This Data Protection and Privacy Policy (Policy) describes the policies and practices relating to collection, storage, usage and sharing of data and information when Users avail of our Services and applies to all users of our devices, online, offline, PORTL web (https://portl.co/) and PORTL App (application) services. PORTL Devices & Services to which this Policy applies include: 

 Portl Studio, Portl BioSense, Portl Fitness and Companion Apps and our website collectively known as the PORTL Platform (Platform) made available to you by Rainvi Technologies Private Limited (“Company”, “Portl”, “we”, “us”, “our”). The PORTL Platform along with our Telemedicine Features, Content and Media Features and the PORTL web and PORTL App services shall comprise of our Services. The terms “User(s)”, Customer(s)”, “you”, “your” refers to any individual or entity who may avail our Services. 

We at PORTL take your online safety and privacy very seriously and understand that particularly in the Health, Fitness and Wellness sector, the data you share is sensitive and needs to be protected by those to whom you have entrusted it. We understand and share the concern of our Users since ultimately we aim to build a community through our Platform and therefore, through this Policy wish to help you make an informed decision. We want you to please read this Policy in its entirety before proceeding further. All data that is provided to us by you, our Users remains protected and is collected in compliance with the applicable laws of India.

CONSENT

For our Users, by agreeing to use and avail of our Services (via our PORTL website, PORTL App and/ or any of our PORTL devices, i.e. PORTL Platform), it is hereby deemed that you have read, understood and agreed to the practices and policies outlined herein, and agree to be bound by this Policy. You understand and agree that when any of our Services are availed, the data provided shall be collected, stored, used and/or shared in the following manner pursuant to an efficacious, customised & holistic user experience.

BRIEF OVERVIEW 

As part of our Services, the use of our devices offline as well as online, web, App services, require certain personal data to be provided and accessed. Such data is collected and used by the Company solely for the purpose of enabling our Users to access personalised digital health, fitness and wellness services. Metadata collected will only be utilised internally after being anonymised and solely for Research & Development purposes in order improve our services. Personal Data includes general contact information pertaining to each User as well as Health and Biometric information as ascertained during your use of our Services. Such information may be shared on a User Opt- out basis only, when the User avails of our Telemedicine Features. In order to provide each of our Users a highly tailored digital health, fitness and wellness programme, we collaborate with qualified, certified Health Professionals who are our Strategic Partners.  When the User avails of our Telemedicine features and Tele-consultation services with certified Health Professionals which include doctors, physiotherapists as the case may be, it is hereby understood and agreed that such consultation inherently entails disclosure of the User’s Health and Biometric data and by opting to use such Telemedicine features, the User consents to such disclosure. In our endeavour to provide an engaging and personalised User experience we have also collaborated with Media and Content Partners such as Spotify, Gaana digital music platforms. In the future we may also collaborate with premier gym brands, trainers etc as Content Partners. Your usage of any of these or any other third- party platforms is not governed by this Policy and we are not responsible for the privacy practices and policies of such third- party platforms. Our PORTL Data Protection & Privacy Policy is to be read in conjunction with our Terms & Conditions (available here).

THE INFORMATION WE COLLECT AND HOW IT IS USED:

The data and information we will be collecting and processing during your usage of our Services include:

1. Information you provide when you create or update your Basic User Profile on our platform and may include your name, email, phone number, address, gender, age, login details, password, banking information. 
2. Location tracking and Bluetooth usage, permissions for which will be required and necessary in order to provide our PORTL App services and access to our PORTL Platform via our devices. These are required for various operations using low powered Bluetooth scanning and in order for us to provide smooth, seamless User Experience. Internet usage permissions are also required and primarily used for application error log collection, application version update detection, user data management, and are necessary permissions. Location tracking, Bluetooth and Internet usage and access features are low powered features that shall run in the background even when the PORTL App is closed and not in use. Your permission preferences may affect and/or restrict your access to and experience of our PORTL App and PORTL platform.
3. When you access the PORTL App and/ or PORTL Platform you also have the option of Facial Registration and should you choose to avail of such registration, such image will be captured and stored but will under no circumstances be shared or revealed to any third parties whatsoever. This Facial Registration is merely to help you avail a more personalized experience when you use our Services. Our PORTL App and PORTL Platform will require access to your camera and permissions for such usage and access shall be sought when creating your User Profile. The camera permission is used to set the user avatar and feedback pictures which are necessary permissions. Your permission preferences may affect and/or restrict your access to and experience of our PORTL App and PORTL platform.
4. Health and Biometric data will be recorded and stored during your use of our Body scanning devices, health monitors and services, and such data will be used to generate personalised health, fitness and wellness feedback reports for you. This information may be shared with Health Professionals unless you opt- out of availing of our Tele- medicine, Tele- consultation Features. 
5. This app will read and store data from third-party wearable devices worn by the user with their prior consent to keep track of activity, sleep, heart rate and associated readings to complement our personalization algorithms. 
6. A Health Questionnaire and Injury & Pain Checklist, formulated by us to better assess your Health and overall fitness needs, will require your participation and any information you share through this Questionnaire and Checklist will be used to formulate a thoroughly personalized Health, Fitness and Wellness programme for you including tailor- made exercise routines. Such data may also be shared with Health Practioners unless you opt- out of our Telemedicine and Tele- consultation Features.
7. Our Fitness Assessment features require your participation with basic body movement tests and along with your own feedback, these will further aid us in generating and providing you with accurate fitness reports and recommendations regarding use of your own/ existing workout equipment etc.
8. The data and information enumerated above as well as the fitness data collected from your Smartwatch such as heart rate, daily physical activity levels such as steps calculation, sleep data are all understood to be Sensitive Data and collected, stored and treated in accordance with the relevant and prevailing law. For more detailed understanding of how PORTL stores your data, please read our Cookies Policy.

Our Services are aimed at providing you with an enhanced, interactive, uniquely customized User experience that makes your Health, Fitness and Wellness journey more engaging and fruitful. All of the above information provided by you is collected and used to generate personalized health, fitness and overall wellness reports for you which include accurate fitness reports, health status, feedback, recommendations and custom-made workout programmes which ultimately help in providing you, our User with a holistic path to your health, fitness and wellness goals.  At every stage that you submit the above information, we require your active participation and at no point is any information or data collected from you without your consent or knowledge, so you are able to make informed choices every step of the way.

All the information provided to us by you, our Users is voluntary. You understand that we may use the aforementioned information of yours (a) for the purpose of providing you our Services, (b) for internal commercial purposes and in an aggregated, anonymised or non-personally identifiable form for research, statistical analysis and business intelligence purposes, (c) for communication purposes so as to provide you a better way of accessing our Services and for obtaining feedback in relation to your Health, Fitness and Wellness goals, (d) debugging customer support related issues (e) for the purpose of contacting you to complete any transaction if you do not complete a transaction after having provided us with your contact information in the course of completing such steps that are designed for completion of required payment transactions. PORTL also reserves the right to use information provided by or about you for the following purposes:

1. Contacting our Users for offering new products or services.
2. Contacting our Users for taking product and Service feedback.
3. Analyzing software usage patterns for improving product design and utility.
4. Analyzing anonymized practice information for internal use.
5.  Processing payment instructions including those through independent third party service providers such as payment gateways, banking and financial institutions, pre-paid instrument and wallet providers for processing of payment transaction or deferral of payment facilities.

The Permissions and usage preferences that you provide when you access and use our PORTL App, PORTL Platform and any of the related devices, will affect and may restrict your access to our Services. PORTL stores this data which is used to save and view auscultation data, and this read and write external storage is required to help us provide you with an enhanced User experience and are necessary permissions, the details of which are available in the Cookies Policy available here.

If you have voluntarily provided the above enumerated information to us for any of the purposes stated above, you hereby consent to such collection and use of such information by PORTL in the manner herein stated.

