This Privacy policy document of the QISPINE App is published in accordance with the provisions of:

1. Section 43A of the Information Technology Act, 2000;
2. Rule 4 of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011; and
3. Regulation 3(1) of the Information Technology (Intermediaries Guidelines and Digital Media Ethics Code) Rules, 2021.

and other applicable law enacted from time to time, which requires the publishing of a privacy policy for handling of, or dealing in personal information including sensitive personal data or information.
This Privacy Policy (hereinafter referred to as “Privacy Policy”) describes how QISPINE collects and handles certain information it may collect and/or receive from you via the use of this Mobile application available on the Android Play store or the IOS App store. This Privacy Policy applies to current and future visitors and users of our Mobile Application. By visiting and/or using/downloading our Mobile Application, you are consenting to the practices described in this Privacy Policy.
For the purposes of this Privacy Policy (“Privacy Policy”), “We”, “Our”, “Us” and “QISPINE” shall mean (“QISPINE”) and “You” and “Your” shall mean User/Customer/Consumer of the Mobile App (“User”), whether registered or not. This Privacy Policy shall be read along with the Terms of Use mentioned in Terms and Conditions. The capitalized terms that are used in this Privacy Policy but not defined herein shall have the same meaning as defined in the Terms of Use. This Privacy Policy is incorporated into, and is subject to, the terms and conditions pertaining to the services rendered by us (“Services”). This Privacy Policy sets out what information we collect when you access the App and create an account with us (“Account”), and how and why we use it. BY ACCEPTING THE PRIVACY POLICY, YOU EXPRESSLY CONSENT TO QISPINE’S COLLECTION, RETENTION, ANALYSIS, USE AND DISCLOSURE OF YOUR PERSONAL INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY.

DEFINITIONS

For the purposes of this Privacy Policy: “Account” means a unique account created for you to access our Services or parts of our Service.
“Personal Information” also called “Personal Data” means any data about an individual who he is identifiable by, or, in relation to such data; or any information that relates to a specific person. Some of the most obvious examples of personal information include one’s name, mailing address, email address, phone number (if they can be used to identify the person). In addition, online footprints that can be used to identify/ track an individual/ his behaviour such as location tracking, or Internet browsing history may also be treated as personal information.
“Non-Personal Information” may be collected by QISPINE which cannot be used to identify you at an individual level, while you are using the Mobile App. This information inter alia includes IP address, browser type, name of your internet service provider.
Personal Information and Non-Personal Information hereinafter together is referred to as the “Collectively Collected information”
“Data” means a representation of information, facts, concepts, opinions or instructions in a manner suitable for communication, interpretation or processing by humans or by automated means;
“Cookies” are small files that are placed on your computer, mobile device or any other device by a website, containing the details of your browsing history on that website among its many uses.
“Device” means any device that can access the Service such as a computer, a cell phone or a digital tablet.
“Usage Data” refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

INFORMATION COLLECTED WHILE USING THE APPLICATION

While using our Application, in order to provide features of our Application, we may collect, with your prior permission: –

• Information regarding your location

We use this information to provide features of our service, to improve and customize our service. The information may be uploaded on our servers and/or a Service Provider’s server or it may be simply stored on your device. You can enable or disable access to this information at any time, through your Device settings.

COLLECTING PERSONAL INFORMATION

The Personal Information collected from you through the QISPINE app shall be preserved digitally with us as your Personal Data.
We use Cookies and similar tracking technologies to track the activity on our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information to improve and analyze our Service. The technologies we use may include:
Cookies or Browser Cookies – you can instruct your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if you do not accept Cookies, you may not be able to use some parts of our Service. Unless you have adjusted your browser setting so that it will refuse Cookies, our Service may use Cookies.
We use both Session and Persistent Cookies for the purposes set out below:
Necessary / Essential Cookies
Type: Session Cookies
Administered by: Us
Purpose: These Cookies are essential to provide You with services available through the Mobile App and to enable you to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that you have asked for cannot be provided, and we only use these Cookies to provide you with those services.
Cookies Policy / Notice Acceptance Cookies
Type: Persistent Cookies
Administered by: Us
Purpose: These Cookies identify if users have accepted the use of cookies on the Mobile App.
Functionality Cookies
Type: Persistent Cookies
Administered by: Us
Purpose: These Cookies allow us to remember choices you make when you use the Mobile App, such as remembering your login details or language preference. The purpose of these Cookies is to provide you with a more personal experience and to avoid You having to re-enter your preferences every time you use the Mobile App.While using our Service, we ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personally, identifiable information may include, but is not limited to:

• Email address
• First name, middle name and last name
• Phone number
• Date of birth
• Device IP address
• Mobile number
• Camera access, microphone access, SMS access
• Permanent address, Correspondence Address, State, Province, ZIP/Postal code, City
• Usage Data
• Information you disclose in your user profile
• Transactional Information for transactions done on the QISPINE App

A. Usage Data
Usage Data is collected automatically when you are using our Services.
Usage Data may include information such as your Device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service and configurations, operating systems, device brand and model, time zone setting, geo-location information, content, unique identifiers associated with your device(s) and pages that you access on the Mobile App, and the dates and times that you visit the Mobile App and paths taken that you visit, the time spent on those pages, unique device identifiers and other diagnostic data. When you access the Service through a mobile device, all or any of the above information pertaining to the mobile device would also constitute usage data.
We may also collect information that your browser sends whenever you visit our Service or when you access the Service by, or through a mobile device.

PROCESSING AND USE OF YOUR PERSONAL DATA

We process data collected from you as described in this policy through your use of the QISPINE Mobile App which may be used for:

• Improving our services, site and how we operate our services;
• Understanding and enhancing your experience of using our site/app, products and services;
•  Personalizing our products and services and to make recommendations;
• Providing and delivering products and services you request;
• Processing, managing, completing, and accounting for transactions;
• Attending and managing your requests to us;
• Providing customer support and to respond to your requests, comments and inquiries;
• Communicating with you about promotions, offers, upcoming events and news, or/ and general information about similar/complimentary products to those you have purchased/enquired about, which we offer, unless you have opted not to receive such information;
• Providing you access to different functionalities of the Service that are available to you as a registered user;
• Sending you related information, including confirmations, invoices, technical notices, updates, security alerts, support and administrative messages;
• Contacting you by email, telephone calls, SMS, push notifications in the app or other such similar electronic communication related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation;
• Processing your personal information without your consent where required by applicable law or the regulation for the purpose of verification of identify or for prevention, detection or investigation including of cyber incidents, prosecution and punishment of offences;
• Protecting, investigating and deterring against fraudulent, unauthorized or illegal activity;
• Performance of an undertaking: the development, compliance and undertaking of the purchase agreement for the products, items or services you have purchased or of any other agreement you have entered into through the Service;
• Business transfers – we may use your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by us about our Service users is among the assets transferred.
• Other purposes – we may use your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our products, services, marketing and your experience.
• We may use third-party Service providers to monitor and analyze the use of our Service. These third-party Service providers or vendors collect, store, use, process and transfer information about your activity on our Service in accordance with their Privacy Policies.
• We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt-out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us.

DISCLOSURE OF YOUR PERSONAL DATA

We may disclose your personal information in the following circumstances: –

• To another company: We may share your personal information with another company for the purpose of business transfers, connection with, or during negotiations of, any merger, sale of our assets, financing, or acquisition of all or a portion of our business.
• To service providers: We may share your personal information with Service Providers to monitor and analyze the use of our Service, for payment processing, or to contact you.
• To business partners: We may share your information with our business partners to offer you certain products, services or promotions.
• To other users: when you share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.
• To third parties: We may share your information with our third-party partners in order to receive additional information about you. We may also share your information with third-party partners to create offers that may be of interest to you. The Mobile App may allow you to connect with other websites, products, or services that we do not have any control over. We may provide paid products and/or services within the Service. In that case, we may use third-party services for payment processing (e.g. payment processors). These payment processors adhere to the standards set by RBI and/or applicable regulatory authorities and in accordance with applicable law. However, usage of such third-party services is subject to their privacy policies and not within our control. We recommend that you have a look at their privacy policies before agreeing to use their services. Our Service may contain links to other websites that are not operated by us. If you click on a third-party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.
• To subsidiaries and holding companies: We share data with our subsidiaries and affiliates to help us provide our Services or conduct data processing on our behalf.
• To law enforcement: Under certain circumstances, we may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public/law enforcement/regulatory authorities (e.g. a court or a government agency).
• For other legal requirement: We may disclose your Personal Data in the good faith and belief that such action is necessary to:
  • Comply with a legal obligation
  • Protect and defend the rights or property of QISPINE
  • Prevent or investigate possible wrongdoing in connection with the Service
  • Protect the personal safety of Users of the Service or the public
  • Protect against legal liability

We may disclose your personal information for any other purpose with your Consent in accordance with the Terms of Use entered into with us.

RETENTION OF YOUR PERSONAL DATA

We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policieWe will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.
We may provide paid products and/or services within the Service. In that case, we may use third-party services for payment. We will not store/retain or collect your payment processing details (e.g. debit/credit/UPI and/or other payment details). The information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy.

