Valeo Privacy Policy

Valeo Wellbeing Technologies DMCC and/or its affiliates (collectively “Valeo”, “we” or “us”) collects information about you when you use our mobile applications, websites, call-centre and other products and services (collectively, the “Services”) and through other interactions and communications you have with us. We realize that you as a User (“You”, “Your”, “User (s)”) care about how your personal information is used and shared. We take your privacy and related concerns very seriously. This privacy policy sets out the basis on which any information, including any personal data, we collect from you, or you provide to us, will be processed by Valeo. Each time you access or use the Services or provide us with information, by doing so you are accepting and consenting to the practices described in this privacy policy

1. WHAT DOES THIS PRIVACY POLICY COVER?

This privacy policy covers our treatment of personally identifiable information (‘personal information’) that we gather when you are accessing or using our Website and Services. This policy does not apply to the practices of companies that we do not own or control, or our business partners, or to individuals that we do not employ or manage. We do not knowingly collect or solicit personal information from anyone under the age of 18 or knowingly allow such persons to register for the Services. If you are under 18, please do not attempt to register for the Services/or send any information about yourself to us, including your name, address, telephone number, email address or provide your biometric information. No one under age 18 may provide any personal information to us or for availing the Services. In the event that we learn that we have collected personal information from a child under age 18 without verification of parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 18, please contact us at support@feelvaleo.com. However, in case of a minor or a legally incompetent person, either a parent or guardian is entitled to invoke or avail Services offered by us.

2. WHEN YOU SIGN UP?

You can sign up / register on our Website through various login / registration methods available there, and further provide us your contact information, such as name, e-mail address and contact number etc. By subscribing to the Valeo Products and Services, you have agreed to receive e-mail notifications and SMSes that are necessary for Valeo / business partners to communicate important information to you. These emails are for notifications only. On your acceptance, Valeo may also use this information to send periodic newsletters and/or promotional material from third party partners or sponsors. You may opt-out of receiving future mailings by changing your account settings. Contact information may also be used by Valeo to contact you, whenever necessary

3. WHAT INFORMATION DOES VALEO COLLECT?

We gather various types of personal information from our users, as explained more fully below. We may use this personal information to provide you Services, personalize and improve our services, to allow our users to set up a user account and profile, to contact users, to fulfill your requests for certain Products and Services, to analyze how users utilize the Website and Services, and as otherwise set forth in this Policy. We may share certain types of personal information with third parties, however we do not share your biometric information with any party, even including our business partners. We collect the following types of information: (a) Information you provide to us: We receive and store any information you knowingly provide to us. For example, we collect personal information such as your name, user name, email address, gender, birth date, weight, height, location, blood test results, nutrition data, workouts, physical activity, photographs, biometric 3 information, and sleep habits and we may collect other activity related or health-related information as our Services and Products are further developed. You can choose not to provide us with certain information, but then you may not be able to register with us or to avail some of our features / Services / Products. For instance, we obtain your biometric information solely to give you feedback from a Health Coach and should you choose not to share your biometric information with us or request us to delete the same, we may deny you entry / Services and our business partner, in its sole discretion, may refund you unavailed Pack costs. We may anonymize your personal information so that you cannot be individually identified, and provide that information to our partners. For example, you may inform us that you are female and sleep an average of 6 hours per night; we may combine this information with content received from our other users, and disclose to our partners that on the whole, our male users sleep more hours per night than our female ones, but we will not tell those partners who you are. (b) Information collected automatically: Whenever you interact with our Website, we automatically receive and record information on our server logs from your browser including your IP address, ‘cookie’ information, and the page you requested. ‘Cookies’ are identifiers we transfer to your computer or mobile device that allow us to recognize your browser or mobile device and tell us how and when pages in our Website are visited and by how many people. You may be able to change the preferences on your browser or mobile device to prevent or limit your computer or device’s acceptance of cookies, but this may prevent you from taking advantage of our Website’s best features. When we collect Website / Services usage information (such as the numbers and frequency of visitors to the Website or customers of our Services), we only use this data in aggregate form, and not in a 4 manner that would identify you personally. For example, this aggregate data tells us how often users use parts of the Website or avail our Services, so that we can make the Website and our Services appealing to as many users as possible. We may also provide this aggregate information to our partners; our partners may use such information to understand how often people use our Website / Services, so that they, too, can provide you with an optimal online and offline experience. We never disclose aggregate information to a partner in a manner that enables other persons to identify you personally. If you are using our Services / Products, you understand and acknowledge that, any information, data or readings from the Services / Product, or collected from Your use thereof, will be automatically uploaded to your account with us. To the extent these automatically collected readings can be used to personally identify you, these readings are personal information for the purposes of this privacy policy.

