PRIVACY POLICY
Effective: April 1, 2020

If you have any questions about our Privacy Policy, you can contact us at support@premaa.com using ‘Privacy Policy’ in the subject line.

 

 

 

 

 

1.              Privacy Policy Overview

 

 

Premaa, owns, operates, or provides access to, several interactive health, wellness, diet and fitness websites, mobile and connected applications, and other online interactive features and services, including, but not limited to, emails, newsletters, chat areas, forums, communities, sweepstakes and contests for consumers (collectively “Services”). This Privacy Policy applies to all information collected about you when you interact with the Services, regardless of how it is collected or stored, and describes, among other things, the types of information collected about you when you interact with the Services, how your information may be used, when your information may be disclosed, how you can control the use and disclosure of your information, and how your information is protected.

 

 

Except as otherwise noted in this Privacy Policy, Premaa is a data controller (as that term is used under the EU General Data Protection Regulation(“GDPR”)), which means that we decide how and why the information you provide to us is processed.  Contact details are provided in Section 17 below.  This Policy may be amended or updated from time to time to reflect changes in our practices with respect to the Processing of your information, or changes in applicable law. We encourage you to read this Policy carefully, and to regularly check this page to review any changes we might make.

 

This Privacy Policy covers information collected through the website Premaa and its related application, which are operated by Dr. Esha Chainani

 

 

 

2.              What Categories of Information We May Process

 

 

 

Personal Information” means information that is about any individual, or from which any individual is directly or indirectly identifiable.

 

Process”, “Processing” or “Processed”means anything that is done with any Personal Information, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

 

We may Process the following categories of Personal Information about you:

 

We also collect other kinds of information from you or other sources, which we refer to as “Other Information” in this Policy, which may include but is not limited to:

 

 

Under certain circumstances and depending on applicable law, some of this Other Information may constitute Personal Information. Personal Information together with Other Information is hereinafter referred to as “User Information”.

 

 

 

3.              Sensitive Personal Information

 

 

 

To the extent that information we collect is health data or another special category of personal data subject to GDPR, we ask for your explicit consent to process the data. We obtain this consent separately when you take actions leading to our obtaining the data, for example, when you sign up for a newsletter on our site or agree to allow us to track you.  You can withdraw your consent at any time by unsubscribing from our newsletters as set out in Section 6 or adjusting your preferences as set out in Section 15. 

 

Children. The Services are not intended for use by children, especially those under 13. No one under the age of 13 should provide any Personal Information or use our public discussion areas, forums or chats. Minors under the age of 18 are not permitted to make purchases through the Services or obtaining coupons or codes from the Services to purchase goods or services on third party websites. If, notwithstanding these prohibitions, your children disclose information about themselves in our public discussion areas, consequences may occur that are not intended for children (for example, they may receive unsolicited messages from other parties). If it is discovered that we have collected Personal Information from someone under 13, we will delete that information immediately.

 

 

 

4.              How We Collect or Create Information

 

 

 

Collection of User Information: We may collect User Information about you from the following sources:

 

Please note that Premaa is not responsible for the information you volunteer about yourself in the discussions in certain public areas of the Services, such as forums, blogs, wikis, chat rooms, private messages, message boards or other publicly accessible interaction, or information that you choose to make public in your member profile or other areas of the Services that allow users to upload or post content. We discourage users from posting such Personal Information in this fashion. You can change your publicly available information at any time via your profile page. To request removal of your Personal Information from these areas, please see Section 17 in this Privacy Policy for further details. In some cases, we may not be able to remove your Personal Information, in which case we will let you know we are unable to do so and why.

 

This Privacy Policy does not cover the practices of third parties, including those that may disclose information to Premaa.

 

Creation of User Information.  We may also create User Information about you, such as records of your interactions with us and details of your purchase history, for internal administrative purposes and analysis.  We may also use User Information you have provided to us with data obtained from third parties to enhance our records or enhance our ability to provide products and services, such as appending additional information to your profile.

 

 

 

5.              Purposes for Which We May Process Your Information

 

 

 

The purposes for which we may Process User Information, subject to applicable law, include:

 

 

 

6.              Direct Marketing

 

 

 

We may Process your User Information to contact you via email, telephone, direct mail, or other methods of communication to provide you with information regarding the Services that may be of interest to you. We may send information to you regarding the Services, upcoming promotions and other information that may be of interest to you, using the contact details that you have provided to us and always in compliance with applicable law.

 

You may unsubscribe from our newsletter lists at any time by following the unsubscribe instructions included in every email we send. We will not send you any emails from a list you have selected to be unsubscribed from, but we may continue to contact you to the extent necessary for the purposes of any other Services you have requested or for additional emails you have signed up for.

