BigToe Privacy Policy

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Privacy Policy

At [Company Name], we value the protection and are responsible for the use of your [“You”, “Your” or “User”] personal data and information. Your privacy is important to us, and we are committed to safeguarding it.

Please take a moment to review our privacy policy to understand how we collect, use, and share your information. By accessing or using our website(WEBSITE URL), mobile applications, or any other services provided by us (collectively referred to as the “App”), you acknowledge and agree to the practices and policies outlined in this privacy policy.

This Privacy Policy is made available in accordance with:

  1. Section 43A of the Information Technology Act, 2000.
  2. Regulation 4 of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011 (“SPDI Rules”); and
  3. Regulation 3 of the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021.
  4. The Digital Personal Data Protection Act, 2023
  5. Any other law/guidelines/ that will be applicable for protection of data and information in the country from time to time
Scope

This privacy policy pertains to how we handle personally identifiable information, both in digitised and non-digitised form (which shall later be digitised), (collectively known as “Personal Information”), collected when you use our App to access third-party Products and Services, including fitness services, or visit offline stores, clinics, fitness centres, or other physical premises (“Premises”). It applies to personal information received by [Name of the Company] from India, and personal data processed outside India for the purpose of providing goods and services to Users. Please note that this policy does not cover the policies or practices of companies not owned or controlled by us (including our franchisees), or individuals not employed by us.

By visiting our Forum, downloading the App, or subscribing to or utilizing Wellness Services, you consent to the collection, use, sharing, disclosure, and processing of your personal information by us and the sellers/service providers on the Forum (“We”, “Us”, “Our”), in accordance with the terms of this Privacy Policy or as otherwise required or permitted under applicable law.

We do not knowingly collect or solicit personal information from individuals under the age of 18, nor do we allow them to register for Wellness Services. If you are under 18, please refrain from attempting to register for Wellness Services, or providing any information about yourself to us. We do not knowingly accept personal information from individuals under the age of 18. If we discover that we have inadvertently collected personal information from a child under the age of 18 without parental consent, we will promptly delete such information. If you believe that we may have collected information from or about a child under 18, please contact us at [EMAIL ID] or reach out to our Grievance Officer.

What information do we collect?

We gather various types of information, including:

Information you intentionally provide:

  • Personal details submitted during registration on our App/website, such as your name, username, email address, gender, birth date, height, and location.
  • Data required for providing Services on the App/website, such as nutrition data, dietary and lifestyle information, physical attributes like height and weight, passwords, workout data (including camera outputs for “live energy” tracking or live workout sessions), physical activity levels, photographs, biometric data, genetic information, racial and ethnic background, family information (as necessary for effective service provision), sleep patterns, and other health-related insights for our Services.
  • Bank details for payment processing.
  • Health-related information, mental wellbeing status, disabilities, vaccination records, past and present medical history, gathered to ensure the safety of our users and premises, fulfill our obligations as an employer, or provide specific benefits.
  • Mobile address book data to facilitate user connections via ‘squads’, with no further processing of this information.
  • Premises access and usage information, including workout sessions, activity levels, user counts, data recorded at reception desks and kiosks, and CCTV footage for common areas, collected in compliance with relevant CCTV policies.

 

The information collected falls under the categories of ‘personal information’ or ‘sensitive personal data or information’ (“SPDI”) as per the SPDI Rules and the Digital Personal Data Protection Act, 2023. By availing services or products or visiting our offline premises, you consent to the collection of such information.

While you have the option to refrain from providing certain information, doing so may hinder your ability to register or access certain features. We may anonymize personal information to provide aggregated insights to our Affiliates. For example, we might combine data on gender and average nightly sleep duration to share generalized findings with Affiliates, such as the average sleep duration among users of different genders.

Information from iOS HealthKit, Health app, and Google Fit:

When you share your iOS Health app data or Google Fit with our App, that data is covered by our privacy policy.

We handle all iOS Health app and HealthKit data in accordance with Apple’s guidelines. To view Apple’s HealthKit developer guidelines, https://developer.apple.com/app-store/review/guidelines/#health-and-health-research.

Google Fit data is handled according to Google Fit Terms of Service. For more information, https://developers.google.com/fit/terms.

Automatically Collected Information:

When you interact with our App, we automatically receive and record information on our server logs, including your IP address, cookie data, and requested pages. Cookies are identifiers that allow us to recognize your browser or device and understand how and when pages in our App are visited.

