1. Introduction
AscendPsychology CogniPsyTech Pvt. Ltd. (“AscendPsychology,” “APCPT”, “us,” "we," “our'', inPsyt) understands the importance of privacy of the user’s (“your”, “you”, “subscriber’’) information. We are committed to protecting your personal information and your right to privacy in connection to the use of our Services (including Website(s), Applications (''Apps”), Services and other Products or Features, collectively referred to herein as “Service” or “Services''.

When you use our Apps or Services, we appreciate that you are trusting us with your information. Please read the following carefully to understand our practices regarding your personal data and how we will collect, use and disclose your personal data. 

This Privacy Policy applies to all information collected through any of our Services, including the use of our App, inPsyt.

By using inPsyt and our Services, you consent to our collection, use, disclosure, and storage of information as described in our Privacy Policy. 

If you have any questions or concerns regarding the Privacy Policy or the use of your personal information, please contact us on support@inpsyt.app

2. Confidentiality and Security
The security of your personal data is important to us. We follow generally accepted standards to protect the personal data submitted to us, both during transmission and once it is received. If you have any questions about the security of your personal data, you can contact us at support@inpsyt.app  Except as described under the “Disclosure of Your Data” section below, we do not provide your personal data to any third party without your specific consent, as defined by the applicable law.

3. What Information We Collect?
Information disclosed to us
We may collect and process personal information that you provide to us while registering for the App, express an interest in obtaining information about the App and our Services, when you use the App or our Services (such as posting messages in our online forums or responding to your questions in the app) or otherwise when you contact us. 
The personal information that we collect depends on the context of your interactions with us and the App, the choices you make and the products and features you use. 

3.1 Personal information
The personal information we collect includes your email addresses, password, date of birth, gender, nickname, and country. 

We also collect your information related to using the features in the App including diary records, goals, assessments, indices & questionnaires, and screening related information. 

3.2 Social Media Log-in
We also provide you with the option to log in using social media accounts and if you choose to register in this way, we will collect the information described in the section called "HOW DO WE HANDLE YOUR SOCIAL LOG-INS" below.

3.3 Payment details
AscendPsychology does not collect or process credit or debit card (“Payment Card”) data directly. Apple and Google collect Payment Card data with respect to subscription and in-app purchases made through the Apps, and our payment processor collects Payment Card data with respect to purchases made through the Websites. Such payment processors generally provide us with some limited data related to you, such as a unique, anonymous token that enables you to make additional purchases using the data they’ve stored, and the type of your card, expiration date, billing address, and the last four digits of your card number.

3.4 Information automatically collected
We automatically collect certain information when you visit, use or navigate the App. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, information about how and when you use our App and other technical information. This information is primarily needed to maintain the security and operation of our App, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.  The information we collect includes:

3.5 Log and Usage Data 
Log and usage data is service-related, diagnostic usage and performance information our servers automatically collect when you access or use our App and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type and settings and information about your activity in the App (such as the date/time stamps associated with your usage, pages and files viewed, searches and other actions such as which features you use), device event information, (such as system activity, error reports [sometimes called 'crash dumps'] and hardware settings).

3.6 Device Data 
We automatically collect device information which may include device and usage information, such as your operating system, device name, device's Universally Unique Identifier (UUID).

3.7 Push Notifications. 
We may request to send you push notifications regarding your account or certain features of the App. If you wish to opt out from receiving these types of communications, you can turn them off in your device's settings.

4. How Do We Use Your Information?
We use personal information collected via our App for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.

In legal terms, we are generally the "data controller" under European data protection laws since we determine the means and/or purposes of the data processing we perform. 

5. We use the information we collect or receive:

1. To facilitate account creation and sign-in process:

   • If you choose to link your account created with us to a third-party account (such as your Google or Apple account), we use the information you allowed us to collect from those third parties to facilitate account creation and sign-in process for the performance of the contract. See the section below, headed "HOW DO WE HANDLE YOUR SOCIAL LOGINS" for further information.

2. To deliver and facilitate delivery of services to the user:- 

   • We may use your information to provide you with the requested services and to personalize your experience in our App and Services.

3. Request feedback:- 

   • We may use your information to request feedback and to contact you about your usage of our App.

4. To enable user-to-user communications:- 

   • We may use your information in order to enable user-to-user communications with each user's consent.

5. To respond to user inquiries/offer support to users:- 

   • We may use your information to respond to your inquiries and solve any potential issues you might have with the usage of our Services.

