Privacy policy

Last Updated: May 18, 2026

This Data Protection and Privacy Policy ("Policy"), as amended from time to time, describes the policies and practices relating to the collection, storage, usage, and sharing of data and information when Users avail our Services.

This Policy applies to all users of our devices, online and offline services, the PORTL website (https://portl.co/), and the PORTL App.

The PORTL devices and services to which this Policy applies include:

  1. Portl Studio
  2. Portl BioSense
  3. Portl Fitness
  4. Portl UltraGym
  5. Companion Apps
  6. the PORTL website

These are collectively referred to as the "PORTL Platform" or "Platform" and are made available by Rainvi Technologies Private Limited ("Company", "PORTL", "we", "us", "our").

The PORTL Platform, together with our telemedicine features, content and media features, the PORTL website, and the PORTL App, comprise our "Services".

The terms "User(s)", "Customer(s)", "you", and "your" refer to any individual or entity who may avail our Services.

We at PORTL take your online safety and privacy seriously. We understand that, particularly in the health, fitness, and wellness sector, the data you share is sensitive and should be protected. Through this Policy, we aim to help you make an informed decision. Please read this Policy in its entirety before using our Services.

All data provided to us by you remains protected and is collected in compliance with applicable laws of India.

1. Definitions

For the purposes of this Privacy Policy:

  1. "Account" means a unique account created for the User to access our Service or parts of our Service.
  2. "Affiliate" means an entity that controls, is controlled by, or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interests, or other securities entitled to vote for election of directors or other managing authority.
  3. "Cookies" are small files placed on your computer, mobile device, or other device by a website, containing details of your browsing history on that website among their many uses.
  4. "Country" refers to India.
  5. "Device" means the Portl Studio, Portl UltraGym, or any device that can access the Service, such as a computer, smartphone, or digital tablet.
  6. "Personal Data" means any information that relates to an identified or identifiable individual.
  7. "Service" refers to the PORTL website, PORTL App, and/or any of our PORTL devices, that is, the PORTL Platform.
  8. "Service Provider" means any natural or legal person who processes data on behalf of the Company, including third-party companies or individuals employed to facilitate the Service, provide the Service on our behalf, perform service-related functions, or assist in analyzing usage of the Service.
  9. "Usage Data" refers to data collected automatically, either generated by use of the Service or from the Service infrastructure itself, such as the duration of a page visit.
  10. "User" means the individual accessing or using the Service, or the company or other legal entity on whose behalf such individual is accessing or using the Service.
  11. "Website" refers to https://portl.co/.

2. Consent

Collection, use, and disclosure of information designated as Personal Information under the Digital Personal Data Protection Act, 2023 ("DPDP Act") requires express consent of the User.

By agreeing to use and avail our Services through the PORTL website, PORTL App, and/or any of our PORTL devices, it is deemed that you have:

  1. read and understood this Policy;
  2. agreed to the practices and policies outlined herein; and
  3. consented to the collection, storage, use, and sharing of your data in the manner described in this Policy.

We shall ensure confidentiality of such data, and grievances relating to such issues shall be handled by the grievance officer appointed by the Company under the DPDP Act ("Grievance Officer").

3. Overview

As part of our Services, the use of our devices, whether offline or online, and our web and app services requires certain Personal Data to be provided and accessed.

"Personal Data" is defined under the DPDP Act, 2023 as any data about an individual who is identifiable by or in relation to such data.

Such data is collected and used solely for the purpose of enabling our Users to access personalized digital health, fitness, and wellness services.

Metadata collected by us will only be used internally after anonymization and solely for research and development purposes to improve our Services.

Personal Data may include:

  1. general contact information;
  2. health information; and
  3. biometric information collected during your use of our Services.

Health and biometric data may be shared, on an opt-out basis only, when a User avails our telemedicine features.

To provide highly tailored digital health, fitness, and wellness programs, we collaborate with qualified and certified health professionals who are our strategic partners. When a User avails telemedicine or tele-consultation services with certified health professionals, including doctors and physiotherapists, such consultation inherently involves disclosure of the User’s health and biometric data. By choosing to use these telemedicine features, the User consents to such disclosure.

We also collaborate with media and content partners, such as Spotify and Gaana. In the future, we may collaborate with premier gym brands, trainers, and other content partners. Your use of such third-party platforms is not governed by this Policy, and we are not responsible for their privacy practices.

This Policy should be read together with our Terms and Conditions.

