Privacy Policy

1. INTRODUCTION

We, Clement Advisory Private Limited a company incorporated under the Indian Companies Act, 2013 with its Registered office at Plot No. 7, Smruti Bungalow, Satish CHS, Near Gaondevi mandir, Manpada Rd, Dombivli, Thane, 421201 (“Clement”/ “we”/ “our”/ “us”).
We provide various services to Users including but not limited to medical emergency aid, risk advisory services, risk profile services, risk assessment, risk analysis and claim support services or any other allied services offered from time to time through our website/mobile application“www.clementadvisory.in” for Users (“Portal”). References to "You", “Users”, “Your” shall mean the Users (including Guests/Visitors) accessing the Services and the Portal.
We respect the privacy of everyone who visits or uses our Portal. This privacy policy (“Privacy Policy”) describes the procedures for collecting, using, and disclosing your information which you share with us for availing the Services or accessing the Portal (“Personal Information”). It also describes the principles and practices that apply to Personal Information collected from Users, over telephone, e-mail communications or during meetings. This Privacy Policy shall be governed by the Terms of Use of the Portal as updated from time to time.
When you visit the Portal, you are not required to provide any Personal Information unless and until you register on the Portal. In addition to this, by agreeing to avail the Services and by submitting your Personal Information, you consent to the collection, transfer, processing, storage, disclosure and other uses described in this Privacy Policy.
We recommend you read this Privacy Policy so that you understand our approach towards the use of your Personal Information. We will not knowingly disclose your Personal Information to third parties, except as provided in this Privacy Policy. We will take reasonable steps to protect the security of the Personal Information we collect from you.
By accepting this Privacy Policy, You authorize Portal to collect, store, use, disclose, retain, and transfer Your Personal Information in accordance with this Privacy Policy.
You can withdraw the consent given by You without any valid reason. All the legal consequences for the effect of such withdrawal shall be borne by You.

2. DEFINITIONS

“Application” shall mean mobile application named “MAA” owned operated and managed by us.
“Clement”; “us”; “we”; “our” shall mean Clement Advisory Private Limited, a company incorporated under the Indian Companies Act, 2013 with its Registered office at Plot No. 7, Smruti Bungalow, Satish CHS, Near Gaondevi mandir, Manpada Rd, Dombivli, Thane, 421201 (“Clement”/ “we”/ “our”/ “us”).
“Register” shall mean registering and has an active subscription for the Services being offered through the Portal for Users on the basis of terms and conditions provided in this Terms of Use.
“Portal” shall mean website/Application from which User can avail Services on risk, health and insurance advice.
“Personal Data or Personal Information” of a person means such personal information which consist of information relating to: (i) Password;
(ii) Full name;
(iii) Address;
(iv) Email ID;
(v) Gender;
(vi) Mobile number;
(vii) Medical records and history;
(viii) Past test reports and records;
(ix) Details of emergency contact personnel;
(x) Number/address of the hospitals/doctors for current treatment (if any);
(xi) Location of the Users, in case of emergency medical aid services;
(xii) Any of the information received under above clauses by body corporate for processing, stored or processed under lawful contract or otherwise:
Provided that, any information that is freely available or accessible in public domain or furnished under the Right to Information Act, 2005 or any other law for the time being in force shall not be regarded as sensitive personal data or information for the purpose of these rules. “Service(s)” shall mean various services facilitated by us through Portal to the Users including but not limited to enlisting Your name on Portal, providing medical aid in case of emergency, risk advisory services, risk profile services, risk assessment and analysis, claim support services, advice on insurance policy.
“User(s)” shall mean any person who is availing Services whether online or offline from the us by using this Portal. “You” or “Your” or “Yourself” refers to the Users or viewers of this Portal.

3. INFORMATION COLLECTED AND STORED

In order to provide safe, efficient, smooth, and customized Services We ask for certain Personal Information which is collected and stored by Us. This facilitates Us to provide Services and features that most likely meet your needs through Portal. We collect Personal Information from You that We consider necessary for achieving this purpose.

