This Privacy Policy (“Policy”) describes the policies and procedures on the collection, use, disclosure and protection of your information when you use our website located at https://Welltra.co.in/, or the Welltra mobile application.
The terms “you” and “your” refer to the user of the Welltra Platform. The term “Services” refers to any services offered by Welltra/You whether on the Welltra Platform or otherwise.
Please read this Policy before using the Welltra Platform or submitting any personal information to Welltra. This Policy is a part of and incorporated within, and is to be read along with, the applicable Terms and Conditions based on the user of the Welltra Platform.
By using the Welltra Platform and the Services, you agree and consent to the collection, transfer, use, storage, disclosure and sharing of your information as described and collected by us in accordance with this Policy. If you do not agree with the Policy, please do not use or access the Welltra Platform.
If you have questions about this Privacy Policy, please contact us through email address provided on our website and/or Mobile Application.
1. DEFINITIONS
Unless otherwise provided in this Privacy Policy, the terms capitalized in the Privacy Policy shall have the meaning as provided hereunder:
a. “Riders” means independent third-party vehicle operators or riders who wish to offer services on the Welltra Platform to a User.
b. “Co-branded Services” shall have the meaning assigned to the term in paragraph 4(c) hereto.
c. “Customer” shall mean a person who wishes to receive services of the Riders on the Welltra Platform.
d. “Device” shall mean computer, mobile or other device used to access the Services.
e. “Device Identifier” shall mean IP address or other unique identifier for the Device.
f. “Mobile Application” shall mean application provided by us on the Device to access the Services.
g. “Mobile Device Information” shall have the meaning assigned to the term in paragraph 2(II)(e)(ii) hereto.
h. “Promotion” shall mean any contest and other promotions offered by us.
i. “Protected Information” shall mean such categories of information that could reasonably be used to identify you personally, including your name, e-mail address, and mobile number.
j. “Third Party” shall mean a third party service provider.
k. “Usage Information” shall have the meaning assigned to the term in paragraph 2(II)(a) hereto.
2. WHAT INFORMATION DO WE COLLECT?
I. INFORMATION YOU PROVIDE TO US
We may ask you to provide us with certain Protected Information. We may collect this information through various means and in various places through the Services, including account registration forms, contact us forms, or when you otherwise interact with us. When you sign up to use the Services, you create a user profile. We shall ask you to provide only such Protected Information which is for lawful purpose connected with our Services and necessary to be collected by us for such purpose.
Information you give us - This includes information submitted when You:
o Create or update the Welltra account which may include your Email ID, Name, Address, Mobile Number, Gender, Date of birth, Login name, Password.
o Use Our Services, we may collect and store information about you to process your requests and automatically complete forms for future transactions, including (but not limited to) your phone number, address, email, billing information etc.
o Correspond with Welltra for customer support.
o Report problems for troubleshooting.
o If you sign up to use our Services as a vendor or Riders, we may collect location details, profile picture, copies of government identification documents and other details (KYC), vehicle related documents such as insurance, pollution certificate etc and such other documents which evidence the health or fitness of the vehicle to provide Services on the Welltra Platform, call and SMS details.
o We collect background check and identity verification information of the Riders. This may include information such as driver history or criminal record (where permitted by law), and right to work. This information may be collected by an authorized vendor on the Company’s behalf.
o In case you sign up as a Rider, enable features that require Welltra’s access to other applications on Your Device aiming to prevent frauds towards the Customers.
o If you sign up to use our Services as an employee or as a stakeholder of a third party to whom the Company has an arrangement and has offered discount coupons/ or extended certain promotional offers, the Company may share any information provided by you with such third party to be utilised by them for limited internal business purposes only.
II. INFORMATION WE COLLECT AS YOU ACCESS AND USE OUR SERVICES
a. In addition to any Protected Information or other information that you choose to submit to us, we and our third party service provider may use a variety of technologies that automatically (or passively) collect certain information whenever you visit or interact with the Services (“Usage Information”). This Usage Information may include the browser that you are using, the URL that referred you to our Services, all of the areas within our Services that you visit, and the time of day, among other information. In addition, we collect your Device Identifier for your Device. A Device Identifier is a number that is automatically assigned to your Device used to access the Services, and our computers identify your Device by its Device Identifier.
b. Usage Information may be collected using a cookie. If you do not want information to be collected through the use of cookies, your browser allows you to deny or accept the use of cookies. Cookies can be disabled or controlled by setting a preference within your web browser or on your Device. If you choose to disable cookies or flash cookies on your Device, some features of the Services may not function properly or may not be able to customize the delivery of information to you. The Company cannot control the use of cookies (or the resulting information) by third parties, and use of third party cookies is not covered by our Privacy Policy.
c. Location data:
Riders: Welltra collects location data when the Welltra App is running in the foreground (app is open and on-screen) or background (app is not in use) of their mobile device. Welltra collects location data only when the Riders have enabled the icon “On-Duty” on the Welltra App.
