Information We Collect

We are committed to protecting your online privacy. We further recognize your need for appropriate protection and management of any Personal Information you share with us. We may collect the following information:

• Personal Information: When you register, we collect your email address, date of birth, and any other information you provide in your profile.
• User Content: We collect the content you create, including your chat messages and shared media.
• Automated Information: We automatically collect information about your device (IP address, device ID, browser type) and your usage of our Services (features you use, time spent).
• Cookies and Tracking Technologies: We use cookies and similar technologies to track activity on our Service. For more details, see the "Cookie Policy" section below.
• International Data Transfers: Your information may be transferred to and processed in countries other than your own. We will ensure appropriate safeguards are in place to protect your data in accordance with this policy.
• Health & Wellness Information: We collect body metrics (such as height, weight, age and gender) that you provide, food images and the nutrition data derived from them, and, where you grant permission, activity data such as steps taken and calories burned synced from Health Connect or a similar platform. Please see the "Health Data" section below for further details.

This privacy policy also applies to data we collect from users who are not registered as members of this Platform, including, but not limited to, browsing behavior, pages viewed etc.

We only collect and use such information collected from you that we consider necessary for achieving a seamless, efficient, and safe experience in using the Platform, customized to your needs including:

• To enable the provision of services opted for by you.
• To enable the viewing of content in your interest.
• To communicate the necessary account and service-related information from time to time.
• To allow you to receive quality customer care services and data collection.
• To comply with applicable laws, rules and regulations.
• Where any service requested by you involves a third party, such information as is reasonably necessary to carry out your service request may be shared with such third party.

We also use your contact information to send you offers based on your interests and prior activity and also to show the content preferred by you. We shall immediately delete all such information upon withdrawal of your consent for the same through the 'unsubscribe' button or through an email to be sent to compliance@digirm.com.

To the extent possible, we provide you with an option of not divulging any specific information that you wish for us not to collect, store, or use. You may also choose not to use a particular service or feature on the Platform and opt-out of any non-essential communications from the Platform.

Further, transacting over the internet has inherent risks which can only be avoided by you following security practices yourself, such as not revealing account/login-related information to any other person and informing our customer care team about any suspicious activity or where your account has/may have been compromised.

Health Data We Collect and How We Use It

As part of the Wellness features of the Platform, we may collect the following categories of health-related information ("Health Data"), in addition to the information listed above:

• Body Metrics: Height, weight, age, gender and other inputs you provide for BMI/BMR and goal calculations.
• Food & Nutrition Data: Images you capture for food scanning, and the calorie, macronutrient and micronutrient information derived from them.
• Activity Data: With your explicit, revocable permission, data such as steps taken and calories burned, synced from Health Connect (or a similar platform) while the Platform is in active use.
• Weight & Trend History: Your logged weight and progress over time.

We access Health Data only with your explicit, revocable permission, such as through the Health Connect permission prompt or during onboarding. Food images are processed using a third-party AI vision service to identify food items and estimate nutrition values; such images and the data derived from them are used solely to power the food-scanning and tracking features of the Platform and are not used to serve you advertisements.

Use of Health Data for Insurance-Linked Offers

With your separate, explicit consent, we (or our insurance partners, where applicable) may use your Health Data, including your fitness and activity trends, to assess your eligibility for wellness-linked insurance products and to offer you personalised pricing or coverage that reflects positive changes in your health and fitness over time – for example, a lower premium or enhanced coverage where your activity or nutrition metrics show sustained improvement, rather than a standard, one-size-fits-all product.

This use of your Health Data is entirely optional. Declining to share your Health Data for this purpose will not affect your access to, or the pricing of, any other Wealth or Wellness feature on the Platform. Where your Health Data is shared with an insurance partner for this purpose, it will be shared only with your consent and only to the extent necessary for that partner to evaluate or price the relevant product, and such sharing will additionally be governed by that partner's own privacy policy.

Our Use of Your Information

The information provided by you shall be used to provide and improve the service for you and all users:

• To provide you with services on your request.
• For maintaining an internal record.
• For enhancing the Services provided.
• For maintaining record under the legal and statutory provisions.

For more details about the nature of such communications, please refer to our Terms of Service.

We use your tracking information such as IP addresses and/or Device ID to help identify you and to gather broad demographic information, and make further services available to you.