Information gathered through manual record-keeping at offline Premises:

When you or an authorized person on behalf of the company enters personal information into our system located on our premises or in our books of accounts, we take this conduct as your consent to keep such information for the purpose to serve you better and improve our offerings.

Purpose and Use of Information:

We, our Affiliates, and service providers may use your Personal Information and SPDI for various purposes, including:

  • If we have a legal duty to use your personal information for a particular reason;
  • To respond to your requests;
  • When we get your consent to use it,
  • To fulfill the purpose for which we have collected your personal information;
  • When it is in our legitimate interests which are our business or commercial reasons for using your personal information, but even so, we will not unfairly put our legitimate interests above what is best for you;
  • To send communications to you about our or our affiliates’ current services, new services or promotions that we are developing, and opportunities that may be available to you;
  • Provision and improvement of quality of Services or products;
  • Contacting you about offerings and collaborations;
  • Business operations and compliance with legal obligations;
  • Generating insights to understand preferences and trends;
  • Fraud protection and risk reduction;
  • To ensure that our site and our services function in an effective manner for you;
  • To alert you to new features or enhancements to our services, changes in terms and conditions, user agreements, and policies and/ or other administrative information;
  • To investigate potential breaches, or to protect your rights, and safety of our website or App;
  • To respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include such authorities outside your country of residence.

 

We strive to gather only the information essential for providing services or addressing your inquiries. It’s your responsibility to ensure that the information you provide is accurate, complete, and up to date.

By providing your contact details on our Website, Apps, or Premises or any other platform, you consent to receiving communications from the Company or any of its associated affiliates via email, SMS, and phone calls.

Sharing of Personal Information

To safeguard your account and personal information, it’s crucial to choose a strong password and limit access to your devices. After accessing your account, remember to sign out to prevent unauthorized access.

We have measures in place to ensure that we only retain your information as long as necessary for its intended purpose or as required by law. Your data may be anonymized, aggregated, or de-identified for various purposes and may be held by us, our affiliates, service providers, or authorized third parties.

While we strive to protect your privacy and information, we cannot guarantee absolute security due to potential risks like unauthorized access, hardware or software failures, and other factors.

Our mobile App may contain links to other websites whose privacy policies may differ from ours. It’s important to review each site’s privacy policy when visiting external links.

Although encryption technology helps enhance security, no system is entirely foolproof. While transmitting information to us over the internet, there’s a risk of interception. Any information you transmit to our mobile App is at your own risk.

Transfer of SPDI outside India:

Subject to applicable law, we may transfer personal information and/or SPDI to any other body corporate ensuring data protection standards comparable to those provided by us under this policy, in India or elsewhere. By using our Services, you consent to the storage and processing of personal information and SPDI by third parties. We will endeavour to ensure that third parties afford the same level of data protection as required under Indian law.

Security of Personal Information:

To enhance account security, ensure your password is well-chosen and kept confidential. Though we strive for security, factors like unauthorized access or hardware issues may affect it. If you wish to opt out of receiving emails or communications, please reach out to our Grievance Officer at [EMAIL ID].

Accessing Personal Information:

You can access, and in some cases, edit or delete certain information through your account settings, including your name, password, email address, and user profile details. However, information automatically uploaded to the App, or collected by us, cannot be altered later. We store your personal information (including SPDI) until you request its deletion.

Grievance Redressal:

If you have any concerns or complaints regarding the use of our Services or Products, please reach out to us at [Email ID] or contact our Grievance Officer/ Consent Manager, whose details are provided in accordance with the Information Technology Act, 2000, SPDI Rules and Digital Personal Data Protection Act, 2023. We will strive to resolve your grievances within the specified timelines as per applicable laws.

Choices and Opt-Out Options:

While you have the choice not to disclose certain information, some details may be necessary for registration or accessing specific features. We will retain your personal information for a reasonable period or as required by law. If you wish to modify or delete information provided to us, please contact us at [Email ID] or reach out to our Grievance Officer. Please note that some information may be essential for the proper functioning of the App.

You may be able to manage your preferences for receiving emails or other communications from us. However, please note that legal notices will still apply to your use of the App.

If you wish to opt-out of any services, offers, or benefits provided by us or sellers on the Forum, you may do so as per the terms specified. Please carefully review notices sent to you from time to time.

Amendments to Privacy Policy:

We reserve the right to amend this privacy policy periodically. Your continued use of the App or Service after any changes are indicative towards your acceptance of the revised policy. We will notify you of any significant changes by posting an announcement on our App or by putting it on a sending you on an registered email.