Customers: We collect precise or approximate location data from the users’ mobile devices if they enable us to do so. Welltra collects this data from the time a ride or delivery is requested until it is finished, and any time the app is running in the foreground of their mobile device. We use this data to enhance your use of our apps, including to improve pick-up locations, enable safety features, and prevent and detect fraud. Welltra collects the Riders’ location data, and links location data collected during a trip with their Customer’s account, even if the Customer has not enabled us to collect location data from their device. This enables us to offer services to the Customers like receipt generation and customer support.
d. Information Third Parties provide about You:
We may, from time to time, supplement the information we collect about you through our website or Mobile Application or Services with outside records from third parties.
e. INFORMATION COLLECTED BY MOBILE APPLICATIONS
i. Our Services are primarily provided through the Mobile Application. We may collect and use technical data and related information, including but not limited to, technical information about your device, system and application software, and peripherals, that is gathered periodically to facilitate the provision of software updates, product support and other services to you (if any) related to such Mobile Applications.
ii. When you use any of our Mobile Applications, the Mobile Application may automatically collect and store some or all of the following information from your mobile device (“Mobile Device Information”), in addition to the Device Information, including without limitation:
Your preferred language and country site (if applicable)
The manufacturer and model of your mobile device
Your mobile operating system
The type of mobile internet browsers you are using
Your geolocation
iii. Information about how you interact with the Mobile Application and any of our web sites to which the Mobile Application links, such as how many times you use a specific part of the Mobile Application over a given time period, the amount of time you spend using the Mobile Application, how often you use the Mobile Application, actions you take in the Mobile Application and how you engage with the Mobile Application
iv. Information to allow us to personalize the services and content available through the Mobile Application
v. Data from SMS/ text messages upon receiving Device permissions for the purposes of (i) issuing and receiving one-time passwords and other device verification, and (ii) automatically filling verification details during financial transactions, either through us or a third-party service provider, in accordance with applicable law. We do not share or transfer SMS/ text message data to any third party other than as provided under this Privacy Policy.
vi. If you are a vendor or a Rider, we will, additionally, record your calls with us made from the device used to provide Services, related call details, SMS details location and address details.
3. USE OF INFORMATION COLLECTED
i. Our primary goal in collecting your information is to provide you with an enhanced experience when using the Services. We use your information to closely monitor which features of the Services are used most, to allow you to view your trip history, rate trips, and to determine which features we need to focus on improving, including usage patterns and geographic locations to determine where we should offer or focus services, features and/or resources.
ii. Based upon the Protected Information you provide us when registering for an account, we will send you a welcoming email to verify your username and password.
iii. We use the information collected from our Mobile Application so that we are able to serve you the correct app version depending on your device type, for troubleshooting and in some cases, marketing purposes.
iv. We use your Internet Protocol (IP) address to help diagnose problems with our computer server, and to administer our web site(s). Your IP address is used to help identify you, but contains no personal information about you.
v. We will send you strictly service-related announcements on rare occasions when it is necessary to do so. For instance, if our Services are temporarily suspended for maintenance, we might send you an email. If you do not wish to receive them, you have the option to deactivate your account.
vi. We may use the information obtained from you to prevent, discover and investigate violations of this Privacy Policy or any applicable terms of service or terms of use for the Mobile Application, and to investigate fraud, chargeback or other matters.
vii. We provide some of your Protected Information (such as your name, pick up address, contact number) to the Rider who accepts your request for transportation so that the Rider may contact and find you.
viii. In case of the Customers, we use the geo-location information for various purposes, including for such Customers to be able to view the Riders in your area that are close to your location to provide services to You, to automatically fetch your location when you open the Welltra App, for the Riders to identify the pickup location and to allow you (if you choose through any features we may provide) to share this information with other people for your safety.
ix. In case of the Riders, we use the geo-location information for (only when the Rider activates the icon “On-Duty” on the Welltra App) the Riders to receive orders close to his location even when the Welltra App is not in use or closed, to enable the Customers track the distance of the Riders from their location for pick up, to share the exact location for the safety of the Customers.