 

 

 

7.              Cookies, Similar Technologies and Online Behavioral Advertising

 

 

 

Premaa and its partners may use cookies and other tracking technologies to analyze trends, administer Services, track users’ movements around the Services and on third party sites, devices and applications, and to gather demographic information about our user base. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on the Services. To manage Flash cookies, please click here. Please see our Cookie Policy for more information, including a more in-depth explanation of what cookies are, the different types of cookies used on the Services, and how to change or delete them.

 

Tracking technologies on the Services may be deployed by Premaa and/or by our service providers or partners. Certain tracking technologies enable us to assign a unique identifier to you, and relate information about your use of the Services to other information about you, including your User Information. We may match information collected from you through different means or at different times and use such information along with offline and online information obtained from other sources (including from third parties), including, but not limited to, demographic information and updated contact information, for the purposes of learning more about you so we can provide you with relevant content and advertising.

 

When you receive email messages or newsletters from us, we may use web beacons, customized links, clear GIFs or similar technologies to determine whether the email has been opened and which links you click in order to provide you with more focused email communications or other information, and/or to aggregate that information with other data we collect to use for some or all of the purposes outlined in this Privacy Policy.

 

We and our partners (including but not limited to e-commerce partners, affiliates, and analytics providers) also may use technologies such as pixel tags, e-tags, IP addresses, Local Shared Objects, Local Storage, Flash cookies and HTML5 to analyze trends; administer the Services; collect and store information such as user settings, anonymous browser identifiers and video viewing history; supplement our server logs and other methods of traffic and response measurement; track users’ location and movements around the Services; gather demographic information about our user base; and to improve our understanding of traffic on the Services, visitor behavior, and responses to promotional campaigns. We may receive reports based on the use of these technologies by these third party companies on an individual and aggregated basis. For example, we may connect information about your IP address to known corporate or User Information and use the associated information related to aggregate content preferences to assist in our efforts to market services to you or the originating corporation(s). Various browsers may offer their own management tools for removing Local Storage. To manage Flash Local Shared Objects please click here.

 

We may use mobile analytics software to collect data and to better understand the functionality of our mobile software, devices and applications on your phone and other devices. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We may link this information to User Information.

 

Premaa and/or certain third parties may collect information about you for online behavioral advertising (“OBA”) purposes in order for you to receive relevant interest-based advertising on the Services and on other websites, platforms and media channels. OBA is also referred to as interest-based advertising.

 

Premaa displays ads on both the Services and on the Channels. We may use Online Data as well as other User Information to send you OBA. For example, if you read an article about a particular subject on the Services, we may use cookies from a vendor to later serve you an advertisement for a particular product or service related to the viewed article. These third party vendors may connect information about pages you visit on the Services with information about pages you visit on other Channels and show you advertising based on this combined information. These advertisements may appear when you are visiting a different section of the Services or on another Channel. Likewise, third party vendors may serve you advertisements when you visit the Services based on your interaction with the Services and other Channels.

 

The specific providers we use for OBA are subject to change. For a list of some of the applicable providers, click here. For information about how to opt out of tracking methods for these entities and others, click here. For more details about OBA and opting out, see Section 15 below.

 

Online Data is aggregated with the Other Information and data we collect as described in this Privacy Policy and/or similar data collected by partners to create groups of users and certain general-interest categories or segments that we have inferred based on (a) demographic or interest data and GeoIP Data, (b) the pages you view and links you click when viewing an email or using the Services and those of our partners, and/or (c) the search terms you enter when using certain search services. We use this information to get a more accurate picture of audience interests in order to serve ads we believe are more relevant to your interests. We store page views, clicks and search terms used for ad personalization targeting separately from your Personal Information.

 

 

 

8.              What is the Lawful Basis for Processing Personal Information

 

 

 

In Processing your User Information in connection with the purposes set out in this Policy, we may rely on one or more of the following legal bases, depending on the circumstances:

 

 

 

9.              What Information We Disclose to Third Parties

 

 

 

We may disclose your User Information to other entities within the Company group, for legitimate business purposes (including operating the Services, and providing services to you), in accordance with applicable law. In addition, we may disclose your User Information to:

 

For some of our Services, we may make some information, such as the name of our users, their mailing address, phone number, email address—and in certain circumstances their employer’s name, company size and other industry data—available on a rental or other basis (e.g., sale) to third party providers of goods and services, for example, when such information is provided in connection with certain content available on our websites.  Depending on where you reside, when you register for certain Services, we may share the Personal Information you provide with certain advertisers and sponsors.

