1.                   INTRODUCTION


1.1               Goapptiv Private Limited (“We”, “Our”, “GoApptiv” or the “Company”) is an entity registered as a private limited company under the Companies Act, 1956 engaged in the business, inter alia, of providing data analytics services in the pharmaceutical sector. This Privacy Policy is with respect to the application “GoApptiv Website” whereby the Company provides a platform for a User to upload certain payment related documents on the basis of which a User is entitled to receive loyalty points which, subject to the policies of the Company, can be redeemed subsequently into gift vouchers from third party vendors (the “Services”). Any person who wishes to procure the Services (the “User”, “Your” or “You”) may access our platform “GoApptiv Website” (the “Platform”) and, subject to submission of the required documents, fulfilment of certain criteria and provision of information which may include Personal Information, the User can obtain use of the Services from the Platform.


1.2               The Company is committed to ensuring that the privacy of its clients, visitors, and Users of the Platform is always respected. This Privacy Policy serves as a testament to Our sincere efforts to uphold privacy laws. The User’s privacy and the protection of the User’s personally identifiable information (“Personal Information”) is one of our top priorities. We assure the User that we follow appropriate and necessary standards when it comes to protecting the User’s privacy. This Privacy Policy discloses and explains how we collect, use, share and protect Personal Information, Usage Information or any other information about the Users. In this Privacy Policy, We also provide information regarding how You can access and update Your Personal Information and make certain choices about how Your Personal Information is used by us.


1.3               This Privacy Policy explains what information will be collected by the Company when You access the Platform, how the information will be used, and how You can control the collection, correction and/or deletion of information. We will not use or share Your information with anyone except as described in this Privacy Policy. This Privacy Policy does not apply to information we collect by other means (including offline) or from other sources. The use of information collected through our Platform shall be limited to the purposes under this Privacy Policy and our Terms of Use to customers.


2.                   TYPES OF DATA COLLECTED


2.1               Among the types of Personal Data that GoApptiv collects, by itself or through third parties, there are: Cookies; Usage Data; email address; ZIP/Postal code; city; first name; last name; date of birth; phone number; address; password; country; picture; User ID; geographic position; various types of Data. We may collect this information through various forms and in various places such as Our  Platform, including when You access the Platform, when You first register with Us, when You create a transaction, when You contact Us, when You update Your information or when You otherwise interact with Us, by, for example, way of telephone, letter or in person. 


2.2               Unless specified otherwise, all Data requested by GoApptiv is mandatory and failure to provide this Data may make it impossible for GoApptiv to provide its services. In cases where GoApptiv specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.


2.3               Users who are uncertain about which Personal Data is mandatory are welcome to contact the Company.


2.4               Any use of Cookies – or of other tracking tools – by GoApptiv or by the Companys of third-party services used by GoApptiv serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available. However, no Personal Information identifying the User is collected nor any data capture mechanism is employed. You may change Your browser settings to accept or reject cookies on personal preference. You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but You can modify the browser setting to decline cookies if You so prefer. If You choose to decline cookies, You may not be able to sign in or use other interactive features of the Platform that may depend on cookies. If You choose to accept cookies, You also have the ability to later delete cookies that You have accepted. If You choose to delete cookies, any settings and preferences controlled by those cookies, including advertising preferences, will be deleted and may need to be recreated. You can find out more about cookies by following this link


2.5               We process the data collected through cookies either independently or with third party service providers, who analyze the data collected through cookies pursuant to contractual relationships with Us. The processing of such data is done to analyze the pages a User visits on the Platform, which Platforms a User has visited before coming to the Platform, and where a User goes after leaving the Platform. The Usage Information and/or the Personal Information may be combined for marketing and for market research purposes, including internal demographic studies, so that we can optimize our products and Services and customize the Platform for You and for the purpose of providing Our Services


2.6               Users are responsible for any third-party Personal Data obtained, published or shared through GoApptiv and confirm that they have the third party's consent to provide the Data to the Company.


2.7               In the event You provide Personal Data belonging to a third party, You shall ensure that due consent has been procured from such third party for providing their Personal Information for further sharing and processing by the Company. You shall ensure that such consent is documented and can be provided, if required by the Company. The Company disclaims all liability arising out of  any unauthorized sharing or processing of any Personal Information belonging to a third party and You agree to indemnify and hold the User harmless against any third party claims which arise out of such unauthorized sharing and processing of Personal Information belonging to a third party.


