INTRODUCTION
We at DLF Wellco Pvt. Ltd. and our affiliates (hereinafter referred to as “DLF THRIVE”, “we”, “us” or “our”), place paramount importance on safeguarding the privacy and security of your personal information and data ("Personal Data"). We want you to feel safe using our website including our mobile application –DLF THRIVE (“Platform”). The Platform includes a service application that connects our members to club management and/or any other service providers (collectively defined as “Operators” herein) with a view to inter alia improving access to services, safety and security and convenience of the members (collectively “Services”). This Privacy Policy aims to inform you of the way in which we collect, use, transfer, and store your Personal Data when you use our Platform, as well as your rights in relation to this Personal Data.
Please read this Privacy Policy carefully prior to accessing our Platform or availing the Services.
By accessing and using our Platform, you hereby acknowledge that you have read, understood, and agree to the processing of your Personal Data in accordance with the terms of this Privacy Policy and our Terms of Use.
Please note that all the Services and Operators have their own rules and regulations to be followed. This document doesn’t intend to bring those details over here. For further information on these Services, please contact the authorized Operators or refer to the Terms of Use.
WHAT DATA IS COLLECTED
The information the Platform collects, and how that information is used, depends on how you use our Services and how you manage your privacy controls. For e.g. for standard Platform Services, only the details of your residence, personal payments (along with your name and phone number), membership plan for the THRIVE club Services will be needed. However, if you choose to use features like online payments, we may require additional information to facilitate the payment processing.
1. PERSONAL DATA
While using the Platform, you shall be asked to provide certain Personal Data that will be used to contact or identify you. This Personal Data is necessary for the performance of the Services and to allow us to comply with our legal obligations. Without it, we may not be able to provide you with all the requested Services.
Where possible, we indicate the mandatory and the optional fields. You always have the option to not provide your Personal Data by choosing not to use a particular Service or feature on the Platform.
However, not sharing the mandatory Personal Data may lead to certain features of the Platform or Services being restricted, unavailable, or unusable. For instance, withholding your email address will not allow the relevant Operator to contact you and send you an update regarding your Service request.
If you submit any Personal Data of another person on the Platform, it will be presumed that you have taken free, specific, informed, unconditional and unambiguous consent from such person to share their Personal Data on the Platform and have made available this Privacy Policy to them and such Personal Data is true and accurate.
Personal Data may include, but is not limited to:
a) Account Creation and Identity Verification. To use the Platform, you would be required to create a user account ("Account") using your Personal Data which shall then be considered as your user profile ("Profile").
For creating an Account and your Profile, the Platform will require certain mandatory Personal Data such as full name, residence address, email address, phone number, date of birth, as mentioned in your official verification documents , at the time of your registration as a user of the Platform. This Personal Data enables the verification of user identity and avoid fraud or identity theft. In addition, you may choose to provide additional Personal Data as may be indicated in your Account and Profile settings which will enable the Operators to provide you personalized Services.
b) Profile and Listing Information. In addition to (a) above, to use certain features on the Platform (such as purchasing a membership plan displayed on the website and/or booking any sessions and/or availing any services like personal trainer, Zumba etc.), certain additional Personal Data may be required, which may include your eating habits, body measurements, email address, phone number ,a profile picture payment information, etc.
c) Communications with authorized Operators. When you communicate with the Operators using the Platform, the Platform collects all such correspondence, information about your communication and any additional information you choose to provide to perform its Services.
d) Payment Information. In addition to the foregoing, to use certain other features on the Platform (such as purchasing a membership plan, diet plan, booking personal trainer, Zumba classes, etc.), certain financial information may be required (as more particularly described in sub section (3) below) to facilitate the processing of payments.
You may be asked to provide certain additional information about yourself on a case-to-case basis in relation to our Platform or Services.
It is clarified that any data which does not reveal your specific identity, does not relate to an identified or identifiable individual, information that is publicly available, information about software and hardware usage, or any anonymized or aggregated data (“Other Information”) is not considered as Personal Data.
2. USAGE DATA
a) When you access or use the Platform:
The Platform may collect information from phones you use to access the Platform and based on your mobile phone settings and how you manage your privacy controls, information that maybe obtain from these devices may include:
Device attributes: information such as the operating system, hardware and software versions.
Device operations: information whether the application has been foregrounded or backgrounded.
Identifiers: unique identifiers, device IDs and other identifiers.
