In this Privacy Policy, ‘Mimblu’ 'us' 'we' or 'our' means Mimblu Tech Private Limited (a private limited company incorporated under the laws of India with corporate identity number U72900MH2021PTC353795) and its related entities or body corporates. This Privacy Policy comprises part of our Terms of Use (“Terms”). All capitalised terms used in this Privacy Policy have the same meaning as in the Terms unless otherwise indicated in Clause 1 below.

This Privacy Policy explains the way we collect and store your information. By providing Personal Information or User Content to us, you consent to our collection, use and disclosure of your Personal Information in accordance with this Privacy Policy and any other arrangements that apply between us. We may change our Privacy Policy from time to time by publishing changes to it on our Platform. We encourage you to check our website periodically to ensure that you are aware of our current Privacy Policy.

Definitions

In this Privacy Policy, the following capitalised terms have the following meanings:

• Applicable Law means the data protection or privacy laws of the India applicable to Mimblu and the Users.
• Automatic Data has the meaning given to it in Clause 2.3.
• Non-personal Information means information which does not relate to a person and/or cannot be used to identify a person.
• Personal Information means any information which can be used to identify an individual, and described in detail in Clause 2.
• User Content means any content whatsoever which are posted, uploaded, generated, provided or otherwise made available by a User through the Platform, including but not limited to any bios, experience, descriptions, usage data, chats, photos, audios, videos, music, text, graphics, works of authorship of any kind and any other information.

What personal information do we collect?

We may collect Personal Information about you when you use the Platform, register on the Platform or interact with us in any way. You understand that the Platform is designed to give you access to a variety of professionally qualified and experienced Counsellors and procure Counselling Services by means of secure in app video and/or voice calls and text messaging. The Platform facilitates virtual medical and other health-related consultations and, therefore, must, as is the case with standard healthcare visits, collect medical and other relevant personal information.

Information you provide to us: We collect all information which Users voluntarily provide to us through using the Platform or interacting with us. This includes information provided:

• during registration;
• during correspondence, enquiries, support services, making payments, phone calls, or customer surveys;
• in the course of availing Counselling Services;
• uploaded onto the Platform in any way;
• any chat text or other correspondence carried out via the Platform;
• if you register to receive our newsletter;

The Personal Information we may collect includes without limitation:

• basic information such as your first and last name;
• contact information including email address and phone number;
• demographic information such as postal code, age, and gender;
• other relevant information (education, profession, work experience and preferences);
• your contact and other information and links to your social media profiles (if you are a Counsellor);
• geographic location;
• login credentials for third-party websites;
• insurance information;
• other information obtained by your use of the Platform; and
• any other information that enables Users to be personally identified.

Information we automatically collect:

We also automatically collect certain technical data that is sent to us from the computer, mobile device and/or browser through which you access the Platform (“Automatic Data”). Automatic Data, includes without limitation, a unique identifier associated with your access device and/or browser (including, for example, your Internet Protocol (IP) address) characteristics about your access device and/or browser, statistics on your activities on the Platform, details of the products and services we have provided to you or that you have enquired about, including any additional information necessary to deliver those products and services and respond to your enquiries, or information about how you came to the Platform. However, to the extent that IP addresses or similar identifiers are considered Personal Information by local law, we also treat these identifiers as Personal Information. We collect Automatic Data based on your consent which was granted to us by you when you registered as a User and accepted this Privacy Policy. If you do not want us to collect this information, do not use the Platform or delete your account on the Platform.  Information we obtain from others: We may also collect or receive Personal Information from third-party sources, such as other Customers, other Counsellors, social media or other third-party integrations.

Non-personal Information:

When you interact with the Platform, we may collect Non-Personal Information. The limitations and requirements of this Privacy Policy on our collection, use, disclosure, transfer and storage/retention of Personal Information do not apply to Non-Personal Information. When you register for the Platform or otherwise submit Personal Information to us, we may associate other Non-Personal Information (including Non-Personal Information we collect from third parties) with your Personal Information. At such instance, we will treat any such combined data as your Personal Information until such time as it can no longer be associated with you or used to identify you.

Personal Information of Minors:

Children under the age of 18 are not permitted to create their own Mimblu accountsIf we learn we have collected or received Personal Information from a child under 18, we shall not be responsible for the consequences thereof and will delete that information without notice. If you believe we might have any information from or about a child under 18, please contact us.

Why do we collect, use and disclose Personal Information?

We may collect, hold, use and disclose your Personal Information for the following purposes:

• to enable you to access and use our Platform, including allowing you to interact with other Users, such as Counsellors whose Counselling Services you wish to book/purchase or Customers who book/purchase the Counselling Services;
• to operate, protect, improve and optimise our Platform, business and our users’ experience, such as to perform analytics, conduct research and for advertising and marketing;
• to send you service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you;
• to carry out our obligations and enforce our rights arising from the Agreement entered into between you and us, including for billing and collection;
• to send you marketing and promotional messages and other information that may be of interest to you, including information sent by, or on behalf of, our business partners that we think you may find interesting;
• and to comply with our legal obligations, resolve any disputes that we may have with any of our users, enforce our agreements with third parties and for anti-fraud purposes.

From time to time, we may use your Personal Information to send important notices, such as communications about appointments made, advice issued, purchases made, and changes made to our terms, conditions and policies. Because this information is important to your interaction with Mimblu, you may not opt-out of receiving these communications.

We may also disclose your Personal Information to a trusted third party who also holds other information about you. This third party may combine that information in order to enable it and us to develop anonymised consumer insights so that we can better understand your preferences and requirements, personalise your experience and enhance the services that you receive.

The information we collect is not distributed, sold or leased to third parties for commercial purposes, except to provide services you have requested on the Platform or for other purposes when we have your permission or when we are obliged to do so.

