Last Updated on: September 14, 2022

1. General Terms

1. Mamily Technology Private Limited, a company incorporated under the laws of India and bearing the Corporate Identification Number (CIN) U74999DL2022PTC394376 (“ Mamily ”, “ we ”, “ us ” or “ our ”), recognizes the value of the Personal Information (defined below) of its users (“ User ”, “ you ”, “ your ”). This Privacy Policy (“ Policy ”) governs the collection and processing of the information that our Users share with us while using our website ( www.mamily.in ) and mobile application(s) (“ Platform ”). This Policy explains what information we collect about you while you access and use the Platform; why we collect this information; how we use your information; how we protect and share your information; the choices we offer you, including your ability to access and update your information and make certain choices about how your information is used.

2. Please read and understand this Policy carefully to understand our privacy practices and their application to your access and use of the Platform. By using our Platform, submitting information to us, interacting with us, or signing up for any promotions or services offered by us, you agree and consent to us, as well as our respective representatives, collecting, receiving, processing, storing, transmitting, using, and sharing amongst ourselves your Personal Information, and disclosing such Personal Information to Mamily’s service providers and other relevant third parties in the manner set forth in this Policy. If you are under the age of Eighteen (18) years, you cannot access or use our Platform. For further details regarding our treatment of children’s Personal Information, please refer to Clause E of this Policy.

3. Please note that certain features of the Platform and the services we offer require the provision of your Personal Information, and where you do not provide such requested information, we may not be able to provide you with the access and use of our Platform and our services, wholly or partly. If you disagree with the terms of this Policy, we recommend you not to accept the Terms (defined below), or use or access our Platform or our services.

4. You may contact our Grievance Redressal Officer, through the contact information provided herein, in case of any queries regarding how we collect, manage, store or process your information.

5. This Policy forms part of the Terms and Conditions for the Platform, which can be accessed at www.mamily.in/customer/terms-and-conditions (“ Terms ”). All capitalized terms used, but not otherwise defined herein, will have the meaning ascribed to them in the Terms. In the event of any conflict, inconsistency or conflict between this Policy and the Terms, the terms set forth in this Policy will prevail specifically in relation to the matters stated herein.

2. Information We May Collect

1. Information you provide . Personal information means any information that relates, directly or indirectly, to an individual, who is identified or identifiable from that information or from such information in combination with other information in the possession of Mamily or any third parties engaged by Mamily, and may include sensitive personal information (“ Personal Information ”). We may ask you to provide only such Personal Information which is required and necessary for lawful purposes in connection with your use of the Platform and our services. We do not use your Personal Information, including your sensitive personal information, for any purposes other than those provided for under this Policy. Such Personal Information may include, without limitation:

1. Your full name, username, password, e-mail address, contact/mobile number, sex, gender, occupation, employment status, marital status, parental status, date of birth, place of birth, city and state in which you reside in India, postal address and postal index number (PIN code), and details in relation to your national identity card such as AADHAAR/PAN Card;

2. Your physical, physiological and/or psychological health information, medical records and history;

3. Your hardware configuration, Internet Protocol address (“ IP Address ”), type of browser used, details regarding the systems or Devices (defined below) you have accessed or used the Platform and/or our services on, and your and your Device’s live geo-location details including region, country, state and city;

4. Your financial information, such as credit or debit card details, bank account number and IFSC code, and information regarding your insurance plan(s);

5. Information related to your employment, including without limitation your employer’s details and contact information, designation, office location, employee identification number, and any additional information provided by your employer;

6. Information related to your family and dependents, including their age, relation to you, health information, and medical history and records; and

7. The images, photographs and documents you upload on the Platform or otherwise share with us.

During the course of your access or use of the Platform, we may request you to provide additional Personal Information in order to verify your identity and/or in order to personalise the services provided by us to you.