 

Some of the Services may include websites that Premaa operates on behalf of third parties (“Licensors”).  Where applicable, we may share some or all of your Personal Information with the Licensor; however this privacy policy does not cover the user of your Personal Information by a Licensor.  The privacy practices of Premaa's Licensors may differ from this policy and we encourage you to contact those third parties directly if you have questions regarding their use of your Personal Information.  When you use a co-branded service (a service operated with a partner of Premaa), or register or otherwise provide information on a co-branded site, where applicable, we may pass the collected information back to that partner, which may include third party service providers whose services are embedded into and/or appear within the Services. 

 

With respect to surveys and quizzes, in the event that responses are publicly disclosed, users will be notified at the time they take the survey or quiz. Otherwise we will disclose only aggregate information regarding its users’ responses in surveys or quizzes to other participants in the survey. Where surveys or quizzes allow users to submit written comments, and where Premaa advises users of the possibility of such disclosure at the time they take the survey or quiz, Premaa reserves the right to disclose any information provided by users, provided that no User Information identifying a specific user is disclosed.

 

Premaa and some of our advertisers may use third party advertising service companies to serve advertisements, for OBA or otherwise, and perform related services when you interact with the Services. Often, these third party advertising companies employ cookies and other technologies to measure the effectiveness of website, app and email advertisements and to create a record of interaction with our content that they use in conjunction with their advertising which appears on other sites or applications, or for reporting website traffic, app use, statistics, advertisement data and/or other activities on the Services. We also engage third party providers to assist with the segmentation of this data.

 

We may also sell or transfer Online Data to certain third parties such as advertisers who will use this data to serve ads that they believe are relevant to your interests, and who agree to maintain the confidentiality of this information. Some of these third parties may combine the Online Data with their own data about you to form a more detailed picture.

 

We may engage third party providers to assist with the collection, storage and segmentation of Online Data and the providers are required to maintain the confidentiality of this information. These third party providers may collect User Information from our Services for their own purposes, such as to monitor fraud around the web.

 

We may also engage third parties for the purpose of recognizing our users and delivering interest-based content and advertisements to them. We may share your User Information with our partners such as your name, postal address, email, or other identifier. Our partners may also: (i) collect information directly from your device, such as your IP address, device ID, advertising ID, and information about your browser or operating system; (ii) combine User Information about you received from Premaa with information about you from other sites or services; and (iii) place or recognize a unique cookie on your browser.

 

If we engage a third-party Processor to Process your User Information, the Processor will be subject to binding contractual obligations to: (i) only Process the User Information in accordance with our prior written instructions; and (ii) use measures to protect the confidentiality and security of the User Information; together with any additional requirements under applicable law.

 

The Services contain links to other sites or partners whose information practices may be different from ours. You should consult the privacy policy of these third parties to learn how your privacy is protected.

 

 

 

10.           International Transfers of Information

 

 

 

Because of the international nature of our business, we may need to transfer your User Information within the Premaa group of companies, and to third parties as noted in Section 9 above, in connection with the purposes set out in this Policy. For this reason, we may transfer your User Information to other countries that may have different laws and data protection compliance requirements to those that apply in the country in which you are located.

 

Where we transfer your Personal Information from the EEA to recipients located outside the EEA who are not in a jurisdiction that has been formally designated by the European Commission as providing an adequate level of protection for Personal Information, we do so on the basis of standard contractual clauses.  You may request a copy of the relevant standard contractual clauses using the contact details provided in Section 17 below.

 

Please note that when you transfer any Personal Information directly to a Company entity established outside the EEA, we are not responsible for that transfer of your Personal Information. We will nevertheless Process your Personal Information, from the point at which we receive the data, in accordance with the provisions of this Privacy Policy.

 

 

 

11.           Data Security

                                                        

 

 

We have implemented appropriate technical and organizational security measures designed to protect your User Information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, unauthorized access, and other unlawful or unauthorized forms of Processing, in accordance with applicable law. In certain instances we may use Secure Sockets Layer encryption and/or transfer certain User Information in a non-human readable format to provide protection. However, we cannot guarantee there will not be a breach, and we are not responsible for any breach of security or for the actions of any third parties.

 

Because the internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement reasonable measures to protect your information, we cannot guarantee the security of your data transmitted to us using the internet.Any such transmission is at your own risk and you are responsible for ensuring that any Personal Information that you send to us are sent securely.

 

 

 

12.           Data Accuracy

                                                        

 

 

We take every reasonable step to ensure that your User Information that we Process is accurate and, where necessary, kept up to date, and any of your User Information that we Process that you inform us is inaccurate (having regard to the purposes for which they are Processed) is erased or rectified.

