Privacy Policy

At Roundglass LLC and Roundglass Wellbeing Private Limited (including all the associated/related/group companies) (Roundglass, “we”, “our” or “us”) we value Your trust, and we respect the importance of protecting the privacy of our Users, visitors, and partners. This privacy policy (“Privacy Policy”) applies to all the platforms offered by us and our affiliates through the various websites and mobile and other applications (“Platform”) owned and operated by Roundglass. We treat Your personal information that identifies You (“Personal Information”), or non-personal information, with respect and in accordance with this Privacy Policy. The usage of the term Personal Information in this Privacy Policy includes sensitive personal data or information, wherever appropriate and/or mandated under applicable law. This Privacy Policy does not cover the privacy practices of other companies and organizations who advertise on our Platforms, and who may use cookies, pixel tags, and other technologies to serve and offer relevant ads. Occasionally, at our discretion, we may include or offer third-party products or services on our Platform. Third-party product websites and/or applications shall have separate and independent privacy policies, terms of use, end-user license agreements, or similar disclosures, that may be available to You from such websites and/or applications, such as the Apple App Store or Google Play Store, or by contacting the third party for more information. We have no responsibility or liability for the content and activities of these linked websites and/or applications.

If You do not agree to the terms of this Privacy Policy in its entirety, You may not access or otherwise use the Roundglass website and/or applications, or any of the Services on the Platform.

1. Overview

This Privacy Policy covers our treatment of Information that we collect when You voluntarily access, use or register on the Platforms offered by Roundglass. Capitalized terms not defined in this Privacy Policy shall have the meaning outlined in the Roundglass Terms and Conditions (“Agreement”) applicable to You. This Privacy Policy is incorporated into and to be read with our Agreement.

We reserve the right to change or update this Privacy Policy at any time without (i) any prior notice; (ii) assigning any reason; or (iii) any liability whatsoever. It shall be Your responsibility to check this Privacy Policy for amendments from time to time. If we make a material change to this Privacy Policy, we may notify You by email if we have Your email address on record, or by posting a notice on the applicable Platform. Your continued use of the Platform following the posting of changes to this Privacy Policy will constitute Your consent and acceptance of those changes.

2. Information Collected by Us

2.1 We collect Personal Information in the following ways: (i) when You register to become a member on the Platform; and (ii) when You access the Platform and provide Information in connection with Your use of the Platform, or otherwise utilize certain aspects of the Platform as described below:

a. Your name, username, password, address, telephone and/or mobile number, email address, professional qualifications, and other basic health Information including but not limited to age, gender, height, weight, blood group, body mass index, etc. You share with us when You create an account on the Platform, sign-up to receive communications or materials from us, or otherwise submit a form to us.

b. Information that You submit when using the Platform, this Information includes, for example, the Information You provide while using any service available on the Platform, Information provided by You while participating in activities, which may include activity postings, survey responses, assessment responses, and any other data You generate, and Information You submit while using support services including third party partner support services.

c. Usage metrics and other device and technical data are collected when You use the Platform. This may include Information such as the number of times that You visit the Platform, the specific services accessed, as well as the frequency and duration along with device identifiers, device Information (such as OS type or browser type), cookie IDs, etc.

d. Location Information when You visit the Platform, either provided by a mobile device or associated with Your Internet Protocol (IP) address.

e. In case of companies, partnership firms, and proprietorship concerns, we may also collect relevant business details such as details pertaining to owners, promoters, shareholders, officers’ names, employees, and their contact details.

f. Parts of the Services may require you to make a payment, You will have to provide certain information so we can complete the payment. This information includes Your name, billing address, payment information, email address, and phone number. Any billing information that you provide is stored by our third-party payment processor and is subject to the payment processor’s privacy policy.

g. If you are a healthcare provider providing services through the Platform, You will need to provide your banking information.

2.2 We may also collect non-personally identifiable Information. We may use both Personal Information and non-personally identifiable Information to create aggregate Information.