2. Information we collect . We may collect information that either you provide to us by registering or creating an account on, and accessing or using, the Platform and/or our services, or that we automatically collect when you interact with, visit, access or use the Platform. Some of the information we collect in the said manner may qualify as Personal Information. The information we may collect from you includes the following:

1. Registration and profile information. You are required to provide certain information at the time of registration and creation of your user account on the Platform, which may include without limitation username, e-mail address, password, date of birth, first name, middle name, last name, contact number(s), postal address, and details of your national identity. Upon creation of your account, you may choose to provide additional information to your profile by using your user account/profile settings, such as your profile picture, and preferences regarding the services provided on the Platform.

2. Health and insurance-related information. You may be required to provide health information, and medical history and records regarding you and/or your family members and dependents, including without limitation your children (if any), in order to facilitate the provision of services available on the Platform to you. Such information may include without limitation your, or your any of your family members’ or dependents’, sex, gender, date of birth, goals and history with respect to family planning, and insurance policies (if any).

3. Employment information. In the event that you access our services and Platform through an arrangement with your employer, you may be required to provide information in relation to your employment, including without limitation your employer’s details and contact information, designation, office location and employee identification number.

4. Usage information . Mamily and third-party providers engaged by Mamily use a variety of technologies that automatically collect certain information whenever you visit or interact with the Platform (“ Usage Information ”). This Usage Information may include, without limitation, your IP Address; information in relation to the browser that you are using such as its type and language; the domain name and Uniform Resource Locator (“ URL ”) that referred you to our Platform; date and time of your requests; search terms; domain name, date and time for each page you view; all of the areas within our Platform that you frequently visit, use and/or interact with, and the day of the week/month thereof. We also collect the name of and information about any advertisement or other link that brought you to us and such information does not personally identify you.

5. Geo-location . We may use your IP Address to gather broad demographic information, such as your geographic location and internet service provider. IP Addresses are also used to help determine the number of our Users, to maintain efficient administration of the Platform and our services, to optimize user experience and to help us analyze aggregate usage behavior.

6. Device information . With respect to the personal computer, mobile phone, other wireless device, or any other Internet enabled device used by you to access the Platform and our services (each, “ Device ”), we collect their corresponding IP Address and/or other unique identifiers (“ Device Identifier ”). A Device Identifier is a number that is automatically assigned to your Device used to access the Platform and our services, and our computer networks identify your Device by its Device Identifier.

7. Third-party websites . This Policy does not apply to any third-party website(s) and mobile application(s), even if such websites/applications are linked to our Platform. If you access our services through other platforms, or our Platform leads you to third-party websites/applications, their privacy practices may differ from those set out under this Policy. Mamily has no control over the policies, actions or omissions of third-party websites and is not responsible or liable for any such policies, acts or omissions. If you submit personal information to any of those websites, your information is governed by the applicable third-party privacy policies and not by this Policy. We recommended that you review the privacy policies of such third parties before availing their services.

8. Information from Care Guides and Employees. We may collect information from the Care Guide and/or the Expert providing consultation to you in accordance with the Terms. For avoidance of doubt, you understand and accept that Experts are third parties whose services are provided to you on the basis of a principal-to-principal arrangement between the Expert and us. The information disclosed to the Expert by you is not governed by the terms of this Policy.

9. Payment information. You will be asked to submit information to our payment processors including without limitation your first name and last name, e-mail address, date of birth (if required), and financial and billing information that is necessary for any payment within the Platform to be successfully carried out.

10. Mailing list. In the event that you sign up to our mailing list, we may require certain contact information such as your full name and your e-mail address, as required for providing you the services in connection with the mailing list.

11. Analytics. We may collect information about your use of the Platform and our services, including without limitation, how many times you visit and use the Platform; which pages you go to; traffic-related data; your IP Address; information regarding your internet service provider; information regarding your Device’s operating system and version; your Device’s brand name and model; timestamps with respect to the start and end of any period/session during which the Platform and/or our services are accessed and used, and the duration of such period/session; and the identification of any crashes of, and defects in, the Platform.

