TREUX.AI (“Treux”, “we”, “us”), is a company registered under the Companies Act, 2013, having its registered
office at 2/20 Parle Pushpa C.H.S., Parle Pushpa, Mahant Road Ext, Vile Parle East, Mumbai 400057, and
includes our assignees, successors-in-interest, affiliates, subsidiaries, or any other person or entity
authorized in writing to operate on and on behalf of us. We own and operate the website www.treux.ai
(“Website”) the mobile applications TruSafe Health, TruSafe for Doctors, and such other mobile or device applications
that we may develop from time to time (collectively referred to as “Apps”) (both Website and Apps are
collectively referred to as the “Treux Portal”).
Treux values your privacy and is committed to the protection of your privacy and any data you share with us.
This Privacy Policy governs how and why we collect, use, share, process, store, and transfer any data,
including any personal data that users of the Treux Portal choose to share with us in the course of availing
our Services (as defined in our Terms and Conditions), including health care providers and patients
(“User(s)”, “you”, “your”), and that we may automatically collect through your use of the Treux Portal, or to
provide Services to you.
Please note that the Treux Portal and Services may not be available to you in your country due
to legal and regulatory reasons. Please contact us at
[email protected] if you wish
to know more about the availability of our Services in your country.
CONSENT
Please read this Privacy Policy carefully. By accessing the Truex Portal
or availing our Services, you explicitly agree to have read, understood,
and be bound by the terms described herein and all the terms
incorporated herein by reference, including our Terms and Conditions.
You agree that the consent provided by you hereunder to Treux to
collect, use, process, and store your data to provide access to the
Treux Portal and Services to you is free, informed, and unconditional.
If you do not wish to be bound by any terms of this Privacy Policy or
our Terms and Conditions, you have a choice, free from any form of
coercion or undue influence, to not use or access the Treux Portal or
avail our Services.
This Privacy Policy is applicable to data and information provided by
you while using Treux’s Portal and Services, and not to any data or
information made available to Treux from any third parties directly or
by third parties on behalf of you. Should Treux obtain information
pertaining to you from third party websites, apps, landing pages, third
parties, etc. that may be accessed by you through Treux or and/or any
third party services that are advertised by Treux, such information will
be subject to the privacy and other policies and terms of the said
websites, apps, landing pages, etc.
You represent that you are duly authorized by any and all third-parties
(including any family member) whose information you share with us. We
act based on your representation of authority and do not make any
independent enquiries to ascertain the veracity of your authorization.
In the event you do not have sufficient authorization to share a third
party’s information with us, you shall be solely responsible for your
acts and omissions including sharing of such information with us and the
consequential processing and actions taken by us in accordance with this
Privacy Policy.
No liability pertaining to the authenticity, genuineness,
misrepresentation, fraud, or negligence, of the information disclosed
shall lie on us, nor will we in any way be responsible to verify any
information you share with us, whether belonging to you, or a third
party.
WHAT INFORMATION DOES TREUX COLLECT AND HOW?
Types of Information
We collect the following broad categories of information from you
(collectively referred to as “**Information**”). For clarity,
Information includes any changes, or updates you make to the
Information.:
- Personal Data: means any information that could be used to
identify you either by or in relation to such information such as,
your name, email address, age, gender, documents, scanned reports,
medical history, health and wellness related information,
prescriptions, internet protocol (IP) addresses and other similar
information.
- Non-Personal Data: refers to information that cannot be used
to
identify you such as the browser name, type of computer and
technical information, the operating system, internet service
providers utilized and other similar usage information.
What Information does Treux collect?
The Information we collect varies depending on your interaction with us,
the Treux Portal, our Services, and the applicable laws. We gather
information directly provided by you, information automatically obtained
when you use the Treux Portal or our Services, and information from
other sources, including third party services and organizations.