2.8               We may, from time to time, supplement the information we collect about You through our Platform with outside records from third parties, obtained rightfully and legitimately in order to enhance our ability to serve You, to tailor our content to You and to offer You opportunities to use such of our Services that we believe may be of interest to You. We may combine the information received from such third party sources with information collected through the Platform or through independent research conducted by Us with Your consent. In these cases, we will apply this Privacy Policy to any Personal Information received, unless otherwise provided. We may process such information received from third parties for legitimate commercial purposes or to enter into contractual obligations with You or in order to fulfil certain contractual obligations or where You have requested third parties to provide information about Yourself to us


3.                   MODE OF PROCESSING THE DATA


3.1               Methods of processing


3.1.1         The Company takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.


3.1.2         The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Company, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of GoApptiv (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Company. The updated list of these parties may be requested from the Company at any time. We aim to protect the Personal Information by i) only sharing and providing access to Personal Information to the minimum extent necessary, subject to appropriate contractual restrictions including confidentiality restrictions where appropriate, and on an anonymized basis wherever possible; (ii) using secure servers to store Personal Information; (iii) verifying the identity of any individual who requests access to Personal Information prior to granting them access to such information; and (iv) using Secure Sockets Layer (SSL) software or other similar encryption technologies to encrypt any payment transactions You make on or via our Platform.


4.                   LEGAL BASIS OF PROCESSING


4.1               The legal basis for collection and processing of any information collected and processed by Us is (i) for the performance of the Services in accordance with Our Terms of Use; and (ii) where it is Our legitimate interests to do so and not overridden by Your rights (for example, in some cases for direct marketing, fraud prevention, network and information systems security, for responding to Your communications, the operation of networks of groups by the network administrators, and improving our Platform). In some cases, we may also have a legal obligation to collect information about You, or may otherwise need the information to protect Your vital interests or those of another person, or where we need to comply with a legal requirement.


4.2               The Company may process Personal Data relating to Users if one of the following applies:

      Users have given their consent for one or more specific purposes;

      provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;

      processing is necessary for compliance with a legal obligation to which the Company is subject;

      processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company;

      processing is necessary for the purposes of the legitimate interests pursued by the Company or by a third party.

      In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.


5.                   RETENTION TIME


5.1               Personal Data shall be processed and stored for as long as required by the purpose they have been collected for or to comply with applicable laws. Therefore:

      Personal Data collected for purposes related to the performance of a contract between the Company and the User shall be retained until such contract has been fully performed.

      Personal Data collected for the purposes of the Company’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Company within the relevant sections of this document or by contacting the Company.


5.2               The Company may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Company may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.


5.3               Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.


6.                   THE PURPOSES OF PROCESSING


6.1               Other than as stated in the Privacy Policy, we do not share any Personal Information with any third party (not being an affiliate, third party service provider or a group company of Us) without Your consent, except when directed by law. The Company can use Personal Information and/or Usage Information to verify User identity the context of any engagement initiated by a User.


6.2               We will communicate with You using the contact information provided in order to respond to any queries that You may have, to provide any information requested regarding the Services or to send marketing and promotional material on our Services. You can choose to opt out of receiving such promotional and marketing communications by sending us an email at [email protected]



6.3                We may also use Your Personal Information to send You information in relation to our Services based on the analysis of the Usage Information collected. We may also send strictly service-related announcements, for instance, if our Services are temporarily suspended for maintenance, we may send You an email, text message, flash notification or telephone call. If You do not wish to receive such alerts, You have the option to unsubscribe from such emails or opt out by sending an email to [email protected]



6.4               We, our business partners, affiliates or third party service providers may use Personal Information or Usage Information collected in the following ways:

(i)                 to operate and improve the Platform and tools associated with the Platform;

(ii)               to create aggregated and anonymized information to determine which Platform features are most popular and useful to Users, and for other statistical analyses;

(iii)             to prevent, discover and investigate violations of this Privacy Policy or the Terms and Conditions, and to investigate fraud or other matters;