12. E-mail, feedback and comments . We may store copies of any e-mail or similar communications between you and us, which can result in the collection of your e-mail address or other Personal Information contained in the text, addresses, or other fields of your e-mail or other communication, as well as the collection of your IP Address or other routing of your communication, and the date and time of your e-mail or other communication. All transmissions between you and us, including e-mails, URLs, cookie identification numbers, usage paths, and any personally identifiable information they might contain, pass through many third party machines, operating systems, programs, browsers, web servers, networks, routers, ethernet switches, Internet Service Providers, proxy servers, intranets, the public telephone systems, or other devices, any of which may create activity logs containing such transmissions, and many of which we cannot control. We do not send e-mails asking for a User’s username and password or any other username or password. We may retain any email, feedback, comments or other communication you send to us in order to process your inquiries, respond to your requests, improve the Platform or our services, and may disclose, publish or use such communications without any obligation to you.

13. Cookies . Cookies are small data files sent from the Platform and stored in the User’s web browser, mobile phone, or other Device while the User is visiting parts of the Platform and/or using certain features of the Platform. We use cookies and other online tracking technologies, such as flash cookies, pixel tags, web bugs, web beacons and web storage, (“ Cookies ”) to collect your information, including without limitation your Usage Information, in order to monitor and improve the Platform and our services. Your web browser allows you to enable, limit or disable the use of Cookies. If you choose to disable Cookies on your Device, some features of the services we offer may not function properly or we may not be able to customize the delivery of our to you. Mamily cannot control the use of cookies and other such tracking files/technologies, or their resulting information, by third parties. The use of third-party cookies and other such tracking files/technologies is not covered by this Policy.

3. Information shared by third parties .

1. Referrals . If you are invited to the Platform by another User, such User can submit personal information about you such as your e-mail address, your social media handle or other contact information. If you have provided Mamily with Personal Information of a third party, please ensure that you have obtained such third party’s consent in relation to the processing and disclosure of their Personal Information and that this Policy is brought to the attention of such third party.

2. Third-party services . If you link, connect, or login to the Platform with a third-party service (such as Google, Twitter, Facebook, Instagram, WhatsApp), you direct such a third-party service to send us information such as your profile information, registration details and contacts list, as available with such service or as authorized by you through your privacy settings with such third-party.

We may, from time to time, collect such relevant information about you as may be necessary from other third parties on a need-to-know basis. We may combine the information you submit under your account, or we collect during your usage of the Platform or our services, with information from such third parties in order to improve your experience on the Platform and the quality of our services.

4. Information collected by mobile applications .

1. If you are using our mobile application(s), we may collect and use technical data and related information, including but not limited to, technical information about your Device, system and application software, and peripherals, which are gathered periodically to facilitate the provision of software updates, product support and other services to you (if any) related to such mobile applications.

2. The mobile application may automatically collect and store some or all of the following information from your mobile device (“ Mobile Device Information ”), in addition to the Device Information, including without limitation: (i) your preferred language and location; (ii) the brand name and model of your Device; (iii) your mobile operating system; (iv) the type of mobile internet browser(s) you are using; (v) your geo-location; (vi) information about how you interact with the mobile application and any of our websites to which the mobile application links, such as how many times you use a specific part of the mobile application over a given time period, the amount of time you spend using the mobile application, how often you use the mobile application, actions you take in the mobile application and how you engage with the mobile application; and (vii) information to allow us to personalize the services and content available through the mobile application.

3. Permissions required upon the installation of the mobile application for its effective functioning include access to your SMS, contacts, location, microphone, identity, device and caller ID, Wi–fi information, photo, media or file gallery, and notifications.