Specific Permissions:

1. Location Permission: The Portl App collects location data both during the app usage and in the background to enable activity tracking, sleep history analysis and Portl BioSense Health tracker operation and health monitoring. This data allows us to create well-informed and data-driven personalization across workout recommendations and programme creation for our users.
2. Bluetooth Permission: The Portl App requires Bluetooth permissions to enable the connection with our Portl BioSense Health Tracker and other Bluetooth enabled devices such as audio output devices and wearable devices.
3. Storage Permission: The Portl App will require access to internal storage of the mobile phones in order to read and write data to support the various features and services that are required by the user.
4. Camera Permission: The Portl App will require access to Camera permissions in order to capture photos for the profile image, set avatar and share progress features

DISCLOSURE

PORTL does not sell your information to any third- parties for any reason whatsoever. Apart from the terms relating to our Stategic Partners mentioned herein your information submitted in the course of your use of our Services and Devices is not disclosed to any other parties. Disclosure to independent third- party payment gateways and other payment processing partners is subject to the terms as specified herein. We use cookies, tracking pixels, web beacons or other location tracking technology tools including Bluetooth usage, Internet usage and access, Camera usage and access when our Services are being availed as per permissions given by you when accessing our PORTL App, PORTL Website and PORTL Platform.  Please read our Cookies Policy as well the general Terms & Conditions.

Please note that we may however, be required by law to share your information: (i) In the event we are informed by any government and/or law enforcement agencies that you are the subject of any legal or governmental investigation; or we are obligated under applicable laws and are required to respond to any governmental or court orders or any related investigative procedures; (ii) For detecting and preventing actual or potential fraud, identity theft or other illegal activities; (iii) In response to claims by third- parties of any violation of their Intellectual Property Rights; (iv) in compliance with applicable laws and under obligation, in order to enforce our Terms & Conditions or other Agreements, Policies as well as to protect the rights, property, safety of our other customers, our employees, the Company or any other persons or entities, in the event of any dispute or claim arising from or relating to your usage of our Services

Under such circumstances we may be compelled to disclose your information, including exchanging information with governmental agencies or other companies and organizations so as to facilitate detection of fraudulent practices and reduction of credit risk. This will entail that the practices and policies contained herein shall cease to apply.

This Policy shall also cease to apply in the event PORTL discovers or it is brought to our notice that you have or are misusing or abusing our Services or have utilized them in any manner to cause harm to any other individual or entity, with or without their knowledge. We recommend you read our User Manual thoroughly and carefully and do not deviate from the usage instructions contained therein.

SECURITY PRACTICES

We at PORTL take the protection and security of your privacy seriously and are committed to protecting your personal information from unauthorized use and access. As part of our security practices, we have adopted and applied measures that comply with applicable industry and legal standards. We implement reasonable procedural, organizational, administrative, technical including encryption measures to protect and limit access to the data and personal information submitted by you. Third- party service providers such as our payment gateway and other payment processing partners are compliant with the payment card industry standard (PCI compliant service providers) and we are not responsible for their privacy policies and practices. Please be aware, however, that information transmitted over the internet is not completely secure. We will do our best to protect your data though we cannot guarantee 100% security once the data is transmitted via the internet.

What you can do to protect your information:

PORTL will never directly contact you via phone calls/ emails/ texts to ask or confirm your Debit/ Credit Card information or bank account details. Do not send/ disclose/ provide your full banking details or debit and credit card information through any unencrypted electronic platforms. If you receive any calls, emails, texts claiming to be from Portl or Rainvi Technologies Pvt. Ltd., which ask for such aforementioned details, please ignore them.

We also recommend that you do not share your username and passwords or any of the account information associated with your usage of our Services with anyone. Please keep in mind that anyone with whom you choose to share aforementioned details shall automatically acquire access to your account with us and any information you have shared with us. You are responsible for keeping these details confidential.

It is also recommended that, when creating passwords, you do not use easily recognizable words including your names, nicknames, email address or other personal data that may be accessed easily. Also, regularly change your password and do not use the same password over multiple online accounts.

Further, it must be noted that we utilize cloud storage facilities of Amazon Web Services as provided by Amazon Web Services Inc., for the purpose of storing your data and they may store this data on their servers located outside India. We are not responsible for the privacy and security measures adopted by Amazon Web Services.