Below is an inclusive list of Information that we may collect from you
in connection with your access and use of the Treux Portal and our
Services:
- Account Information: Information that we need you to provide
to
enable you to register for the use of the Treux Portal. When you
register for an account on the Treux Portal ("User Account"), we
require certain Information such as your name, date of birth,
gender, phone number and email address for the purpose of user
registration, identification and account verification.
- Payment Transaction Information: We may collect your first
name,
last name, phone number, and billing address, when you register for
availing the Services offered on the Treux Portal. Your payment
details may be collected through a third-party gateway to which you
will be required to provide requisite information separately in
order to process your payments.
- Medical Information: We will collect information such as
medical
records that include and are limited to prescriptions, pathology
reports, hospital discharge summaries and vaccination /immunization
records of self or of the registered family members and other such
information as provided/uploaded by you while availing our Services
or accessing the Treux Portal. We may also get access to your health
records, and health care provider notes that are uploaded by your
health care provider on the Treux Portal.
- Information we automatically collect from your use of the Treux
Portal: When you use the Treux Portal, we automatically collect
information about the functionalities you use on the Treux Portal
and how you use them. This Information is necessary for the
effective performance of the contract between you and us, to enable
us to comply with legal obligations given our legitimate interest in
being able to provide and improve the functionalities relating to
the Treux Portal and the Services.
- Geo-location Information: When you use the Treux Portal, we
may
collect information about your location such as your IP address,
which in turn would enable us to infer your city, region/state,
country, continent, internet service provider (ISP), and
longitude/latitude coordinates of location. We may use and save your
location data to show the relevant Services available in your
location, and enforce security measures to protect the User Account.
- Usage Information: We collect Information about your
interactions with the Treux Portal such as the pages viewed on the
Treux Portal and the User Account dashboard, content created or
uploaded through use of the Treux Portal and Services.
- Log File and Device Information: When you use the Treux
Portal,
we automatically collect and store certain information in server
logs. This includes details of how you used the Treux Portal, access
to your User Account, certain information that your web browser
sends whenever you visit our website, internet protocol address,
information inferred from your internet protocol address like
location, ISP details, device information such as hardware
configuration and operating system, browser types, referring / exit
pages and URL’s, number of clicks, domain names, landing pages,
pages viewed and other such information. We do not link this
automatically collected data to your Personal Data.
- Information we collect from third parties: We may work with a
limited number of third parties (including mobile network providers,
and delivery service providers, collection agencies, analytics
providers) to provide the Services and may receive information about
you from such third parties. We also receive profile information
from the social media platform(s) that you use to log in or create
accounts with us, as per their terms and policies. In order to sync
your health records from multiple sources, we may obtain a read only
permission of you Gmail account. Any Information we receive from
third parties will be subject to the privacy policy and terms of use
of such third parties e.g. any Information about you that we obtain
from Google API’s will adhere to the Google API services users data
policy.
- Cookies and Tracking Technologies: Cookies are alphanumeric
identifiers with small amounts of data that are stored on your
devices hard-drive containing information about you, commonly used
as an anonymous unique identifier. We collect device specific
information (such as your hardware model, operating system version,
unique device identifiers). We may also associate your device
identifiers with your User Account. Most web browsers are set to
accept cookies by default. You may decline these cookies by changing
your browser settings, if permitted. However, do note that this may
impact certain features of the Treux Portal or your experience in
using the Treux Portal.
- Access to Google Account:You may choose to provide explicit
consent to connect/integrate your Google account(s) with your User
Account on the Treux Portal. Connecting your Gmail account will help
you have all your medical records organized in your User Account
with us. Please note that any data obtained by this integration will
be used by us solely for providing the service of secure storage,
retrieval and quick discovery of medical records. We shall not use
or transfer any Information received from the integration of the
email addresses to third parties for any purpose other than as
explicitly authorized and consented by the you. You can choose to
de-link your Gmail account at any time and/ or you can delete your
Information by writing to [email protected].
How do we collect Information?
