Privacy Policy

Terms & Conditions can be visited here

Please read this Privacy Policy (this “Privacy Policy”) carefully.

To use the Services that and its affiliates (collectively, “”, “we,” “us,” or “our”) provide, you as a user of the Services must accept this Privacy Policy (“User”, “you”, “your”). If you do not consent to the terms of the Privacy Policy, please do not access or use the Services. Personal Information. Your privacy is important to , and is committed to carefully managing your individually identifiable information (“Personal Information”) in connection with the Services that provides. “Personal Information” means any information that may be used, either alone or in combination with other information, to personally identify an individual, including, but not limited to, a first and last name, a personal profile, an email address or other contact information.

This Privacy Policy describes the information practices for , including what type of information is gathered and tracked, how the information is used, and with whom the information is shared. is committed to protecting the privacy of the data you provide in the Service as appropriate, but at the same time encouraging you to interact with and share information about you progress with other users using the Services. This Privacy Policy applies to our Services operated in India, and we provide this Privacy Policy explaining our online information practices and the choices you can make about the way Personal Information is collected and used in connection with the Service. By using the Website and the Mobile App, User acknowledges and accepts this Privacy Policy. Each User’s participation is also governed by the “Terms & Conditions,” which is entered into and agreed to by each User prior to using the Website and the Mobile App. Unless we define a term in this Privacy Policy, all capitalized terms used in this Privacy Policy have the same meanings set forth in our Terms & Conditions.

This Privacy Policy also applies to User’s use of interactive features or downloads that:

(i) owns or controls;

(ii) are available through the Website or the Mobile App or services; or

(iii) interact with the Website (including through social media) and/or the Mobile App or services. Information That Collects Personal Information. We have implemented this Privacy Policy because your privacy, and the privacy of other Service users, is important to us. We operate in accordance with applicable data protection legislation and regulations. We recognize the importance of protecting the privacy of Personal Information collected about our users. This Privacy Policy discloses what Personal Information we gather, how we use it, and how you can correct or change it. It is our intention to give you as much control over your Personal Information as possible to preserve your privacy, while still allowing us to utilize that Personal Information in the course of our business to provide you a valuable service. Consent and Modification. By using the Service, you consent to the terms of this Privacy Policy and to our processing of Personal Information for the purposes set forth herein. If you do not agree to this Privacy Policy, please do not use the Service. We reserve the right, at our discretion, to change this Privacy Policy at any time, which change shall become effective upon posting by the Company on the Website, the Mobile App, via the Service or sending you an email or other notification. You will be deemed to have agreed to Additional Terms (as defined in the Terms & Conditions) by your decision to continue accessing the Mobile App or services or the Website or otherwise using any of the Services following the date in which such Additional Terms become effective. Receipt and Collection of Information. We collect Personal Information from users. In each case, you will only be required to provide the Personal Information that we need in order to be able to provide the services you have requested. You may be entitled under data protection laws to access and review the Personal Information that we hold on you, if you provide the necessary consent and background information and pay any mandated fee. All such communications regarding access to your personal data should be addressed to: connect@transforminds.in .

Such inquiries should clearly be marked as data protection queries and as being time sensitive. In particular, we receive and/or collect Personal Information from you in the following ways: may collect and process Personal Information when User registers for or uses the Services and/or uses the Website and/or the Mobile App, interacts with the Website and/or the Mobile App, use any aspects of our Services or otherwise contacts . QuitFit may collect and process certain Personal Information from User such as the User’s name, telephone number, e-mail address, mailing address, telephone number, user name, and password. uses the Users’ Personal Information that collects for the following general purposes: to fulfill User’s request for use of certain features of the Website and/or the Mobile App or services, to conduct surveys, and for QuitFit's billing purposes. QuitFit may also collect and process Personal Information relating to User’s use of QuitFit's Services and any details of any e-mail correspondence or any other social media interactions that User has with . QuitFit will collect only as much Personal Information as needs for the purposes specified in this Privacy Policy, for purposes specified at the time of collection of the Personal Information, or for other purposes that you consent to in the future. QuitFit provides Users the option, at User’s sole election, to upload a profile image that is viewable by other participants of the Services, but this is not mandatory. Users may delete User’s profile picture at any time by logging into the Mobile App / LMS /website or services and visiting the profile settings page. Demographic & Non-Identifying Information. QuitFit may collect and process demographic information from or about User at the Website and the Mobile App / Pre Recorded Course or services from time to time, such as information about User’s gender, age, country, and zip code (“Demographic Information”).

