website or Mobile App by means of any mechanism or technology which conceals your actual geo-location or provides incorrect details of your location (for example, use a virtual private network (VPN) to access the services).

    4. We will not be responsible or liable for any collection, storage or processing of your personal information or data if you use any mechanism or technology to access or use Website or services which conceals your actual geo-location.

    5. Please be sure to read this Privacy Policy which is also available at [Privacy Policy]. It is your own responsibility to ensure that you are fully aware of the Privacy Policy when accessing the Website / Mobile App, as applicable. We reserve the right to make changes to the Privacy Policy at any time. Your continued use of the Website or Mobile App shall signify your acceptance to be bound by the latest Privacy Policy.

    6. In order to provide you with uninterrupted use of the Services offered through this Website, Company may collect and, in some circumstances, disclose information about you as provided by you while subscribing to the Website, Mobile App and / or availing the Services. To enhance better protection of your privacy, Company has laid down the following terms, explaining its information security practices including but not limited to the way your information is collected and used. If you have any questions or concerns regarding this Privacy Policy or wish to have discrepancies or grievances, you can contact [Sanjeev Singhal] the Grievance Officer at the following contact details [sanjeev@eldercare.international].

  2. INFORMATION RECEIVED, COLLECTED, STORED AND USED BY THE COMPANY

    1. Company may collect Personal and Sensitive Information from you including your first and last name, address, telephone and mobile number(s), email address, credit / debit card details, medical data and any other information that is considered personal about you, in relation to availing the Services. Please note that as a user of this Website you are required to provide a valid e-mail address and mobile number at the time of registration and choose a username or alias that represents your identity on the Website and related mobile apps. Please note that upon successful registration it would be deemed that you have read and understood the Terms and Conditions of use of the Website and Mobile App.

    2. INFORMATION YOU ARE REQUIRED TO PROVIDE TO US

We may ask for and collect the following personal information about you when you use the Website or Mobile App and without this information we may not be able to provide you with all the requested services;

      1. Registration Data 

To use certain features on the Website or Mobile App, you may be required to provide basic contact Information including but not limited to, First Name, Last Name and Email Address

      1. User Profile Details

We may further collect and record the following personal information under the "My Profile" section, which helps us provide customized feeds and maintain a user profile, including but not limited to:

  • Name

  • Gender

  • Email ID

  • Date of birth

  • Country 

  • City

  • Address of the Elder  where service is required  

  • Identity proof and number 

  • Occupation 

  • Industry

  • Annual Income

  • Mobile Number

  • Medical History 

  • Blood Group

  • Known Medical Conditions/ Allergies

  • Hospitalization history in the past 1 year (if any)

  • Personal Doctor/ Physician details (if any)

  • Staying with [Spouse/Children/ Caretaker/ Alone]

  • Local Guardian and the following contact details from the local guardian

    • Name

    • Mobile number

    • Email id

    • Address

 

      1. Mobile Device Permissions

When accessing our Mobile App on mobile devices/ tablets/ TVs/ wearable devices or any other device having access of the said App, we may request and gain access to the following:

    • Accounts - Used for managing multiple user accounts within the Mobile App and for login purposes;

    • Contacts - Used for accessing users Contact in order to share articles through the App; 

    • Phone - To read phone state and enable user notifications on user's device. IMEI (International Mobile Equipment Identity) is being collected to uniquely identify every user only;

    • Camera - In order for the user to upload images and profile image of the User; 

    • Microphone - To enable voice command related actions; 

    • Bluetooth – To enable the mobile to be connected to the wearable device; 

    • Storage - To access files and folders from inside the App

    • SMS - To send and receive verification messages.

Permissions to these settings may be essential for adequate running of the App. Permissions can be managed through the respective user devices using the ‘settings’ option.

    1. INFORMATION YOU PROVIDE TO US VOLUNTARILY

If you send us personal correspondence, such as emails or letters, or if other users or third parties send us correspondence about your activities or postings on the Website or Mobile App, we may collect and store such information.

We may collect additional information at other times, when you provide feedback(s), modify your content or email preferences, respond to surveys, or communicate with us. This information may include your name, e-mail id, mobile number, location, etc.