(iv)              to customize the content or the Services on the Platform for You, or the communications sent to You through the Platform;

(v)                to provide You the Services;

(vi)              to improve our ability to provide You the Services;

(vii)            to observe, improve and administer the quality of Services;

(viii)          to analyse how the Platform is used, diagnose technical problems;

(ix)              to remember the basic information provided by You for effective access;

(x)                to confirm Your identity in order to determine Your eligibility to use the Platform and avail the Services;

(xi)              to notify You about any changes to the Platform;

(xii)            to transmit, share or transfer the data to a group company or affiliate of Us to enable such group company or Affiliate to provide You with the Services;

(xiii)          to enable Us to comply with Our legal and regulatory obligations;

(xiv)          for the purpose of sending administrative notices, Service related alerts and other similar communication with a view to optimizing the efficiency of the Platform;

(xv)            to do market research, troubleshooting or project planning,

(xvi)          to protect against errors, fraud and other criminal activity; and

(xvii)        to reinforce the Terms of Use.


6.5               We may share non-Personal Information, such as aggregated User statistics and log data, with our business partners for the purposes of industry analysis, demographic profiling, to deliver targeted advertising about other products or services, or for other business purposes. This information is solely used to analyze the Platform and understand usage statistics, as mentioned above, and is anonymous. The Company may share this data with its business partners on an anonymous basis.  We do not sell, share, rent or trade the information we have collected about You, including Personal Information, other than as disclosed within this Privacy Policy or at the time You provide Your information. We do not share Your Personal Information with third parties otherwise than as mentioned under this Privacy Policy for those third parties’ direct marketing purposes unless You consent to such sharing at the time You provide Your Personal Information.


6.6               You may be presented with an opportunity to receive information and/or marketing offers directly from third parties with whom You have created a transaction through the Platform. If You do agree to have Your Personal Information being shared, Your Personal Information will be disclosed to such third parties and all information You disclose will be subject to the Privacy Policy and practices of such third parties. We are not responsible for the privacy policies and practices of such third parties and, therefore, You should review the privacy policies and practices of such third parties prior to agreeing to receive such information from them. If You later decide that You no longer want to receive communication from a third party, You will need to contact that third party directly.


6.7               We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. Thus, we may access, use, store, transfer and disclose Your information (including Personal Information), including disclosure to third parties such as government or law enforcement officials or private parties as we reasonably determine is necessary and appropriate: (i) to satisfy any applicable law, regulation, governmental requests or legal process; (ii) to protect the safety, rights, property or security of the Company, our Services, the Platform or any third party; (iii) to protect the safety of the public for any reason; (iv) to detect, prevent or otherwise address fraud, security or technical issues; and /or (v) to prevent or stop any activity we consider to be, or to pose a risk of being, an illegal, unethical, or legally actionable activity. Such disclosures may be carried out without notice to You.


6.8               We may share Your information, including Your Personal Information and Usage Information with our parent, subsidiaries and affiliates for internal reasons. We also reserve the right to disclose and transfer all such information: (i) to a subsequent Company, co-Company or operator of the Platform or applicable database; or (ii) in connection with a corporate merger, consolidation, restructuring, the sale of substantially all of our membership interests and/or assets or other corporate change, including, during the course of any due diligence process. You will be notified via email and/or through a prominent notice on the Platform of any change in Companyship or uses of Your Personal Information, as well as any choices You may have regarding Your Personal Information.


6.9               We may partner with another party to provide the Services including specific services if required. When You sign-up for the Services, We may share names, other Personal Information including details of any documentation provided by You that is necessary for the Company to provide the Services. We may specifically share Your Personal Information with our business partners who we are required to contractually provide data in order to provide the Services. For instance, we may provide Your Personal Information to a company registered on our Platform whose products purchased by You will entitle You to receive reward points. We may also share Your Personal Information with our vendors who we have contractual arrangements with to provide gift card services which will be received by you upon redemption of your reward points. These include Amazon, Flipkart etc. Our contractual arrangements with such third parties restrict these parties from using Personal Information except for the explicit purpose of assisting in the provision of these Services. We also protect Your Personal Information off-line other than as specifically mentioned in this Privacy Policy. Access to Your Personal Information is limited to employees, agents or partners and third parties, who We reasonably believe will need that information to enable Us to provide Services to You. However, We are not responsible for the confidentiality, security or distribution of Your own Personal Information by our partners and third parties outside the scope of our agreement with such partners and third parties.


