At Paloma Care (referred to as the Website, App, Company, we, us, or our), we place the utmost importance on safeguarding your privacy. This Privacy Policy outlines in detail how we collect, use, and share information, including any personal information you may provide. We encourage you to read this Privacy Policy thoroughly and in its entirety.

This Privacy Policy should be read alongside and in conjunction with our Terms and Conditions. By accessing or logging into our website or App (collectively referred to as the “Services”), you explicitly acknowledge and agree to be bound by the terms outlined in this Privacy Policy.

1. What Does This Privacy Policy Cover?

This Privacy Policy outlines how we handle personally identifiable information (“personal information”) that we collect when you access, use, or engage with our Mobile App or Website for the purpose of availing third-party Products and Services, which include but are not limited to Doctor Consultations, Nutrition and Mental health and other consultations.

This policy does not apply to the privacy practices or procedures of entities that we do not own or control (including our franchise partners), nor does it extend to individuals who are not employed by us.

By visiting our Website or Platform, downloading our Mobile App, purchasing Products through the Platform, or subscribing to or availing of Fitness & Nutrition Services or consulations, you provide your consent to the collection, use, disclosure, sharing, and processing of your personal information by Diverse and all associated sellers and service providers on the Platform (collectively referred to as “We,” “Us,” or “Our”), as described in this Privacy Policy or as permitted or required under applicable laws.

2. What Information Do We Collect?

We gather the following categories of information:

2.1. Information You Provide to Us

This includes personal information shared by you at the time of registering on our Mobile App or Website, such as:

• Your name, username, email address, gender, date of birth, height, and location.
• Personal information and Sensitive Personal Data or Information (SPDI), as required for delivering our Services on the Mobile App or Website. This may include your nutrition-related information, passwords, data related to workouts and physical activity, photographs, and other health-related data such as sleep patterns or wellness insights used for our Services and Products.
• Your banking information, used specifically for processing payments.

All the data mentioned above falls under the definition of “personal information” or “sensitive personal data or information” in accordance with the SPDI Rules. By providing this information, you give your explicit consent for us to collect and process it.

While you may choose not to share certain information with us, doing so may restrict your ability to register or use specific features and Products available on our platform. We may also anonymize your data to ensure that your identity cannot be traced, and may share this anonymized information with our partners. For instance, if you mention that you are female and get an average of 6 hours of sleep each night, we may compile this with data from other users and inform our partners that, on average, male users sleep more hours than female users—without revealing your identity.

2.2. Information Collected Automatically

Each time you interact with our Mobile App/website, certain technical information is automatically collected and recorded on our server logs. This includes:

• Your IP address
• Cookie data
• The pages you visit on the Mobile App

Cookies are small data files we transmit to your computer or mobile device, which allow us to identify your browser or device and understand how you interact with our Mobile App. You may be able to modify your browser or device settings to block or limit the acceptance of cookies, but doing so may hinder your access to some of the best features of our Mobile App.

When we collect information about how users interact with our Mobile App/Website (such as the number and frequency of visits), we use it in aggregated form only. This means it is analyzed in a way that does not personally identify you. For example, this usage data may tell us how often users access certain parts of the Mobile App/Website, which helps us improve the platform for everyone. Similarly, we may share this aggregate data with our partners, so they can better understand usage patterns and enhance your experience. At no point will we share this data in a way that can personally identify you.

3. Purpose and Use of Information

We, along with our affiliates and/or the sellers or service providers available on the Mobile App/Website, may access and utilize your Personal Information and Sensitive Personal Data or Information (SPDI) for the following reasons:

3.1. Delivery of Products and Services:

To provide you with the Products and Services offered on the Website and Mobile App, as well as to optimize, improve, or further develop the Platform’s functionality and operations for a better user experience.

3.2. Communication with You:

To reach out to you regarding the Products and Services available on the Platform, including through ongoing or future partnerships with third-party service providers.

3.3. Business Operations and Management:

For routine business and operational purposes such as managing, administering, and operating our business, which includes engaging with clients or users, handling user requests, and tailoring or enhancing our Services.

3.4. Payments and Financial Transactions:

To handle payment processing, generate bills, and manage invoicing-related activities.

3.5. Analytics and Insights:

To compile aggregated data and create insights (excluding SPDI) that allow us to identify patterns and preferences, thereby gaining a deeper understanding of your behavior and choices.

3.6. Legal and Regulatory Compliance:

To fulfill our legal obligations under applicable laws and regulations, as well as to prevent and protect against fraud, legal violations, or risks to information security.

3.7. Other Specified Purposes:

For additional purposes that are specifically communicated to you at the time of information collection, or for any other lawful reason for which we are authorized.

4. Deleting Targeting Cookies

You can remove your interest-based profile by deleting the cookies stored in your browser.

4.1. Information Stored in Cookies

The cookies saved on a user’s hard drive typically include the following details:

• User Interest Segments: Data reflecting the user’s interest in a particular product, service, brand, or model, as observed during their visit to a specific website.

• Timestamp: The time and date when the user profile was last updated.

4.2. Effect of Cookie Deletion

When a user deletes cookies from their browser, all associated profile data is completely erased.

5. Sensitive Data and Children’s Privacy

5.1. Sensitive Data Exclusion:

For the sake of clarity, no data segments are created—nor will be created—that relate to information considered sensitive. This includes, but is not limited to, data concerning political views, religious beliefs, physical or mental health conditions, or sexual orientation.

5.2. Children’s Data:

We are particularly mindful of children’s privacy. No segments or profiles are intended to be created for the purpose of targeting or profiling children.