• When You Registered on Our Portal, We collect Your Personal Information. “Personal Information” means and includes without limiting any information or data which includes –
• Name and Address of Users
• Email ID
• Login ID and Password
• Mobile Number
• Gender
• Occupation
• Age
• Medical records and History
• Past Test report/Records
• Details of emergency contact number
• Number/Address of hospitals/doctors for current treatment (if any)
• Location of the User through mobile, in case of emergency medical aid
We may collect Personal Information about Your activity on Our Portal, such as date and time You logged in, features of Our Portal that You have been using, searches, clicks and pages visited by You.
Additionally, We may collects User location data from mobile devices for providing Services. We may share this location with third party service providers such as highway authorities, ambulance and other medical service providers. User accepts, acknowledges and understands that if the User turns on the background location, We may have access to the devices location, even if you are not directly interaction with the Portal.
As part of Our Services, We may use third-party technologies to understand how Our Users as a whole use Our Services and constantly enhance, innovate Services to reflect the needs of the Users. When You use, or access the Portal, We may also collect and store additional information which may or may not personally identify You or be identifiable with other information collected. Such information includes, without limitation, Your internet protocol address, Your usage and log in information, email id, browser types, domain name, device locations, geographic locations, type of operating system, browser type and version, operating system, identifiers associated or other technologies that may uniquely identify Your device or browser and other statistical data involving Your use of the Portal and/or Our Services. This information is collected passively using various technologies or may be provided by You through communications with Us.
User understands that User shall be solely responsible for the accuracy and truthfulness of the Personal Information shared with Us. In the event the User is sharing any Personal Information on behalf of a third person, the User represents and warrants that he/she has the necessary authority to share such Personal Information with Us and We shall not be responsible for verifying the same. The User understands and acknowledges that such Personal Information shall be subject to the terms and conditions of this Privacy Policy.
You understand, acknowledge and agree that when you access social media your Personal Information is identified by such social media sites, and they may provide your Personal Information to us, or we may collate or derive your Personal Information on the basis of your engagement on social media.
Unless specifically requested, We ask that You do not send Us and You do not disclose, on or through the Portal or otherwise to Us, any sensitive personal information, including any of the following: (i) racial or ethnic origin; (ii) political opinions; (iii) religion; (iv) ideological or other beliefs; (v) sexual orientation; (vi) national identification numbers/Aadhar card number; (vii) criminal background; (viii) administrative or criminal proceedings and sanctions; or (ix) any other sensitive personal data information.

4. COLLECTION OF NON-PERSONAL INFORMATION

We may automatically collect non-personal information about You such as the type of internet browsers You use or the website from which You linked to Our Portal. We may also aggregate details which You have submitted to the Portal (for example, gender, birth date any health/ medical reports) You cannot be identified from this information, and it is only used to assist Us in providing an effective Service on this Portal. We may from time-to-time supply third parties with this non-personal or aggregated Information in connection with the Services providing on this Portal.
The details related to the aggregation of information provided by You on the Portal shall be used for our reference. But the details of individual information shall not be used by us. For example – for the purpose of analysis, the data shall be used by us in order to analyse the number of people who want to maintain the data with us. But data, information, preferences and choices related to you and Services obtained shall not be used by Us.

5. DEVELOPMENT OF DERIVATIVE DATA

On the basis of data provided by You, including but not limited to Your medical history, geographical location, gender, age etc., we may recommend hospitals to You. You have the option of choosing Your doctor/hospital where You have been opting treatment. On the basis of Your usage of Service, we may create certain derivative data that is used only to provide better Services to You.

6. HOW WE USE PERSONAL AND NON-PERSONAL DATA

The information is collected and used to:
(i) Suggest options of the different doctors/hospitals for online and offline consultation.
(ii) Suggest the right insurance policy and risk assessment based on the personal information provided by You.
(iii) provide details of Your medical history and/or reports shared by You to the hospital.
(iv) create and administer Your accounts and to improve the quality of as well as Your experience of the Portal and Services, including but not limited to fixing up appointments with hospitals, risk assessment.
(v) monitor User activity, such as keyword searches or new postings, and more effectively manage traffic on the Portal.
(vi) customize Your experience.
(vii) occasionally send promotional emails, share notifications of our upcoming Programs on Portals, messages or contact You to communicate about existing Services or new services, special offers, benefits, or other information which We think You may find interesting using the email address, contact details which You have provided.
(viii) measure User’s interest in our Services.
(ix) manage our relationship with You.
(x) maintain and update our records.
(xi) monitor suspected fraud, misconduct, and unlawful activities on the Portal.
(xii) Ensure proper consultation Services.
(xiii) Create aggregation of the information collected and run our analytics tool to identify preferences, common difficulties faced while using Portal, expectations etc.

By accepting this Privacy Policy, You expressly agree to receive targeted User advertisement, service provider offers, promotions, calls and communications relevant to Your use of the Portal.
We will not knowingly disclose Your Personal Information to third parties, except as provided in this Privacy Policy. We will take reasonable steps to protect the Personal Information We collect from You.
We may share data provided by You with Your consent to this Privacy policy to third-party service providers certain information, such as Your history of searches and interests in terms of specific browsing or queries updated by You in aggregated mode so as to better understand which advertisements and services may interest You.
We will retain Your Personal Information as long as it is reasonably required or otherwise permitted or required by applicable law or regulatory requirements even after Your account is terminated. We may also retain Your Personal Information so long as it is necessary to fulfil the purposes for which it was collected (including for purposes of meeting any legal, administrative, accounting, or other reporting requirements). We endeavour, Your Personal Information is safeguarded against inappropriate access and disclosure, as per this Privacy Policy. Please refer to Our “Data retention” clause for more information regarding retention of information shared by You.