QuitFit may collect this information through various forms and in various places on the Website and/or the Mobile App / Pre Recorded Course or services, including account registration forms, contact forms, or when User otherwise interacts with the Website and/or the Mobile App / Pre Recorded Course or services. To the extent that combines any non-personally identifiable Demographic Information with User’s Personal Information that collects directly from User on the Website and the Mobile App / Pre Recorded Course / or services, will treat the combined data as Personal Information under this Privacy Policy. QuitFit also collects data about User, including about User’s smoking behaviour and related information that enables User to fully participate in the Service. Information Collects or Stores as User Accesses and Uses the Website and Service In addition to any Personal Information or other information that User choose to submit to via QuitFit's Website, and QuitFit's third-party service providers may use a variety of technologies that automatically (or passively) store or collect certain information whenever User visits or interacts with the Website (“Usage Information”).

This Usage Information may be stored or accessed using a variety of technologies that may be downloaded to User’s personal computer, browser, laptop, tablet, mobile phone or other device (a “Device”) whenever User visits or interacts with QuitFit's Website and/or the Mobile App or services of Transforminds Wellness LLP. To the extent associates Usage Information with User’s Personal Information QuitFit collects directly from User on the Website, will treat it as Personal Information. This Usage Information may include: • User’s IP address, UDID or other unique identifier (“Device Identifier”).

A Device Identifier is a number that is automatically assigned to User’s Device used to access the Website, and 's computers identify User’s Device by its Device Identifier;

• User’s Device functionality (including browser, operating system, hardware, mobile network information);

• User’s subscription level;

• the URL that referred User to 's Website;

• the areas within 's Website and/or Mobile App that User visits and User’s activities there, including remembering User, User’s preferences and pages User requested and/or viewed;

• User’s Device characteristics; and

• certain other Device data, including the time of day, among other information. QuitFit may use various methods and technologies to store or collect Usage Information (“Tracking Technologies”). Tracking Technologies may set, change, alter or modify settings or configurations on User’s Device. The Tracking Technologies that may be used are the following (and subsequent technology and methods later developed which perform a similar function):

• Cookies. A cookie is a data file placed on a Device when it is used to visit the Website. A Flash cookie (or locally shared object) is a data file placed on a Device via the Adobe Flash plug-in that may be built-in to or downloaded by User to User’s Device. HTML5 cookies can be programmed through HTML5 local storage. Unlike Flash cookies, HTML5 cookies do not require a plug-in. Regular cookies may generally be disabled or removed by tools that are available as part of most commercial browsers, and in some but not all instances can be blocked in the future by selecting certain settings. Each browser User uses will need to be set separately and different browsers offer different functionality and options in this regard. Also, these tools may not be effective with regard to Flash cookies or HTML5 cookies. For information on disabling Flash cookies go to Adobe’s web site www.adobe.com. Please be aware that if User disables or removes cookies, Flash cookies, or HTML5 cookies on User’s Device, some parts of 's Website, Mobile App and/or Services may not function properly, and that when User revisits 's Website, Mobile App and Services User’s ability to limit cookies is subject to User’s browser settings and limitations.

• Web Beacons. Small graphic images or other web programming code called “web beacons” (also known as “1×1 GIFs” or “clear GIFs”) may be included in pages and messages of our Website, Mobile App and Services. Web beacons may be invisible to User, but any electronic image or other web programming code inserted into a page or e-mail can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Website, Mobile App and Services, to monitor how users navigate the Website, Mobile App and Services, to count how many e-mails that were sent were actually opened or to count how many particular articles or links were actually viewed.