4. Information We Collect and How It Is Used

During your use of our Services, we may collect and process the following categories of information:

4.1 Basic User Profile Information

Information you provide when creating or updating your user profile may include:

  1. name
  2. email address
  3. phone number
  4. address
  5. gender
  6. age
  7. login details
  8. password
  9. banking information
4.2 Location, Bluetooth, and Internet Usage Data

Location tracking, Bluetooth usage, and internet permissions may be required in order to provide PORTL App services and access to the PORTL Platform through our devices.

These permissions may be used for:

  1. low-powered Bluetooth scanning;
  2. app error log collection;
  3. app version update detection;
  4. user data management; and
  5. enabling a smooth and seamless user experience.

Location, Bluetooth, and internet-related features may continue to run in the background even when the PORTL App is closed and not actively in use. Your permission preferences may affect or restrict your access to and experience of the PORTL App and Platform.

4.3 Facial Registration and Camera Access

When accessing the PORTL App and/or PORTL Platform, you may choose facial registration. If you do:

  1. your image may be captured and stored;
  2. such image will not be shared with third parties; and
  3. such feature is intended only to help provide a more personalized experience.

The PORTL App and Platform may require access to your camera. Camera permissions may be used for:

  1. setting a user avatar;
  2. uploading feedback pictures; and
  3. other profile-related personalization functions.

Your permission preferences may affect or restrict your access to and experience of the PORTL App and Platform.

4.4 Health and Biometric Data

Health and biometric data may be recorded and stored during your use of our body scanning devices, health monitors, and related services.

This data is used to generate personalized:

  1. health reports;
  2. fitness reports;
  3. wellness feedback; and
  4. recommendations.

This information may be shared with health professionals unless you opt out of telemedicine or tele-consultation features.

4.5 Third-Party Wearable Device Data

With your prior consent, the app may read and store data from third-party wearable devices to track:

  1. activity;
  2. sleep;
  3. heart rate; and
  4. associated readings.

This data is used to complement our personalization algorithms.

4.6 Health Questionnaire and Injury & Pain Checklist

You may be asked to complete a health questionnaire and an injury and pain checklist. Information shared through these tools may be used to formulate a personalized health, fitness, and wellness program, including tailored exercise routines.

Such data may also be shared with health practitioners unless you opt out of telemedicine and tele-consultation features.

4.7 Fitness Assessment Data

Our fitness assessment features may require your participation in basic body movement tests. Together with your feedback, this information helps us generate:

  1. fitness reports;
  2. workout recommendations; and
  3. recommendations regarding use of your existing workout equipment.
4.8 Sensitive Data

The information listed above, including data collected from your smartwatch such as:

  1. heart rate;
  2. daily physical activity levels, including steps;
  3. sleep data; and
  4. other fitness-related metrics

is treated as sensitive data and collected, stored, and handled in accordance with applicable law.

4.9 Purpose of Collection and Use

All information provided by you is collected and used to generate personalized health, fitness, and wellness outputs, including:

  1. fitness reports;
  2. health status summaries;
  3. feedback;
  4. recommendations; and
  5. custom-made workout programs.

At every stage where such information is submitted, we seek your active participation, and no information is collected without your knowledge or consent.

4.10 Additional Uses of Information

All information provided by you is voluntary. We may use your information:

  1. to provide our Services;
  2. for internal commercial purposes;
  3. in aggregated, anonymized, or non-personally identifiable form for research, statistical analysis, and business intelligence purposes;
  4. for communications relating to your use of our Services and to obtain feedback in relation to your health, fitness, and wellness goals;
  5. to debug customer support-related issues;
  6. to contact you to complete a transaction that you did not complete after providing contact information;
  7. to offer new products or services;
  8. to obtain product and service feedback;
  9. to analyze software usage patterns to improve product design and utility;
  10. to analyze anonymized practice information for internal use;
  11. to process payment instructions, including through independent third-party service providers such as payment gateways, banks, financial institutions, pre-paid instrument providers, and wallet providers;
  12. to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or sale or transfer of some or all of our assets, including transactions in which Personal Data held by us forms part of the transferred assets; and
  13. for other purposes such as data analysis, identifying usage trends, determining effectiveness of promotional campaigns, and improving our Service, products, services, marketing, and user experience.

5. Retention of Personal Data

We retain Personal Data only for as long as necessary for the purposes set out in this Privacy Policy and as permitted or required under the DPDP Act, 2023 and other applicable laws.

