Privacy Policy

We, Aurus Inc. (“Company”, “we”, “our”, “us”) are the owners of the ‘Aatman’ application (the “Application”).

Overview & Consent Management

AATMAN obtains consent from Users before collecting, processing, or using Personal Information where required under applicable laws. By using the Application and providing Personal Information, Users consent to the collection, use, storage, disclosure, and processing of such information for the purposes described in this Privacy Policy.

Where health, wellness, fitness, or other sensitive personal information is processed, AATMAN will obtain explicit consent where required by applicable law.

Users may withdraw their consent at any time by contacting us at privacy@myaatman.com. or through available account settings. Withdrawal of consent shall not affect the lawfulness of processing carried out prior to such withdrawal.

Records of consent may be maintained for compliance, audit, and legal purposes in accordance with applicable laws and retention requirements.

PLEASE READ THIS PRIVACY POLICY CAREFULLY. BY CLICKING ON THE CONSENT CHECK BOX, AND BY PROVIDING US PERSONAL INFORMATION, YOU CONSENT TO OUR USE OF YOUR PERSONAL INFORMATION IN ACCORDANCE APPLICATION THE TERMS OF THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, YOU MAY WITHDRAW YOUR CONSENT OR ALTERNATIVELY CHOOSE NOT TO PROVIDE YOUR PERSONAL INFORMATION ON THE APPLICATION. SUCH AN INTIMATION TO WITHDRAW YOUR CONSENT CAN BE PROVIDED BY EMAIL ON privacy@myaatman.com.

IF YOU ARE ACCESSING THE APPLICATION ON BEHALF OF A THIRD PARTY, YOU REPRESENT THAT YOU HAVE THE AUTHORITY TO BIND SUCH THIRD-PARTY TO THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY AND, IN SUCH AN EVENT YOUR USE OF THE APPLICATION SHALL REFER TO USE BY SUCH THIRD PARTY. IF YOU DO NOT HAVE SUCH AN AUTHORITY (TO PROVIDE ANY PERSONAL INFORMATION OF A THIRD PARTY) OR DO NOT AGREE TO THE TERMS OF THIS PRIVACY POLICY, THEN YOU SHOULD REFRAIN FROM USING THE APPLICATION.

This Privacy Notice is an electronic contract that is compliant and construed in accordance with data protection laws of the applicable jurisdictions.

1. Definitions

  1. i. “User/s”, “you”, “your”, shall mean and include individuals who visit, access and/ or use the Application;
  2. ii. “Customer” shall mean an entity, organization, individual which has purchases, subscribes, uses, accesses the Application;
  3. iii. “Controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Information;
  4. iv. “Processor” means a natural or legal person, public authority, agency, or other body which processes Personal Information on behalf of/ on the instructions of the Controller;

2. Personal, Health and wellness information

For the purpose of this Privacy Policy, “Personal Information” means any information that relates to a natural person, which, either directly or indirectly, in combination with other information available, is capable of identifying such person means all information that can be used to personally identify a person, including but not limited to, as first and last name, physical address, email address, contact number.

As part of providing wellness and healthcare-related services, AATMAN may collect, process, and store health and wellness information.

Such information is processed solely for the purposes of providing wellness services, health assessments, activity tracking, analytics, personalized recommendations, reporting, and other services requested by Customers and Users.

Health and wellness information shall be protected through appropriate technical, administrative, and organizational safeguards designed to prevent unauthorized access, disclosure, alteration, or destruction.

Such information shall only be retained for as long as necessary to fulfill the purposes described in this Privacy Policy or as required by applicable law, contractual obligations, or Customer instructions.

Existing rights for customers:

Subject to applicable laws, Users may have the following rights regarding their Personal Information:

  • Right to access Personal Information held about them.
  • Right to request correction of inaccurate or incomplete Personal Information.
  • Right to request deletion of Personal Information.
  • Right to withdraw consent at any time where processing is based on consent.
  • Right to request portability of Personal Information where applicable.
  • Right to request information regarding how Personal Information is collected, used, disclosed, and processed.

When the Company receives Personal, Health & Wellness Information from its Customer, the Company acts as a Processor and shall process such Information as per the instructions received by the Controller. If you have any questions related to the handling of your Personal Information by the Company or to exercise your rights, requests may be submitted by contacting privacy@myaatman.com . We may require reasonable verification of identity before processing such requests.

For Personal Information collected on behalf of Customer please refer to Clause 6 of this Privacy Policy.

We may collect your Personal Information in the following ways:

  1. i. Personal Information collected from Users of the Application:

    When you use our Application, we may collect certain Personal Information from you, including your full name, contact number, email address, location, IP address, date of birth, body height and weight.

  2. ii. Personal Information collected when you contact us:

    We may collect your Personal Information from you when you contact us or write to us on our email address.

  3. iii. Integrations:

    We may receive your Personal Information when you integrate our Application with third party tools, applications, devices and platforms.