Data from device settings: information that you allow us to receive through device settings that you turn on, such as access to your GPS location.
Network and connections: information about IP address of device.
The Platform collects the above information to provide automatic updates and additional security so that your interaction is not used on other people’s devices. In addition, the information provides us valuable feedback on your identity as a device holder as well as your device behavior, thereby allowing us to improve our Platform and provide an enhanced customized user experience to you.
b) When you visit our Platform:
Platform collects usage information that your device sends whenever you visit and use the Platform. This usage data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile and desktop/ laptop operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data like pages that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
c) Cookies Data
Cookies are small data files placed on your device that a website stores on your computer while you are browsing a website. The Platform utilizes cookies to accumulate small fragments of information on designated portions of the application to facilitate analysis of the Platform and user engagement. Cookies are used to reduce the frequency of password entry during a session. Cookies further assist us in obtaining information beneficial for tailoring services more precisely to your interests.
There are some third-party cookies embedded on the Platform. The use of this information collected from third-party cookies helps the Platform identify you and to make it more user friendly. Cookies and other technologies may be used to store your preferences and settings, help you with signing in, provide related ads and analyze Platform operations.
Our Platform will allow you to decline these cookies but if you choose to do this it might affect Service on some parts of our Platform.
d) Information Collected from Third Parties
If you use the Platform to send personal correspondence to the Operators, such as emails , or if other individuals or third parties send us correspondence about your activities regarding the Platform or our Services, the Platform and the Operators may collect such information into a file specific to you. For example, all correspondence from third party service providers regarding payment of dues, service tickets raised etc. will be collected on the Platform and by the Operators for the purpose of reflecting such correspondence on the Platform
3. PERSONAL DATA NECESSARY FOR PAYMENT RELATED SERVICES
The Platform and Operators collect the following Personal Data, as it is necessary for the adequate performance of the Services and to comply with applicable law. Without it, you will not be able to use payment services offered by the Operators on the Platform:
a) Financial information pertaining to certain payment Services: The Platform may also be utilized under relevant contractual arrangements with respective Operators for managing payments.
b) Payment Information. When you use any payment Services on the Platform, certain financial information may be required to facilitate the processing of such payments. You are to note that the Platform engages with authorised third party payment service providers to enable you to process your payments in connection with the use of any payment Services. You will be required by such third-party payment service providers to provide certain Personal Data to facilitate financial transactions on the Platform. Please note that to this extent, you will be subject to the terms of use and privacy policy that is maintained by such third-party service provider and the Platform, or your authorised Operator does not collect any such financial transactional information. The Platform and Operators will only check and validate the status and success of such financial transactions from such third parties and maintain the validated information in relevant ledger for such financial Services.
WHEN AND HOW PERSONAL DATA IS COLLECTED
The above-mentioned Personal Data and other information is collected in several ways including:
a) Directly from you, for example when you use our Platform, our Services or when you contact us through phone, email or use our contact us feature.
b) Indirectly from you when for example, your IP address, device data, browsing data and other information is collected while the user is interacting with our Platform.
c) When you are a recipient of Services provided by the Operators or the Platform.
d) When you provide Personal Data on the Platform to enable identity verification.
e) When you reach out to the customer support teams or when a support ticket is created on the Platform.
f) When you provide feedback to the Operators by using the Platform.
g) Web forms and surveys on the Platform.
h) Off-site services and events that relate to the Platform or Services or conducted by the Operators.
i) APIs embedded in the Platform.
j) Any other interaction initiated by you by using the Platform or with the Operators.
HOW WE USE YOUR PERSONAL DATA AND OTHER INFORMATION
a) Personal Data
The Platform and the Operators accesses, stores, and uses the information that is collected from you to provide our Services, to research and develop new ones. The Personal Data collected by your use of the Platform is not sold or traded in any form to anyone. The information is used solely for the purpose of enabling Services and making your experience better on the Platform.
The Platform and the Operators use your Personal Data to provide the Services you request, to customize your user experience and to improve our Platform and Services. To the extent we intend the Platform or Operators use your Personal Data to market any Services to you, you will be provided with the ability to opt-out of such uses. You can opt-out of receiving marketing materials at any time by following the unsubscribe instructions provided, indicating your preference when we call you, or by directly contacting us.