6. To manage user accounts:- 

   • We may use your information for the purposes of managing a user account and keeping it in working order.

7. To send administrative information to you:- 

   • We may use your personal information to send you the product, service and new feature information and/or information about changes to our terms, conditions, and policies.

8. To protect our Services:- 

   • We may use your information as part of our efforts to keep our App safe and secure (for example, for fraud monitoring and prevention).

9. To enforce our terms, conditions and policies for business purposes and to comply with legal and regulatory requirements or in connection with our contract.

10. To respond to legal requests and prevent harm:- 

    • If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.

11. Fulfill and manage your orders:- 

    • We may use your information to fulfill and manage your orders, payments, returns, and exchanges made through the App.

12. To send you marketing and promotional communications:- 

    • We and/or our third-party marketing partners may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. For example, when expressing an interest in obtaining information about us or our App, subscribing to marketing or otherwise contacting us, we will collect personal information from you. You can opt out of our marketing emails at any time (see the "WHAT ARE YOUR PRIVACY RIGHTS" below).

13. Deliver targeted advertising to you, as permitted by law:- 

    • We may use your information to develop and display personalized content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness.

14. For other business purposes:- 

    • We may use your information for other business purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our App, products, marketing strategies and your experience. 

    • We may use and store this information in aggregated and anonymized form so that it is not associated with individual end users and does not include personal information. We will not use identifiable personal information without your consent.

15. To protect our rights, the rights of affiliates or related third parties, or take appropriate legal action, such as to enforce our Terms of Use.

16. To conduct health and behavioural research, including the ones with research partners:- 

    • We only use your responses and analyse them for internal research purposes or to make your app experience better and offer insights and suggestions. We never share this information to any third party research partners. We use it only for such research purposes as described below under “How We Share Information.”

17. As otherwise necessary or useful for us to conduct our business, so long as such use is permitted by law or for any other purpose with your consent.

6. Will Your Information Be Shared with Anyone?

1. We only share information with consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations. 

2. We may process or share your data that we possess based on the following legal ground:

3. Consent: We may process your data if you have given us specific consent to use your personal information for a specific purpose.

4. Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.

5. Performance of a Contract: Upon entering into a contract with you, we may process your personal information to fulfill the terms of our contract.

6. Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with the applicable law, governmental requests, a judicial proceeding, a court order, or a legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).

7. Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

8. We may also share Information within the Company, including among affiliates, or with our parent company, or subsidiaries.

9. Third Party: We may also share Information with other third-party companies with whom we have a business relationship with or whom we hire to perform services on our behalf, including assisting with the purposes described under the “How We Use Information” section. For example, we may hire a company to help us with sending and managing emails, and we might provide that company with your email address and certain other information in order to facilitate them with sending you an email message on our behalf. Similarly, we may hire companies to host or operate some of our Services and related computers and software applications. These service providers are not allowed to use or disclose your information other than as specified in our contract and as permitted by law.

10. Business Transfers: We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

6.1 Link to privacy policy of third-party service providers used by the App

1. Google Play Services

2. Google Analytics for Firebase

3. Firebase Crashlytics

4. Unity

5. SDKBOX

7. How Do We Handle Your Social Log-ins?
If you choose to register or log in to our services using a social media account, we may have access to certain information about you.

Our App offers you the ability to register and log in using your third-party social media account details (like your Google or Apple log-ins). Wherein you choose to do this, we will receive certain profile information about you from your social media provider. The profile Information we receive may vary depending on the social media provider concerned, but it will often include your name, email address, as well as other information you choose to make public on such social media platforms.

We will use the information we receive only for the purposes that are described in this privacy notice or that are otherwise made clear to you in the relevant App. Please note that we do not control, and are not responsible for other usage of your personal information by your third-party social media provider. We recommend that you review their privacy notice to understand how they collect, use and share your personal information, and how you can set your privacy preferences on their sites and apps.

8. Where Is Your Data Stored and Is Your Information Transferred Internationally?
All the data you provide to us through the Service is stored on AWS/our secure servers located in India. Any Information you provide will be processed by a computer server located within India.

If you are accessing our App from anywhere, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information (see "WILL YOUR INFORMATION BE SHARED WITH ANYONE?" above). 

We may transfer, store, and process your information in countries other than your own.

Our servers are located in India. If you are a resident in the European Economic Area, then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. We will however take all necessary measures to protect your personal information in accordance with this privacy notice and applicable law.
Unfortunately, the transmission of data via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the App and Services; the transmission is at your own risk. Once we have received your data, we will use strict procedures and security features to try to prevent unauthorized access.