• Embedded Scripts. An embedded script is programming code that is designed to collect information about User’s interactions with the Website, Mobile App and Services, such as the links User clicks on. The code is temporarily downloaded onto User’s Device from QuitFit 's web server and/or Mobile App or a third party service provider, is active only while User is connected to the Website and/or Mobile App, and is deactivated or deleted thereafter.

• ETag, or entity tag. A feature of the cache in browsers. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL. If the resource content at that URL ever changes, a new and different ETag is assigned. Used in this manner ETags are a form of Device Identifier. ETag tracking may generate unique tracking values even where the consumer blocks HTTP, Flash, and/or HTML5 cookies. QuitFit may use Tracking Technologies for a variety of purposes, including:

• Strictly Necessary. QuitFit may use cookies or other Tracking Technologies that considers is strictly necessary to allow User to use and access QuitFit 's Website, Mobile App and Services, including cookies required for system administration, to prevent fraudulent activity, or to improve. • Performance Related. QuitFit may use cookies or other Tracking Technologies that are useful in order to assess the performance of the Website, Mobile App and Services, including as part of QuitFit's analytic practices or otherwise to improve the content, products or services offered through the Website, Mobile App and Services.

• Functionality Related. QuitFit may use cookies or other Tracking Technologies that are required to offer User enhanced functionality when accessing the Website, including identifying User when User sign in to QuitFit's Website or keeping track of User’s specified preferences, including in terms of the presentation of content on QuitFit's Website. QuitFit obtains User’s consent to QuitFit's information storage or collection Tracking Technologies by providing User with transparent information in QuitFit's Privacy Policy and providing User with the opportunity to make a choice to disable cookies as set forth above. Please note that QuitFit is not required to obtain User’s consent to the information collection Tracking Technologies identified above that is strictly necessary. User has the right to object to other use of information storage or collection technologies. There may be other Tracking Technologies now and later devised and used by in connection with the Website, Mobile App and Services. Further, third parties may use Tracking Technologies with QuitFit's Website. QuitFit does not control those Tracking Technologies and is not responsible for them. However, User consents to potentially encountering third party Tracking Technologies in connection with use of QuitFit's Website, Mobile App and Services and accepts that QuitFit's statements under this Privacy Policy do not apply to the Tracking Technologies or practices of such third parties. User should check the third party websites to confirm how User’s information is collected and used. Various third parties are developing or have developed signals or other mechanisms for the expression of consumer choice regarding the collection of information about an individual consumer’s online activities over time and across third-party web sites or online services (e.g., browser do not track signals). Currently, QuitFit does not monitor or take any action with respect to these signals or other mechanisms. Information Third Parties Provide About User QuitFit may, from time to time, supplement the information collected directly from User at the Website, Mobile App and through Services with outside records from third parties for various purposes, including to enhance 's ability to serve User, to tailor QuitFit's content to User and to offer User opportunities that may be of interest to User. To the extent combines any non-personally identifiable information receives from those sources with User’s Personal Information collect on the Website, Mobile App and Services, it will be treated as Personal Information and will apply this Privacy Policy to such combined information, unless it has disclosed otherwise. Interactions with Third-Party Websites The Website, Mobile App and Services may include functionality that allows certain kinds of interactions between the Website, Mobile App and Services and User’s account on a third-party web site or application. The use of this functionality may involve the third-party operator providing certain information, including Personal Information, to . For example, when User registers with the Website and/or Mobile App or services, User may have an option to use User’s Facebook, Google or other account provided by a third-party site or application to facilitate the registration and log-in or transaction process on the Website, Mobile App and Services or otherwise link accounts. If QuitFit offers and User chooses to use this functionality to access QuitFit's Website, Mobile App and Services, the third-party site or application may send Personal Information about User to the Website and/or Mobile App. If so, QuitFit will then treat it as Personal Information under this Privacy Policy, since is collecting it as a result of User’s accessing of and interaction on QuitFit's Website, Mobile App and Services. In addition, QuitFit may provide third-party sites’ interfaces or links on the Website, Mobile App and Services to facilitate User’s sending a communication from the Website, Mobile App and Services. For example, QuitFit may use third parties to facilitate emails, text messages, blog postings, tweets or Facebook postings. These third parties may retain any information used or provided in any such communications or other activities and these third parties’ practices are not subject to QuitFit’s Privacy Policy. QuitFit may not control or have access to User’s communications through these third parties. Further, when User uses third-party sites or services, User is using their services and not QuitFit’s services and QuitFit is not responsible for their practices. User should review the applicable third-party privacy policies before using such third-party tools on QuitFit's Website. How QuitFit Uses the Personal Information Except as set forth in this Privacy Policy or as specifically agreed to by QuitFit , User will not disclose any information QuitFit gathers from User on QuitFit’s Website, Mobile App and Services. Except as set forth in this Privacy Policy, QuitFit does not share User’s Personal Information with third parties for those third parties’ direct marketing purposes. QuitFit may provide to third parties information about User that does not allow User to be identified or contacted, including where such information is combined with similar information of other users of QuitFit’s Website, Mobile App and Services. For example, QuitFit might inform third parties regarding the number of unique users who visit and/or use QuitFit’s Services, the demographic breakdown of the registered users of QuitFit's Services, or the activities that users engage in while on QuitFit’s Website and/or Mobile App. In connection with the Business Premium Services, the Business Customer may disclose certain Personal Information to QuitFit. To the extent that QuitFit collects and processes Personal Information supplied by the Business Customer, is considered to be the data controller for the purposes of European data protection legislation and will process User’s Personal Information in accordance with this Privacy Policy. QuitFit may use User’s information that collects about User: • to contact User occasionally to inform User of new Services features, or news or articles thinks will be of interest to User. may send User regular updates on issues thinks will be of interest to User;