x. In addition, we may use your Protected Information or Usage Information that we collect about you: (a) to provide you with information or services or process transactions that you have requested or agreed to receive including to send you electronic newsletters, or to provide you with special offers or promotional materials on behalf of us or third parties; (b) to enable you to participate in a variety of the Services’ features such as online or mobile entry sweepstakes, contests or other promotions; (c) to contact you with regard to your use of the Services and, in our discretion, changes to the Services and/or the Services’ policies; (d) for internal business purposes; (e) for inclusion in our data analytics; and (f) for purposes disclosed at the time you provide your information or as otherwise set forth in this Privacy Policy.
xi. We do not use the information collected from you for targeted advertising.
4. HOW AND WHEN DO WE DISCLOSE INFORMATION TO THIRD PARTIES
We do not sell, share, rent or trade the information we have collected about you, other than as disclosed within this Privacy Policy or at the time you provide your information. Following are the situations when information may be shared:
a. WHEN YOU AGREE TO RECEIVE INFORMATION FROM THIRD PARTIES.
You may be presented with an opportunity to receive information and/or marketing offers directly from third parties. If you do agree to have your Protected Information shared, your Protected Information will be disclosed to such third parties and all information you disclose will be subject to the privacy policy and practices of such third parties. We are not responsible for the privacy policies and practices of such third parties and, therefore, you should review the privacy policies and practices of such third parties prior to agreeing to receive such information from them. If you later decide that you no longer want to receive communication from a third party, you will need to contact that third party directly.
b. THIRD PARTIES PROVIDING SERVICES ON OUR BEHALF
As You access and use our services, we collect certain information from You, including but not limited to, phone number, email address, device make-details, and IP address. By accessing and using the Services, You expressly consent to the sharing and disclosure of your information so collected, with our third-party service providers, business partners, and agents. Please refer to the such third-party privacy policy for more details before using their services on the Welltra Platform.
We use third party companies and individuals to facilitate our Services, provide or perform certain aspects of the Services on our behalf – such as host the Services, design and/or operate the Services’ features, track the Services’ analytics, process payments, engage in anti-fraud and security measures, provide customer support, provide geo-location information to our drivers, enable us to send you special offers, host our job application form, perform technical services (e.g., without limitation, maintenance services, database management, web analytics and improvement of the Services‘ features), or perform other administrative services. These third parties will have access to user information, including Protected Information to only carry out the services they are performing for you or for us. Each of these third parties including are required to ensure the same level of data protection as us and are obligated not to disclose or use Protected Information for any other purpose.
Analytics Third Party may set and access their own cookies, web beacons and embedded scripts on your Device and they may otherwise collect or have access to information about you, including non-personally identifiable information
We use a third-party hosting provider who hosts our support section of our website. Information collected within this section of our website by such third party is governed by our Privacy Policy.
c. CO-BRANDED SERVICES.
Certain aspects of the Services may be provided to you in association with third parties (“Co-Branded Services”) such as credit houses, loan providers, sponsors and charities, and may require you to disclose Protected Information to them. Such Co-Branded Services will identify the third party. If you elect to register for products and/or services through the Co-Branded Services, you shall have deemed to consent to providing your information to both us and the third party. Further, if you sign-in to a Co-Branded Service with a username and password obtained through our Services, your Protected Information may be disclosed to the identified third parties for that Co-Branded Service and will be subject to their posted privacy policies.
d. CONTESTS AND PROMOTIONS
We may offer Promotions through the Services that may require registration. By participating in a Promotion, you are agreeing to official rules that govern that Promotion, which may contain specific requirements of you, including, allowing the sponsor of the Promotion to use your name, voice and/or likeness in advertising or marketing associated with the Promotion. If you choose to enter a Promotion, you agree that your Protected Information may be disclosed to third parties or the public in connection with the administration of such Promotion, including, in connection with winner selection, prize fulfilment, and as required by law or permitted by the Promotion’s official rules, such as on a winners list.