Following are the key Services for which Personal Data is collected from you:
i. Account set up and administration.
ii. Correspondence/communication with you pursuant to you registering an Account or your usage of the Platform.
iii. Verification or authentication of the information or identifications provided by you including verification of your Account and Profile.
iv. Ensuring that the content on the Platform is presented in the most effective manner for you and for your device.
v. Provide you with newsletters, information, products, or Services that you request or with may be of interest you, where you have consented to be contacted for such purposes.
vi. Periodically communicate with you (like new feature/benefits introduction, newsletters, contests, feature usage guidance, compliance requirements, offerings, etc.)
vii. Notify you about changes to the Platform, this Policy, or the Terms of Service.
viii. In any other manner that is described to you before you provide your Personal Data.
ix. Detection and prevention of fraud, identity theft, spam, abuse, security incidents, and other harmful activity.
x. Conducting security investigations and risk assessments.
In addition, the Platform and the Operators also use your Personal Data generated because of our Services availed by you to:
i. To ensure compliance of your access and use of Services with our legal obligations and applicable laws. The Platform may share such information with Operators, our advisors, third-party service partners, and service providers to facilitate a seamless user experience.
ii. Dispute resolution.
iii. Troubleshoot problems.
iv. Measure consumer interest and satisfaction in our Services.
v. Inform you about online and offline Services and updates.
vi. Customize your user experience on the Platform.
vii. Enforce our terms of use and Privacy Policy.
viii. Improvement of our Services and as otherwise described to you at the time of collection.
ix. Continually improving our Service offerings, the Platform collects and analyzes demographic and Profile data about users' activity on our Platform. The information that is collected (including recordings of customer support calls and chats) may be used to assist you when you contact our customer support services, to investigate and address your queries, and monitor and improve our customer support responses. This information may also be used for staff training, quality assurance, or to retain evidence of a specific transaction or interaction.
In connection with the activities above, the Platform may use your Personal Data and information regarding your conduct and interactions with the Operators to conduct a trend analysis for the purpose of studying the usage pattern, usage data of the Platform for inter alia a) to provide customised Services to you, b) to prevent fraud or c) any other illegal activity on the Platform.
Please note that in limited cases, automated processes may restrict or suspend access to the Platform, if such processes detect an activity that we think poses a safety or other risk to the Platform, Services offered on the Platform, us, Operators or other users including third parties.
b) Use of your Device Information
Once registered, the Platform uses the information provided by you in the following ways:
i. To establish identity and verify the same.
ii. Monitor, improve and administer our Platform.
iii. Provide Service.
iv. Analyze how the Platform is used, diagnose Service or technical problems and maintain security.
v. Send communications notifications, information regarding the services requested by you or process queries and applications that you have made on the Platform.
vi. Manage our relationship with you and inform you about other Services we think you might find of some use.
The Platform will use and retain your information for such periods as necessary to provide you with the Services, to comply with our legal obligations, to resolve disputes, and enforce our agreements. Please note that your Personal Data will be pseudonymized/ anonymized wherever possible to uphold your privacy.
c) Disclosure To Third Parties
Your Personal Data may be shared with our group companies and authorized Operators who help us provide services to you. We only share your Personal Data in accordance with the applicable law. In the interest of clarity, we share your Personal Data for the purposes set out in this Policy, with the following categories of recipients:
i. Your authorised Operators provide Services to the users relating to inter alia utilities (water, laundry, mobility etc.), use of clubs, your use of premises etc.
ii. Third parties where we have a duty to or are permitted to disclose your Personal Data by law (e.g. law enforcement officials, government authorities)
iii. With the police in the exercise of their functions or with others as required by a court order.
iv. Third parties where we or any of our group company, sell or buy any business or assets, in which case we may disclose your Information to the prospective seller or buyer of such business or assets.
We may disclose your Personal Data, without any prior notice or consent, if we are under a duty to do so in order to comply with any legal obligation or an order from the government and/or a statutory authority, or in order to enforce or apply our Terms of Use or assign such Personal Data in the course of corporate divestitures, mergers, or to protect the rights, property, or safety of us, our users, or others. This includes exchanging Personal Data with other companies and organizations for the purposes of fraud protection and credit risk reduction.
We and our affiliates may share your Personal Data with another business entity should we (or our assets) merge with, or be acquired by that business entity, or re-organization, amalgamation, restructuring of business for continuity of business. Should such a transaction occur then any business entity (or the new combined entity) receiving any such Personal Data from us shall be bound by this Policy with respect to your information.
d) Analytics
We may use the Personal Data you have shared with us or the data that has been generated by your use of the Platform for analytics purposes. The analytics will enable us inter alia to understand and improve how users interact with our Platform, customize Services for users, user behavior and quality of Services provided through the Platform.
