Privacy Policy

This Privacy Policy (“Policy”) describes how JamunJar Health and Wealth Private Limited (“JamunJar”, “We”, “Us” or “Company”) processes Personal Data of users of the website https://www.jamunjar.com and the JamunJar mobile application and users who access or avail of the Services through physical, telephonic, electronic, digital or any other mode or medium (together, the “Platform”) as a Data Fiduciary under the Digital Personal Data Protection Act, 2023 (“DPDP Act”).Your use of the Platform is subject to Your consent to this Policy, provided in accordance with the DPDP Act. Where processing is based on your consent, You may withdraw such consent at any time in the manner set out in Clause 14 below.This Platform is not intended for independent use by children (persons below the age of 18 years). Where any Service is availed on behalf of, or for the benefit of, a child, such use shall only be undertaken by a parent or lawful guardian, and JamunJar shall obtain verifiable consent of the parent or lawful guardian prior to processing the child's Personal Data, in accordance with Section 9 of the DPDP Act. JamunJar shall not undertake tracking, behavioural monitoring, or targeted advertising directed at children.This Privacy Policy does not create any contractual, financial, or legal rights for any user or viewer.

The following definitions shall be applicable to this Policy:“Data Fiduciary” means JamunJar, which determines the purpose and means of processing Personal Data.“Data Principal” means the individual to whom the Personal Data relates, i.e. You.“Personal Data” means any data about an individual who is identifiable by or in relation to such data.While the DPDP Act does not create a distinct statutory category of “sensitive personal data,” JamunJar voluntarily applies heightened safeguards to the following categories of Personal Data, given the health-related nature of the Services:

• password;
• mobile no, email and demographic details like address, location etc.;
• physical, physiological and mental health condition including medical records, prescriptions, diagnostic reports and history;
• sexual orientation;
• any detail related to the above provided to or processed by JamunJar under lawful contract; and
• Aadhaar number and biometric information associated with Aadhaar, which shall be collected, stored and used strictly in accordance with the Aadhaar (Targeted Delivery of Financial and Other Subsidies, Benefits and Services) Act, 2016 and regulations made thereunder, and only where separate, explicit consent for Aadhaar-based authentication has been obtained.

Information freely available in the public domain or furnished under the Right to Information Act, 2005 shall not be regarded as sensitive personal data.

• “Services” - refers to all services provided by JamunJar and the products and services made available through JamunJar by independent third-party sellers or service providers, as applicable, whether accessed or availed through the Platform or through any physical, telephonic, electronic, digital or other mode or medium.
• “Third Party Service Provider(s)” - encompasses group companies, affiliates, third-party vendors, agents, contractors, consultants, or service providers.
• “Website” - refers to JamunJar.com and any subsequent pages listed under its sitemap.
• “You,” “Your,” or “User(s)” - denotes the individual accessing or using the Platform or utilizing the services of JamunJar in any capacity, whether through the Platform or through any physical, telephonic, electronic, digital or other mode or medium.

Information You Provide to Us:Some Services require registration to create an account. The typical registration information may include Your mobile number, name, email address, etc., which helps us in identifying You personally. We may also collect Personal Data voluntarily provided by You through the Platform or through any physical, telephonic, electronic, digital or other mode or medium, including through physical forms, telephone calls, messages, correspondence or interactions with our personnel or representatives. This information is necessary for initiating and continuously using Your account and the Services. If the information provided by You is incorrect or has changed, You can update or delete it unless we are required to retain it for legitimate business or legal purposes. However, backend audit trail keeping may require us to retain a copy/log of such information for as long as legally permitted or required.We may collect the following Personal Data from You (this is an indicative list):

1. (i)Personal Information includes details that identify You, such as Your name, date of birth, credentials, passwords, phone number, PAN, Aadhaar (subject to the safeguards in Clause 2 above), fax number, email address, gender, marital status, city of residence.
2. (ii)Most features of the Website would require registration information, which may necessitate providing Your email address, mobile number, password, and other details needed for registration. The type of Personal Information collected depends on the service you avail or propose to avail.
3. (iii)The Website may occasionally request additional Personal Information to provide you with benefits or value-added services. On these occasions, you have the choice to provide or decline this information. Failure to provide required information may prevent you from availing specific Services made available through JamunJar.