Please also note that we shall not be responsible for any breach of security or for any actions of any third parties or events that are beyond the reasonable control of the Company including but not limited to, acts of government, device and data hacking, unauthorised access to data and storage device, computer, mobile or any device glitches or crashes, breach of security and encryption, poor quality of Internet, wi-fi service or telephone, mobile data service of the User etc.

We reserve the right to update (change, modify, add or delete) portions of the terms of this privacy policy, at our sole discretion, at any time. Timely notifications will be made of all such updates and we recommend our Users review these update notifications.  In the event you use our services on behalf of someone else (such as your child) or an entity (such as any organisation or business), you represent that you are authorised by such individual or entity to (i) accept this privacy policy on such individual’s or entity’s behalf, and (ii) consent on behalf of such individual or entity to our collection, use and disclosure of such individual’s or entity’s information as described in this privacy policy. We may also disclose or transfer Users’ personal and other information provided by a User, to a third party as part of reorganization, acquisition or a sale of the assets of our company. Any third party to which we transfer or sell our assets will have the right to continue to use the personal and other information Users provided to us, in accordance with our Terms & Conditions.

If you wish to opt-out of receiving non-essential communications such as promotional and marketing-related information regarding the Services or withdraw your consent for the collection, usage, storage, disclosure of your information in accordance with the terms of this Policy, please write to us at  support@portl.co Kindly note that we will require time to process any such requests and your request shall be processed, not less than 30 business days from the date of receipt of such request. Please also note that in the event of such withdrawal of your consent we may not be able to offer you further access to any or all of our devices and services and we shall not use your data for any purpose unless required by law.

Grievance Officer

If you have any queries regarding the terms of this Policy or our Terms & Conditions or our Website Privacy Policy, you may write or email our Grievance Officer at the following address and email address respectively.

PORTL GRIEVANCE OFFICER

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

Email: support@portl.co

PORTL COOKIES POLICY– HOW & WHY WE USE THEM

WHAT ARE COOKIES AND LOCAL STORAGE?

Cookies are small text files that are placed on your browser or device by websites, apps, online media, and advertisements. There are different types of cookies. Cookies served by the entity that operates the domain you are visiting are called “first party cookies.” So, cookies served by PORTL while you are on the PORTL Platform are first party cookies. Cookies served by companies that are not operating the domain you are visiting are called “third party cookies.” For eg., we may allow Google to set a cookie on your browser while you visit the PORTL App and PORTL Platform, and that would be a third party cookie. Cookies may also endure for different periods of time. “Session Cookies” only last only as long as your browser is open. These are deleted automatically once you close your browser. Other cookies are “persistent cookies” meaning that they survive after your browser is closed. For example, they may recognize your device when you re-open your browser and browse the internet again.

“Pixel tags” (also called beacons or pixels) are small blocks of code installed on (or called by) a webpage, app, or advertisement which can retrieve certain information about your device and browser, including for example: device type, operating system, browser type and version, website visited, time of visit, referring website, IP address, and other similar information, including the small text file (the cookie) that uniquely identifies the device. Pixels provide the means by which third parties can set and read browser cookies from a domain that they do not themselves operate and collect information about visitors to that domain, typically with the permission of the domain owner.

Local storage is a technology that allows a website or application to store information locally on your device. “Software Development Kits” (also called SDKs) function like pixels and cookies, but operate in the mobile app context where pixels and cookies cannot always function. The primary App developer can install pieces of code (the SDK) from partners in the App, and thereby allow the partner to collect certain information about user interaction with the App and information about the User/ End User device and network information.

WHEN AND WHY DO WE USE THESE TECHNOLOGIES?