    1. INFORMATION WE COLLECT AUTOMATICALLY

We collect information about you and your use of our service, your interactions with us and our advertising, as well as information regarding your computer or other devices used to access our service (such as mobile devices, tablets and other viewing devices).

This information includes, but is not limited to:

    • Activities on our Website or Mobile App, such as type of pages viewed, time spent on pages, search queries etc;

    • Your interactions with our email, customer care and messaging platforms;

    • Geo-location information through IP addresses;

    • Device information like device ID, device model etc. and other unique identifiers;

    • Advertising identifiers, such as those found on mobile devices & tablets, devices that include identifiers;

    • Information collected via the use of cookies and other technologies*; 

To improve the responsiveness of the Mobile App for our users, we may use ‘Cookies’ or similar electronic tools to collect information to assign each visitor a unique, random number as a User Identification (‘User ID’) to understand the user's individual interests using the identified computer.

Unless you voluntarily identify yourself (through registration, for example), we would not know who you are, even if we assign a cookie to your computer. The only personal information which a cookie can hold is the information you supply. A cookie cannot read data from your hard drive. Our advertisers may also assign their own cookies to your browser(s) (if you click on their ads), a process that we do not control. We receive and store certain types of information whenever you interact with us via Website or Mobile App through your computer/ laptop/ notebook/ mobile/ tablet/ pad/ handheld device or any other electronic device capable of connecting to internet. For more details, you can refer to our Cookie Policy [Insert hyperlink]

      1. User Experience and Support

We identify and use your Internet Protocol (“IP”) address to help diagnose any problems with our server, and to administer our application. Your IP address is also used to help identify you and to gather broad demographic information to customize your experience on Website or Mobile App. We will occasionally ask you to complete optional online surveys. These surveys may ask you for contact information and demographic information (like zip code, age, etc.). We use this data to tailor your experience on the Website or Mobile App, providing you with content that we think you might be interested in and to display content according to your preferences.

    1. INFORMATION WE COLLECT THROUGH THIRD PARTIES

      1. Social Media Login

When you register using your other accounts like on Facebook, Gmail and/or other platforms in the future  we shall retrieve Information from such accounts to continue to interact with you and to continue providing the services. We collect the following information from the respective social media platforms, including but not limited to:

        • Facebook - Public information, Name, Email ID, Friend list

        • Google - First name, Last name, Email ID

      1. Transactional or Billing Information

Based on your purchase of a subscription package, our payment gateway partner may collect information with respect to your credit/debit card details or other bank account details along with your billing address. This information is stored by our payment gateway partner. For instance, the services will be using third party payment gateway partners to process and facilitate the payment of your subscription fee to the services for providing you access to the subscription. 

 

Please note that the Company does not directly collect any financial information such as credit card or debit card or net banking details from you. 

 

Such payment gateway partners are not controlled by us. When you visit such payment gateways you do so at your own risk. These payment gateways may have their own privacy policies in place, which we recommend you review if you visit any such payment gateways. We do not assume any responsibility or liability for such payment gateways, the content of such payment gateways and their privacy practices, nor do we endorse them. We encourage you to familiarize yourself with the privacy statements provided by such payment gateways prior to providing them with information about you or entering into any transactions with them.

      1. Financial Information 

For provision of services and subscriptions, you may be required to present additional financial or sensitive personal information to our partners, on their respective websites). You understand, agree and acknowledge that the Company does not process any information provided on partner/vendor websites. Your Personal Information, Sensitive Information and financial information will be dealt by these partners in accordance with their respective privacy policies and other terms and conditions and the Company shall not be liable, accountable or responsible for your Personal Information, Sensitive Information or any other information which you provide to these payment gateways. The Company, may however, receive a copy of such information (e.g. PAN numbers, transaction IDs and details) provided by you to third parties (vendors, partners) solely for the purpose of reconciliation and validation of transaction, or for the purpose of resolution of complaints such as a transaction failure, processing of refunds, only as permissible by law. The Company will not process any information without consent, as applicable by the local laws.