Where we have given you (or where you have chosen) a password which enables you to access certain parts of the App and Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone, and suggest that you change your password frequently.

9. How We Protect Information 

1. We maintain administrative, technical, and physical safeguards designed to protect the information that you provide on our Services. These safeguards vary based on the sensitivity of the information that is being collected, used and stored. However, no security system is impenetrable and we cannot guarantee the security of our Services, nor can we guarantee the security of the information you transmit to us over the internet, including your usage of the email. We are not liable for the illegal acts of third parties such as criminal hackers.

2. It is your responsibility to safeguard the devices you use to access our Online Services (such as laptops, tablets and mobile devices), and to use appropriate security settings on those devices. If those devices are lost, stolen or misplaced, others may be able to access your account and your personal information using those devices. If you log into the Services using a public computer or device, or the computer or device of another person, you should log out of your account affirmatively (i) prior to ending your session, or (ii) if you will be inactive on the Services for more than a few minutes; otherwise, the next user using that computer or device may be able to access your account and the information in your account if your session has not ended.

3. You agree that we are not responsible for any harm that may result from someone accessing your account or personal information on a lost, stolen or misplaced device or on a public computer or kiosk where for any reason you do not take the necessary steps to log out of your account prior to ending a session on such public computers or kiosks.

4. We offer mobile applications that enable us to communicate with you via push notifications. You may be able to turn off push notifications in your mobile phone settings. You may also be able to control the preview settings in your email applications. Please note, choosing to disable a certain function of the mobile application may impact the functionality of other areas of the mobile application.

5. We retain the information for as long as necessary for the purpose for which it is collected, it is subject to a longer period if the information is relevant to a legal challenge.

10. How Long Do We Keep Your Information?

1. For data related to your account: We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this notice will require us to keep your personal information for longer than six (6) months past the termination of the user's account.

2. When we have no ongoing legitimate business requirement to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

3. For transactional data relating to your purchases: Such data is kept for the entire period of the contractual relationship, then in accordance with legal obligations and applicable statute of limitation periods. Please note that this data does not include Payment Card information, which is processed by our third-party payment processors, and not inPsyt.

4. For data collected based on your consent to receive our marketing communications: We will use such data until you withdraw consent or applicable law requires that such data is no longer used.

5. When your data are collected in the context of requests/queries: Such data are kept for the period necessary to process and reply to such requests or queries.

6. Other data will be kept as long as necessary for the purposes pursued and in compliance with our legal obligations, including the applicable statute of limitations.

11. Do We Collect Information from Minors?
We do not knowingly solicit data from or market to children under 17 years of age. By using the App, you represent that you are at least 17 years of age or that you are the parent or guardian of such a minor and consent to such minor dependent’s usage of the App. If we learn that personal information from users less than 17 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data, we may have collected from children under age 17, please contact us at support@inpsyt.app.

12. Posting Messages, Comments and Content 
Our Services may have collaboration areas, including but not limited to “blogs,” and “forum”, “bulletin boards,” “leader boards,” and “health games,” that permit users to have collaborative discussions and/or share information. Users may have the ability to post content to one or more of our forums. Such Services may permit you to select a display name or image that will be “a nickname” on the Online Service. Please note, any information you submit or post to these collaboration areas, including your display name or image, may be visible by other users of the Online Service, and such users may share it with others. Therefore, please be thoughtful in what you write and understand that this information may become public.

All such users may request and obtain removal of certain posted content by contacting us at support@inpsyt.app and specifically identifying the content to be removed. Please be advised that any such removal does not ensure complete or comprehensive removal of all the traces of the content posted on our forum(s). 

12.1 Links to Third Party Sites
The Products may, from time to time, contain links to and from the Products of our partner networks, advertisers and affiliates. If you follow a link to any of these external websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these websites or their policies. Please check these policies before you submit any personal data to these external websites.

13. What Are Your Privacy Rights?
In some regions (like the European Economic Area), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws.

If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. However, please note that it will not affect the legitimacy of the processing before its withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/dataprotection/bodies/authorities/index_en.htm

If you are resident in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html  

If you have questions or comments about your privacy rights, you may email us at support@inpsyt.app

14. Account Information
At any point, if you would like to review or change the information in your account or terminate your account, you can:

Log in to your account settings and update your user account.
Contact us using the contact information provided.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with applicable legal requirements.

