B2B PRIVACY POLICY

DEFINITIONS

The purpose of this policy is to regulate the privacy policy in compliance with the Digital Personal Data Protection Act, 2023 (“DPDP Act”). In this policy, the terms are used with the following meaning:

Term	Definition
Child	An individual who has not completed the age of eighteen years
Data	Representation of information, facts, concepts, opinions or instructions in a manner suitable for communication, interpretation or processing by human beings or by automated means;
Digital Personal Data	Personal data in digital form
Personal Data	Any data about an individual who is identifiable by or in relation to such data
Personal Data Breach	Any unauthorised processing of personal data or accidental disclosure, acquisition, sharing, use, alteration, destruction or loss of access to personal data, that compromises the confidentiality, integrity or availability of personal data;
Processing	In relation to personal data, it means a wholly or partly automated operation or set of operations performed on digital personal data, and includes operations such as collection, recording, organisation, structuring, storage, adaptation, retrieval, use, alignment or combination, indexing, sharing, disclosure by transmission, dissemination or otherwise making available, restriction, erasure or destruction.

1. SCOPE AND APPLICATION

SAHCHI HEARING AND SPEECH SOLUTIONS PRIVATE LIMITED (“Gabify”, “Company” or “we”) wants you to be familiar with how we collect, use and disclose information from and about you. This Privacy Policy describes our practices in connection with business-to-business related services (the “Company B2B Services”).

By using the Company B2B Services, you agree to the terms and conditions of this Privacy Policy. The Company B2B Services are for a general audience and are not targeted to children.

This Privacy Policy applies to all users, including those who use the Company B2B Services without being registered with a Company B2B Service and those who have registered with a Company B2B Service.

This Privacy Policy applies to the Company’s collection and use of your personal information (i.e., information that identifies a specific person, such as full name or email address). It also describes the Company’s practices for handling non-personal information (for example, demographics and service usage).

2. COLLECTION OF INFORMATION

Depending on your interactions with us, the Company and our service providers may collect the following information from and about you:

Registration Information. It is the information you submit to register for the Company B2B Services, for example, to create an account, register for using Neurolens by Gabify. Registration Information may also include, for example, name, email address, address, and phone number.

Activity Information. When you access and interact with the Company B2B Services, the Company and its service providers may collect certain information about those visits.

For example, to permit your connection to the Company B2B Services, our servers receive and record information about your computer, device, and browser, including potentially your IP address, browser type, and other software or hardware information.

If you access the Company B2B Services from a mobile or other device, we may collect a unique device identifier assigned to that device, geolocation data (including your precise location), or other transactional information for that device.

Cookies and other tracking technologies (such as browser cookies, pixels, beacons, local storage, and other mechanisms) use various approaches to collect and store data. Some of these technologies store data in the browser or on your device. Other technologies may use network-related or other information to recognise your device (e.g., IP address).

Company’s websites, apps and other services use these technologies, for example, when you first request a web page and then store the data on your computer or other device so the website or other service can access information when you make subsequent requests for pages from that service.

These technologies may also be used to collect and store information about your usage of the Company B2B Services, such as pages you have visited, search history, and the video and other content you have viewed.

Other parties that support the Company B2B Services by providing services, such as tracking aggregate Company B2B Services usage statistics, may also use these technologies to collect similar information when you use the Company B2B Services or other parties’ services.

Your browser may be initially set to accept cookies, but you can change your settings to notify you when a cookie is being set or updated, and to block cookies altogether. Please consult the “Help” section of your browser for more information, including on how to clear data from local storage and, depending on your browser, how to turn off other data collection by the browser.

Please note that by blocking any or all cookies, you may not have access to certain features, content or personalisation available through the Company B2B Services.

Information from Other Sources. We may supplement the information we collect with information from other sources, such as publicly available information about your online and offline activity from social media services, advertisers, commercially available sources, and information from our Company Affiliates or business partners.

Depending on your interactions with us, the Company may not have collected information from you for each of the categories above.

‘Do Not Track’. At this time, we do not respond to the ‘Do Not Track’ signal, as we await the work of interested stakeholders and others to develop standards for how this signal should be interpreted.

3. USE AND DISCLOSURE

We may use and disclose some or all of the information we collect from and about you for the following purposes. To provide the Company Services. We use information we collect from and about you to provide the Company Services. This may include:

To measure, maintain and improve those Company Services and features and to develop new products and services, including making inferences, conducting research and quality and safety assurance measures.
To perform identity verification.
To provide you with customer support and to respond to inquiries. This may include the use of chatbots. Please note that your inquiries and responses to these chatbots may be transcribed and retained.
To maintain our facilities and infrastructure.
To comply with internal policies, including accounting, audit, and other internal functions.
To maintain records, conduct risk and security controls, and monitor.