7. REVIEW OF SENSITIVE INFORMATION

We will ensure that any Personal Information or Sensitive Personal Data or Information provided by You shall be available for Your review and revisions as and when required and requested.

8. COOKIES

We may set “Cookies” on the use of the Portal by Users. Cookies are small, encrypted files that a site or its service provider transfer to Your computer’s hard drive through Your web browser that enables the site’s or service provider’s system to recognize Your browser and capture and remember certain information to enhance Your experience and cater to Your needs better.

9. DISCLOSURES

We may use the uploaded activity data, in an aggregated manner, for enhancing the quality of Our Services. Keeping in mind the rules regarding Privacy Policy, We may send, rent, share, distribute, lease, or otherwise provide or disclose User’s Personal Information to third parties, in the following circumstances -
Administrators – We may provide access to User’s Personal Information to any of Our authorized administrator for an internal business purpose, who shall be under confidentiality obligations towards the same.
Affiliates – We may provide Personal Information that We collect to Our affiliates. For example, We may disclose Personal Information to Our affiliates/professional consultants who provides consultation to Users through Portal in order to respond to Your requests for information or Services.
Third-Party Applications – We may share Your information to third party application, for example when You choose to access Our Services through an application or a platform. Facebook, LinkedIn, Google, Instagram etc. You understand and acknowledge that We are not responsible for those third parties use Your information, so You should make sure You trust the application or platform and that it has a Privacy Policy which is acceptable to You.
Joint marketing arrangements – Where permitted by law, We may share Your Personal Information with joint marketers with whom We have a marketing arrangement, who shall be under confidentiality obligations towards the same.
Legal and Regulatory Authorities – We may be required to disclose Your Personal Information due to legal or regulatory requirements. In such instances, We reserve the right to disclose Your Personal Information as required in order to comply with Our legal obligations, including but not limited to complying with court orders, warrants, or discovery requests. We may also disclose Personal Information about Our Users to law enforcement officers or others, in the good faith that such disclosure is reasonably necessary to enforce this Privacy Policy; respond to claims that any Personal Information violates the rights of third parties; or protect the rights, property, or personal safety of Portal, Our Users or the general public. You agree and acknowledge that We may not inform You prior to or after disclosures made according to this section.
Persons who acquire our assets or business – We may transfer your Personal Information if We are acquired by / We acquire or merge with another entity or transfer a part of Our business, including the Portal to a third party. Any third party or resultant entity that receives Your Personal Information pursuant to a merger, demerger or business transfer shall have the right to continue to use Your Personal Information. In the event of such a sale or transfer, We reasonably notify You.
Service providers or business partners – We may use certain trusted third party and individuals to help Us to provide, analyses, and improve the Services or provide marketing, development or consulting services, data storage, payment processing and other features related to the Service. These third parties may have access to Your Personal Information only for the purposes of performing their respective tasks and are under obligations similar to those in this Privacy Policy. We may disclose Your Personal Information to service providers who perform hosting Services on Our behalf.
Notwithstanding anything mentioned hereinabove, We shall not be responsible for the actions or omissions of the parties (including but not limited to the entities listed above) with whom the Personal Information is shared, nor shall We be responsible and/or liable for any additional information User may choose to provide directly to any third party.

10. DATA RETENTION

We may retain and use Your Personal Information as necessary to comply with Our legal obligations, resolve disputes, and enforce Our agreements. We may also need to retain certain data for record keeping purposes, and there may also be residual information that will remain in our databases and on other records, which will not be removed.

11. SECURITY

We value Your Personal Information; We will ensure an adequate level of protection. We have therefore implemented technology and policies with the objective of protecting Your Personal Information from unauthorized access and improper use and will update these measures as new technology becomes available, as appropriate. All Personal Information is securely stored with shared hosting server. As a matter of security, We take back-up of systems periodically. Although We provide appropriate firewalls and protections, Our systems are not hack proof. Data pilferage due to unauthorized hacking, virus attacks, technical issues is possible, and We take no liabilities or responsibilities for it.
You are responsible for all actions of Your User account and password. Therefore, We do not recommend that You disclose Your password to any third party. If You choose to share Your User account and password or any Personal Information with third parties, You are solely responsible for the same. If You lose control of Your password, You may lose substantial control over Your Personal Information and may be subject to legally binding action.