Information collected during Your use of our Services:Using or availing of the Services offered by JamunJar may result in the collection of performance and usage information such as the date and time of Your visit or interaction, browser/computer type, default language setting, unique Internet Protocol address, number of links clicked within the Website, pages viewed, and the webpage from which You arrived. This information will not be used to personally identify You. Usage of facilities/products/services through any App will be subject to additional terms and conditions regarding data collection and disclosure, to be read along with this Privacy Policy. JamunJar shall not be liable for any consequences arising from the use of third-party Apps or breaches of data privacy occurring at their end.Information Obtained from Affiliates or Third Parties:We may receive information about You from other sources, including commercially available ones such as social media, data aggregators, and public databases. We may also collect information from our affiliates or group companies.Information Obtained through Cookies or Anonymous Identifiers:Cookies are small electronic text files utilized by Websites to store User preferences and settings. JamunJar cannot control the use of cookies or the resulting information by advertisers or third parties hosting data on JamunJar websites. You may reset your browser to control cookies, although some Services offered by the Website may not function correctly if cookies are refused, reset, or deleted.Consequences of Not Providing Information or Withdrawing Consent:If you do not provide your information, consent to its usage, later withdraw consent for its intended purpose, submit misleading or false information, or fail to update your information, JamunJar reserves the right to discontinue/cancel the services for which the information was sought. Any decision by JamunJar in this regard shall be binding on You and shall supersede the terms of the services, without prejudice to Your rights under Clause 14 below.

We may use the information we collect from You for the purposes listed below, each of which shall be processed only on the basis of Your consent or another valid ground for processing recognised under the DPDP Act, and only to the extent necessary for such purpose:

• Providing the Services and facilitating products and services made available through JamunJar.
• Addressing your inquiries or complaints.
• Offering and facilitating Services through the Platform or through any other mode or medium made available by JamunJar Personalizing your experience.
• Improving the Platform, products, Services, and customer service.
• Processing transactions under your User ID and Password.
• Sending periodic communications (emails/SMS/mobile notifications/WhatsApp).
• Managing contests, promotions, surveys, or other features.
• Closing sales and gathering post-sales information.
• Communicating for post-sales requirements.
• Conducting statistical analysis.
• Enhancing products/services using advanced technologies.
• Performing sales and marketing activities.
• Aadhaar authentication as per laws.
• Detecting and protecting against fraud or criminal activity.
• Complying with legal or regulatory requirements.

Third-party service providers may assist us in these tasks, but we are not liable for any damages incurred by them.You may withdraw Your consent to any or all of the above purposes at any time, in accordance with Clause 14 below, without affecting the lawfulness of processing carried out prior to such withdrawal.

JamunJar encourages you to update your personal information as required. You are also entitled to review the information provided and ensure that any inaccuracies are corrected or amended when feasible. All personal information provided will be on an ‘as is’ basis. JamunJar is not responsible for any actions or policies of third-party service providers, and users are requested to check the applicable privacy policy and familiarize themselves with the terms and conditions of usage of such third-party service providers when providing personal information. JamunJar shall not be liable for any variance in the features or benefits offered by such third-party service providers and does not assume warranty on the efficiency or efficacy of such offers.

• JamunJar collects Personal Data only to the extent voluntarily provided by you or otherwise collected in connection with your use of or availing of the Services, whether through the Platform or through any physical, telephonic, electronic, digital or other mode or medium. JamunJar confirms that it will not rent or sell Your Personal Data.
• Where JamunJar engages a Data Processor to process Personal Data on its behalf, such processing shall be governed by a valid contract, and JamunJar shall remain responsible for ensuring compliance with the DPDP Act in respect of such processing, notwithstanding any such engagement, including for the following purposes:
• To ensure that the business partner can provide personalized service as promised by JamunJar
• To comply with any applicable law, regulation, legal process, enforceable governmental request, or customary practice directly or through affiliates or agencies.
• To meet requirements of participation in any telecommunication or electronic clearing network.
• For statistical analysis, verification, or risk management.
• To enforce applicable terms of service, including investigation of potential violations.
• To detect, prevent, or address fraud, security, or technical issues.
• To protect against harm to the rights, property, or safety of JamunJar, its users, or the public as required or permitted by law.
• To comply with regulatory guidelines and/or as required under applicable laws.

JamunJar retains the right to share non-personally identifiable information with third parties for business purposes, to assess website traffic, patterns, and other similar purposes. Additionally, JamunJar retains the right to share non-personally identifiable information to comply with applicable legal and regulatory processes or to protect and defend the rights and interests of JamunJar, its affiliates, and/or other users or to enforce the terms and conditions binding on all users of the website.

JamunJar may contact you via email, postal service/courier, mobile messaging services, WhatsApp, telephone, or social media if you consent or if required by operational or regulatory needs. JamunJar may also use third-party service providers to communicate with you. Where You are registered under the National Customer Preference Register (“NCPR”) or any equivalent do-not-disturb registry, JamunJar shall only contact You for commercial communications in accordance with applicable TRAI regulations, including where You have granted specific consent for such communications or the communication falls within a recognised transactional exemption. You can unsubscribe from these communications at any time.