We may retain and use Personal Data to the extent necessary to:

  1. comply with legal obligations;
  2. resolve disputes; and
  3. enforce legal agreements and policies.

We also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period, except where:

  1. it is used to strengthen security;
  2. it is used to improve the functionality of our Service; or
  3. we are legally required to retain it for a longer period.

6. Deleting Your Personal Data

You have the right to delete, or request our assistance in deleting, the Personal Data we have collected about you.

Our Service may allow you to delete certain information directly from within the Service.

You may update, amend, or delete your information at any time by:

  1. signing into your Account and visiting the account settings section; or
  2. contacting us to request access to, correction of, or deletion of your personal information.

Please note that we may need to retain certain information where we have a legal obligation or lawful basis to do so.

7. Permissions

The permissions and usage preferences that you provide when accessing and using the PORTL App, PORTL Platform, and related devices may affect and restrict your access to our Services.

PORTL stores such permissions-related data as necessary to support service functionality, including saving and viewing auscultation data and enabling read and write access to storage, subject to the details set out in our Cookies Policy.

If you voluntarily provide any of the information listed in this Policy for the stated purposes, you consent to its collection and use in the manner described herein.

7.1 Specific Permissions
Location Permission:

The PORTL App may collect location data during app usage and in the background to enable:

  1. activity tracking;
  2. sleep history analysis; and
  3. operation of the Portl BioSense health tracker and related health monitoring.

This data helps us create data-driven personalization across workout recommendations and program creation.

Bluetooth Permission:

Bluetooth permissions may be required to enable connection with:

  1. Portl BioSense health trackers;
  2. other Bluetooth-enabled devices;
  3. audio output devices; and
  4. wearable devices.
Storage Permission:

The PORTL App may require access to internal storage on your mobile device in order to read and write data needed to support requested features and services.

Camera Permission:

The PORTL App may require access to the camera, images, and file uploads in order to:

  1. capture photos for profile images;
  2. set avatars;
  3. support sharing of progress;
  4. store medical records; and
  5. capture heart pulse rate.

8. Disclosure of Information

PORTL does not sell your information to third parties for any reason.

Except as described in this Policy, information submitted by you in the course of using our Services and Devices is not disclosed to other parties.

However, Personal Data may be disclosed or transferred in the following circumstances:

8.1 Business Transfers

If the Company is involved in a merger, acquisition, reorganization, or asset sale, your Personal Data may be transferred. We will provide advance notice to the email address attached to your Account before your Personal Data becomes subject to a different privacy policy.

8.2 Payment Processing

Disclosure to independent third-party payment gateways and payment processing partners shall be subject to the relevant terms governing those services.

8.3 Use of Tracking Technologies

We may use cookies, tracking pixels, web beacons, location tracking tools, Bluetooth access, internet access, and camera-related access features when our Services are used, subject to the permissions you grant and as further described in this Policy and our Cookies Policy.

8.4 Legal and Protective Disclosures

We may be required by law to share your information:

  1. if a government agency or law enforcement authority informs us that you are the subject of an investigation;
  2. if we are required to respond to court orders, legal process, or governmental directions;
  3. to detect and prevent actual or potential fraud, identity theft, or other illegal activities;
  4. in response to third-party claims of intellectual property infringement;
  5. to enforce our Terms and Conditions, policies, and agreements; or
  6. to protect the rights, property, or safety of our customers, employees, the Company, or any other person or entity.

Under such circumstances, we may disclose your information, including exchanging information with governmental agencies, companies, or organizations to facilitate fraud detection and reduction of credit risk.

8.5 Misuse of Services

This Policy may cease to apply to the extent necessary if PORTL discovers, or it is brought to our notice, that you have misused or abused our Services or used them to cause harm to another individual or entity, whether with or without their knowledge.

We recommend that you read the applicable user manual carefully and do not deviate from the usage instructions provided therein.

9. Security Practices

We are committed to protecting your personal information from unauthorized access and use.

As part of our security practices, we implement reasonable:

  1. procedural measures;
  2. organizational measures;
  3. administrative measures;
  4. technical measures, including encryption; and
  5. access controls

to protect data and personal information submitted by you, in accordance with applicable legal and industry standards.

Third-party service providers such as payment gateways may be PCI-compliant service providers. However, we are not responsible for their privacy policies or practices.