3. How We Use the Information Collected From You

a. To enable You to use the Platform and making available such Information to our partners to enable them to improve the content available to You.

b. To contact You with relevant Information pertaining to the content on the Platform and for other promotional and marketing activities including conducting surveys on behalf of third parties. We will not share, trade, or sell Your Information to any third parties for use beyond providing the Services to You, except when You give us explicit permission and You may at any time opt-out of having Your Personal Information shared.

c. To improve our Platform and to personalize Your experience on the Platform.

d. To keep a record or monitor Your communications with us/our support team to help resolve any issues You might be facing and have complained about and, also for the purpose of monitoring quality, security, and training.

e. To inform You about our improved or additional services, such as letting You know about upcoming changes or improvements as well as to send You marketing communications, promotional offers, and deals that we think You may be interested in.

f. Communications You initiate through the Platform, such as a connect invitation sent to another user who is not a registered user, will list Your name, along with Your current office/business address and phone/fax numbers in the message and such other Information as may be required by the Platform from time to time. Registered users may communicate with one another using the Platform. These messages may only be initiated between two registered users.

g. If you are a healthcare provider providing services through the Platform, we may use Your banking information to facilitate payments for your services related to the Platform.

4. Storage of Information

Any Personal Information we obtain about You will be stored in accordance with jurisdiction specific applicable law, and standards. By using our Platform and checking the box to accept our Agreement and Privacy Policy, You consent to the collection, transfer, storage, and processing of Personal Information to, from, and in India or any other country where Roundglass or its affiliates, subsidiaries, or service providers maintain facilities. The registration process and act of checking the box will be construed as obtaining prior written consent from You through electronic communication.

5. Security Measures

5.1 The security of Your Personal Information is important to us. We follow generally accepted industry standards to protect Your information, both during transmission and once it is received. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security. While no security system is completely secure, we and our service providers take appropriate security measures to protect against unauthorized access or disclosure of the information collected by us. We review our security measures periodically and are committed fully to securing Your Information and protecting Your privacy.

5.2 The safety and security of Your Information also depends on You. Where we have given You (or where You have chosen) a password for accessing the Platform or certain functions therein, You are responsible for keeping this password confidential. We ask You not to share Your password with anyone.

6. Cookies

Cookies are small pieces of data stored by Your internet browser on Your hard drive after our web server sends them to Your web browser or mobile device. We, along with thousands of other websites, use cookies to enhance Your experience and to measure Your usage of the Platform. With the help of cookies, we may present You with customized offerings or content that may be of interest to You. We may also use cookies to recognize You on subsequent visits or to remember Your username, so You do not have to re-enter it each time You visit the Platform. You may be able to set Your browser to notify You when You receive a cookie or to prevent cookies from being sent. Please note, however, that, by not accepting cookies You may limit the functionality we can provide to You when You visit our Platform.

7. Information We May Disclose and To Whom We May Disclose Information

We may only disclose the Information we collect as mentioned below. The other organizations to whom we disclose Information are obligated to use such Information only for the purposes stated below. You give Your explicit consent towards the following disclosures:

a. Disclosures to Partners

We may disclose the Personal Information we collect to our partners so that they are better able to prepare the content which is made available by us from time to time for Your best user experience. In all cases, we will require our partners to whom we provide Personal Information to comply with our instructions and policies and to use the Information solely for the purposes for which we have retained them. Disclosure of Personal Information to these service providers is done to help us serve You better.

b. Disclosures to Other Affiliated Companies

We may disclose Personal Information, such as name, address, telephone number, and transaction or experience Information to our affiliates. We may disclose Personal Information to our affiliates for purposes such as and including but not limited to:

i. Fulfilling Your requests; and

ii. Offering You other products or services that we think may be of interest to You.

c. Other Disclosures Permitted by Law

We may make additional disclosures of Information as permitted or required by law. For example, we may disclose Information to law enforcement agencies or insurance regulators without seeking any further consent from You.

