Privacy Policy

Effective as of May 28, 2019

We are committed to respecting your data policy and providing transparency about our data practices. This Privacy Policy (this "Privacy Policy") explains how GHRS Private Limited ("Company" or "we" or "us") collects, stores, uses, transfers and discloses Personal Data from users ("you") in connection with the Nice Day mobile application and related services.

We reserve the right to and may change this Privacy Policy from time to time. If we make any material changes, we will notify you by email (sent to the email address specified when you register), through the App, or by presenting you with a new version of Privacy Policy to accept, if we, for example, add new processing activities or collect some addition Personal Data form you.

Your continued use of the App after the effective date of an updated version of the Privacy Policy will indicate your acceptance of the Privacy Policy as modified. In some cases, you will have to explicitly accept changes to Privacy Policy to continue using the App. We encourage you to periodically review our website and the App for the latest information on our data privacy practices.

1. Personal data and information we collect from you

Personal data you provide us

When you sign up to use the App, we may collect Personal Data such as:

  1. Full Name
  2. Email Address
  3. Password
  4. Phone Number
  5. Location

When you use the App, you may choose to provide personal information about you such as:

  1. Age
  2. Gender
  3. Other information about your health and activities (collectively, "Personal data")

Information we collect automatically

When you access or use the App, we may automatically collect the following information

  1. Device Information:

    We collect information about the mobile device you use to access the App, including the mobile network information.

  2. Location Information:

    We collect your IP address, time zone, and information about your mobile service provider, which allows us to infer your general location.

  3. Information collected by Cookies and Other Tracking Technologies:

    We use various technologies to collect information about your use of the App, such as frequency of use, which areas and features of the App you visit and your patterns generally, engagement tracking with particular features, etc. To collect this information, we may send cookies to your mobile device or computer. Cookies are small data files stored on your hard drive or in device memory.

If the information covered by the Section is aggregated or de-identified so it is no longer reasonably associated with an identified or identifiable natural person, we may use it for any business purpose. To the extent information covered by this Section is associated with an identified or identifiable natural person and is protected as personal data under applicable data protection Laws, it is referred to in this Privacy Policy as "Personal Data". We use pseudonymization for particular types of Personal Data. Please bear in mind that provisions of Section 3 do not apply to pseudonymised Personal Data.

YOUR CONSENT: By creating a profile in App, you explicitly consent that:

  1. WE MAY STORE PROCESS YOUR PERSONAL DATA YOU PROVIDE THROUGH THE USAGE OF THE APP AND THROUGH THE ACCOUNT CREATION PROCESS SOLELY FOR THE PURPOSE OF PROVIDING SERVICES TO YOU, TO IMPROVE OUR SERVICE FEATURES AND OTHER PURPOSES INDICATED IN SECTION 2 OF THIS PRIVACY POLICY. SUCH SERVICES MAY INCLUDE SENDING YOU INFORMATION AND REMINDERS THROUGH THE APP OR TO THE EMAIL ADDRESS YOU PROVIDED US.
  2. PERSONAL DATA YOU PROVIDE US THROUGH THE ACCOUNT CREATION PROCESS INCLUDES PERSONAL DATA YOU ENTER INTO THE APP, SUCH AS YOUR ACCOUNT DATA (E.G. YOUR NAME, PHONE NUMBER AND EMAIL ADDRESS), AND YOUR HEALTH DATA (E.G. ASTHMATIC CONDITIONS ETC.).
  3. WE WILL NOT TRANSMIT ANY OF YOUR PERSONAL DATA TO THIRD PARTIES UNLESS OTHERWISE IS PROVIDED BY THIS PRIVACY POLICY.

2. How we use your personal data and information

We may use your information, including your Personal Data, for the following purposes:

  1. To analyse, operate, maintain and improve the App, to add new features and services to the App.
  2. To customise content you see when you use the App.
  3. To provide and deliver the products and services you request, process transactions and send you related information, including confirmations and reminders.
  4. To customise product and service offerings and reccomendations to you.
  5. To identify your identity.
  6. To send you technical notices, updates, security alerts and support and administrative purposes, if applies.
  7. For billing (invoicing), account management and other administrative purposes, if applies.
  8. To provide you seamless customer service.
  9. To monitor and analyse trends, usage and activities in connection with our App.
  10. Solely with respect to information that you mark for sharing, for Comapny promotional purposes.
  11. To link or combine with information we get from others or (and) from you to help understand your needs and provide you with better service (to use in automated decision-making processes).
  12. For scientific and academicc research purposes.
  13. For any other purposes disclosed to you at the time we collect Personal Data or any other purposes indicated in this Privacy Policy.