      1. Auto renewal Subscription

When you choose any subscription or paid service, we or our payment gateway provider may collect your purchase, address or billing information, including your credit card number and expiration date etc. However, when you order using an in-App purchase option, same are handled by such platform providers. The subscriptions or paid services may be on auto renewal mode unless cancelled. If at any point you do not wish to auto-renew your subscription, you may cancel your subscription before the end of the subscription term. We do not capture/store any personal payment information with us.

      1. Information from other Sources

We may receive information about you from other sources, add it to our account information and treat it in accordance with this policy. If you provide information

to the platform provider or other partner, whom we provide services, your account information and order information may be passed on to us. We may obtain updated contact information from third parties in order to correct our records and fulfil the services or to communicate with you.

Demographic and purchase information: We may refer to other sources of demographic and other information in order to provide you with more targeted communications and promotions, based on the consents provided by you.

    1. PURPOSES AND LAWFULNESS OF PROCESSING

The Company will only collect and process personal data about you where we have a lawful basis. Lawful basis on which we would process your personal information includes obtaining explicit consent from you for processing your personal information or processing for ‘legitimate interests’ where processing is necessary by us to provide you with customer support or process your data for providing premium services (For e.g. processing of your information by our payment gateway service providers).

We use information to provide, analyse, administer, enhance and personalize our service and marketing efforts, to process your registration, your orders, payments, and to communicate with you related to the cases mentioned below. For example, we use information to:

      1. Determine your health related service requirements; 

      2. Prevent, detect and investigate potentially prohibited or illegal activities, including fraud;

      3. Analyse and understand our audience, improve our service (including our user interface experiences) and optimize content selection, recommendation algorithms and delivery;

      4. Communicate with you concerning our service (for example by email, push notifications text messaging, and online messaging channels), so that we communicate news regarding the Company to you, details about new features and content available on the Website or Mobile App, special offers, promotional announcements, contests and consumer surveys, and to assist you with operational requests such as password reset requests;

      5. Notify you about changes in terms of service;

      6. Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing, chargeback and collection.

We may use your information to provide you with personalised experience when you visit/use one of our sites/apps, and for insight and marketing purposes.

We provide personalisation by using data you submit to us in terms of cookies, IP addresses, web beacons or similar technologies in relation to the devices you use. By doing so, we can provide you with contents and/or advertising that we believe are more relevant to your interests. Please provide explicit consent for the same when we collect your data and/or adjust your user preferences in your account profile concerning your choices/preferences provided.

    1. INFORMATION USED BY THE COMPANY

The Information as supplied by the users enables us to improve the services and provide you the most user-friendly experience. In some cases/provision of certain service(s) or utility (ies), we may require your contact address as well. All required information is service dependent and the Company may use the above mentioned user information to, maintain, protect and improve the services (including advertising on the ‘Application’) and for developing new services. We may also use your email address or other personally identifiable information to send commercial or marketing messages with your consent, as applicable by local laws [with an option to subscribe / unsubscribe (where feasible)]. We may, however, use your email address without further consent for non-marketing or administrative purposes (such as notifying you of major changes, for customer service purposes, billing, etc.)

Any personally identifiable information provided by you will not be considered as sensitive if it is freely available and/ or accessible in the public domain like any comments, messages, blogs, scribbles available on social platforms like Facebook, twitter etc. Any information posted/ uploaded/ conveyed/ communicated by users on the public sections of the Website or Mobile App becomes published content and is not considered personally identifiable information subject to this Privacy Policy.

In case you choose to decline to submit personally identifiable information, we may not be able to provide certain services to you. In any case, we will not be liable and or responsible for the denial of certain services to you for lack of you providing the necessary personal information. When you register with our services, we contact you from time to time about updating your personal information to provide the users such features that we believe may benefit/ interest you.

    1. DISCLOSURE TO THIRD PARTIES

      1. General Disclosure

At times, the Company may make certain personal information available to strategic partners that work with the Company to provide service (s), or that help the Company market to customers. For example, when you purchase and activate subscription, you authorize the Company to exchange the information you provide during the activation process to carry out a service. If you have approved the service, your account will be governed by the Company’s Privacy Policy. Personal information will only be shared by the Company to provide or improve our service and marketing aspects; it will not be shared with third parties for their marketing purposes. The Company may also carefully select other companies to send you information about their products or services which are related to the site's service but are not necessary to its operation (“Extended Service”). If the Company intends to use personally identifiable information for an Extended Service, the Company’s Website will provide you with the ability and requisite instructions to decline this service.