Cookies and similar technologies: Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our website. 

Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list – however, we may still communicate with you, for example, to send you service-related emails that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes. 
To otherwise opt out, you may:
Access your account settings and update your preferences
Contact us using the contact information provided.

15. Your right to information
You may request and obtain from us, once a year and free of charge, the information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year.
​
16. The kind of information we collect

1. Identifiers - e.g. Email address.

   • Information we collect - YES

2. Personal information categories listed in the California Customer Records statute e.g. Name, contact information, education, employment, employment history and financial information.

   • Information we collect - NO

3. Protected classification characteristics under California or federal law - e.g. Gender and date of birth.

   • Information we collect - YES

4. Commercial information- e.g. Transaction information, purchase history,

   • Information we collect - Yes

5. Commercial information- e.g. Financial details and payment information.

   • Information we collect - NO

6. Biometric information- e.g. Fingerprints and voiceprints.

   • Information we collect - NO

7. Internet or another similar network activity - e.g. Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems and advertisements.

   • Information we collect - NO

8. Geolocation data - e.g. Device location.

   • Information we collect - NO

9. Audio, electronic, visual, thermal, olfactory, or similar information - e.g. Images and audio, video or call recordings created in connection with our business activities.

   • Information we collect - NO

10. Professional or employment-related information - e.g. Business contact details in order to provide you our services at a business level, job title as well as work history and professional qualifications if you apply for a job with us.

    • Information we collect - NO

11. Education Information - e.g. Student records and directory information.

    • Information we collect - NO

12. Inferences drawn from other personal information - e.g. Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.

    • Information we collect - YES

13. We may also collect other personal information outside of these categories in instances where you interact with us in-person, online, or by phone or mail in the context of:

    • Receiving help through our customer support channels

    • Participation in customer surveys or contests; and

    • Facilitation in the delivery of our Services and to respond to your inquiries

17. How do we use and share your personal information?
More information about our data collection and sharing practices can be found in this privacy notice.
You may contact us by email at support@inpsyt.app with the subject – My Privacy, or by referring to the contact details at the bottom of this document.
If you are using an authorized agent to exercise your right to opt out, we may deny a request if the authorized agent does not submit a proof that they have valid authorization to act on your behalf.

18. Will your information be shared with anyone else?
We may disclose your personal information with our service providers pursuant to a written contract between us and each of the service providers. Each service provider is a for-profit entity that processes the information on our behalf.

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" your personal data.

AscendPsychology CogniPsyTech Pvt. Ltd. has not disclosed or sold any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. AscendPsychology CogniPsyTech Pvt. Ltd. will not sell personal information in the future belonging to website visitors, users and other consumers.

19. Your rights with respect to your personal data

19.1 Right to request deletion of the data - Request to delete
You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation or any processing that may be required to protect against illegal activities.

19.2 Right to be informed - Request to know

1. Depending on the circumstances, you have a right to know:

2. Whether we collect and use your personal information

3. The categories of personal information that we collect

4. The purposes for which the collected personal information is used

5. Whether we sell your personal information to third parties

6. The categories of personal information that we sold or disclosed for a business purpose

7. The categories of third parties to whom the personal information was sold or disclosed for a business purpose; and the business or commercial purpose for collecting or selling personal information.

8. In accordance with applicable law, we are not obligated to provide or delete consumer information that is deactivated in response to a consumer request or to activate individual data to verify a consumer request.

20. Right to Non-Discrimination for the Exercise of a Consumer's Privacy Rights
We will not discriminate against you if you exercise your privacy rights.

21. Verification process
Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with the information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g. phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.

We will only use personal information provided with  your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. If, however, we cannot verify your identity from the information we possess, , we may request that you provide additional information for the purposes of verifying your identity, and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying your information.

22. Other privacy rights
You may object to the processing of your personal data.

You may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the data.

You can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.

23. Do We Make Updates to This Notice?
We may update this privacy notice from time to time to reflect changes to our data practices. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by posting a prominent notice of such changes or by directly sending you a notification or by in-Product message, email (sent to the email address if specified in your account) or by means of a notice in the Products prior to the change coming to effect. We encourage you to periodically review this page for the latest data on our privacy practices.

24. How Can You Contact Us About This Notice?
If you have questions or comments about this notice, you may contact our Data Protection Officer (DPO), Supriya Nair, by email at supriya@inpsyt.app, or by post to:
402/7A, New Mhada Colony, Andheri West, Mumbai, Maharashtra 400093, India