TRANSFER OF YOUR PERSONAL DATA

Your information, including Personal Data, is processed at QISPINE’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to and maintained on computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate data transfer controls in place including the security of your data and other personal information.
If we are involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.

SECURITY OF YOUR PERSONAL DATA

The security of your Personal Data is important to us. We take due care to protect your data. Technical measures are in place to prevent unauthorized or unlawful access to data and against accidental loss or destruction of, or damage to, data. The employees who are dealing with the data are trained to protect the data from any illegal or unauthorised usage. We work to protect the security of your information during transmission by using secure sockets locker (SSL) software.
We maintain physical, electronic and procedural safeguards in connection with the collection, storage, and disclosure of personal customer information. We take reasonable steps to secure your personal information in an effort to prevent the loss, misuse and unauthorised access, disclosure, alteration and destruction.
It is your responsibility to protect against unauthorised access to your password and your computers, devices, and applications.

YOUR RIGHTS WITH REGARDS TO PERSONAL INFORMATION

As a user of our Services, you have the following rights, any of which you may exercise by contacting us as per contact details of the Data Protection Officer provided below.

• Access to your personal information: You may request a record of your Personal Information being processed by us, upon the verification of your identity and other information as per the QISPINE’s internal policy. It includes your name, contact details, email id, mobile no.
• Review, Correct and Rectify your information: You may review, correct or rectify the inaccurate Personal Information that is stored with us.
• Withdrawing your consent: You may withdraw consent to processing that you have given us and prevent further processing of your Personal Information subject to the terms of this Privacy Policy. You may also withhold your consent prior to the collection and processing of your combined information.

CHANGES TO YOUR INFORMATION

You may review, correct, update, change the basic information such as name and address that you have provided by logging into your account. However, you are not permitted to, delete any part of the personal information, or to delete/modify any other information that is generated & stored on the Mobile App. If you choose to update your Personal Data or modify it in a way that is not verifiable by us, or leads to such information being incorrect, we will be unable to provide you with access to our Mobile App or the Services, and such modification may be regarded as the user seeking to discontinue his or her access to our Mobile App or the Services. We reserve the right to verify and authenticate your identity and your Personal Data in order to ensure accurate delivery of Services. Access to or correction, updating or deletion of your Personal Data may be denied or limited by us if it would violate another person’s rights and/or is not otherwise permitted by the applicable laws.

CHILDREN’S PRIVACY

Use of the Mobile App is available only to persons who can form a legally binding contract under the Indian Contract Act, 1872. If you are a child (less than 18 years) you may only disclose information to us with your parent(s) or legal guardian’s consent. Your parent(s) or legal guardian’s can view all information within or associated with the account created by you for availing of QISPINE’s services.
If we need to rely on consent as a legal basis for processing your information, we may require your parent’s consent before we collect and use this information. If we become aware that we have collected Personal Data from any person who cannot form a legally binding without verification of parental consent, we take steps to remove that information from our servers. Please note that misrepresenting your age is illegal.

CHANGES TO THIS PRIVACY POLICY

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.
We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the “Last updated” date at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

DATA PROTECTION OFFICER

In accordance with the Data Privacy Laws made thereunder, the name and contact details of our Data Protection Officer are provided below. If you have any concern about the Privacy Policy or grievances on the Mobile App, any concerns or questions or In case of any unusual/fraudulent activity in the account and about loss/theft of any of your personal data, please contact the Data Protection Officer as per contact details provided below and we will try to resolve the issue for you.
Name:
Address:
Phone number:
E-mail:

DISCLAIMER

We cannot ensure that all your personal information will never be disclosed in ways not otherwise described in this Privacy Policy. Therefore, although we are committed to protecting your privacy, we do not promise, and you should not expect, that your information or private communications will always remain private. As a User of the Mobile App, you understand and agree that you assume all responsibility and risk for your use of the Mobile App, the internet generally, and the information you post or access and for your conduct on and off the Mobile App.

INDEMNIFICATION

You agree and undertake to indemnify us in any suit or dispute by any third party arising out of disclosure of information by you to third parties either through Our Mobile App and your use and access of websites, applications and resources of third parties. We assume no liability for any actions of third parties with regard to your personal information you may have disclosed to such third parties.

DISPUTE RESOLUTION

Any dispute under the Privacy Policy shall be governed by Indian laws & shall be subject to the exclusive jurisdiction of the courts of Mumbai. Name : – ____________________
Address: – ____________________
E-mail: – _____________________
Telephone: – __________________