Please note:
  1. information transmitted over the internet is not completely secure;
  2. we cannot guarantee 100% security once data is transmitted via the internet; and
  3. we shall not be liable for any breach that occurs despite our taking reasonable measures.

The Company assumes no liability for disclosure of Personal Information due to transmission errors, unauthorized third-party access, or other causes beyond its control.

We take reasonable measures to protect your privacy in relation to the Services, but we shall not be liable for unauthorized or unlawful disclosures by third parties not under our control.

10. Our Roles and Responsibilities

We shall:

  1. collect and use your information only in accordance with this Privacy Policy;
  2. not collect information from outside sources other than information expressly sought through our website, app, devices, or Services;
  3. not share or disclose User contact information to third parties without the User’s consent, except as stated in this Policy or as required by law;
  4. take reasonable steps to ensure confidentiality of data;
  5. access, view, or use User information only to facilitate product or service delivery, improve our Services, resolve issues, investigate suspected violations of our Terms, or comply with law; and
  6. seek to ensure that financial transactions are facilitated through secure sites of approved, authorized, and digitally encrypted payment gateways.

Despite reasonable efforts, you understand and agree that internet technology is not infallible and we shall not be liable for a breach that occurs despite reasonable protective measures.

11. Your Duties and Obligations

You shall:

  1. ensure the accuracy of all information you provide to us;
  2. inform us of any subsequent change in User information already provided;
  3. maintain confidentiality of your account credentials and access details; and
  4. ensure that each User exclusively uses their own account.

12. How You Can Protect Your Information

PORTL will never directly contact you by phone call, email, or text message to ask for or confirm your debit card, credit card, or bank account information.

You should not send or disclose your complete banking details or card information through unencrypted electronic means. If you receive any communication claiming to be from PORTL or Rainvi Technologies Pvt. Ltd. requesting such details, please ignore it.

We recommend that you:

  1. do not share your username, password, or account information with anyone;
  2. use strong passwords that do not contain easily recognizable personal details;
  3. change your password regularly; and
  4. avoid reusing the same password across multiple online accounts.

Please note that:

  1. we use cloud storage facilities of Amazon Web Services, and your data may be stored on servers located outside India;
  2. we are not responsible for the privacy and security measures adopted by Amazon Web Services; and
  3. we are not responsible for breaches caused by third parties or events beyond our reasonable control, including acts of government, hacking, unauthorized access, device glitches, poor internet, Wi-Fi, telephone, or mobile data service issues.

13. Policy Updates

We reserve the right to update, change, modify, add, or delete portions of this Privacy Policy at our sole discretion at any time.

Timely notifications of such updates will be made, and we recommend that Users review such notifications carefully.

If you use our Services on behalf of another person, such as your child, or on behalf of an organization or business, you represent that you are authorized to:

  1. accept this Privacy Policy on that individual’s or entity’s behalf; and
  2. consent on that individual’s or entity’s behalf to our collection, use, and disclosure of information as described in this Policy.

We may also disclose or transfer Users’ personal and other information to a third party as part of a reorganization, acquisition, or sale of company assets. Any such third party may continue to use that information in accordance with our Terms and Conditions and applicable law.

14. Opt-Out and Withdrawal of Consent

If you wish to:

a. opt out of receiving non-essential communications such as promotional and marketing-related information; or

b. withdraw your consent for the collection, usage, storage, or disclosure of your information in accordance with this Policy, please write to us at support@portl.co.

Please note:
  1. We may require time to process such requests;
  2. Requests shall be processed no earlier than 30 business days from the date of receipt; and
  3. If you withdraw consent, we may not be able to continue providing you with some or all of our devices and Services.

Following such withdrawal, we shall not use your data for further purposes unless required by law.

15. Grievance Officer

If you have any queries regarding this Policy, our Terms and Conditions, or related privacy matters, you may contact our Grievance Officer at:

PORTL Grievance Officer

Address: 8-2-293/82/A/1270, 2nd Floor, JSP Jubilee Crown, Jubilee Hills, Hyderabad, Telangana - 500033

Email: support@portl.co

16. Jurisdiction

If users choose to visit the website or app, their visit and any dispute over privacy is subject to this Policy and the website’s Terms of Use.

Any dispute arising out of this Policy shall be governed by the laws of India and be subject to the exclusive jurisdiction of the courts of Hyderabad Metro City, Telangana, India.

17. Cookies Policy: How and Why We Use Them

17.1 What Are Cookies and Local Storage?

Cookies are small text files placed on your browser or device by websites, apps, online media, and advertisements.