4. INFORMATION STORED ON COOKIES

The cookie information stored on the User’s hard drive is: (i) User segment hits or information on a specific Product, Service, brand or model in which the User has shown interest during its visit to a certain website; and (ii) time and date stamp of the latest update of the User profile. If the cookie is deleted by the User, all profile data is removed. Further, Valeo is very sensitive to the issue of children’s privacy and marketing directed to children. No segments are intended to be established for the profiling of children.

5. RIGHTS YOU HAVE OVER YOUR DATA

Request an electronic copy of your profile: You can ask us to send you an electronic copy of the data that we have on you. We will provide you a summary of the information we have, within 30 days of receiving the request. You may be charged a reasonable fee for the same.

Ask us to correct information: If you think that your data is incorrect or incomplete, you may send us an email to correct the information. We will comply with all reasonable requests and will notify you in case we deny your request.

6. DISCLOSURE OF INFORMATION

Except as specified below, Valeo will not disclose your personally identifiable information without your permission. (a) With regards to your medical records, only You have the ability to authorize persons to view and share them. We will not provide access to any person unless authorized by you. The data will only be shared with Valeo Health Coaches for feedback and coaching purpose. (b) In the course of providing products or services, Valeo’s technical and maintenance contractors may have limited access to the information you provide, which shall be in encrypted form. These contractors include technicians, vendors and suppliers that provide Valeo with technology, services, and/or content related to enhancing operation and maintenance of the Website. Access to your Personal Information by these contractors is limited to the information reasonably necessary for the contractor to perform its limited functions for Valeo. We also contractually require these contractors to protect the privacy of your information consistent with this Policy. (c) Valeo may disclose your personal information in connection with legal action against someone who may be violating Valeo policy or 6 applicable law or to avoid liability on the part of Valeo and to protect our rights or property. (d) Valeo will release your personal information if required to do so by Law or Court order. In such cases, Valeo will endeavor to notify you of this disclosure.

7. REMOVAL OF INFORMATION

You can remove or change any information you store or provide to us by requesting us through an e-mail or changing the personal information you have provided. When you remove or change information, Valeo may retain that information in the form of back-up or archival data, but it will not be available readily on the Website.

8. E-MAIL AND OTHER COMMUNICATIONS

We may contact you, by email or other means; for example, we may send you promotional offers on behalf of other businesses, or communicate with you about your use of the Website or Services / Product. Also, we may receive a confirmation when you open an email from us. This confirmation helps us make emails more interesting and improve our service. If you do not want to receive email or other mail from us, please indicate your preference by emailing us at support@feelvaleo.com.

9. IS PERSONAL INFORMATION ABOUT ME SECURE?

Your account is protected by a password for your privacy and security. You need to prevent unauthorized access to your account and personal information by selecting and protecting your password appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your account. We endeavor to protect the privacy of your account and other personal information we hold in our records, but we cannot guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time.

10. WHAT PERSONAL INFORMATION CAN I ACCESS?

Through your account settings, you may access, and, in some cases, edit or delete the following information you’ve provided to us:

1. name and password
2. email address
3. user profile information, including your height, weight, and location

11. The information you can view and update may change as the Website changes. Please note that any information that is automatically uploaded from your use of a Service to the Website or our database, or collected otherwise from You by us, cannot be later changed or updated. If you have any questions about viewing or updating information we have on file about you, please contact us at: support@feelvaleo.com.

12. CHANGES TO THIS PRIVACY POLICY

We may amend this Policy from time to time. Use of information we collect now is subject to the Policy in effect at the time such information is used. If we make changes in the way we use personal information, we will notify you by posting an announcement on our Website or sending you an email. You are bound by any changes to the Policy when you use the Website or the Services after such changes have been first posted.