3. Use and Disclosure of the Information We Collect

We use and share the information we collect about you with certain third parties, including without limitation our service providers, contractors, vendors, partners, related entities, only in accordance with applicable laws, and subject to the terms of this Policy and as set forth below:

1. To facilitate your use of the Platform . We, or any third party acting on our behalf, may use the we collect about you information for the purposes set forth below:

1. To verify your identity;

2. To provide, maintain, develop and improve our services;

3. To provide updates and upgrades of the Platform;

4. To personalize your use of our services;

5. To process transactions and billing, for identification and authentication purposes;

6. To identify, monitor and remedy any technical issues in the Platform and any attempted circumvention of device security;

7. To communicate with you in relation to transactions, security, privacy, and administrative issues in connection with your use of the services;

8. To respond to your enquiries, feedback and comments;

9. To tell you about certain services we offer that we think you may be interested in;

10. To comply with applicable laws;

11. To enforce our policies;

12. To resolve disputes with other Users;

13. To enforce agreements with any third parties; and

14. For the administration of, and troubleshooting regarding, our services. Third parties who provide technical support for the operation of our services, such as web, hosting, inventory management, content optimization, connection checking, remote customer support and account management purposes, may need to access such information from time to time, but are not permitted to disclose such information to others.

2. To display on your public profile . You may make certain information, including your Personal Information, publicly visible to others which may include without limitation your profile picture, your username and a short description about you to other Users. We may display parts of your public profile and other content you make available to the public like listing details on third-party websites, platforms and applications. Information you share publicly on the Platform may be indexed through third-party search engines. In some cases, you may opt-out of this feature in your account settings. We will not publicly display any sensitive personal information that you provide to us.

3. To share information with third parties . It may be necessary or appropriate for us to provide access to your Personal Information to third parties such as our service providers, contractors, vendors, partners and affiliates, in order to operate the Platform, our services and our business. Without prejudice to the generality of the foregoing, in the event your employer has offered access to the Platform, we may share your Personal Information, including without limitation, your name, amount spent on the Platform and our services, and health information such as the stage of family planning and/or pregnancy you are at, with the employer. We may share information regarding your usage of, and interaction with, the Platform with third-party services such as Google, Twitter, Facebook, Instagram and WhatsApp. In order to determine and verify your coverage to use Mamily’s service under your insurance policy/plan, we may share Personal Information, including without limitation, your name, postal address, employee or member identification number, employer’s name and other information from your insurance policy/plan, with your insurance payer. Where practical, we will seek to:

1. Obtain confidentiality agreements consistent with this Policy and that will limit others’ use or disclosure of the Personal Information you have shared; and

2. Require such third parties to protect your Personal Information and meet our data security standards, including ensuring they are bound by legally enforceable obligations to comply with all applicable personal data protection requirements, while such Personal Information remains in its possession or under its control.

We may choose to anonymize your Personal Information before sharing it with any third party.

4. To enforce our legal obligations . We may also share your Personal Information if we are required to do so by law or we in good faith believe that such action is necessary to: (i) comply with the law or with legal process (such as pursuant to court order, or instructions by governmental authority, or a request by law enforcement officials); (ii) to protect, enforce, and defend our Terms, rights (including intellectual property rights) and property, and the terms of agreements we are party to; (iii) protect against the misuse or unauthorized use of the Platform or our services; or (iv) protect the personal safety or property of our Users or the public (among other things, this means that if you provide false information or attempt to pose as someone else, information about you may be disclosed as part of any investigation into your actions).

5. To carry out advertising and marketing . We may use the information you share with us to send you promotional messages and e-mails, marketing, advertising, and other information based on your preferences and carry out social media advertising through social media platforms, personalize, measure, and improve our advertising, administer referral programs, rewards, surveys, contests, or other promotional activities or events sponsored or managed by Mamily or its third-party service providers, contractors, vendors, partners or affiliates, and invite you to events and relevant opportunities.

We may also disclose or share information that does not personally identify any individual User, including anonymized information or Aggregated Information, with third parties, such as usage statistics of the Platform and/or our services, or IP Addresses. Aggregated information is information recorded about Users and collected into groups so that it no longer reflects or references an individually identifiable User (“ Aggregated Information ”). Such third parties may collect information when Users use the Platform and/or our services. Such third parties may use this aggregated information about your visits to the Platform and other websites/applications in order to provide advertisements on the other websites/applications and other forms of media about goods and services of interest to you.

6. Business transfers . In the event Mamily undertakes or becomes involved in a merger, acquisition, reorganization, any form of sale of some or all of our assets, bankruptcy, or an insolvency event, then we will provide notice to you if such a transaction results in your information being subject to a different policy.