6.10           The Platform may contain content that is supplied by a third party, and those third parties may collect Platform usage information and other information when web pages from any online or mobile services are provided to Your browser. In addition, when You are using the Platform, You may be directed to other Platforms that are operated and controlled by third parties that we do not control. We are not responsible for the privacy practices employed by any of these third parties. These other Platforms may send their own cookies to You, independently collect data or solicit Personal Information and may or may not have their own published privacy policies. When You leave the Platform, we encourage You to read the privacy statements of all third party Platforms before submitting any information to third parties.


6.11           Should you require detailed information on the nature of data processed for a particular purpose, please reach out to us at [email protected].


7.                   CHILDREN’S PRIVACY

7.1               Protecting the privacy of young children is especially important. For that reason, We do not knowingly collect or solicit Personal Information from anyone under the age of 13.

7.2               In the event that we learn that we have collected Personal Information from a child under age 13, we will delete that information as quickly as possible.

7.3               If You believe that we might have any information from or about a child under 13, please contact us at [email protected].

8.                   OPT IN

8.1               If You wish to specifically opt for receiving non-essential communications such as promotional and marketing-related information regarding the Company, the Platform and the Services, please send the Company an email at [email protected].

9.                   DATA TRANSFER


9.1               Your Personal Information collected through the Platform may be stored and processed in India or any other country in which We or Our subsidiaries, affiliates or service providers maintain facilities. We may transfer information that We collect about You, including Personal Information, to affiliated entities, or to other third parties across borders and from Your country or jurisdiction to other countries or jurisdictions around the world. If Your Personal Information is transferred to another country, We will ensure that, where those countries are not deemed to have adequate protection, We have signed agreements incorporating the Model Contract Clauses to ensure the adequate protection of Your Personal Information.


10.               THE RIGHTS OF USERS


10.1           Users may exercise certain rights regarding their Data processed by the Company. In particular, Users have the right to do the following:

      Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.

      Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.

      Access their Data. Users have the right to learn if Data is being processed by the Company, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.

      Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.

      Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Company will not process their Data for any purpose other than storing it.

      Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Company.

      Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof.

      Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

      opt out of receiving any promotional or marketing material by clicking on the “Unsubscribe” button or by sending an email to [email protected]. Please note that if You withdraw Your consent, this will not affect the lawfulness of our use and processing of Your information if such processing is based on another lawful basis other than consent;

      Details about the right to object to processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Company or for the purposes of the legitimate interests pursued by the Company, Users may object to such processing by providing a ground related to their particular situation to justify the objection.


10.2           Generally, we do not rely on consent as a legal basis for processing Your Personal Information other than in relation to sending third party direct marketing communications to You via email or text message. You have the right to withdraw Your consent to marketing at any time by contacting us at [email protected]

10.3           Any requests to exercise User rights can be directed to the Company through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Company as early as possible and always within one month.

11.               LEGAL ACTION


11.1           The User's Personal Data may be used for legal purposes by the Company in court or in the stages leading to possible legal action arising from improper use of GoApptiv or the related Services. The User declares to be aware that the Company may be required to reveal personal data upon request of public authorities.



12.1           In addition to the information contained in this privacy policy, GoApptiv may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.



13.1           More details concerning the collection or processing of Personal Data may be requested from the Company at any time. Please see the contact information at the beginning of this document.



14.1           GoApptiv does not support “Do Not Track” requests.


14.2           To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.



15.1           The Company reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page and possibly within GoApptiv and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Company. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.


15.2           Should the changes affect processing activities performed on the basis of the User’s consent, the Company shall collect new consent from the User, where required.



16.               GRIEVANCE OFFICER


16.1           If you have any grievances with respect to the provision of the Services or any portion of this Privacy Policy, please contact us on [email protected]. Compliance officer should also be responsible to take care of any concerns pertaining to processing of information (under the Information Technology Act, 2000 and applicable rules).



Prepared by

Prepared on

Modified date

Approved by

Date of Approval & Adoption





Board of Directors

24-07-2020 as further approved on 27-07-2020