Below is a non-exhaustive list of ways in which we may obtain your
Information:
- You provide certain Information in order to complete the sign-in
process on the Treux Portal to avail our Services.
- If you contact us for any query, or grievance, we may collect
Information and maintain copies of your correspondence (including
email addresses).
- Your responses to surveys that we might ask you to complete for
research purposes.
- Non-Personal Data collected automatically during your interaction
with the Treux Portal including using cookies or web beacons. Please
note that we may store such Non-Personal Data or associate it with
your Personal Data to improve our Services and deliver a
personalized service, estimate usage patterns and audience size,
speed up searched, and recognize when you return to the Treux
Portal.
- We may collect certain Information through permissions sought by the
Treux Portal only when you choose to provide access to such
Information. This includes camera and storage permissions,
geo-location, access to certain photographs and files (to enable
reading of your medical and health records) and cache, or permission
to provide notifications. We may also require access to read your
messages to read the authentication OTP received to complete the
registration process.
HOW DO WE USE THE INFORMATION WE COLLECT?
You agree and acknowledge that all Information gathered from you may be
used by Treux for the following purposes:
- to enable you to register and verify your User Account, to activate
your User Account, to enable the provision of Services to you as set
out in the Terms and Conditions, and integration with third party
services;
- to copy, reproduce, store, distribute, publish, export, adapt, edit
and translate the Information for the provision of Services;
- to enable you to view the content and participate in the interactive
features of product;
- to provide you with notices about your User Account, including
expiration and renewal notices;
- To notify you about changes to our Services, or any new products or
services we offer or provide though the Treux Portal, including to
provide you with marketing and advertisement information;
- To notify you of any updates to our Privacy Policy and Terms and
Conditions;
- To respond to your comments, reviews and questions and provide
better customer service;
- to track personalise and improve your experience of our Services and
the Treux Portal;
- to understand your preferences and to enhance, personalise, and
customise your experience of the Treux Portal;
- to ensure the functioning of the Services, and to prevent the use of
our Services and the Treux Portal in breach of our terms;
- to comply with central, state or local laws;
- to respond to law enforcement officials or to judicial orders,
subpoenas or other processes;
- to prevent fraud and abuse;
- to fulfil any other purpose for which you provide consent to us.
Additionally, Non-Personal Information may be used in an aggregated or
anonymised form for internal research, statistical analysis and business
intelligence purposes including those for the purposes of determining
the number of visitors and transactional details, and we may share such
research, statistical or intelligence data in an aggregated or
anonymised form with third parties and affiliates.
Please note that we may use Non-Personal Data without restriction. We
may retain Non-Personal Data and will continue to use such Information
as permitted under this Privacy Policy and applicable law.
DISCLOSURE OF PERSONAL INFORMATION
We may disclose Personal Data that we collect from you or that you
provide:
- to contractors, service providers, including healthcare
professionals, health coaches, wellness coaches, medical experts,
counsellors, health practitioners, partner labs, partner vaccination
providers, partner scan providers, other providers, and other third
parties who are bound by contractual obligations to keep your
Personal Data confidential in order to provide our Services or to
repair and improve the Treux Portal;
- to maintain our Services;
- as required by law, which can include providing information as
required by a court order to comply with central, state or local
laws that require disclosure, or to government institutions/
authorities to the extent required under such applicable laws;
- to a buyer or other successor in the event of a merger, divestiture,
restructuring, reorganization, dissolution or other sale or transfer
of some or all company’s assets, whether as a going concern or as
part of bankruptcy, liquidation or similar proceeding, in which
Personal Data maintained by the Treux Portal is among the assets
transferred;
- for verification, risk management and internal compliance,
governance and security purposes, including KYC, anti-fraud, credit
risk management and other security and compliance policies and
processes;
- to enforce this Privacy Policy and our Terms and Conditions;
- for any other purpose disclosed by us when you provide the Personal
Data and other Information;
- If we believe disclosure is necessary or appropriate to protect the
rights, property, or safety of Treux, your safety, or safety of
others;
- We may also share de-identified and/or aggregated information (that
cannot be used to identify you and is not Personal Data), to the
extent permitted under applicable laws. We may use and disclose such
information in a number of ways, including research, internal
analysis, analytics, and any other legally permissible purposes.
