Koott ("Koott") is the owner of [https://www.koott.in]. Koott is committed to your
privacy.
A. Objective:
This policy (hereinafter "Privacy Policy") discloses Kootts' practices for their website as well as
subscriber based services ("Services ") including the type of information being collected, method of such
information collection, use of such information and sharing of such information with third parties. This
document comprises Koott's Privacy Policy and is accessible to providers of such information, on
https://www.koott.in

 

B. Definitions:
Sensitive Personal Data or Information' or "SPDI" of a person means such Personal Information (defined
below) which consists of information relating to:
(a) password;
(6) financial information such as bank account or credit card or debit card or other payment instrument
details;
(c)physical, physiological and mental health condition;
(d) sexual orientation;
(e)medical records and history;
(f) biometric information;
(g) any detail relating to the above provided by an individual of provider of SPDI or Personal Information
to Koott for providing service; and
(h) any of the information received under (a) to (h) above by Koott for processing or storing of such
information under a lawful contract or otherwise.
The information mentioned in (a) to (h) above, does not include any information that is freely available
or accessible in public domain or furnished under the Right to Information Act, 2005 or any other law
for the time being in force.

"Personal information" shall mean and include information that relates to a natural person, which, either
directly or indirectly, in combination with other information available or likely to be available with
Koott, is capable of identifying such person.
Koott or any person, who on behalf of Koott collects, receives, possess, stores, deals or
handles information in the nature of SPDI or Personal Information, shall be governed by this Privacy
Policy.

 

C. Our Privacy Principles:
Our Privacy Policy is centered around informing you of your rights to the Personal Information which we
may collect from you during your visit to our website(s) or during the course of our doing business with
you.

D. Consent:
By using our website or services, you hereby consent to collection of your Personal Information by
Koott.
In case we need your SPDI in order to provide you services, we will require your consent before we are
able to collect and use the SPDI. Your clicking on the "I Accept" tick box provided on the website(s), will
confirm your acceptance of the terms contained in this Privacy Policy.
By accepting the terms contained in this Privacy Policy available at on https://www.koott.in, you
are representing that you are 18 (eighteen) years of age or above.
In case you are under the age of 18 (eighteen) years; please do not share any SPDI or Personal
Information with us, without having your parent or legal guardian to accept the terms of this Privacy
Policy on your behalf.

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By providing your information to us, you hereby consent to and acknowledge that collection, storage,
use, disclosure or transfer of the SPDI or Personal Information by Koott under the terms of this
Privacy Policy is for a lawful purpose and is necessary for providing services to you.
Please be aware that, if you do not allow us to collect required amount of information from you, we may
not be able to deliver certain services to you and furthermore even if we could, some of our web based
services may not be able to take account of your customizable preferences.

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E. What information do we collect and store on our computer systems:
We shall collect your SPDI or Personal Information if it is reasonable and necessary to do so, subject to
the guidelines of this Privacy Policy.
We may collect information in any of the following ways:
a. Information provided to us: For example, when you sign up or register on our website, and provide
any information about yourself like your name, e-mail address, house or office address and telephone
numbers in order to enquire about our products or services at [https://www.koott.in].
b. Information we get from your usage of our website or our web based services at
https://www.koott.in]: Such information may include passwords, device information, location
information and details of the computer system or computer network which you use to visit our
websites and undertake any activity therein.
C. Any other information which either individually or in combination with any other information is
capable of identifying you.
You may also need to provide Koott your SPDI or Personal Information during the course of using
some of our services, a few of which have been mentioned below, for instance:

i. Your details on our system for ease of identification and reference;
i. providing financial information while subscribing to our services;
ii. documents which relate to your health records;
iv. participating in our customer surveys and reviews;
v. communicating with us regarding our services or otherwise through telephonic communications, e-
mails or otherwise.
Our primary purpose for collection of information from you is for your ease of access and use of the
services available on our website and to keep you informed about other related services and
functionalities provided by Koott
Furthermore, we may use your SPDI or Personal Information for the purpose of following up with you
from time to time after your visit to our website.
We may also collect information from time to time for tracking user behavior and preferences for
internal analytics from all users of our services. We may combine your SPDI or Personal Information
along with the information collected from other users to provide you with a better experience as a user
of our services.

You understand and acknowledge that certain information may be collected each time you visit our
website, mobile application or access our services. Such information may be stored in server logs in
encrypted form. Such encrypted data might not be sufficient to identify you personally in most cases,
but the same shall be capable of providing us with information regarding your visit to our website or the
browsing activities of yours.
Such information may include:
i. IP address of your server from which you access our services or website;
ii. The type of browser which is being used; for example: Internet Explorer, Firefox, Opera, Google
Chrome etc.
ii. the operating system which you might be using;
iv. the duration of stay on our website along with the date and time of access of our website;
The above mentioned data may be used by Koott to understand the use, number and frequency of
users visiting our website. Some of the information may be shared with our developers, strategic
business partners of Koott and some of our associates for the purpose of enhancing our business
and our website. Such information is usually collected by us through the help of pixel tags and cookies,
which are industry standard technology used by major websites.