e. ADMINISTRATIVE AND LEGAL REASONS
We cooperate with Government and law enforcement officials and private parties to enforce and comply with the law. Thus, we may access, use, preserve, transfer and disclose your information (including Protected Information, IP address, Device Information or geo-location data), to Government or law enforcement officials or private parties as we reasonably determine is necessary and appropriate: (i) to satisfy any applicable law, regulation, subpoenas, Governmental requests or legal process; (ii) to protect and/or defend the Terms and Conditions for online and mobile Services or other policies applicable to any online and mobile Services, including investigation of potential violations thereof; (iii) to protect the safety, rights, property or security of the Company, our Services or any third party; (iv) to protect the safety of the public for any reason; (v) to detect, prevent or otherwise address fraud, security or technical issues; and /or (vi) to prevent or stop activity we may consider to be, or to pose a risk of being, an illegal, unethical, or legally actionable activity.
f. WHEN YOU SHARE INFORMATION
Protected Information may be collected and shared with third-parties if there is content from the Mobile Application that you specifically and knowingly upload to, share with or transmit to an email recipient, online community, website, or to the public, e.g. uploaded photos, posted reviews or comments, or information about you or your ride that you choose to share with others through features which may be provided on our Services. This uploaded, shared or transmitted content will also be subject to the privacy policy of the email, online community website, social media or other platform to which you upload, share or transmit the content.
g. BUSINESS TRANSFER
We may share your information, including your Protected Information and Usage Information with our parent, subsidiaries and affiliates for internal reasons, including business and operational purposes. We also reserve the right to disclose and transfer all such information: (i) to a subsequent owner, co-owner or operator of the Services or applicable database; or (ii) in connection with a corporate merger, consolidation, restructuring, the sale of substantially all of our membership interests and/or assets or other corporate change, including, during the course of any due diligence process.
h. MARKET STUDY AND OTHER BENEFITS
We may share your information, including your Protected Information and Usage Information with third parties for any purpose, including but not limited to undertaking market research/ study, conduct data analysis, determine and customize product or service offerings, to improve the products or Services or to make any other benefits/products/ services available to you.
5. THIRD PARTY CONTENT AND LINKS TO THIRD PARTY SERVICES
The Services may contain content that is supplied by a third party, and those third parties may collect website usage information and your Device Identifier when web pages from any online or mobile Services are served to your browser. In addition, when you are using the Services, you may be directed to other sites or applications that are operated and controlled by third parties that we do not control. We are not responsible for the privacy practices employed by any of these third parties. For example, if you click on a banner advertisement, the click may take you away from one of our websites onto a different web site. These other web sites may send their own cookies to you, independently collect data or solicit Protected Information and may or may not have their own published privacy policies. We encourage you to note when you leave our Services and to read the privacy statements of all third party web sites or applications before submitting any Protected Information to third parties.
6. SOCIAL MEDIA FEATURES AND WIDGETS
Our online and mobile Services may include social media features, such as the Facebook Like button, and widgets such as a “Share This” button, or interactive mini-programs that run on our online and mobile Services. These features may collect your IP address, photograph, which page you are visiting on our online or mobile Services, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our online Services. Your interactions with these features and widgets are governed by the privacy policy of the company providing them.
7. INFORMATION COLLECTED BY RIDERS
This Privacy Policy shall not cover the usage of any information about you which is obtained by the Rider while providing you a ride on a bike booked using the Services, or otherwise.
If you are a Rider, we may share your name, vehicle number, driving license number, phone number and/or profile picture (if applicable), tracking details with our customers to provide them the Services.
8. CHANGE OF INFORMATION AND CANCELLATION OF ACCOUNT
a. You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information provided as part of account registration. If your Protected Information changes, or if you no longer desire our Services, you may correct, delete inaccuracies, or amend information by making the change on our member information page or by contacting us through through email address mentioned on our website or Mobile Application. We will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable.
b. You may also cancel or modify your communications that you have elected to receive from the Services by following the instructions contained within an e-mail or by logging into your user account and changing your communication preferences.
c. If upon modifying or changing the information earlier provided to Us, we find it difficult to permit access to our Services to you due to insufficiency/ inaccuracy of the information, we may, in our sole discretion terminate your access to the Services by providing you a written notice to this effect on your registered email id.
d. If you wish to cancel your account or request that we no longer use your information to provide you services, contact us through email address mentioned on the trip bill received. We will retain your Protected Information and Usage Information (including geo-location) for as long as your account with the Services is active and as needed to provide you services. Even after your account is terminated, we will retain your Protected Information and Usage Information (including geo-location, trip history, and transaction history) for such statutory time-period as needed to comply with our legal and regulatory obligations in accordance with the applicable laws of the country, to resolve disputes, conclude any activities related to cancellation of an account, investigate, or prevent fraud and other inappropriate activity related to your account. After completion of such statutory period, your data may either be deleted from our database or be anonymized and aggregated, and then may be held by us as long as necessary for us to provide our Services effectively, but our use of the anonymized data will be solely for internal analytic purposes.
