True Care is the owner of [https://www.truecarecounselling.com]. True Care is committed to your privacy.
'Sensitive Personal Data or Information' or "SPDI" of a person means such Personal Information (defined below) which consists of information relating to:-
(b) financial information such as bank account or credit card or debit card or other payment instrument details;
(c) physical, physiological and mental health condition;
(d) sexual orientation;
(e)medical records and history;
(f) biometric information;
(g) any detail relating to the above provided by an individual of provider of SPDI or Personal Information to True Care for providing service; and
(h) any of the information received under (a) to (h) above by True Care for processing or storing of such information under a lawful contract or otherwise.
The information mentioned in (a) to (h) above, does not include any information that is freely available or accessible in public domain or furnished under the Right to Information Act, 2005 or any other law for the time being in force.
"Personal information" shall mean and include information that relates to a natural person, which, either directly or indirectly, in combination with other information available or likely to be available with True Care, is capable of identifying such person.
C. Our Privacy Principles:
By using our website or services, you hereby consent to collection of your Personal Information by True Care.
Please be aware that, if you do not allow us to collect required amount of information from you, we may not be able to deliver certain services to you and furthermore even if we could, some of our web based services may not be able to take account of your customizable preferences.
E. What information do we collect and store on our computer systems:
We may collect information in any of the following ways:
a. Information provided to us: For example, when you sign up or register on our website, and provide any information about yourself like your name, e-mail address, house or office address and telephone numbers in order to enquire about our products or services at [https://www.truecarecounselling.com].
b. Information we get from your usage of our website or our web based services at [https://www.truecarecounselling.com]: Such information may include passwords, device information, location information and details of the computer system or computer network which you use to visit our websites and undertake any activity therein.
c. Any other information which either individually or in combination with any other information is capable of identifying you.
You may also need to provide True Care your SPDI or Personal Information during the course of using some of our services, a few of which have been mentioned below, for instance:
i. Your details on our system for ease of identification and reference; ii. providing financial information while subscribing to our services; iii. documents which relate to your health records; iv. participating in our customer surveys and reviews; v. communicating with us regarding our services or otherwise through telephonic communications, e-mails or otherwise.
Our primary purpose for collection of information from you is for your ease of access and use of the services available on our website and to keep you informed about other related services and functionalities provided by True Care.
Furthermore, we may use your SPDI or Personal Information for the purpose of following up with you from time to time after your visit to our website.
We may also collect information from time to time for tracking user behavior and preferences for internal analytics from all users of our services. We may combine your SPDI or Personal Information along with the information collected from other users to provide you with a better experience as a user of our services.
You understand and acknowledge that certain information may be collected each time you visit our website, mobile application or access our services. Such information may be stored in server logs in encrypted form. Such encrypted data might not be sufficient to identify you personally in most cases, but the same shall be capable of providing us with information regarding your visit to our website or the browsing activities of yours.
Such information may include:
i. IP address of your server from which you access our services or website; ii. The type of browser which is being used; for example: Internet Explorer, Firefox, Opera, Google Chrome etc. iii. the operating system which you might be using; iv. the duration of stay on our website along with the date and time of access of our website;
The above mentioned data may be used by True Care to understand the use, number and frequency of users visiting our website. Some of the information may be shared with our developers, strategic business partners of True Care and some of our associates for the purpose of enhancing our business and our website. Such information is usually collected by us through the help of pixel tags and cookies, which are industry standard technology used by major websites.
While you use our online services, True Care's servers (which are hosted by a third party service provider) may collect information directly and automatically about the activities undertaken by you therein; for instance by way of cookies and pixel tags.
(Note: 1. Cookies are small amounts of data that is sent to a user's browser from a web server and is eventually stored on a user's computer hard drive. This anonymous information is maintained distinctly and is not linked to the sensitive personal data or information you submit to True Care.
2. Pixel tags are typically single pixel, transparent GIF images that are added to a web page. Even though the pixel tag is virtually invisible, it is still served just like any other image you may see online. The web page is served from the site's domain while the image is served from the ad server's domain. This allows the ad server to read and record the cookie with the unique ID and the extended information it needs to record).
Whether you intend your web browser to accept cookies is entirely up to your preferences and settings.
(Note: 1. If you do not change your internet browser settings, your browser may already accept cookies by default. However, if you decline cookies, you may not be able to experience all the features of our website and online services offered by us.
2. You may choose to delete the cookies accumulated by your web browser or disable such cookies entirely, but this may make parts of our website inaccessible for you thereby impacting the experience you might want to have on our website. Therefore we would recommend you to keep such cookies turned on).
True Care shall not trade or disclose the SPDI or Personal Information provided by you in any manner, except as specified herein or if express consent has been sought from you for disclosure of such information.
F. Usage of the information collected:
True Care has complied with and implemented reasonable security practices and procedures, and has a comprehensive documented information security programme and information security policy(ies) that contain managerial, technical, operational and physical security control measures to protect your Personal Information and SPDI.
i. True Care collects and uses necessary Personal Information or SPDI on lawful basis and for legitimate business reasons for collection of information;
ii. True Care shall be transparent with providers of Personal Information or SPDI as to what information is to be collected and how the same shall be processed. True Care shall not publish or share your Personal Information without your express consent.
iii. Sessions may be used for training and quality purposes.
iv. Information received for a particular purpose shall not be used for any other activity without the provider having been informed, and where required, only upon receiving provider's permission.
v. True Care shall be compliant with applicable jurisdictional records retention requirements and apply information retention rationale which are reasonable in context;
vi. True Care shall ensure that information is securely disposed of after expiry of retention period.