• to contact User with regard to User’s use of the Services and, in ’s discretion, changes to the Services and/or the service policies; • for internal business purposes;

• for purposes disclosed at the time User provide User’s information or as otherwise set forth in this Privacy Policy;

• to provide User with information or services or process transactions that User has requested or agreed to receive including to send User electronic newsletters;

• to provide User with marketing materials or relevant advertising, promotions and recommendations from or our business partners;

• to enable User to participate in a variety of the Service features;

• to process User’s account registration, including verifying User’s information is active and valid;

• to identify User as the author of any comments that User sends to to be posted on the Website or Mobile App;

• to ensure that content on the Website and Mobile App is presented in the most effective manner for User and for User’s computer or mobile device;

• to provide User with information relating to any events held by , where User has consented to be contacted for such purposes; and

• to provide User with access to User’s personal account.

User can always opt out of utilizing the Service, and accordingly opt out of QuitFit’s use of User’s Personal Information, by sending an email to connect@transforminds.in How and When Does QuitFit Disclose Information To Third Parties? QuitFit may share User’s Personal Information, including performance measurement information associated with User’s name that is collected or generated at the Website, Mobile App or through the Services. Personal Information may occasionally be transferred to third parties who act for QuitFit for further processing in accordance with the purposes for which the data was originally collected or for purposes to which User has subsequently consented. For example, sometimes a third party may have access to User’s Personal Information in order to support QuitFit’s information technology or to handle mailings on QuitFit’s behalf. If transfers User’s Personal Information to an outside agent or organization for such purpose, QuitFit will take appropriate measures in an effort to protect User’s privacy and the Personal Information transfer. QuitFit may share your Personal Information with various business partners. Some of these business partners may use your personal information to facilitate the offering of services or products that may be of interest to you. We may also share your Personal Information as otherwise described to you at the time of collection. QuitFit may, in its sole discretion, share or transfer Personal Information where permitted or required by law, to comply with legal process, to interact with antifraud databases, to protect User’s vital interests, to protect the security or integrity of QuitFit’s databases or the Website and the Mobile App or services, to enforce the Terms & Conditions or protect the business or reputation of and/or its Business Customers, to take precautions against legal liability, to protect and defend the rights or property of and/or its Business Customers, for required institutional risk control, or for resolving disputes, inquiries or complaints with respect to User’s use of the Website, Mobile App and Services. QuitFit reserves the right to disclose and transfer all Personal Information: (i) to an operator of the Website or Mobile App or applicable database provided such entity agrees to be bound by the terms and conditions hereof to the extent applicable; or (ii) to a successor in interest of in connection with a merger, consolidation, restructuring, change of control, the sale of substantially all of QuitFit’s interests and/or assets or other organizational change, including, during the course of any due diligence process, provided such successor entity agrees to be bound by the terms and conditions hereof. What About Information Users Disclose Publicly Or To Others? User-Generated Content and Public Information. “User Content” is any content, materials or information (including without limitation, any text, information, graphics, messages, photos, images, and works of authorship kind), data, questions, comments, suggestions or other content, including personally identifiable information that you upload, send, email, display, perform, distribute, post or otherwise transmit to us, at our request or on your own, on, or through the Services (such as message boards, Public Forums etc), whether in connection with your use