We may disclose your Personal Information if we believe disclosure of your Personal Information is necessary or appropriate to protect the rights, property, or safety of Mimblu, our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction. We limit our uses of data for anti-fraud purposes to those which are strictly necessary and within our assessed legitimate interests to protect our customers and our Services.

You are not obligated to provide the Personal Information that we have requested, but, if you chose not to do so, in many cases we may not be able to provide you with our products or services or respond to any queries you may have.

Do we use your Personal Information for direct marketing?

We and/or our carefully selected business partners may send you direct marketing communications and information about our services. This may take the form of emails, SMS, mail or other forms of communication, in accordance with the Applicable Law. By registering on the Platform and accepting this Privacy Policy, you hereby grant your consent to receiving such communications from us unless you opt-out as provided hereunder. You may opt-out of receiving marketing materials from us by contacting us through the contact us feature below, or by using the opt-out facilities provided (eg an unsubscribe link). We do not control third parties' collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way.

To whom do we disclose your Personal Information?

We may disclose Personal Information for the purposes described in this Privacy Policy to:

• to other Users (such as Customers or Counsellors, as the context requires), for the purpose of evaluating them and possibly entering into discussions for entering into an engagement for the provision of Counselling Services;
• our employees and related bodies corporate;
• third-party suppliers and service providers (including providers for the operation of our Platform and/or our business or in connection with providing our products and services to you);
• professional advisers, dealers and agents;
• payment systems operators (eg merchants receiving card payments);
• our existing or potential agents, business partners or partners;
• our sponsors or promoters of any competition that we conduct via our services;
• anyone to whom our assets or businesses (or any part of them) are transferred;
• specific third-parties authorised by you to receive information held by us;
• and/or other persons, including government agencies, regulatory bodies and law enforcement agencies, or as required, authorised or permitted by law.

In certain circumstances, we may have to disclose certain Personal Information to third parties in order to administer or provide the services that you are requesting, including scheduling consultations with Counsellors. Personal information will never be shared with third parties for their marketing purposes. For example, when you create an account with us, and request a consultation with a Counsellor, you authorize us and such Counsellor to exchange the information you provide while registering with us. If your request is accepted by the Counsellor, your interaction will, among other things, be governed by our and the Counsellor’s respective privacy policies.

Using our website and cookies

We may collect Personal Information about you when you use and access our website. While we do not use browsing information to identify you personally, we may record certain information about your use of our website, such as which pages you visit, the time and date of your visit and the internet protocol address assigned to your computer.

We may also use 'cookies' or other similar tracking technologies on our website that help us track your website usage and remember your preferences. Cookies are small files that store information on your computer, TV, mobile phone or other device. They enable the entity that put the cookie on your device to recognise you across different websites, services, devices and/or browsing sessions. You can disable cookies through your internet browser but our websites may not work as intended for you if you do so.

We may also use cookies to enable us to collect data that may include Personal Information. We will handle any Personal Information collected by cookies in the same way that we handle all other Personal Information as described in this Privacy Policy.

 

Data Security

rotect your Personal Information from misuse, interference and loss, as well as unauthorised access, modification or disclosure and we use a number of physical, administrative, personnel and technical measures to protect your Personal Information. However, we cannot guarantee the security of your Personal Information.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password or PIN for access to certain parts of our Platform, you are responsible for keeping such password and PIN confidential and not share it with anyone. We are not responsible for circumvention of any privacy settings or security measures we provide.

Retention

We may retain your Personal Information as long as you are registered to the Platform as a User. You may close your account by contacting us. However, we may retain Personal Information for an additional period as is permitted or required under applicable laws. Even if we delete your Personal Information, it may persist on backup or archival media for an additional period of time for legal, tax or regulatory reasons or for legitimate and lawful business purposes.

Exclusions

Links: Our Platform may contain links to websites operated by third parties. Those links are provided for convenience and may not remain current or be maintained. Unless expressly stated otherwise, we are not responsible for the privacy practices of, or any content on, those linked websites, and have no control over or rights in those linked websites. The privacy policies that apply to those other websites may differ substantially from our Privacy Policy, so we encourage individuals to read them before using those websites.

Personal Information Provided to Others: This Privacy Policy does not apply to any Personal Information that you provide to another User or visitor through the Platform or through any other means, including to Counsellors or Customers, or information posted by you to any public areas of the Platform or your social media profiles. 

User Content: You may post content on the Platform, including your comments, feedback, pictures, and any other information that you would like to be available on the Platform in your own initiative. Although you may set certain privacy settings for such information by logging into your account profile, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of third parties with whom you may choose to share your User Content. Therefore, we cannot and do not guarantee that your User Content will not be viewed or used by unauthorized person that may violate this Privacy Policy, the law, or your personal privacy.

Accessing or correcting your Personal Information

You can access the Personal Information we hold about you by contacting us using the contact us feature below. Sometimes, we may not be able to provide you with access to all of your Personal Information and, where this is the case, we will tell you why. We may also need to verify your identity when you request your Personal Information.

If you think that any Personal Information we hold about you is inaccurate, please contact us using the contact us feature below and we will take reasonable steps to ensure that it is corrected. We will consider and respond to all requests in accordance with all applicable laws.

Making a complaint

If you think we have breached the Applicable Law, or you wish to make a complaint about the way we have handled your Personal Information, you can contact us using the contact us feature below. Please include your name, email address and/or telephone number and clearly describe your complaint. We will acknowledge your complaint and respond to you regarding your complaint within a reasonable period of time. If you think that we have failed to resolve the complaint satisfactorily, we will provide you with information about the further steps you can take.

Contact Us

For further information about our Privacy Policy or practices, or to access or correct your Personal Information, or make a complaint, please contact us using the details set out below:

care@mimblu.com