6. Email and Other Communications

• We may communicate with you through email or other channels.
• This communication may include:
  • Promotional messages sent either by us or by third parties with whom we share your personal information.
  • Service-related updates concerning your usage of the Mobile App or Website or any Products.
• Additionally, we may receive a read confirmation when you open our emails. This helps us improve the content and relevance of our communications to you.

6.1. Opting Out

If you prefer not to receive such emails or other communications, you can indicate your preference by either of the following:

• Email us at: support@palomacare.in
• Contact our Grievance Officer

7. Sharing of Personal Information

We do not rent or sell your personally identifiable information to anyone. We only share your personal information in identifiable form with third parties in the specific scenarios outlined below:

7.1. Third Parties with Your Express Consent

• For services offered through Diverse Services, we share your information only with those third parties for whom you have provided explicit consent.

7.2. Affiliated Businesses and Third-Party Websites

• In some cases, affiliated businesses or third-party websites may sell products or offer services via the Mobile App or website—either independently or in collaboration with us.
• You will be able to identify when an affiliated business is involved in a transaction.
• Your personal information will only be shared with such businesses to the extent necessary for the related transaction or service.

7.3. Agents and Service Providers

• We engage third-party companies or individuals to perform tasks on our behalf (e.g., customer support, payment processing, data analytics).
• These agents will have access to your personal information only as necessary to carry out their responsibilities.
• They are not permitted to use the data for any purpose beyond our instructions, unless otherwise communicated.

7.4. User Submissions (Public Content)

• Any content or personal information you voluntarily share in public spaces on our platform (e.g., forums, chat rooms, message boards) becomes publicly available.
• Such information may be collected and used by others, and Paloma Care cannot be held responsible for such use.

7.5. Business Transfers

• In the event of a merger, acquisition, or reorganization, your personal information may be part of the transferred assets.

8. Billing and Refund Policy

8.1. Subscription Billing:

Refund requests will be reviewed at our discretion in case of service lapses. Contact: support@palomacare.in

8.2. One-Time Billing:

Some wellness programs operate on a one-time payment basis.

• Sessions already attended cannot be refunded.
• In the case of unforeseen inability to attend, refund requests will be reviewed on a case-by-case basis.
• Contact: support@palomacare.in

9. Legal Compliance and Protection

• We may release your information if we believe, in good faith, that such action is:
  • Necessary to comply with applicable laws;
  • Enforce our Terms and Conditions or other agreements;
  • Protect the rights, property, or safety of Paloma Care, its employees, users, or others;
  • For purposes of fraud detection or credit risk reduction, including cooperation with other entities.

9.1. With Your Consent

• Other than as described above, you will be notified before your personal information is shared with any third party.
• You will have the opportunity to opt-out or prevent such sharing.

10. Transfer of Sensitive Personal Data or Information (SPDI) Outside India

10.1. Cross-Border Transfer of Data

• In accordance with applicable laws, we may transfer your personal information and/or Sensitive Personal Data or Information (SPDI) to:
  • Other body corporates (as per the Information Technology Act, 2000),
  • Located within India or in other countries,
  • Provided they maintain a level of data protection equal to or greater than that offered by us under this policy.

10.2. Your Consent to Transfer

By using our Services and Products, you:

• Acknowledge and accept the terms of this data transfer.
• Consent to the storage and processing of your personal information and SPDI by third parties,
  • In locations within or outside India.

10.3. Our Commitment

We will:

• Make best efforts to ensure that any third party or location receiving your SPDI offers a comparable level of data protection as required under Indian law.

10.4. Ongoing Consent

• By continuing to use the Services and Products, you expressly consent to the transfer, sharing, and disclosure of your personal information or SPDI in accordance with this Privacy Policy.

11. Is Personal Information About Me Secure?

• Your account is protected by an OTP-based login for security.
• To help prevent unauthorized access, please:
  • Keep your OTP confidential,
  • Sign out after use, and
  • Limit access to your device and browser.

We take reasonable steps to protect your data and will destroy or anonymize it once:

1. The original purpose of data collection is no longer relevant, and
2. Retention is no longer required under applicable law.

⚠ Note: Despite our efforts, no system is completely secure. Events like unauthorized access, hardware/software failure, or internet interception may compromise your data.

• Links to other websites may exist on our Mobile App and website. We are not responsible for their privacy practices and advise you to read their policies.

12. What Personal Information Can I Access?

You can view and update:

• Name and phone number
• Email address
• Profile information (e.g., height, weight, location)

Some data (e.g., automatically uploaded data or collected insights) cannot be modified later.

13. Grievance Redressal & Contact Information

For concerns, data access, updates, or deletion, contact us at: 📧 support@palomacare.in

You may also reach our Grievance Officer: Name: Ms. Sneha Thomas Email: sneha@palomacare.in

We aim to address grievances within 15 days, or as per applicable law.

14. What Choices Do I Have?

You can:

• Opt not to provide certain information, though some features may be unavailable.
• Request deletion/modification of your information by writing to support@palomacare.in or the Grievance Officer.
• Choose not to receive marketing emails—email us with your preferences.

Please note:

• Deleted information may persist in backup or archived formats.
• We may retain and use aggregated or anonymized data (not personally identifiable).
• You are responsible for reviewing legal notices, including changes to this policy, which may still apply to you even if you opt out of email notifications.

14.1. Opting Out of Services

You may opt out of any services, offers, or benefits by following the process shared with you in service-related communications. If you do not opt out, you are considered to have opted in.

15. Changes to This Privacy Policy

We may update this privacy policy from time to time. If we do:

• We’ll post the changes on our Mobile App/Website or notify you via email.
• Continued use of our App/Website, Product, or Services means you accept the revised policy.