of the Services or through the use of any Third Party Websites or Third Party Services or otherwise, and whether publicly posted or privately transmitted. QuitFit or others may store, display, reproduce, publish, distribute or otherwise use User Content online or offline in any media or format (currently existing or hereafter developed) and may or may not attribute it to User. Others may have access to this User Content and may have the ability to share it with third parties. Please think carefully before deciding what information User shares, including Personal Information, in connection with User’s User Content. Be aware that public postings (including group messaging with other Users) are not confidential. Please note that QuitFit does not control who will have access to the information that User chooses to make public, and cannot ensure that parties who have access to such publicly available information will respect User’s privacy or keep it secure. QuitFit is not responsible for the privacy or security of any information that User makes publicly available on the Service, the Mobile App or Website or what others do with information User shares with them on the Mobile App and Website or through services. QuitFit is not responsible for the accuracy, use or misuse of any User Content that User discloses or receives from third parties through the Service. Name and Likeness. QuitFit may also publish User’s name, voice, likeness and other Personal Information that is part of User’s User Content, and may use the content, or any portion of the content, for advertising, marketing, publicity and promotional activities, provided that QuitFit will not exercise such rights as to any User Content which identifies User in a public manner (other than in providing the Services to the Business Customer and the Business Customer’s other participants) unless User provides a separate consent to in writing (email is sufficient) authorizing such use. For full terms and conditions regarding User Content User submits to the Service, please review QuitFit’s Terms & Conditions. Profiles.

A User’s profile page may be, by default, set up to display information such as the User’s display name, images, location (city/state/country), groups that the User has joined and optional information added by User. Profile information is used by primarily to be presented back to and edited by User when User accesses the Service and to be presented to others permitted to view that information on the Service. may offer users the ability to manage their public profile and use profile preference settings, the functionality and features of which are subject to change from time to time, so visit it frequently to confirm the settings reflect User’s then current preferences and recommends that User does not post information or content as part of User’s profile that User is not prepared to make public. Changing setting options may not result in immediate changes to the settings, which are subject to QuitFit’s operations and maintenance schedules. User should carefully consider the use of such settings to improve information display options and to ensure the settings are properly set and functioning in the manner desired. Notwithstanding the availability of profile preference settings, User should be aware that these settings are for convenience only, do not employ complex data security protection and may not be error free. Further, other users that have access may repost or otherwise make public User’s information or content. Accordingly, discretion and good judgment should be exercised when posting information or content as part of User’s profile. Use of Anonymous Information. We may use Anonymous Information (as defined below), or disclose it to third party service providers, to provide and improve the Service. We may also disclose Anonymous Information (with or without compensation) to third parties, including advertisers and partners, for purposes including, but not limited to, targeting advertisements. “Anonymous Information” means information which does not enable identification of an individual user, such as aggregated information about use of the Service. Opting Out. You may choose not to receive future promotional, advertising, or other Service-related notifications from us by changing the notification settings on your device. If you choose not to receive notifications, you may still use the Service but you may not receive, or may be unable to use, certain services that involve our interaction with you. Choice.