d. Third Parties

i. We do not sell, trade, or otherwise transfer to outside parties Your Personal Information. We may provide Your Personal Information to website hosting partners and other parties who assist us in operating our website, conducting our business, or serving our Users, so long as those parties agree to keep this Information confidential and adhere to our instructions and policies. We may, additionally, release Your Personal Information: (a) when we, in good faith, believe that it is necessary to protect our rights or property, (b) to any successor or purchaser in a merger, acquisition, liquidation, dissolution, or sale of assets, or internal restructuring, or (c) when we, in good faith, believe that access, use, preservation or disclosure of the Information is necessary to comply with any applicable law, legal process or enforceable governmental request, to enforce applicable Agreement, including investigation of potential violations, detect, prevent, or otherwise address fraud, security or technical issues or protect against harm to the rights, property or safety of our users or the public at large, as may be required or permitted by law. We also permit consultants and lawyers who may advise us in the course of litigation or arbitration concerning the Platform to have access to Your usage data and Personal Information, if required. Your consent will not be required for disclosure in these cases, but we will attempt to notify You, to do so. However, non-personally identifiable Information forming part of Your Personal Information may be provided to other parties for marketing, advertising, or other users without any prior intimation to You and/or Your express consent.

ii. In accordance with applicable Laws, we may share Your usage data, Personal Information, and/or non-personal information with third parties to (a) assist us and such concerned third parties in studying the user behavior and accordingly evaluating and improving the quality of the Services provided through the Platform; (b) determine Your preferences and/or the Platform to suit Your needs in a more targeted way, and (c) promote the Platform to third parties.

iii. For purposes of clarity, the usage data may be provided to anyone on an aggregate and anonymous basis for analytical purposes.

iv. We may permit our third-party agents, service providers, vendors, and sub-contractors (such as vendors and suppliers that provide us with technology, services, data analysis, research, advertising, and marketing assistance and/or content in connection with our operation and maintenance of the Platform) to access Your Personal Information, in connection with performing services for us and/or to operate the Platform. However, such third-party agents are not authorized to use that Personal Information for their benefit and are required to strictly adhere to our instructions and policies.

e. Third Parties for Users based in India

If you are a User of the Connect services, we may share Your usage data and Personal Information with Your healthcare provider to enable them to assess the efficacy of the Services offered on the Platform, if applicable. We, however, do not provide Your usage data or Personal Information to Your employer except where you give your explicit consent to share this information with Your employer based on the services you elect to receive.

8. Aggregate Data

We reserve the right to transfer and/or sell aggregate or group data about the Platform users (including usage data where the same is not linked to Personal Information) for lawful purposes. Aggregate or group data is data that describes the demographics, usage, or other characteristics of the Platform users as a group, without disclosing Personal Information. We may also share aggregate data with our partners– like publishers, advertisers, or connected applications. For example, we may share Information publicly to show trends about the general use of our services through the Platform.

9. Links to Other Websites

The Platform may contain links to other websites of interest. However, once You have used these links to leave our site, You should note that we do not have any control over the other website(s). Therefore, we cannot be responsible for the protection and privacy of any Information which You provide while visiting such other website(s) and such other website(s) are not governed by this Privacy Policy. You should exercise caution and look at the privacy policy applicable to the website in question.

10. Information Retention

We will retain Your Personal Information only as long as is necessary for the purposes to which You consent under this Privacy Policy and in compliance with applicable law, after which we will delete it from our systems.