3. Protected Health Information (PHI)

For the purposes of this Privacy Policy, Protected Health Information ("PHI") means individually identifiable health information that is transmitted or maintained in any form or medium, including electronic media ("ePHI").

Where applicable, we may collect, access, use, store, process, and disclose PHI/ePHI solely for the purpose of providing healthcare-related services through the AATMAN platform and in accordance with the instructions of our customers, applicable agreements, and applicable laws

PHI/ePHI is protected using appropriate administrative, technical, and physical safeguards, including encryption of PHI/ePHI at rest and in transit, access controls, authentication mechanisms, audit logging, and other industry-standard security measures designed to protect the confidentiality, integrity, and availability of such information.

We process PHI/ePHI in compliance with applicable healthcare privacy and security requirements, including the Health Insurance Portability and Accountability Act (HIPAA), where applicable. We also comply with other applicable data protection and privacy laws based on the user's jurisdiction, including the General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), and the Digital Personal Data Protection Act, 2023 (DPDPA), as applicable.

Where we process PHI/ePHI on behalf of a Customer, such processing shall be governed by the applicable Business Associate Agreement, Data Processing Agreement (DPA), or other contractual arrangements executed with the Customer.

4. Cookies

Cookies are alphanumeric files which are placed on to your device when you visit the web-based admin interface of the Application.

Types of Cookies Used

  1. i. Permanent cookies : Permanent cookies help us recognize you as an existing user, so it’s easier for you to return to the Application without signing in again. After signing in, the permanent cookies stay on your browser and will be read when you return to our sites. These remain on your computer/device for a pre-defined period.
  2. ii. Session cookies : Session cookies only last for as long as the session exists (they get erased when the user closes the browser).
  3. As for the domain to which it belongs, there are either:
    1. a. First-party cookies: These cookies are set by the web server of the visited page and share the same domain.
    2. b. Third- party cookies: These cookies are placed by third party on your device and may provide information to us and third parties about your usage of the Application.

Use of Cookies

We use Personal Information captured through cookies to make your interaction with us faster and more secure. They may be used for the following purposes:

  1. i. Preferences: Cookies allow the Application to remember information that changes the way the site behaves or looks, such as your preferred language or the region you are in. Remembering your preferences enables us to personalize and display advertisements and other content for you.
  2. ii. Security/Optimization: Cookies allow us to maintain security by authenticating users, preventing fraudulent use of login credentials and protect user data from unauthorized parties. We may use certain types of cookies allow us to block many types of attacks, such as attempts to steal content from the forms present on the Application.
  3. iii. Communication: We may use information collected via cookies to communicate with you, for sending newsletters, seeking your opinion and feedback and providing you services and promotional materials.
  4. iv. Analytics and Research: We may use cookies to better understand how people use our Offerings so that we can improve them.

Disabling Cookies

You can decide whether to accept or not to accept cookies. You can disable the cookies by adjusting the settings on your browser (please check your browser’s ‘Help’ option). Disabling cookies may affect the functionality of our Application.

5. Accuracy of Information

User undertakes that they shall be solely responsible for the accuracy, correctness, or truthfulness of the Personal Information shared with us whether of its own or any third party. In the event the User is sharing any Personal Information on behalf of a third person, the User represents and warrants that they have the necessary authority to share such Personal Information with the Company, obtained a written consent from such third party and the Company shall not be responsible for verifying the same. The User understands and acknowledges that such Personal Information shall be subject to the terms and conditions of this Privacy Policy.

6. Processing of Personal Information by us on behalf of the Customers:

This section concerns the Personal Information of the User collected by the Customer through the Application, and such collection may be facilitated by us:

  1. i. The Company as a Processor: The Customer sets the purpose and means of processing of such Personal Information. We process such Personal Information only on behalf of and on the instructions of the Customer and for the purposes of rendering services to the Customer.
  2. ii. Customer Privacy Policy: If you are the User of the Application and your Personal Information was shared with us by the Customer, the privacy policy of the Customer, on whose behalf we collect and process the Personal Information, will apply. This means that any enquiry, request, objection or complaint that you as a User may have in connection with the collection and/or processing of Personal Information that forms part of your Application usage should be addressed to and resolved by the Customer.
  3. iii. Personal Information: We may process Personal Information of the users of the Application, including but not limited to the name, email address, contact number, Protected Health Information, User’s Application account details, details of support tickets, height, weight, BMI, blood sugar, blood pressure, cholesterol, sleep duration, fluid intake, steps data, fitness activity information.

    The Customer has complete control over the Personal Information (including Protected Health Information) and the Company processes the Personal Information (including Protected Health Information) on the Customer’s behalf.

  4. iv. Customer Responsibility: The Customer represents that it has acquired all necessary consents and/or relies on other appropriate legal basis for the processing of Personal Information of end-Users. Customer confirms that end-Users have been informed about that their Personal Information is transferred to the Company as a processor and other third parties used by the Company for the provision of Services.