You may also stop the delivery of informational or promotional mail from [info@eldercare.international] by following the instructions on the mail.

      1. Advertising

When we present information to our advertisers to help them understand our audience and confirm the value of advertising on our Website or Mobile App, it is usually in the form of aggregated statistics on traffic to various pages/ content within our Website or Mobile App. We use third-party advertising companies to serve ads when you visit our Website or Mobile App. These companies may use information (including your name, address, email address or telephone number or any other personally identifiable information) about your visits to this and other websites or applications, in order to provide advertisements about goods and services of interest to you. We do not provide any personally identifiable information to third party websites/ advertisers/ ad-servers without your consent.

      1. Service Providers

 [www.eldercare.international] may include links to various third-party websites that may collect your personal information. Use of your information collected by such third-party platform will be governed by the privacy policy in such third-party platform. Such websites or applications are governed by their respective privacy policies, which are beyond our control. Once you leave our servers (you can tell where you are by checking the URL in the location bar on your browser), use of any information you provide is governed by the privacy policy of the operator of the website or application you are visiting. That policy may differ from ours. If you can't find the privacy policy of any of these sites via a link from the application's homepage, you should contact the website or application owners directly for more information. For specific purposes like enabling geographic tracking, measurement and storage of personal information, electronic medical records for delivering services like MARS or getting the member admitted to a hospital or getting the member checked by medical practitioner for which the Company may have to share confidential information of the Subscriber with such partner and associates. Further, we may share non-personally identifiable information publicly and with our partners - like publishers, advertisers, developers, or rights holders. For example, we share information publicly to show trends about the general use of our services. We also allow specific partners to collect information from your browser or device for marketing/promotions and measurement purposes using their own cookies or similar technologies.

      1. Promotional Offers

We'll share or disclose your personal information outside of [www.eldercare.international] when we have your consent. For example, providing SMS and E-mail related services such as marketing newsletters, promotions and offers.

      1. Business Transfers

We provide personal information to our affiliates and other trusted businesses or persons to process it for us, based on our instructions and in compliance with our Privacy Policy and any other appropriate confidentiality and security measures. For example, we may use service providers to help us with customer support. 

In the event, the Company is merged with or acquired by another company or in case of re-organization or re-structuring of business, we and our affiliates may share your personal information, wholly or in part, with another business entity.

      1. Legal

The Company may disclose personally identifiable information if required to do so by law or in good faith belief that such action is necessary to: 

    • Conform to the edicts of the law or comply with legal process served on the Website or Mobile App or its owners;

    • Protect and defend the rights or property of the Website and Mobile App owners or of the users of the Company;

    • Act under exigent circumstances to protect the personal safety of users of the Company, the Website or Mobile App, its owners, or the public.

    1. YOUR CONTROL AND CHOICES

When you use the services from the Company, we make good efforts to provide you, as and when requested by you, with access to your personal information and shall further ensure that any personal information or sensitive personal data or information found to be inaccurate or deficient shall be corrected or amended as feasible, subject to any requirement for such personal information or sensitive personal data or information to be retained by law or for legitimate business purposes. 

We ask individual users to identify themselves and the information requested to be accessed, corrected or removed before processing such requests, and we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup tapes), or for which access is not otherwise required. In any case, where we provide information access and correction, we perform this service free of charge, except if doing so would require a disproportionate effort. Because of the way we maintain certain services, after you delete your information, residual copies may take a period of time before they are deleted from our active servers and may remain in our backup systems.

To exercise rights applicable to you as a data subject, you must write to us at and raise a request for the specified right. Kindly ensure you use appropriate subjects to mention the right (e.g. Data Access Request, Data Portability Request, Data Deletion Request) while raising all such requests as this would help us process your requests in a faster and more efficient manner.
We provide you the ability to exercise certain controls and choices regarding our collection, use and sharing of your personal information. In accordance with applicable law, your controls and choices may include:

      1. Data Access and Portability

You may also be entitled to request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format and/ or request us to transmit this information to another service provider (where technically feasible).