G. How such information may be shared:
We shall share your SPDI or Personal Information with people or entities outside of True Care only with your consent.
Over and above the terms mentioned hereinabove, we might share SPDI or Personal Information with a third party for the following reasons and under the following circumstances:
You understand, agree and acknowledge that our collection, storage and processing of your SPDI or Personal Information is for a lawful purpose connected with a function or activity of True Care and affiliates.
In the rare event that we need to pass on your Personal Information or SPDI to law enforcement authorities, we will keep you informed about the same as soon as reasonably possible.
We will under no circumstances either publish or share your SPDI or Personal Information without obtaining your prior approval.
H. Withdrawal of permission to collect sensitive personal data or information:
You may at any time withdraw your consent to collection, storage, use, disclosure and transfer of the sensitive personal data by True Care, by addressing a written communication to such effect to the contact address of the True Care grievance officer provided below.
I. Ensuring that personal information is accurate and up to date:
True Care shall:
i. update existing records whenever provider of such information intimates True Care of any change;
ii. periodically review and assess the information available on True Care's client database.
In case you intend to update your SPDI or Personal Information which we have on record with us, (e.g. if you change your address), please provide the updated details at firstname.lastname@example.org for the purpose of enabling us to make the required change. You may be requested to provide some verification before the information is updated.
Please note that we shall not be responsible for the authenticity of any Personal Information or SPDI provided to us by you.
(Note: 1. Safeguarding your information to help protect you from possibility of identity theft is top priority for True Care. We shall not at any time, request your credit card information, your account ID, login password, or national identification numbers in a non-secure or unsolicited e-mail or telephone communication.
2. Do not: i. Share information which is absolutely confidential to you, (Example: Social Security Number, Bank Account Pin, or other confidential details which may not be required for business purposes unless specifically requested for;
ii. Embed unwarranted links or attachments, obscene data, templates, documents, ideas, thoughts or expressions unless specifically requested for;
iii. Share any disparaging or defaming comments).
J. Keeping of personal information for as long as is necessary for the purposes for which such information was collected:
True Care Counseling Services Pvt Ltd. - Full name of the venture, we may define early on and then use True Care everywhere shall:
i. comply with applicable jurisdictional records retention requirements and apply information retention rationale which are reasonable in context.
ii. ensure that information is securely disposed of at the end of the appropriate retention period.
K. Observe rights afforded to individuals including:
i. Right to opt-out of receiving marketing communication from True Care; ii. right to withdraw consent with regard to information or to opt-out with regard to information; iii. right to have inaccurate information/discrepancies corrected, and information previously provided amended; iv. right of access to information that has already been provided; v. right to have grievances addressed expeditiously.
True Care shall ensure that all queries relating to privacy are promptly and transparently dealt with in accordance with applicable jurisdictional laws and regulations.
L. True Care has appropriate measures in place to protect Personal Information or SPDI from unauthorized access and disclosure, theft, damage, loss, alteration, etc.
True Care shall: i. Train staff, and inform third party service providers on privacy obligations; ii. deploy appropriate security measures to protect SPDI or Personal Information whether onsite or off-site; (The level of security will depend on the nature of the data and the potential harm that could be caused by accidental/ unauthorized loss or disclosure of the information); iii. comply with applicable jurisdictional confidentiality and security policies and guidelines; iv. ensure that a secure method of transit is employed whenever SPDI or Personal Information is transferred between different locations. v. ensure that where processes are outsourced, the third party service provider has appropriate security measures in place and is contractually bound to maintain relevant privacy obligations. vi. review the information collection procedures, storage and processing practices, including physical security measures, to guard such information from unauthorized access. vii. restrict access of SPDI or Personal Information to the employees of True Care, third party service providers who need to know such information and are subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.
M. Suitable safeguards to be put in place when personal information is transferred from India to other countries and vice versa:
Any Personal Information for which True Care is responsible for will be adequately protected in the country of destination in consonance with protection of data available under the Data Protection Rules.
Your information may be transferred to or be maintained on computers, computer systems and computer resources located outside of your state or country where the privacy laws may not be as protective as those where you live. If you are located outside India and choose to provide information to us, please be aware that True Care keeps or transfers information to India and processes it here. Your submission of such information represents your agreement to that transfer.
(Note: Please note that the transmission of information over the Internet is not completely secure. Although True Care strives to protect your SPDI or Personal Information, we cannot guarantee the security of your data while it is being transmitted to our site; therefore any transmission is at your own risk. Once we have received your information, we have commercially reasonable procedures and security features in place to reasonably endeavor to prevent unauthorized access).
N. Force Majeure:
A "Force Majeure Event" shall mean any event that is beyond the reasonable control of True Care and shall include, without limitation, sabotage, fire, flood, explosion, acts of God, civil commotion, strikes or industrial action of any kind, riots, insurrection, war, acts of government, computer hacking, unauthorized access to computer data and storage device, computer crashes, breach of security and encryption, etc.
O. Grievance Officer:
This document is an electronic record in terms of Information Technology Act, 2000 and rules made there under. This electronic record is generated by a computer system and does not require any physical or digital signatures.