To allow service providers to assist us in providing and managing the Company's B2B Services. Information we collect from and about you may be made available to certain service providers, such as contractors, chatbot providers, analytics and other measurement companies, and agents or sponsors, who help us analyse and understand your use of the Company B2B Services, organise and/or host events, and manage and/or provide the Company B2B Services.

To contact you. The company may periodically send emails or notifications related to the Company's B2B Services. There are certain service notifications and other emails that you may not opt out of, such as notifications of changes to the Company B2B Services or policies.

To share with our Company Affiliates. The company may share information we collect from and about you as described in this Privacy Policy with Company Affiliates for the purposes described in this Privacy Policy. A link to a website that lists Company Affiliates can be found at the beginning of this policy. Users who visit Company Affiliates’ services should still refer to their separate privacy policies, which may differ in some respects from this Privacy Policy.

In the ordinary course of our business, we may share information that we collect from or about you with other parties in order to process your requests and fulfil your orders for video content offered through the Company B2B Services.

To protect the rights of the Company and others. There may be instances when Company may use or disclose information we collect from and about you as described in this Privacy Policy, including situations where Company has a good faith belief that such use or disclosure is necessary in order to:

protect, enforce, or defend the legal rights, privacy, safety, or property of Company, our Company Affiliates or our or their employees, agents and contractors (including enforcement of our agreements and our terms of use);
protect the safety, privacy, and security of users of the Company B2B Services or members of the public;
protect against fraud or for risk management purposes;
comply with the law or legal process; or
respond to requests from the public and government authorities.

To complete a merger or sale of assets or other corporate transaction. If Company sells all or part of its business or makes a sale or transfer of its assets or is otherwise involved in an acquisition, reorganization, merger or transfer of all or a part of its business, or other corporate transaction (including in connection with a bankruptcy or similar proceedings), Company may transfer or disclose information we collect from and about you as described in this Privacy Policy to the party or parties involved in the transaction as part of that transaction.

Depending on your interactions with us, Company may not have collected, used or disclosed information from you in each of the categories above, and to the extent that Company has disclosed information from or about you, it may not include all of the information that we collect from and about you as described in this Privacy Policy.

Please note that when the information collected from or about you does not identify you as a specific person, we may use that information for any purpose or share it with other parties, to the extent permitted by applicable law.

4. SECURITY

The company uses commercially reasonable administrative, technical, personnel, and physical measures designed to safeguard information in its possession against loss, theft and unauthorised use, disclosure, or modification.

However, no one can guarantee the complete safety of your information.

5. USER ACCESS AND CONTROL

If you would like to access, review, correct, update, suppress, delete, or otherwise limit our use of your personal information you have previously provided directly to us, you may contact us.

In your request, please include your email address, name, address, and telephone number and specify clearly what information you would like to access, change, update, suppress, or delete.

We will try to comply with your request as soon as reasonably practicable and consistent with applicable law.

Please note that, subject to applicable law, in some cases we may not comply with your request where we may require your information in order to comply with applicable law, or to protect, enforce or defend our rights or employee rights, or those of a Company Affiliate.

We will try to comply with your request(s) as soon as reasonably practicable and consistent with applicable law.

6. OTHER IMPORTANT INFORMATION

Updates to Privacy Policy. The Company may modify this Privacy Policy at any time by posting an updated policy on the Company Services. Please look at the Effective Date at the top of this Privacy Policy to see when this Privacy Policy was last revised. Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on the Company B2B Services.

Location of Data. The Company B2B Services are hosted in and managed from the India. If you are a user located outside the India you understand and consent to having any personal information processed in the India in any other country in which we have facilities or in which we engage service providers.

The India and other countries’ data protection laws may not be the same as those in your jurisdiction. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in the India may be entitled to access your personal information.

Linked Services. The Company B2B Services may be linked to sites operated by unaffiliated companies, and may carry advertisements or offer content, functionality, games, newsletters, contests or sweepstakes, or applications developed and maintained by unaffiliated companies.

The company is not responsible for the privacy practices of unaffiliated companies, and once you leave the Company B2B Services, you should check the applicable privacy policy of the other service.

In addition, Company is not responsible for the privacy or data security practices of other organizations, such as Meta, X (formerly Twitter), Apple, Google, Microsoft or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer, including in connection with any information you disclose to other organizations through or in connection with the Company B2B Services.

Data Retention. We will retain your information for the period necessary to fulfil the purposes outlined in this Privacy Policy unless a longer retention period is required or allowed by law.

We may also retain backup information related to your account on our servers for some time after cancellation or your request for deletion, for fraud detection or to comply with applicable law or our internal security or recordkeeping policies.

It may not always be possible to completely remove or delete all of your information due to technical constraints or contractual, financial or legal requirements.

Deidentified Information. To the extent we process “deidentified” personal information, as defined under applicable law, we will maintain and use that information in deidentified form and will not attempt to reidentify the information except as permitted by applicable law.

7. CONTACT US

If you have questions about this Privacy Policy, please contact us at:

Email: care@gabify.life

info@gabify.life