JamunJar may enable third parties to offer subscription and/or registration-based services through the website, app, or other platforms such as WhatsApp, Twitter, Alexa, etc. JamunJar is not responsible for the actions or policies of these third parties, and users are advised to review the applicable privacy policy and familiarize themselves with the terms and conditions of usage of such service providers when providing personally identifiable information. JamunJar shall not be liable for any variations in the features or benefits offered by these third parties and does not provide warranties on the efficiency or effectiveness of such offers.Where necessary for providing the Services or facilitating products and services made available through JamunJar, JamunJar may share specific Personal Information with third parties for various activities, including but not limited to:

• Marketing purposes
• Document management/retention
• Cloud storage
• Logistical activities such as printing and couriering documents
• Cross-selling and up-selling of products of JamunJar or its group/parent companies
• Customer support provided by call centers
• Improving services and products

JamunJar reserves the right to amend or modify this Privacy Policy, including replacing it with a new policy, at any time at its sole discretion. Users are advised to periodically review the terms and conditions outlined in this Privacy Policy. JamunJar shall not be liable for any loss arising from a user's failure to review updates to this Policy, save where such loss arises from JamunJar's own breach of applicable law.

We take reasonable precautions to protect your Personal Data from unauthorized access, alteration, disclosure, or destruction. Specifically:

• We provide role-based access to employees/partners.
• We review our information practices to guard against unauthorized access.
• We allow access to personal information for employees, contractors, and agents under strict confidentiality obligations.
• We use password-based authentication for User access. You are responsible for maintaining the confidentiality of your login ID and password; we recommend changing your password periodically.
• Communications between your device and our Website are encrypted using at least TLS 1.2 (or higher) encryption to prevent eavesdropping, tampering, and message forgery. Your Website password is also encrypted.

While JamunJar implements commercially reasonable technical and organisational safeguards to protect Personal Data, no method of electronic transmission or storage is completely secure and JamunJar cannot guarantee absolute security.

JamunJar may store and process Personal Data using third-party data centres and cloud service providers located in India or in other jurisdictions, except jurisdictions restricted by the Central Government under the DPDP Act. Such transfers shall be subject to contractual and technical safeguards consistent with the DPDP Act.We protect your information with HTTPS, which encrypts data between your device and our servers. Look for the padlock icon in your browser for secure connections.

Trademarks, logos, slogans, and service marks on this Website belong to JamunJar or others. Without written permission, JamunJar does not allow their use or display. Legal remedies will be sought for any intellectual property violations. Reproduction of these pages without JamunJar's prior written consent is prohibited unless for private, non-commercial viewing.

JamunJar will only retain Personal Information or Sensitive Personal Data as long as necessary to fulfil its purpose or as required by law. In some cases, data may be anonymized for further use without referring to the user. Upon deactivation, termination, or withdrawal of consent, Personal Information may no longer be used and may be removed after the legally prescribed retention period. Unless permanently purged, Personal Information may continue to be retained in accordance with applicable legal, regulatory and internal record retention requirements, after which it may be anonymised or securely deleted, as applicable. Upon withdrawal of consent or where the specified purpose is no longer being served, JamunJar shall erase such Personal Data unless retention is required for compliance with applicable law.

In the event of a Personal Data breach, JamunJar shall notify the Data Protection Board of India and affected Data Principals in the manner and within the timelines prescribed under the DPDP Act and rules made thereunder.

Subject to applicable law, You have the right to:

• access a summary of Your Personal Data processed by JamunJar and the processing activities undertaken;
• seek correction and completion of inaccurate or incomplete Personal Data;
• seek erasure of Personal Data that is no longer necessary for the purpose for which it was processed;
• withdraw consent at any time, as easily as it was given;
• nominate another individual to exercise these rights in the event of Your death or incapacity; and
• file a grievance with JamunJar's Grievance Officer for data protection matters, and thereafter with the Data Protection Board of India if unresolved.

Requests may be sent to: data.privacy@jamunjar.com

Where required under the DPDP Act, JamunJar shall appoint a Data Protection Officer based in India, whose contact details shall be published on the Platform and made available to the Data Protection Board of India.

Information, content, and materials provided on this Website are presented “As Is,” and JamunJar does not make any express or implied representation or warranty regarding their accuracy or completeness.

Should you require any further clarifications regarding the content of this Privacy Policy or the terms and conditions stated herein, please contact:Ajay Poddar
data.privacy@jamunjar.com
Damji Shamji Corporate Square, C Wing, Office No. 312, Laxmi Nagar, Ghatkopar East, Mumbai – 400075