12. INTERACTION BETWEEN YOU AND PORTAL

We are interested in your views, and we value the Feedback (defined below) we receive from you. However, we do not have control or are responsible for any such Feedback or the Personal Information which you make available through the Portal. We encourage you to be careful regarding the Personal Information you disclose in this way.
Subject to any applicable law, any communication or feedback sent by you to the Portal or Users (including without limitation testimonials, reviews, comments, blogs, contents, images, audio, feedback etc. collectively “Feedback”) is on a non-confidential basis, and We are under no obligation to refrain from reproducing, publishing or otherwise using it in any way or for purpose. We can use the feedback including without limitation any ideas, inventions, concepts, techniques or know-how disclosed therein, for any purpose including without limitation developing, manufacturing and/or marketing services.
You agree that You will not assert any ownership right of any kind in the Feedback (including without limitation copyright, patent, trademark, unfair competition, moral rights, or implied contract) and You hereby irrevocably waive the right to receive any financial or other consideration in connection with the Feedback, including without limitation acknowledgment of You as the source of the Feedback. Your submission of any Feedback shall constitute an assignment to Us of all worldwide rights, titles and interests in all copyrights and other intellectual property rights in the Feedback. For this reason, We ask that You do not send Us any Feedback that You do not wish to assign to Us, including any confidential information, Personal Information, or any original creative materials. You shall be responsible for the content and information contained in any Feedback sent by You to the Portal or otherwise to us, including without limitation for its truthfulness and accuracy.

13. THIRD PARTY LINKS

We may have links to other website/Application, or You are referred to Our Portal through a link from another website/Application. We shall not be responsible for the privacy policies and practices of other websites/Applications. Such content is subject to their terms of use and any additional guidelines and privacy information provided in relation to that use on their website/application.
We recommend that You check the policy of each website/application You visit to better understand Your rights and obligations especially when You are submitting any type of content on those third-party websites/applications. Please contact the owner or operator of such website/application if You have any concerns or questions.

14. LOGOS, CONCEPTS, IDEAS

We exclusively develop Our logos, concepts, and ideas for use in advertising, promotion, public relations and whatever else is appropriate to promote the services of Our guests. You are not supposed to misuse, steal any of Our creations, logos, and also not use any of Our creations appearing on the Portal for any purposes, otherwise the act may attract penal action.

15. INDEMNIFICATION

User agrees to indemnify Us, Our partners, affiliates, officers, agents, and employees and hold Us harmless from and against any claims, losses, damages, and demand, suffered by us arising out of or relating to: (i) accuracy and correctness of Personal Information and contents that User submits or shares through the Portal (ii) User’s violation of this Privacy Policy (iii) User’s violation of any rights of another User. (iv) infringement of any third-party intellectual property rights (v) any breach of applicable laws and regulations.

16. LIMITATION OF LIABILITY

Clement will not be liable for any damages, direct or indirect, incidental, special or consequential or exemplary damages and all liabilities (including for negligence, loss or damage such as loss of revenue, unavailability of system or loss of data and loss of Your Personal Information) and for use of or inability to use Services of any kind that is offered or to provide indemnity or any other remedy to You or any third party. We make reasonable efforts to ensure that the Portal is free from defects or viruses. It is your responsibility to ensure that you use the correct devices for accessing and using the Portal and to protect from anything that may damage it.

17. RESERVATION OF RIGHTS

All rights not expressly granted in this Privacy Policy are reserved by Us. Nothing contained in this Privacy Policy shall be construed as conferring by implication, estoppels or otherwise any license or right under any copyright, patent, trademark, or other intellectual property right of Clement or any other person or to User.

18. GOVERNING LAW AND DISPUTES

This Privacy Policy is governed by the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules 2011, which is designed to protect Personal Information and other relevant laws, and Our policies. You agree that the Governing Laws in whatsoever case shall be Indian Laws and regulations.
Any dispute arising, between You and Clement shall be governed under the laws of India and courts of law at Thane, Maharashtra, India shall have exclusive jurisdiction over such disputes.

19. CHANGES TO THIS POLICY

Amendments to this Privacy Policy will be posted to this Portal and will be effective when posted. Your continued use of this Portal following the posting of any amendment, modification, or change shall constitute your acceptance of the amendment. Please check our Privacy Policy on a regular basis.

20. CHILDREN

The Portal is not directed at anyone who We know to be under the age of 18, nor do We collect any personal information from anyone who We know to be under the age of 18. If You are under the age of 18 years, please do not use the Service and do not submit any personal information to Us. In case You are under the age of 18 years and wish to use the Portal You should obtain permission from Your parents and guardians before sharing any Personal Information about yourself to the Portal.

21. CONTACT US

If You want to avail any of our Services, You can email Us at support@clementadvisory.in If You have questions or concerns or grievances regarding this Privacy Policy, You can email Us at above mentioned email Id or at grievance officer’s ID as given below.
In accordance with the IT Act and rules made there under, the name and contact details of the Grievance Officer are provided below:
Mr./Mrs./Ms. ___________________
Contact Number-
Email ID- greivances@clementadvisory.in

I ACCEPT