We will not sell, license or trade your personal information. We will not share your personal information with others unless they are acting under our instructions or we are required to do so by law.

Information collected via our server logs includes users' IP addresses and the pages visited, which will be used to manage the web system and troubleshoot problems. We also use third-party analytics, tracking, optimization and targeting tools to understand how users engage with our Platform so that we can improve it and cater personalized content/ads according to their preferences.

How Information Is Collected

Before or at the time of collecting personal information, we will identify the purposes for which information is being collected. If the same is not identified to you, you have the right to request the Company to explain the purpose of the collection of said personal information, pending the fulfillment of which you shall not be mandated to disclose any information whatsoever.

We will collect and use your personal information solely to fulfill those purposes specified by us, within the scope of the consent of the individual concerned or as required by law. We will only retain personal information as long as necessary for the fulfillment of those purposes. We will collect personal information by lawful and fair means and with the knowledge and consent of the individual concerned.

Personal data should be relevant to the purposes for which it is to be used, and, to the extent necessary for those purposes, should be accurate, complete, and up-to-date.

External Links on the Platform

The Platform may include advertisements, hyperlinks to other platforms or resources. We have no control over any other platform or resources or contents available on these other platforms, which are provided by companies or persons other than us. You acknowledge and agree that we are not responsible for the availability of any such external sites or resources, and do not endorse any advertising, services or other materials on or available from such platforms or resources.

You acknowledge and agree that we are not liable for any loss or damage which may be incurred by you as a result of the availability of those external sites or resources, or as a result of any reliance placed by you on the completeness, accuracy or existence of any advertising, services or other materials on, or available from, such platforms. These external third-party platforms and resource providers may have their own privacy policies governing the collection, storage, retention and disclosure of your personal information that you may be subject to. We recommend that you enter their platform and review its privacy policy.

Cookies

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. By continuing to browse the site, you are agreeing to our use of cookies. Cookies contain information that is transferred to your computer's hard drive. You can set your browser to refuse all or some browser cookies, or to alert you when Platforms set or access cookies. If you disable or refuse cookies, please note that some parts of this Platform may become inaccessible or not function properly.

The types of cookies we use:

• Strictly Necessary Cookies: These are cookies that are required for the operation of our Platform. They include, for example, cookies that enable you to log into secure areas of our Platform, use a shopping cart or make use of e-billing services.
• Analytical/Performance Cookies: They allow us to recognize and count the number of visitors and to see how visitors move around our Platform when they are using it. This helps us to improve the way our Platform works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality Cookies: These are used to recognize you when you return to our Platform. This enables us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Targeting Cookies: These cookies record your visit to our Platform, the pages you have visited and the links you have followed. We will use this information to make our Platform and the advertising displayed on it more relevant to your interests. We may also share this information with third-parties for this purpose.

Please note that third-parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies. You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our Platform.

Compliances

The Company operates the Platform in accordance with applicable laws and regulatory frameworks, including but not limited to:

• The Information Technology Act, 2000.
• The Digital Personal Data Protection Act, 2023.
• The Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021.
• The Consumer Protection Act, 2019.
• All other applicable rules, regulations and guidelines issued thereunder.

The Platform is a digital wellness software service and is not classified as a medical device, diagnostic system, healthcare provider or clinical service under any applicable law. The Company does not provide medical diagnosis, treatment, prescription or emergency healthcare services.

Users agree to comply with all applicable laws, regulations and policies while accessing or using the Platform and acknowledge that any violation of applicable law may result in suspension or termination of access, without prejudice to the Company's other legal remedies.

Confidentiality

You further acknowledge that the Platform may contain information that is designated confidential by us and that you shall not disclose such information without our prior written consent. Your information is regarded as confidential and therefore will not be divulged to any third party, unless if legally required to do so to the appropriate authorities.

We will not sell, share, or rent your personal information to any third party or use your e-mail address for unsolicited mail. Any emails sent by us will only be in connection with the provision of agreed services, and you retain sole discretion to seek discontinuation of such communications at any point in time.

Other Information Collectors

Except as otherwise expressly included in this Privacy Policy, this document only addresses the use and disclosure of information we collect from you. To the extent that you disclose your information to other parties, whether they are on our Platform or other sites throughout the Internet, different rules may apply to their use or disclosure of the information you disclose to them.