Note where we share your Personal Data, appropriate protections will be in place to protect such information as required by applicable data protection laws. Sometimes, we may share Information in an aggregated, pseudonymised and/or anonymised form which cannot reasonably be used to identify an individual.
In case there is a requirement to disclose your Personal Data for any purpose not specified above, your consent will be taken before sharing Personal Data for such purpose.
HOW LONG DO WE RETAIN YOUR DATA
The Platform and Operators will retain your Personal Data for as long as needed to fulfil the purpose for which we collected it and for a reasonable period thereafter to comply with audit, accounting, contractual, technical and legal requirements, for security purposes, and/or to resolve any future disputes. There may be retention of any Other Information indefinitely or to the extent allowed by applicable law. Our retention guidelines are applicable even when you no longer are using our Platform or availing our Services.
YOUR PRIVACY CONTROLS
We ensure that you are in full control of the Personal Data we collect and how it is used. Additionally, you may also reach out to us or your respective Operator to modify or delete your Personal Data available with us.
a)Platform
i. When you are signed in to the Platform, as a registered user you can review, manage or update your Personal Data. For example, you can edit your date of birth, alternative email address.. Please note that no user can update or modify their Personal Data that is available with us while they are registered on the Platform. This Personal Data is collected from your original verification documents and cannot be modified or deleted.
ii. All registered Users have an option to opt-out from receiving notifications from the Platform. Please note this opt-out may not apply to promotional and marketing messages served by the Operators for important notices and updates.
b)Device-level settings: Your device may have controls that determine what device level information you share with us.
c)You can also request certain Personal Data to be removed from our servers based on applicable law or by writing to your respective authorized Operator and to us at info@dlfthrive.com. Please note that any deletion of specific information may require the approval of the authorised Operators, and we may still retain some information and records of transaction for specific period as required by any law, contract with authorised Operators or as per this policy, wherever applicable.
HOW DO WE KEEP YOUR DATA SECURE
a) Security Precautions
The Platform, the Operators and us have implemented reasonable physical, administrative, and technical safeguards to help us protect your Personal Data from unauthorized access, use and disclosure which include:
i.Storing Personal Data on secure cloud servers with appropriate firewalls.
ii.All Personal Data during transit and at rest and use is encrypted with the use of Secure Sockets Layers (SSL) or TLS based encryption, for the transmission of the information.
iii. Implementation of multi-factor authentication system to access your Account and Profile.
iV. Role-based access controls are implemented to limit Operator access to your Personal Data on a strict need-to-know basis consistent with the purposes for which we have collected such Personal Data.
V. Anti-malware and intrusion detection systems are utilised to guard against unauthorized access to our network.
Vi. Wherever possible your Personal Data is anonymized or pseudonymized to uphold your privacy.
vii. Periodical review of our information collection, storage, and processing practices, including physical security measures, to prevent unauthorized access to our systems.
viii. Compliance & Cooperation with Regulations and applicable laws.
Periodical review this Privacy Policy and make sure that your Personal Data is processed fairly.
An incident response plan has been implemented to quickly respond to any suspected leak or breach of Personal Data. When we receive formal written complaints, we respond by contacting the person who made the complaint. We work with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of your Personal Data that we cannot resolve with you directly.
In addition, we are in the process of implementing necessary information security practices and certificates or its equivalent or as may be notified and made mandatory under applicable laws, such as:
ISO 27001/2022 (formally known as ISO/IEC 27001:2005): is a specification for an information security management system (ISMS) and is the suggested level of certification required under the Information Technology Act, 2000. An ISMS is a framework of policies and procedures that includes all legal, physical and technical controls involved in an organization’s information risk management processes.
Given the nature of the transmission of data over the internet, we do not take any responsibility for the transmission of Personal Data including the Personal Data you provide to us or on the Platform. Any transmission of your Personal Data on the internet is done at your risk. We do not take any responsibility for you or any third party circumventing the privacy settings or security measures contained on the Platform. You also agree and understand that data transmission over the internet may be liable to risk and we would assume no liability for any disclosure of information due to errors in transmission issues or unauthorized third-party access to our Platforms or databases.
While all reasonable efforts to ensure that your Personal Data submitted by you over the Platform is safe and secure, we offer no representation, warranties or other assurances that the security measures are adequate, safe, foolproof or impenetrable.