- to deal with requests, enquiries, complaints or disputes and other
customer care related activities including those arising out of your
request of the Services and all other general administrative and
business purposes.
Treux may only make your Information, including Personal Data,
accessible to its employees and data processors on a need-to-know basis,
and provided that such employees and data processors are obliged to
ensure its confidentiality.
The Treux Portal may contain links to or integrations with other
services such as Google, WhatsApp, Twitter, and other media services and
platforms whose information practices may be different than ours. Users
should consult these other services' privacy notices as we have no
control over information that is submitted to, or collected by, these
third parties. Please note that the Information shared by you using the
Share button via the Treux Portal leading to WhatsApp, Gmail and shared
thereafter through one of these tools are shared by you voluntarily out
of your free will without any coercion or influence.
RESTRICTIONS
By accessing our Services and the Treux Portal, and by providing
Personal Data to us, you confirm that you have the capacity to enter
into a legally binding contract with us. You agree that you are above 18
years of age, and if you are below 18 years of age, you agree that you
are being represented by your parent or legal guardian who has the
capacity to enter into a legally binding agreement on your behalf to
avail our Services. You also warrant and represent that any Personal
Data and other Information that you submit or otherwise provide to us is
true, accurate and complete, and you agree to keep it that way at all
times.
YOUR RIGHTS
- You can access, review, modify and correct the Personal Data
provided by you by logging into your User Account. We may not
accommodate a request to change information if we believe the change
would violate any law or legal requirement or cause the information
to be incorrect. If you update or change any Information provided to
us, we will keep a copy of the Information that you originally
provided to us in our archives for documentation purposes.
- All the Information provided to us by a User, including Personal
Data, is voluntary. You have the right to withdraw consent at any
time. You may either do so by logging into your User Account, or by
writing to us at [email protected].
Please note that we need access
to your Personal Data for providing Services to you. In case you
choose not to provide access to your Personal Data, withdraw consent
to your Personal Data or request deletion of your Personal Data, we
may delete your User Account to accommodate such request, and
terminate your access to our Services.
- Please note that withdrawal of consent or request for deletion of
your Personal Data will only be applicable to the Personal Data
uploaded by you and synced to the App. We cannot delete any Personal
Data including any medical records uploaded by your health care
provider on our App.
- When you choose to share your Personal Data including medical
records with your healthcare provider, the health care provider is
granted a view-only access to such Personal Information for a
limited period as may be specified at the time of obtaining your
consent. Such Personal Data will not be stored with the health care
provider. In case you do not want to share your medical records in
response to a consent request from a health care provider, you may
deny consent. Similarly you also have the right to revoke consent
previously granted either to us, or to a health care provider. In
case you deny consent, your medical records will no longer be
accessible by your health care provider.
- You may send us an email at [email protected]
to request access to,
or deletion of any Personal Data that you have provided to us. You
may also make any corrections to your Personal Data via the
self-service portal on the App.
- You have the right to a grievance redressal mechanism. This is set
out in Section 8 herein.
- You have the right to nominate an individual to exercise any rights
you may have under this Privacy Policy or applicable laws in case of
death or incapacity.
HOW DO WE PROTECT YOUR INFORMATION?
Your security is important to us. We adopt reasonable security practices
and procedures as required by applicable law that include, technical,
operational, managerial and physical security control measures in order
to protect all User information including Personal Data in our
possession from accidental loss, misuse and unauthorised access, use,
disclosure, alteration and destruction.