There are different types of cookies:

  1. First-party cookies: cookies served by the entity operating the domain you are visiting. Cookies served by PORTL while you are on the PORTL Platform are first-party cookies.
  2. Third-party cookies: cookies served by companies not operating the domain you are visiting. For example, Google may set a cookie on your browser while you visit the PORTL App or Platform.

Cookies may also differ by duration:

  1. Session cookies: last only while your browser is open and are deleted automatically when you close it.
  2. Persistent cookies: remain on your device after the browser is closed and may recognize your device when you return.

Pixel tags, also called beacons or pixels, are small blocks of code installed on or called by a webpage, app, or advertisement, and can collect information such as:

  1. device type;
  2. operating system;
  3. browser type and version;
  4. website visited;
  5. time of visit;
  6. referring website;
  7. IP address; and
  8. similar technical information.

They may also access the small text file, or cookie, that uniquely identifies the device.

Local storage is a technology that allows a website or app to store information locally on your device.

Software Development Kits (SDKs) function similarly to pixels and cookies in mobile app environments where traditional browser-based technologies may not work. An app developer may integrate SDK code from partners, allowing those partners to collect information about app usage, device information, and network information.

17.2 When and Why We Use These Technologies

This Cookies Policy should be read together with our Privacy Policy and Terms and Conditions.

We use cookies and other identification technologies, including location tracking, Bluetooth, and internet usage, when you access the PORTL website, PORTL App, and social media accounts for purposes including:

  1. authenticating Users;
  2. storing information about you, including on your device or browser cache;
  3. remembering user preferences and settings;
  4. determining the popularity of content;
  5. delivering and measuring the effectiveness of advertising campaigns;
  6. analyzing traffic and trends; and
  7. understanding user behavior and interests in relation to our Platform.

We may store temporary or permanent cookies on your device. You may erase or block cookies through your browser settings.

If you turn cookies off, you may be prevented from using certain features of the Platform.

In connection with advertising or service optimization, PORTL may permit authorized third parties to place or recognize a unique cookie on your browser or device.

We do not store personally identifiable information in cookies.

PORTL does not control third-party sites that may appear as search results or links when you access our Platform. Those third-party sites may place their own cookies or files on your device, collect data, or solicit personal information from you, and PORTL shall not be liable for those practices.

These third parties may also set cookies on our behalf when you visit the PORTL Platform so they can deliver the services they provide to us.

When you visit the PORTL Platform, you may therefore receive cookies from third-party websites or domains. More information about such cookies may be available on the relevant third party’s website.

We cannot provide an exhaustive list of all third-party analytics providers with whom we work, and PORTL is not responsible for the privacy practices of such third parties. We encourage you to read the privacy policies of all external sites thoroughly.

17.3 Types of Cookies We May Use

The following is a non-exhaustive list of cookies and similar technologies we may use:

Authentication Cookies

These cookies, including local storage and similar technologies, help us identify when you are logged in so we can provide the appropriate experience and features, such as account information, order history, and account settings.

Security and Site Integrity Cookies

These cookies support security features and help keep PORTL safe and secure. For example, they help us remember when you are logged into secure areas and help protect your account from unauthorized access.

Site Features and Services Cookies

These cookies provide functionality that helps us deliver our products and Services, such as pre-filling fields and enabling customized content, recommendations, and social plug-ins.

Analytics and Research Cookies

These cookies help us understand, improve, and research our products and Services, including how users interact with the PORTL website, PORTL App, and related devices and services.

Advertising Cookies

These technologies may be used to deliver relevant advertising, track campaign effectiveness, and understand how users interact with advertisements shown on our behalf.

17.4 How to Control Cookies

Most internet browsers automatically accept cookies by default. You can usually change browser settings to block cookies or alert you when cookies are being sent.

If you disable cookies that we use, this may affect your experience on the PORTL Platform. For example:

  1. you may not be able to access certain areas of the Platform;
  2. you may not receive personalized information; or
  3. you may be unable to log into certain services or accounts.

If you use multiple devices to access the PORTL Platform, you will need to adjust the browser settings on each device separately according to your preferences.

Browser settings for cookies are usually found in the "Options", "Preferences", or "Help" menu of your internet browser.

This Cookies Policy is to be read together with our Data Protection and Privacy Policy, PORTL Terms and Conditions, and all related policies, and together they constitute a binding agreement between you and PORTL.