While you use our online services, Koott's servers (which are hosted by a third party service
provider) may collect information directly and automatically about the activities undertaken by you
therein; for instance by way of cookies and pixel tags.
(Note:
1. Cookies are small amounts of data that is sent to a user's browser from a web server and is eventually
stored on a user's computer hard drive. This anonymous information is maintained distinctly and is not
linked to the sensitive personal data or information you submit to Koott.
2. Pixel tags are typically single pixel, transparent GIF images that are added to a web page. Even
though the pixel tag is virtually invisible, it is still served just like any other image you may see online.
The web page is served from the site's do
ain while the image is served from the ad server's domain.
This allows the ad server to read and record the cookie with the unique ID and the extended information
it needs to record).
Whether you intend your web browser to accept cookies is entirely up to your preferences and settings.

(Note:
1. If you do not change your internet browser settings, your browser may already accept cookies by
default. However, if you decline cookies, you may not be able to experience all the features of our
website and online services offered by us.
2. You may choose to delete the cookies accumulated by your web browser or disable such cookies
entirely, but this may make parts of our website inaccessible for you thereby impacting the experience
you might want to have on our website. Therefore we would recommend you to keep such cookies
turned on).
Koott shall not trade or disclose the SPDI or Personal Information provided by you in any manner,
except as specified herein or if express consent has been sought from you for disclosure of such
information.

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F. Usage of the information collected:
Koott has complied with and implemented reasonable security practices and procedures, and has a
comprehensive documented information security programme and information security policy(ies) that
contain managerial, technical, operational and physical security control measures to protect your
Personal Information and SPDI.
i. Koott collects and uses necessary Personal Information or SPDl on lawful basis and for legitimate
business reasons for collection of information;
ii. Koott shall be transparent with providers of Personal Information or SPDI as to what information
is to be collected and how the same shall be processed. Koott shall not publish or share your
Personal Information without your express consent.
ii. Sessions may be used for training and quality purposes.
iv. Information received for a particular purpose shall not be used for any other activity without the
provider having been informed, and where required, only upon receiving provider's permission.
v. Koott shall be compliant with applicable jurisdictional records retention requirements and apply
information retention rationale which are reasonable in context;

vi. Koott shall ensure that information is securely disposed of after expiry of retention period.

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G. How such information may be shared:
We shall share your SPDI or Personal Information with people or entities outside of Koott only with
your consent.
Over and above the terms mentioned hereinabove, we might share SPDl or Personal Information with a
third party for the following reasons and under the following circumstances:
For providing your SPDI or Personal Information to our affiliates and or other trusted business associates
or technology partners (we employ other companies and individuals to perform certain specific
functions on our behalf) which is then processed at their end based on our instructions and in
compliance with this Privacy Policy and applicable laws. They have access to as much of your Personal
Information that may be needed to perform their functions, but shall not use it for any other purposes or
disclose it further.
Please note that we shall share your SPDI or Personal Information only with organizations and
individuals who ensure the same level of data protection that has been set out in this Privacy Policy and
as may be required by applicable Indian legislations.

You understand, agree and acknowledge that our collection, storage and processing of your SPDI or
Personal Information is for a lawful purpose connected with a function or activity of Koott and
affiliates.
In the rare event that we need to pass on your Personal Information or SPDI to law enforcement
authorities, we will keep you informed about the same as soon as reasonably possible.
We will under no circumstances either publish or share your SPDI or Personal Information without
obtaining your prior approval.

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H. Withdrawal of permission to collect sensitive personal data or information:
You may at any time withdraw your consent to collection, storage, use, disclosure and transfer of the
sensitive personal data by Koott, by addressing a written communication to such effect to the
contact address of the Koott grievance officer provided below.

I. Ensuring that personal information is accurate and up to date:
Koott shal:
i. update existing records whenever provider of such information intimates Koott of any change;
ii. periodically review and assess the information available on Koott's client database.
In case you intend to update your SPDI or Personal Information which we have on record with us, (e.g. if
you change your address), please provide the updated details at admin@koott.in for the purpose
of enabling us to make the required change. You may be requested to provide some verification before
the information is updated.
Please note that we shall not be responsible for the authenticity of any Personal Information or SPDI
provided to us by you.