      1. Rectification of Inaccurate or Incomplete Information

You can ask us to correct inaccurate or incomplete personal information concerning you (this is the information which you cannot update yourself within your account) by sending us an email. You can access and update some of your personal information through your account settings. If you have chosen to connect your profile to a third-party application, like Facebook or Google, you can change your settings and remove permission for the app by changing your account settings. You are responsible for keeping your personal information up-to-date. The Company may send you periodic reminders via e-mail to maintain the accuracy of your personal information. 

      1. Data Retention and Erasure

We retain your personal information as long as necessary for the legitimate interests specified in this policy and for us to comply with our legal obligations. If you no longer want us to use your information, then you can request that we erase your personal information and close your account. 

Please note that if you request for the erasure of your personal information:

      • We may retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety. For example, if we suspend an account for fraud or safety reasons, we may retain certain information from that account to prevent that user from opening a new account in the future.

      • We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, we may keep some of your information for tax, legal reporting and auditing obligations.

      • Information you have shared with others (e.g., Reviews, forum postings) may continue to be publicly visible on the Website or Mobile App, even after your account is cancelled. However, attribution of such information to you will be removed. Additionally, some copies of your information (e.g., log records) may remain in our database, but are disassociated from personal identifiers.

      • Because we maintain copies of personal information to protect from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.

      • If you have multiple accounts with us, you will need to raise separate requests for each of those accounts, using the associated email IDs. 

  1. WITHDRAWING CONSENT AND RESTRICTION OF PROCESSING

For withdrawing your consent at any time during the tenure of your services with us, you may choose to do so by sending us an e-mail. We shall review your request and may ask you to verify your identity. Post verification we will withdraw the consent for which request was made by you and stop any further processing of your personal information.

  1. OBJECTION TO PROCESSING

Where your personal information is processed for direct marketing purposes, you may, at any time ask us to cease processing your data for these direct marketing purposes by sending an e-mail to us.

Please be aware that if you do not allow us to collect personal information from you, we may not be able to deliver certain experiences, products, and services to you, and some of our services may not be able to take account of your interests and preferences. If collection of personal information is mandatory, we will make that clear at the point of collection so that you can make an informed decision whether to participate. If you have questions about the specific personal information about you that we process or retain, and your rights regarding that personal information, please contact our customer support team.

  1. DATA TRANSFER, STORAGE & PROCESSING GLOBALLY

We operate globally and may transfer your personal information to individual companies affiliated companies or third parties in locations around the world for the purposes described in this Privacy Policy. Wherever your personal information is transferred, stored or processed by us, we will take reasonable steps to safeguard the privacy of your personal information. 

  1. SECURITY AND COMPLIANCE WITH LAWS

We are continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unauthorized access, loss, destruction, or alteration. Some of the safeguards we may use to protect your information are firewalls and data encryption, and information access controls. If you know or have reason to believe that your account credentials have been lost, stolen, altered, or otherwise compromised or in case of any actual or suspected unauthorized use of your account, please contact us by contacting our customer support team.

  1. CHANGE IN POLICY

This Privacy Policy is subject to change from time to time. We reserve the right, at our sole discretion, to modify the terms of this Privacy Policy from time to time in order to ensure compliance with applicable laws (“Updated Terms"). The Updated Terms shall be effective immediately and shall supersede the terms of this Privacy Policy. We will notify you of any changes to this privacy policy if the changes made to the policy significantly affects your rights or as may be required by law. You shall be solely responsible for reviewing the Privacy Policy from time to time for any modifications. By continuing to use the Website or Mobile App after the Updated Terms have been published, you affirm your agreement to the Updated Terms.

  1. CONTACT INFORMATION

      1. Support

If you require any information or clarification regarding the use of your personal information or this privacy policy or grievances with respect to use of your personal information, please email us at [support@eldercare.international].

      1. Data Controller Officer

The Data Controller Officer appointed by the Company is [hello@eldercare.international].

      1. Complaints

You can write to our data protection officer in case of any grievance or complain. You have the right to complain about the data processing activities carried out by the Company before the competent data protection authorities. If you have any queries, complaints regarding the collecting, processing, transfer of personal data/information or regarding this policy please do contact our Data Controller Officer.