    We will process the Personal Information for as long as we provide services to the Customer and the Customer maintains active accounts of such Users.

  5. v. Return and deletion of data:

    Unless otherwise required by applicable law, we have no obligation to store the Customer’s Personal Information after termination of the engagement with the Customer and deletion of the Customer’s account and all accounts associated with it.

    Either at the choice/ instructions of the Customer or on expiry/ termination of our services, we will delete all the Personal Information including all copies, unless applicable law requires us to store such Personal Information.

7. Use of Personal Information

We use the Personal Information for the following purposes:

  1. i. to inform you about our Offerings and to respond to your requests;
  2. ii. for creation or development of business intelligence or data analytics in relation to the Offerings provided by us (for this purpose we may share the Personal Information with certain software or tools available online)
  3. iii. to provide you with a better experience when you access our Application and to improve the Offerings;
  4. iv. to maintain and manage our Application;
  5. v. to manage our relationship with you;
  6. vi. with your consent, may be published on the leaderboard in the Application;
  7. vii. for internal record keeping; and
  8. viii. to comply with our legal or statutory obligations.

8. Disclosures

We do not sell, rent, share, distribute, lease or otherwise provide your Personal Information to third parties, without your prior consent. Keeping this in mind, we may disclose your Personal Information in the following cases:

  1. Affiliates : We may provide your Personal Information to our affiliates to enable them to improve the Offerings, provide feedback and respond to their queries.
  2. Service Providers: We may share your Personal Information with the service providers who work with us in connection with operating the Application and/ or providing the Offerings. All such service providers are subject to stringent confidentiality restrictions consistent with this Privacy Policy.
  3. Merger or Acquisition: We may transfer your Personal Information if we are acquired by another entity, or if we merge with another company or transfer a part of our business, including the Application, to a third party. Any such third party or resultant entity that receives your Personal Information shall have the right to continue to use your Personal Information in line with the purposes set out herein. In the event of such a sale or transfer, we may notify you.
  4. Legal and Regulatory Authorities: We may disclose your Personal Information in order to comply with our legal obligations/ court orders/ requests by Govt. authorities.

9. Data Retention

We will retain User’s Personal Information as long as it is required to be retained for the purpose of provision of the Offerings. We may also retain and use User’s Personal Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

10. Security

Your Personal Information is stored on data centers controlled by us in an encrypted format. Although we provide appropriate firewalls and protections, we cannot guarantee the security of Personal Information transmitted as these systems are not hack proof. Data pilferage due to unauthorized hacking, virus attacks, technical issues is possible, and we will take necessary measures to mitigate such events.

11. Your Rights

You have the right to access Personal Information in our possession, right to have us rectify or modify any such Personal Information, right to have us erase/delete your Personal Information, right to restrict us from processing such Personal Information, right to object to our use of Personal Information, withdraw consent at any time where we are relying on consent to process Personal Information. Depending on the nature of the request, we may ask you to complete a Personal Information request form or seek certain details to verify the request. All requests for Personal Information will be handled within a reasonable period of time. If you would like to exercise ANY of these rights, please contact privacy@myaatman.com.

12. Choice and Opt-Out

We may send you communications including but not limited to (a) notices about your use of our Application and Offerings, including those concerning violations of use, (b) updates, (c) promotional information regarding our Offerings, and (d) newsletters. You may opt out of receiving promotional emails and newsletters from us by following the unsubscribe instructions provided in those emails. Alternatively, you can opt out, at any time, by emailing unsubscribe@myaatman.com with your specific request.

13. Links to other Websites

Our Application may contain links to other websites/ platforms of interest. Please note that we do not have any control over such other websites/ platforms, and you will be accessing such websites, platforms, and applications at your own risk. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such websites and platforms and those are not governed by this Privacy Policy. You should exercise caution and look at the privacy policy applicable to such websites/ platforms.

14. Governing Law and Jurisdiction

These Terms shall be governed by and construed in accordance with the applicable laws of the jurisdiction in which the User resides or accesses the Services, unless otherwise required by applicable law. Any disputes arising out of or in connection with these Terms shall be subject to the exclusive jurisdiction of the competent courts and authorities in such jurisdiction.

15. Changes to this Policy

Please revisit this page periodically to stay aware of any changes to this Privacy Policy, which we may update from time to time. If we modify this Privacy Policy, we will make it available through the Application and indicate the date of the latest revision. If such modifications materially alter your rights or obligations hereunder, we will make reasonable efforts to notify you of the change via email or through our Application.

16. Contact us

If you have any questions or concerns or grievances regarding this Privacy Policy or wish to withdraw your consent in relation to the processing of your Personal Information you can reach out to our appointed grievance redressal officer via email at privacy@myaatman.com.

Registered address:

Aurus, Inc.

932 Washington St, Norwood, MA 02062