You acknowledge that as a registered user on the Platform you are responsible for maintaining the security of your Account such as your Account login credentials and passwords, and that you should not provide these credentials to any unauthorized user or third party. If it comes to your knowledge or if you have reason to believe that your Account credentials have been stolen or been made known to others, you must contact us immediately at info@dlfthrive.com. You acknowledge that you are responsible for all acts done, using your Account login credentials. We are not responsible if someone else accesses your Account on account of your failure to maintain the security of your Account credentials. If we determine at our sole discretion, that you are engaged in malicious activity on the Platform, such as privacy violations, illicit data mining, profiling, or the unauthorized transmission of user data, it shall block your access to the Platform and your account may not be ever retrieved.
b) Third Party Links
When using the Platform or Services, you may encounter links to third-party websites/apps, payment gateways, service provider ads that are not affiliated with us. We are not responsible for the privacy practices or the content of those linked websites or URLs. With this Privacy Policy we’re only addressing the disclosure and use of data collected by us. If you visit any websites or avail Services through any other third party or through the links on the Platform, please ensure you go through the privacy policies and terms of use of each of those websites and third parties. Their data collection practices, and their policies might be different from this Privacy Policy and our Terms of Use and we neither have control over any of their policies nor do we have any liability in this regard.
CHILDREN
Our Platform is not available for use directly by children (under the age of 18 or any other age of children as per the applicable laws) and does not provide information aimed at or specifically targeting children. If you are categorized as a child under the applicable laws and use our Platform and our Services, then we shall presume that you are registered as a dependent by a Registered Account user and are using our Platform and our Services only under the guidance and involvement of the Registered Account user (in such cases a parent or legal guardian.) Please note that in case a child who is a dependent of a Registered Account holder on the Platform, uses or accesses the Platform, it will be assumed that such use and access has been done under the guidance of the Registered Account holder and the Operators or us will not be held liable for any misuse of the Platform or Services by children.
YOUR CONSENT
By using the Platform and our Services / or by providing your information, you consent to the collection and use of the Personal Data you disclose during your interaction with us in accordance with this Privacy Policy, including but not limited to your consent for collecting, using, sharing, and disclosing your information as per this Privacy Policy.
Please note that the Privacy Policy may be updated from time to time, and it is your responsibility to look through them as often as possible. Your continued use of the Platform after any changes to this Privacy Policy are posted, will be considered as deemed acceptance of those changes.
YOUR RIGHTS
In accordance with the applicable data protection and privacy laws in India, and subject to certain exceptions where information needs to be retained for legal, internal audit, security & fraud prevention purposes you may have the certain rights such as right to access what Personal Data we hold about you, or the right to deletion or right to have incomplete or inaccurate data about you corrected or completed.
You always have the right to report any Personal Data breach at info@dlfthrive.com and the right to not be discriminated against by us for exercising any of your privacy rights.
If you would like to exercise any of these rights, please contact us at info@dlfthrive.com. Upon verifying the authenticity of such a request, we will process such requests in accordance with applicable data protection and privacy laws of India. Please note, to protect your privacy, we will take steps to verify your identity before processing and fulfilling your request.
TERMINATION
An option to uninstall the Platform from their mobile devices is extended to all users.
However, please note that the deleting of the Account and Profile can only be carried out by us or authorized Operators upon verification and confirmation that you are no longer a member with us. Upon receiving such a request, all information corresponding to the specific Account, including but not limited to Profile details, transactional data will be eradicated.
There might be scenarios where we may not be able to execute account deletion, such as if there exists an outstanding dispute, transactions suspected to be fraudulent, unresolved claims attached to your account. Upon resolution of the obstruction preventing deletion, the relevant information is promptly deleted and cannot be retrieved thereafter.
Notwithstanding anything contained herein above, we may continue to retain certain information if deemed necessary for regulatory compliance, legitimate business interests like fraud prevention, enhancing user safety and security, or to fulfill our legal and contractual obligations.
TERMS OF USE
Your use of the Platform is also governed by our Terms of Service. You are free to use the application only if you agree with our policies and practices encapsulated in this Policy read in conjunction with the Terms of Service.
SUPPORT AND GRIEVANCES
We support and encourage all users to contact us for questions, concerns, or suggestions relating to our Terms of Use and our Privacy Policy or practices involving the usage of data. We may be contacted at info@dlfthrive.com.