Our Cookies Policy is to be read in conjunction with our Data Protection and Privacy Policy and our Terms & Conditions. We encourage you to please read our policies in their entirety to thoroughly understand these terms.  We use cookies and other identification technologies including location tracking and bluetooth and internet usage when you are accessing our PORTL Website, PORTL App, Social Media accounts for various purposes, including: authenticating Users and End Users, store information about you (including on your device or in your browser cache) and your use of our PORTL Platform, remembering user preferences and settings, determining the popularity of content, delivering and measuring the effectiveness of advertising campaigns, analyzing site traffic and trends, and generally understanding the online behaviors and interests of people who interact with and/or access our Platform.

We may store temporary or permanent cookies on your computer. You can erase or choose to block these cookies from your computer. You can configure your computer’s browser to alert you when we attempt to send you a cookie with an option to accept or refuse the cookie. If you have turned cookies off, you may be prevented from using certain features of the Platform. In the course of displaying advertisements regarding its services or optimizing services to its Users/ End Users, PORTL may allow authorized third parties to place or recognize a unique cookie on the User’s browser/device. We do not store personally identifiable information in the cookies. It is to also be noted, PORTL does not exercise control over the sites displayed as search results or links when you access our Platform. These other third- party sites may place their own cookies or other files on your computer, mobile and other hand – held devices, collect data or solicit personal information from you, for which PORTL shall not be responsible or liable. 

These third parties may also set cookies on your device(s) on our behalf when you visit the PORTL Platform to allow them to deliver the services they are providing. When you visit the PORTL Platform you may receive cookies from third party websites or domains. More information about these cookies may be available on the relevant third party’s website. Please note that we cannot provide an exhaustive list of all third party analytics providers with whom we work or collaborate and PORTL is not responsible in any way whatsoever for these third- parties and your use or access of such third- party sites is not governed by PORTL policies. We encourage you to thoroughly read the privacy policies of all external sites.

SOME TYPES OF COOKIES WE MAY USE (non- exhaustive list)

Authentication Cookies – These cookies (including local storage and similar technologies) tell us when you’re logged in, so we can show you the appropriate experience and features such as your account information, order history and to edit your account settings.

Security & Site Integrity Cookies – We use these cookies to support or enable security features to help keep PORTL safe and secure. For example, they enable us to remember when you are logged into a secure area of the Services and help protect your account from being accessed by anyone other than you.

Site features and Services – These provide functionality that help us deliver products and Services. For example, cookies help you log in by pre-filling fields. We may also use cookies and similar technologies to help us provide you and others with social plug- ins and other customized content and experiences, such as making suggestions to you and others.

Analytics & Research – These are used to understand, improve, and research products and Services, including when you access the PORTL website, PORTL App and related devices, websites and apps from a computer or mobile device. For example, we may use cookies to understand how you are using site features, and segmenting audiences for feature testing. We and our partners may use these technologies and the information we receive to improve and understand how you use websites, apps, products, services and ads.

Advertising – Things like cookies and pixels are used to deliver relevant ads, track ad campaign performance and efficiency. For example, we and our ad partners may rely on information gleaned through these cookies to serve you ads that may be interesting to you on other websites. Similarly, our partners may use a cookie, attribution service or another similar technology to determine whether we’ve served an ad and how it performed or provide us with information about how you interact with them.

HOW CAN I CONTROL COOKIES?

Most internet browsers are initially set up to automatically accept cookies. You can change the settings to block cookies or to alert you when cookies are being sent to your device. There are a number of ways to manage cookies. Please refer to your browser instructions or help screen to learn more about how to adjust or modify your browser settings.

If you disable the cookies that we use, this may impact your experience while on the PORTL Platform, for example you may not be able to visit certain areas of the PORTL Platform or you may not receive personalised information when you visit the PORTL Platform or you may also be unable to login to services or programs, such as logging into forums or accounts.

If you use different devices to view and access the PORTL Platform (e.g. your computer, smartphone, tablet etc) you will need to ensure that each browser on each device is adjusted to suit your cookie preferences. The browser settings for changing your cookies settings are usually found in the ‘options’ or ‘preferences’ menu of your internet browser. You should use the ‘Help’ option in your internet browser for more details. This policy is to be read in conjunction with our Data Protection & Privacy Policy and the PORTL Terms & Conditions as well as all other related policies and together constitute a binding agreement between you and PORTL.