11. Your Rights

11.1 We value the confidentiality of Your Personal Information and will take all commercially reasonable efforts to ensure that You can exercise Your rights given to You under General Data Privacy Regulation (GDPR) and other applicable data privacy laws. You have the following rights in Your Information:

a. Right to access: You have the right to request access to the Personal Information we store and process about You.

b. Right to correct: You have the right to rectify Your inaccurate Personal Information including completion of incomplete Personal Information.

c. Right to erasure: You have the right to erase Your Personal Information unless data retention for said category of data has been stipulated for a mandatory minimum period of time as per existing law.

d. Right to object: You have the right to object at any time to our processing of Personal Information. For example, if Users have requested to receive Information from us, e.g., Newsletters, but do not wish to receive further Information, data subjects can easily opt out of receiving further Information from us.

e. Right to withdraw consent: As a rule, if the processing of Your Personal Information is based on Your consent at any time by unsubscribing from an email or sending us an email. Please note that this does not affect the processing of Your Personal Information before the withdrawal of Your consent.

f. Right to data portability: You have the right to receive Your Personal Information collected and stored by us in a structured, commonly used, and readable format. You have the right to transmit this Personal Information to a third party without hindrance from us, if technically feasible

11.2 If You have registered with our Platform, You may access, modify, or delete Your Personal Information by logging into our Platform using Your username and password and visiting Your account profile page. You may also send us an email to the Privacy/Grievance Officer at privacy@roundglass.com to exercise Your above-mentioned rights. We may not accommodate a request to change Information if we believe the change would violate any law or legal requirement or cause the Information to be incorrect. If You withdraw a registration or cancel a subscription, we may retain Your Personal Information in our records and we may continue to use and disclose that data in a manner consistent with this Privacy Policy unless You request the deletion of the same. In any event we may disclose appropriate data to law enforcement agencies, if required to do so, without Your express consent.

12. Legal Basis For Processing Personal Information under GDPR

If You are a resident of the European Economic Area (“EEA”), our legal basis for collecting and using the Personal Information described above will depend on which Services are You use on the Platform. Our Legal Basis for collecting and processing Your Personal Information shall be as follows:

a. Consent: basis Your consent to process Your Personal Information

b. Contractual Obligation: You have entered into a contract with us, and we need to use Your Personal Information to provide You access to the Platform.

c. Legal Obligation: wherein we have to process Your data to comply with a legal obligation we are subjected to.

d. Vital Interests: where it is necessary to process Personal Information to protect the vital interests of a natural person.

e. Legitimate Interests: where it is necessary for the purposes our legitimate interests provided, they do not override Your rights in Your Personal Information.

13. “Opting Out” – Consumer Selections Regarding Information Sharing

We are committed to protecting Your Personal Information, and to using or sharing it in ways that will improve or expand upon the Services we provide to You. By accepting the terms of this Privacy Policy by checking the acceptance box on the Platform, You agree to the sharing of Personal Information as described above.

While browsing the Roundglass website, or our web or mobile applications and/or using the Services, You will not be provided with the opportunity to opt-out of the sharing of Personal Information until You register on the Platform.

The practices and policies contained in this Privacy Policy replace all previous notices or statements with respect to the same subject.

14. Children’s Data

If you are below Eighteen (18) years of age, You may not use or register on the Platform. We do not knowingly collect Personal Information from children under the age of Eighteen (18) on the Platform. We screen users who wish to provide Personal Information in order to prevent users under the age of Eighteen (18) from providing such information. However, a Parent or Guardian can provide such information if our Services are required by such children in the opinion of their parents or guardian. If we become aware that we have inadvertently received Personal Information from a user under the age of Eighteen (18) without the consent of the parent or guardian, we will delete such information from our records. If we change our practices in the future, we will obtain prior, verifiable parental consent before collecting any Personal Information from children under the age of Eighteen (18). 15. Contacting Us If there are any questions or complaints regarding this Privacy Policy and our practices in relation to handling of Your Personal Information, You may contact the designated Grievance/Privacy Officer at privacy@roundglass.com

Roundglass LLC
1756 114th Avenue SE
Bellevue, WA 98004
support@roundglass.com

Roundglass Wellbeing Private Limited
9th Floor, Plot no. IT C-9,
IT Park, Sector 67, Mohali,
Punjab-160062
support@roundglass.com