All data, content and/or all User Information is encrypted during
transmission and will be stored encrypted at-rest. Personal Data
collected while providing Services is stored in secure environments
inaccessible to the public; and only to duly authorised people,
employees, officers, or agents of Treux that require access to such
Information to provide Services.
While we strive to protect your privacy, you acknowledge that:
- The transmission of Information via the internet is not completely
secure, and beyond our reasonable control;
- The security, integrity, and privacy of your Information cannot be
guaranteed;
- Any such Information may be tampered with by third parties.
We assume no liability or responsibility for disclosure of your Personal
Data due to errors in transmission, unauthorised third-party access, or
other causes beyond our control. Any transmission of Personal Data is at
your own risk. We are not responsible for circumvention of any privacy
settings or security measures of the Treux Portal.
The safety and security of your information also depends on you. Where
we have given you an OTP for access to certain parts of our the Treux
Portal, you are responsible for keeping this OTP confidential. We ask
you not to share this OTP with anyone, as this may allow others access
to your User Account and Information including Personal Data.
GRIEVANCE REDRESSAL
In compliance with Information Technology Act, 2000 and the rules made
thereunder, or any other law as may be in force from time to time, the
Grievance Officer of Treux for the purpose of this Privacy Policy shall
be:
Grievance Officer Name:
Tejal Nadkarni
Email Address:
In case you have any questions, comments or concerns about this Privacy
Policy or wish to exercise any of the rights available to you under
applicable laws, you can contact us at [email protected] .
RETENTION
We shall retain your Personal Data and Information only for as long as
is necessary for the provision of Services to you, and to the extent
necessary to comply with our legal obligations. If you no longer want to
use the Treux Portal and want your User Account or Information to be
deleted, you may contact us on [email protected]
to request such
deletion. Except where your Personal Data is required to be maintained
by any law, statute or guidelines, at any instance of you withdrawing
your consent to use our the Treux Portal or Services, we shall delete
all Personal Data provided by you. Once deleted, all Personal Data and
Information shall be non-recoverable.
AMENDMENTS TO THE PRIVACY POLICY:
This Privacy Policy may be updated from time to time. If we make
material changes to how we treat your Personal Data, we will notify you
on the Treux Portal, on the email address you provide to us, or SMS, or
our preferred choice of communication. Thereafter, it is your
responsibility to keep yourself updated of the changes made to the
Privacy Policy. Your continued use of the Treux Portal after we make
changes to the Privacy Policy is deemed to be an acceptance of such
changes. You are responsible for ensuring we have your updated contact
details at all points in time for you to access your User Account as
well get notified of the changes to the Privacy Policy.
REMEDIES WITH TREUX
Users understand and agree that Treux has the requisite authority to
review the Information for the purposes specified in the Privacy Policy
to determine whether Users are adhering to the policies and terms and
conditions defined herein. Treux reserves the right to seek additional
information if, in its sole discretion, such information is necessary
for the provision of Services or completeness of its records or mandated
by any applicable laws or regulations.
Users understand and agree that Treux may screen and verify the
Information provided by you and modify such Information requested during
or for creating the User Account. Treux may, at its sole discretion,
close the User Account, if any information provided by you is found to
be false, incomplete or insufficient.
If Treux determines, at its sole discretion, that the User has violated
any terms of this Privacy Policy, it reserves the right to take actions
to prevent/control such violation including without limitation, removing
the offending communication or content from the Treux Portal and/or
terminating the membership of such Users.
Treux shall also be entitled to investigate occurrences which may
involve such violations and may and take appropriate legal action,
involve and cooperate with law enforcement authorities in prosecuting
Users who are involved in such violations
GOVERNING LAW AND DISPUTE RESOLUTION
The validity, construction, enforceability, and any dispute arising out
of or in connection with respect to Treux’s Portal or Services shall be
subject to and governed by the laws of India, and the courts in Mumbai,
Maharashtra will have exclusive jurisdiction to adjudicate all disputes.