7. Companies in the group . We may share your Personal Information with our group companies or associate entities in order to improve personalization and efficiency of the Platform and/or our services. This will enable us to provide you with information about various products and services or help us address your questions and requests in connection with the Platform and/or our services.

4. Retention of your Personal Information

1. Unless any applicable law, regulation or governmental/court order permits a longer period of retention, we will hold your Personal Information on our computer networks for as long as is necessary for the fulfilment of the purposes outlined in this Policy, or until you request for the withdrawal of your Personal Information, whichever is earlier. Please note that even if we delete your Personal Information, it may persist in backup or archival files for legal, taxation or regulatory purposes.

5. Children

1. We do not knowingly market or advertise our services to children under the age of Eighteen (18) years. Our Terms prohibit Users who have not attained the age of Eighteen (18) years from accessing the Platform or our services. In the event we learn that we have collected Personal Information from a child under the age of Eighteen (18) years, we will delete such Personal Information. We may collect information regarding the User’s children under the age of Eighteen (18) years in order to provide our services. If you believe that we might have any Personal Information from or about a child in contradiction with the abovesaid, please contact us through our grievance redressal officer, whose contact details are provided below.

6. Security

1. The security and confidentiality of your Personal Information is extremely important to us. We have implemented technical, administrative and physical security measures to protect your Personal Information from unauthorized access and improper use, and review such measures from time to time.

2. If we collect information from your Device, we encrypt it while it’s being transferred to us. Once your information reaches our servers, as part of our security program, we employ standard procedures and safeguards, such as maintaining firewalls and having an intrusion detection system, to protect the confidentiality, security and integrity of the information we maintain.

3. However, as with any information travelling over the internet and kept in servers, we cannot guarantee absolute security. Consequently, we cannot ensure or warrant the security of any information you transmit to us and you do so at your own risk. When we work with third parties, we require that they maintain the confidentiality, security and integrity of the information and commit that the information is not used for any prohibited purpose. Additionally, we use commercially reasonable computer security safeguards to protect our databases and servers against risks of loss, unauthorized access, destruction, misuse, modification, or inadvertent or improper disclosure of data. These include internal reviews of our data collection, storage and processing practices and security measures, as well as physical security measures to guard against unauthorized access to systems where we store personal data. We restrict access to Personal Information to our employees, service providers, contractors, vendors, partners, agents and affiliates who need to know that information in order for us to provide, develop or improve the Platform and our services.

7. Access, Correction and Withdrawal of your Personal Data

1. You may seek a copy of, request us to modify or correct, withdraw, your Personal Information provided directly to us in connection with the Platform and/or our services, by writing to us at [email protected] . We will make reasonable efforts to comply with your request within Seven (7) working days of receipt of such request.

2. Please note that if your Personal Information has been provided to us by a third party, including without limitation the organization/business you are employed with, you must contact such party directly to make queries, feedback, and access and correction requests to Mamily on your behalf.

3. Please note that if you withdraw your consent to any or all use of your Personal Information, depending on the nature of your request, Mamily may not be in a position to continue to provide its services to you or administer any contractual relationship in place.

8. Grievances and Complaints

1. If you have any questions, comments, requests, notices or grievances in respect of this Policy or the usage of your Personal Information, you may reach out to our grievance officer, Ms. Divya Deswal, who can be contacted at [email protected] .

9. Updates

1. Mamily may, at its sole discretion, modify this Policy at any time. Whenever we do so, the revised Policy will be posted and the ‘Last Updated’ date, will be updated at the top of this Policy. You are requested to keep yourself updated with the Policy from time to time. Your continued usage of the Platform will be deemed to be an acceptance of the modifications of the Policy.

10. Governing Law and Jurisdiction

This Policy will be governed in all respects by the laws of India. To the fullest extent permitted by applicable laws, you hereby expressly agree that any proceeding arising out of or relating to this Policy will be instituted in courts in New Delhi, India.