We will not process Personal Data in a way that is incompatible with the purposes for which it has been collected or subsequently authorised by you in accordance with Section 2 of this Privacy Policy or collect any Personal Data that is not required for the mentioned purposes. For any new purpose of processing we will ask your separate explicit consent. To the extent necessary for those purposes, we take all reasonable steps to ensure that Personal Data is reliable for its intended use, accurate, complete, and current. We also undertake to collect only such amount and type of Personal Data that is strictly required for the purposes mentioned in this Section of the Privacy Policy.

3. Your rights

Modification, correction and erasure

You are able to modify, correct, erase, and update your Personal Data by writing to us at support@ghrsindia.com .

Access

You have right to access your Personal Data you insert into the App and ask us about what kind of Personal Data we have about you. You can do this by using the App settings or writing to us at support@ghrsindia.com .

Resident Rights

Individuals have certain statutory rights in relation to their personal data. Subject to any exemptions provided by law, you may have the right to request access to Personal data (including in a structured and portable form), as well as to seek to update, delete or correct Personal data:

  1. Rectification of Personal Data and Restriction of Processing: You are responsible for ensuring the accuracy of your Personal Data that you submit to Nice Day. Inaccurate information will affect your experience when using the Nice Day App and tools and our ability to contact you as described in this Privacy Policy. If you believe that your Personal Data is inaccurate, you have right to contact us and ask us to correct such Personal Data by contacting us at support@ghrsindia.com . You shall also have the right to request restriction of processing of your Personal Data, if you contest the accuracy of the Personal Data and we need some time to verify its accuracy.
  2. Access to your Personal Data and Data Portability: The App gives you the ability to access and update Personal Data within the App and your account settings. You shall have the right to request information about whether we have any Personal Data about you, to access your Personal data (including in a structured and portable form) by simply writing us at support@ghrsindia.com .
  3. Erasure of your Personal Data: If you believe that your Personal Data is no longer necessary in relation to the purposes for which it was collected or otherwise processed, or in cases where you have withdrawn your consent or object to the processing of your Personal Data, or in cases where the processing of your Personal Data does not otherwise comply with the Data Protection Laws, you have right to contact us and ask us to erase such Personal Data as described above. You can simply write us at support@ghrsindia.com . Please be aware that erasing some Personal Data inserted by you may affect your possibility to utilize the App and its features. Erasure of some Personal Data may also take some time due to technical reasons.
  4. Right to object processing of your Personal Data: You can object processing your Personal Data and stop us from processing your Personal data, simply write us at support@ghrsindia.com . Please be aware that erasing some Personal Data inserted by you may affect your possibility to use the App and its features.
  5. Notice about automated decision-making: We use automated decision-making tools that process your Personal Data in order to provide you proper Services. Normally, such automated decision-making works more precisely, if you insert more Personal Data about your health, age etc.
  6. Notification requirements: We commit to notify you within reasonable period of time and your data protection authority within the timeframe specified in applicable law about any personal data breaches in the App.

Please keep in mind that in case of a vague access, erasure, objection request or any other request in exercise of the mentioned rights we may engage the individual in a dialogue so as to better understand the motivation for the request and to locate responsive information. In case this is impossible, we reserve the right to refuse granting your request.

Following the provisions of the Laws we might also require you to prove your identity (for example, by requesting an ID or any other proof of identity) in order for you to invoke the mentioned rights, specifically if you exercise them in respect to special categories of Personal Data like data about health. This is made to ensure that the rights described in this section are exercised by an actual Personal Data subject or an authorized person.

Please note that we will grant your request within 30 days after receiving it, but it may take us up to 90 days in some cases, for example for full erasure of your Personal Data stored in our backup systems – this is due to the size and complexity of the systems we use to store data.