To the extent that we use third party advertisers, they adhere to their own privacy policies. Since we do not control the privacy policies of third parties, you are subject to ask questions before you disclose your personal information to others.

Our Disclosure of Your Information

Due to the existing regulatory environment, we cannot ensure that all of your private communications and other personally identifiable information will never be disclosed in ways not otherwise described in this Privacy Policy. By way of example (without limiting the foregoing), we may be forced to disclose information to the government, law enforcement agencies or third parties. Therefore, although we use industry-standard practices to protect your privacy, we do not promise, and you should not expect, that your personally identifiable information or private communications would always remain private.

We do however assure you that any disclosure of your personally identifiable information shall be personally intimated to you through an email sent to your provided email address.

As a matter of policy, we do not sell or rent any personally identifiable information about you to any third party. However, the following describes some of the ways that your personally identifiable information may be disclosed:

• External Service Providers: There may be several services offered by external service providers that help you use our Platform. If you choose to use these optional services, and in the course of doing so, disclose information to the external service providers, and/or permit them to collect information about you, then their use of your information is governed by their privacy policy.
• Law and Order: We cooperate with law enforcement inquiries, as well as other third parties to enforce laws, such as intellectual property rights, fraud and other rights. We can (and you authorize us to) disclose any information about you to law enforcement and other government officials as we, in our sole discretion, believe necessary or appropriate, in connection with an investigation of fraud, intellectual property infringements, or other activity that is illegal or may expose us or you to legal liability.

Accessing, Reviewing & Changing Your Profile

You can review and change the information you submitted except Email ID. An option for facilitating such change shall be present on the Platform and such change shall be facilitated by the User. If you change any information, we may or may not keep track of your old information.

We will not retain in our files information you have requested to remove for certain circumstances, such as to resolve disputes, troubleshoot problems, and enforce our terms and conditions. Such prior information shall be completely removed from our databases, including stored 'back up' systems.

If you believe that any information we are holding on to you is incorrect or incomplete, or to remove your profile so that others cannot view it, the User needs to remediate and promptly correct any such incorrect information.

Security

We treat data as an asset that must be protected against loss and unauthorized access. We employ many different security techniques to protect such data from unauthorized access by members inside and outside the Firm. We follow generally accepted industry standards to protect the Personal Information submitted to us and information that we have accessed.

However, as effective as encryption technology is, no security system is impenetrable. Our Firm cannot guarantee the security of our database, nor can we guarantee that information you provide won't be intercepted while being transmitted to the Firm over the Internet.

Severability

Each paragraph of this Privacy Policy shall be and remain separate from and independent of and severable from all and any other paragraphs herein except where otherwise expressly indicated or indicated by the context of the agreement. The decision or declaration that one or more of the paragraphs are null and void shall not affect the remaining paragraphs of this Privacy Policy.

Amendment

Our Privacy Policy may change from time to time. The most current version of the policy will govern our use of your information and will always be on the Platform. Any amendments to this Policy shall be deemed as accepted by the User on their continued use of the Platform.

Consent Withdrawal, Data Download & Data Removal

To withdraw your consent, or to request the download or deletion of your data with us for any or all our services at any time, please email to compliance@digirm.com.

Your Rights

Unless subject to an exemption, and depending on your jurisdiction, you have the following rights concerning your data:

• The right to request a copy of your data which we hold about you.
• The right to request correction of any personal data if it is found to be inaccurate or out of date.
• The right to withdraw your consent to processing at any time.
• The right to object to the processing of personal data.
• The right to complain to a supervisory authority.
• The right to obtain information as to whether your personal data are transferred to a third country or an international organisation.

Where you hold an account with us, you are entitled to a copy of all personal data we hold concerning you, and may request that we restrict how we use your data in your account when you log in.

You can manage much of your information directly within the Platform. For any other request, please contact us at compliance@digirm.com.

Disclaimer

We do not store any account-related information or any credit/debit card details. We shall not be liable for any loss or damage sustained by Users as a result of any disclosure (inadvertent or otherwise) of any information concerning the User's account, credit cards or debit cards in the course of any online transactions or payments made for any products and/or services offered through the Platform.

In case any Personal Information is shared by you with us, which is not requested by us during registration (whether mandatorily or optionally), we will not be liable for any information security breach or disclosure in relation to such information.