 

 

 

13.           Data Minimization

                                                        

 

 

We take every reasonable step to ensure that your User Information that we Process is limited to the User Information reasonably necessary in connection with the purposes set out in this Policy or as required to provide you services or access to the Services.

 

 

 

14.           Data Retention

 

 

 

We take every reasonable step to ensure that your User Information is only Processed for the minimum period necessary for the purposes set out in this Policy.  The criteria for determining the duration for which we will keep your User Information are as follows: we will retain copies of your User Information in a form that permits identification only for as long as is necessary in connection with the purposes set out in this Policy, unless applicable law requires a longer retention period. Unless there is a specific legal requirement for us to keep the information, we plan to retain it for no longer than is necessary to fulfill a legitimate business need.

 

Except as may be set forth in this Privacy Policy, Online Data related to OBA is retained by Premaa for not more than 180 days after which it shall expire. However, the 180 day period may commence again if the same user subsequently visits or interacts with an ad, email, the Services or a Channel.

 

 

 

15.           What Can I Do to Control My Information?

 

You may directly take steps to change your preferences as follows:

 

Your Newsletter and Email Subscriptions. You can opt out or unsubscribe from a newsletter or other email list at any time by following the instructions at the end of the newsletters or emails you receive. Please allow five to ten business days for changes to take effect. On some Services, member service-related communications are an integral part of such Services to which you subscribe and you may continue to receive emails as part of that particular portion of the Services unless you cancel your account, even if you opt out of the newsletters or email list.  If you have provided more than one email address to us, you may continue to be contacted unless you request to unsubscribe each email address you have provided.

 

Push Notifications. We send you push notifications from time-to-time in order to update you about any events or promotions that we may be running. If you no longer wish to receive these types of communications, you may turn them off at the device level. To ensure you receive proper notifications, we will need to collect certain information about your device such as operating system and user identification information.

 

Location Based Services. You may opt-out of having your Precise Location Data collected by Premaa at any time by editing the appropriate setting on your mobile device (which is usually located in the Settings area of your device).

 

Cookies and Pixel Tags. You may stop or restrict cookies and pixel tags on your computer or purge cookies from your browser by adjusting your web browser preferences. However, if you “turn off,” purge, or disable cookies or pixel tags, although you may still use the Services, you may not be able to use all of the features, functions, or services available on the Services.

 

16.           Terms of Use

 

For more information concerning your use of the Premaa website and application, please consult the Terms of Use, which is incorporated by reference into this Privacy Policy.  We recommend that you review the Terms of Use regularly, in order to review any changes we might make from time to time. 

 

(c)        Disclosure or Sale of Personal Information

 

We may and may have disclosed or sold the categories of Personal Information listed in Section 9 (“What Information We Disclose to Third Parties”) for a business or commercial purpose. 

 

We may and may have disclosed Personal Information to the following categories of third parties for a business purpose:

 

We may have disclosed or sold Personal Information to the following categories of third parties for a business purpose or a commercial purpose:

 

The Services are not intended for use by minors. We do not sell personal information of minors under 16 years of age without affirmative authorization.

 

(d)        Right to Request Deletion of Personal Information

 

You have the right to request deletion of Personal Information collected or maintained by us.  To do so, please submit a request on support@premaa.in. On submitting a request by email, we may ask for additional information to verify your request.

 

(e)        Right to Opt-Out of the Sale of Personal Information

 

You have the right to opt-out of the sale of personal information by a business.  To do so, please submit a request on support@premaa.in submitting a request by email, we may ask for additional information to verify your request.

 

(f)        Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

 

You have the right not to receive discriminatory treatment by the business for the exercise of the privacy rights conferred by the California Consumer Privacy Act.

 

(g)        Authorized Agent

 

To make a request under the California Consumer Privacy Act on a consumer’s behalf, we require a signed authorization letter from the consumer to support@premaa.in

 

(h)        Contact for More Information

 

If you have any questions or concerns about our privacy policies and practices, you may contact us on support@premaa.in

 

 

(i)         Date Privacy Policy Last Updated

 

Our Privacy Policy was lasted updated as of the date indicated at the beginning of the policy.

 

 

 

19.           How this Privacy Policy May Change

 

We may change this Privacy Policy from time to time, and all changes will be effective at the time we post them. If we believe there is a significant change to this Privacy Policy or our data collection and use practices, we will indicate on our websites that our Privacy Policy has changed prior to the change becoming effective. The then-posted version of the Privacy Policy supersedes all prior versions. Your continued access to or use of any of the Services shall be deemed your acceptance of the Privacy Policy.

 

We urge you to come back to this web page and review this Privacy Policy regularly so that you remain aware of the terms and conditions that apply to you.