At all times, you may choose whether or not to provide or disclose Personal Information. The notices that we provide on the Service in circumstances where we collect Personal Information should help you to make this choice. If you choose not to provide the Personal Information we request, you may still use the Service, but you may be unable to access certain programs and services that involve our interaction with you. Access/Accuracy. To the extent that you do provide us with Personal Information, we wish to maintain accurate Personal Information. If you would like to delete or correct any other of your Personal Information that we may be storing, you may submit a request to us by sending an email to connect@transforminds.in Your email should include adequate details of your request. Collection of Information by Third-Party Websites. We may use a reputable third party to present or serve advertisements that you may see on the Service. These third party ad servers may use cookies, web beacons, clear gifs or similar technologies to help present such advertisements, and to help measure and research the advertisements’ effectiveness. The use of these technologies by these third party ad servers is subject to their own privacy policies and is not covered by our Privacy Policy. Links to Other Websites. The Service may contain links to third party websites that are not owned or controlled by us. We are not responsible for the privacy practices or the content of such other third party websites, and you visit them at your own risk. Children’s Privacy. The Service is neither directed to nor structured to attract children under the age of 18 years. Accordingly, we do not intend to collect Personal Information from anyone we know to be under 18 years of age. We will direct potential users under 18 years of age to use the Service with the consent of parents or gaurdians. If we learn that Personal Information of persons less than 18 years of age has been collected without verifiable parental consent, then we will take the appropriate steps to delete this information. To make such a request, or if there are any questions or concerns about the Privacy Policy for the Service or its implementation, please contact us at connect@transforminds.in Security. The security of your Personal Information is important to us. We follow generally accepted industry standards, including the use of appropriate administrative, physical and technical safeguards, to protect the Personal Information submitted to us. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect Personal Information, we cannot guarantee it's absolute security or confidentiality. If you have any questions about security, you can contact us at connect@transforminds.in Please be aware that certain Personal Information and other information provided by you in connection with your use of the App may be stored on your device (even if we do not collect that information). You are solely responsible for maintaining the security of your device from unauthorized access. Merger, Sale or Bankruptcy. If we are acquired by or merged with a third party entity, or if we are subject to a bankruptcy or any comparable event, we reserve the right to transfer or assign Personal Information in connection therewith.

If you elect not to provide Personal Information You may choose not to provide with your Personal Information. However, if you choose not to provide your Personal Information, you may not be able to use our Services, as the processing of this information is necessary for the performance of our Services. Data Protection Officer For the purposes of data protection law, the controller is Transforminds Wellness LLP, which can be contacted at:

Address: A 303, Pinewoods, Prestige Residency Complex, Waghbil Naka, Ghodbunder Road, Thane West, Mumbai - 400615

Email: connect@transforminds.in

Our Accountability/Dispute Resolution QuitFit uses a self-assessment approach to assure compliance with this Privacy Policy and periodically verifies that the policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented and accessible and in conformity with the promises in this policy. encourages interested persons to raise any concerns using the contact information provided and will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of Personal Information in accordance with this policy. Service: International Users QuitFit’s Service is operated in India. If User is located outside of India, please be aware that information collects, including Personal Information, will be transferred to, and processed, stored and used in India. The data protection laws in India may differ from those of the country in which User is located, and User’s Personal Information may be subject to access requests from governments, courts, or law enforcement in India according to laws of India. Indian law may not provide the degree of protection for Personal Information that is available in other countries. QuitFit takes commercially reasonable steps to ensure that User’s data is treated securely, including entering into appropriate data transfer agreements.

By using the Service or providing with any information, User consents to the transfer to, and processing, usage, sharing and storage of User’s information, including Personal Information, in India as set forth in this Privacy Policy. If User does not consent to such transfer, User may not use the Service. If you choose to access and use the Website, Mobile App and/or Service from outside India, you acknowledge that you are doing so on your own initiative, at your own risk, and are responsible for compliance with applicable laws. Business Transitions In the event QuitFit goes through a business transition, such as a merger, acquisition by another organization, or sale of all or a portion of its assets, User’s Personal Information might be among the assets transferred.

How can I get more information about the Privacy Policy? If User has questions or concerns about the Privacy Policy, User can contact at:connect@transforminds.in

Updates/Modifications QuitFit reserves the right to amend this Privacy Policy at any time as needed without notice provided to User.