9. SECURITY
The Protected Information and Usage Information we collect is securely stored within our databases, and we use standard, industry-wide, commercially reasonable security practices such as encryption, firewalls and SSL (Secure Socket Layers) for protecting your information. However, as effective as encryption technology is, no security system is impenetrable. We cannot guarantee the security of our databases, nor can we guarantee that information you supply won't be intercepted while being transmitted to us over the Internet or wireless communication, and any information you transmit to the Company you do at your own risk. We recommend that you not disclose your password to anyone.
10. GRIEVANCE OFFICER
Welltra Manager would be appointed the grievance officer for the purposes of the rules drafted under the Information Technology Act, 2000, who may be contacted at Welltra2023@gmail.com. You may address any grievances you may have in respect of this privacy policy or usage of your Protected Information or other data to him.
11. CHANGES TO THE PRIVACY POLICY
From time to time, we may update this Privacy Policy to reflect changes to our information practices. Any changes will be effective immediately upon the posting of the revised Privacy Policy. If we make any material changes, we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on the Services prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.
Health and Fitness Data
We collect health and fitness data to provide personalized services and insights to enhance your well-being. This data helps us tailor our features to meet your health and wellness needs effectively. Here’s a breakdown of the types of data we collect and how we use them:
1. Activity Data
Collection: We collect data on your physical activities, such as steps taken, distance traveled, and calories burned. This data is gathered through the App's integration with your mobile device's sensors, such as the accelerometer and GPS.
Use:
Tracking Progress: To help you track your daily activity levels and progress toward fitness goals.
Personalized Feedback: To provide you with insights and recommendations on improving your activity levels.
Goal Setting: To assist you in setting and achieving personal fitness goals based on your activity trends.
2. Sleep Data
Collection: We collect data on your sleep patterns, including the duration, quality, and stages of sleep. This data is obtained through your interactions with the App and, where applicable, through the integration with compatible sleep monitoring devices or apps.
Use:
Sleep Analysis: To analyze your sleep patterns and provide insights into your sleep quality.
Recommendations: To offer personalized recommendations to improve your sleep habits.
Sleep Trends: To help you understand how your sleep patterns change over time and how they affect your overall health.
3. Heart Rate Data
Collection: We collect data on your heart rate and related metrics through sensors in your device or connected wearable technology. This data includes resting heart rate, active heart rate, and heart rate variability.
Use:
Health Monitoring: To monitor your heart rate and provide insights into your cardiovascular health.
Activity Correlation: To correlate heart rate data with physical activities and provide feedback on your fitness levels.
Alerts: To notify you of any significant changes or anomalies in your heart rate that may require attention.
How We Use Health and Fitness Data
a. Personalized Insights:
We analyze your health and fitness data to provide you with tailored insights, suggestions, and motivational content. For example, based on your activity data, we might suggest ways to increase your daily steps or improve your workout efficiency.
b. Goal Setting and Progress Tracking:
We use your data to help you set realistic fitness and health goals. You can monitor your progress over time through detailed charts and reports that reflect your activity levels, sleep patterns, and heart rate trends.
c. Recommendations and Feedback:
We offer personalized recommendations based on your data, such as ideal activity levels, optimal sleep durations, and heart rate targets for different types of workouts.
d. Improved User Experience:
We utilize your health and fitness data to improve the functionality of our App, ensuring that it better aligns with your needs and preferences. This includes customizing the user interface and experience based on your interactions with the App.
e. Research and Development:
We may use aggregated and anonymized health and fitness data to improve our algorithms and develop new features. This data helps us understand trends and user behaviors without identifying individual users.
Data Security and Privacy
a. Secure Storage:
Your health and fitness data are stored securely using encryption and other industry-standard security measures to protect against unauthorized access and disclosure.
b. Data Sharing:
We do not share your health and fitness data with third parties without your explicit consent, except as required to provide the App’s services or comply with legal obligations. If you consent, your data may be shared with third-party services integrated into the App for additional features or analysis.
c. Data Retention:
We retain your health and fitness data only for as long as necessary to provide our services and comply with legal obligations. You can request the deletion of your data at any time through the App’s settings.
d. User Control:
You have control over your health and fitness data and can access, review, and manage your data preferences through the App. You can also export your data for personal use or delete it if you no longer wish to use our services.
Contact: support@welltra.in