(Note:
1. Safeguarding your information to help protect you from possibility of identity theft is top priority for
Koott. We shall not at any time, request your credit card information, your account ID, login
password, or national identification numbers in a non-secure or unsolicited e-mail or telephone
communication.
2. Do not:
i. Share information which is absolutely confidential to you, (Example: Social Security Number, Bank
Account Pin, or other confidential details which may not be required for business purposes unless
specifically requested for;
ii. Embed unwarranted links or attachments, obscene data, templates, documents, ideas, thoughts or
expressions unless specifically requested for;
ii. Share any disparaging or defaming comments).

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J. Keeping of personal information for as long as is necessary for the purposes for which such
information was collected:
Koott Wellness PVT LTD. - Full name of the venture, we may define early on and then use
Koott everywhere shall:
i. comply with applicable jurisdictional records retention requirements and apply information retention
rationale which are reasonable in context.
ii. ensure that information is securely disposed of at the end of the appropriate retention period.

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K. Observe rights afforded to individuals including:
i. Right to opt-out of receiving marketing communication from Koott;
ii. right to withdraw consent with regard to information or to opt-out with regard to information;
ii. right to have inaccurate information/discrepancies corrected, and information previously provided
amended;
iv. right of access to information that has already been provided;
v. right to have grievances addressed expeditiously.
Koott shall ensure that all queries relating to privacy are promptly and transparently dealt with in
accordance with applicable jurisdictional laws and regulations.

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L. Koott has appropriate measures in place to protect Personal Information or SPDI from
unauthorized access and disclosure, theft, damage, loss, alteration, etc.
Koott shall: i. Train staff, and inform third party service providers on privacy obligations;
ii. deploy appropriate security measures to protect SPDI or Personal Information whether onsite or off-
site; (The level of security will depend on the nature of the data and the potential harm that could be
caused by accidental/ unauthorized loss or disclosure of the information);
ii. comply with applicable jurisdictional confidentiality and security policies and guidelines;
iv. ensure that a secure method of transit is employed whenever SPDI or Personal Information is
transferred between different Iocations.
V.ensure that where processes are outsourced, the third party service provider has appropriate security
measures in place and is contractually bound to maintain relevant privacy obligations.
vi. review the information collection procedures, storage and processing practices, including physical
security measures, to guard such information from unauthorized access.
vii. restrict access of SPDI or Personal Information to the employees of Koott, third party service
providers who need to know such information and are subject to strict contractual confidentiality
obligations and may be disciplined or terminated if they fail to meet these obligations.

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M. Suitable safeguards to be put in place when personal information is transferred from India to other
countries and vice versa:
Any Personal Information for which Koott is responsible for will be adequately protected in the
country of destination in consonance with protection of data available under the Data Protection Rules.
Your information may be transferred to or be maintained on computers, computer systems and
computer resources located outside of your state or country where the privacy laws may not be as
protective as those where you live. If you are located outside India and choose to provide information to
us, please be aware that Koott keeps or transfers information to India and processes it here. Your
submission of such information represents your agreement to that transfer.
(Note:
Please note that the transmission of information over the Internet is not completely secure. Although
Koott strives to protect your SPDI or Personal Information, we cannot guarantee the security of
your data while it is being transmitted to our site; therefore any transmission is at your own risk. Once
we have received your information, we have commercially reasonable procedures and security features
in place to reasonably endeavor to prevent unauthorized access).

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N. Force Majeure:
Notwithstanding anything contained in this Privacy Policy or elsewhere, Koott shall not be held
responsible for any loss, damage or misuse of your sensitive personal data or information, if such loss,
damage or misuse is attributable to a Force Majeure Event (as defined below).
A "Force Majeure Event" shall mean any event that is beyond the reasonable control of Koott and
shall include, without limitation, sabotage, fire, flood, explosion, acts of God, civil commotion, strikes or
industrial action of any kind, riots, insurrection, war, acts of government, computer hacking
unauthorized access to computer data and storage device, computer crashes, breach of security and
encryption, etc.

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O. Grievance Officer
In accordance with the Information Technology Act, 2000 and rules made there under, the name and
contact details of the Grievance Officer who can be contacted with respect to any complaints or
concerns including those pertaining to breach of Koott's terms of use of services, other polices or
questions are provided as under:
Mr. Faisal Vysam Purath is the Grievance Officer of Koott for the purpose of this Privacy Policy. If you have
any questions or grievances, you may mark your correspondence to the email address of -
hello@koott.in Any communication relating to the above, which is not addressed to this e-mail
address, shall not be treated as a valid and binding communication for the purpose of this Privacy
Policy.
This document is an electronic record in terms of Information Technology Act, 2000 and rules made
there under. This electronic record is generated by a computer system and does not require any
physical or digital signatures.

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