4. Retention of your personal data

We will retain your Personal Data as long as your account is active or needed to provide you services, and only for as long as it serves purposes of processing identified in Section 2 of this Privacy Policy. At any time, you can remove your Personal Data as specified in Section 3 of this Privacy Policy.

You should be aware that we may retain certain Personal Data and other information after your account has been terminated in an aggregated, anonymized form. Any posts or comments you submit may remain visible if and after you delete your account. We reserve the right to use your information in any aggregated data collection after you have terminated your account, however we will ensure that the use of such information will not identify you personally. We will also retain your Personal Data as necessary to comply with legal obligations, resolve disputes and enforce our agreements.

If you remove data from your account, you will no longer see it in the App, but some backups of the data may remain in our archive servers for a reasonable period of time due to technical solutions we use. However, we undertake to delete any such backups within a reasonable period of time.

If you choose to delete the App and deactivate your account, write to us at support@ghrsindia.com . We retain your Personal Data for a reasonable period thereafter in case you decide to re-use the Services. We also retain some of your information as necessary to comply with our legal obligations, to resolve disputes, to enforce our agreements, to support business operations, and to continue to develop and improve our Services. Where we retain information for Service improvement and development, we take steps to eliminate information that directly identifies you, and we only use the information to uncover collective insights about the use of our Services, not to specifically analyze personal characteristics about you.

5. Security

We take all reasonable and appropriate measures to protect all collected Personal Data from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the nature of the Personal Data that we process and risks associated with special categories of Personal Data we collect (information about health etc.). Among others, we utilize the following information security measures to protect your Personal Data:

  1. Pseudominization and tokenization of certain categories of your Personal Data.
  2. Encryption of your Personal Data in transit and in rest.
  3. Systematic vulnerability scanning and penetration testing.
  4. Protection of data integrity.
  5. Organizational and legal measures: For example, our employees have different levels of access to your Personal Data and only those in charge of data management get access to your Personal Data and only for limited purposes required for the operation of the App. We impose strict liability on our employees for any disclosures, unauthorized accesses, alterations, destructions, misuses of your Personal Data.
  6. Conducting periodical data protection impact assessments in order to ensure that the App fully adheres to the principles of ‘privacy by design’, ‘privacy by default’ and others. We also commit to undertake privacy audit in case of Company’s merger or takeover.

Please understand that you can help keep your information secure by choosing and protecting your password appropriately, not sharing your password and preventing others from using your mobile device. Please understand that no security system is perfect and, as such, we cannot guarantee the absolute security of the App, or that your information won’t be intercepted while being transmitted to us. If we learn of a security systems breach, we may either post a notice, or attempt to notify you by email and will take reasonable steps to remedy the breach as specified in this Privacy Policy.

We process information in a way that is compatible with and relevant for the purpose for which it was collected. To the extent necessary for those purposes, we take reasonable and appropriate steps to ensure that any information in our care is accurate, complete, current and reliable for its intended use.

6. Children’s privacy

General age limitation: We are committed to protecting the privacy of children account.

7. Third party links

Although the App may contain links to third party websites or services, we are not responsible for the privacy policies and/or practices on those third-party websites or services. Please understand that this Privacy Policy applies only to information we collect from you. Where we have linked to a third-party website or service, you should read the privacy policy stated on that third-party website or service.

8. Email Communications

We may contact you from time to time via email to communicate with you about products, services, offers, promotions, rewards, and events offered by us and others, and provide news and information that we think will be of interest to you. If applicable Laws prescribe so, certain exclusions may apply to the residents of some countries regarding an active opt-in for any email communications from us.

This Privacy Policy does not apply to information, content, business information, ideas, concepts or inventions that you send to the Company by email. If you want to keep content or business information, ideas, concepts or inventions private or proprietary, do not send them in an email to the Company.

9. Contact us

If you have any questions or concerns about your privacy, any provisions of this Privacy Policy or any of your rights, you may contact us at:

GHRS Private Limited

CLC Tower, Plot #146, Sector 44 Rd,
Sector 44, Gurugram, Haryana - 122003
Email: info@ghrsindia.com