Legal
Privacy Policy
Draft, not yet legally reviewed
This privacy policy is an unreviewed draft prepared as a starting point. It must be reviewed and approved by a qualified legal professional, and all placeholders completed, before this website goes live.
This Privacy Policy explains how we collect, use, store and protect your personal data, including health-related data, when you use our website and take part in our corporate wellness programmes. It is written in line with the principles of India’s Digital Personal Data Protection Act, 2023 (the "DPDP Act").
Who we are
- Legal name
- EDIT ME: registered company name, for example Inmarkai Wellness Private Limited
- Registered address
- EDIT ME: full registered address, including city, state and PIN code
- Registration
- EDIT ME: company identification number (CIN or registration number)
- siddharth@inmarkai.com
1. The personal data we collect
We collect only the data we need to deliver and improve your wellness programme. Depending on how you interact with us, this may include:
- Identity and contact data, such as your name, work email address, phone number, employer and job function.
- Programme data, such as attendance and participation records, session bookings, tournament sign-ups, and the goals you set with your coach.
- Health and fitness data, such as height, weight, body composition, resting heart rate, activity levels, injury history, dietary preferences and restrictions, and similar measurements you choose to share.
- Nutrition data collected by our registered dietitians during consultations, including food diaries and dietary assessments.
- Mental wellbeing data, meaning information you share during counselling, assessment or therapy sessions with our clinical psychologists.
- Website and technical data, such as IP address, browser type, device type and pages visited, collected to keep the website secure and working correctly.
- Communications, meaning messages you send us through our contact form or by email.
We treat health data and mental wellbeing data as sensitive. We apply stricter access controls, stricter sharing rules and stricter retention rules to them, as described below.
2. How we collect it
- Directly from you, through assessments, consultations, forms, sessions and messages.
- From your employer, limited to onboarding information such as your name, work email and department, so we can enrol you in the correct programme.
- Automatically, meaning basic technical information collected by our website and platform for security and reliability.
3. Why we use your data, and our lawful basis
Under the DPDP Act we process your personal data on the basis of your consent, or where processing is necessary for a legitimate use permitted by law. We use your data to:
- Design, deliver and adjust your individual wellness programme.
- Schedule sessions and tournaments, and communicate with you about them.
- Produce aggregated, de-identified reporting for your employer on programme participation and overall outcomes.
- Respond to your enquiries and provide support.
- Keep our website and platform secure, and comply with our legal obligations.
We do not sell your personal data. We do not use your personal data to make automated decisions that produce legal or similarly significant effects on you.
4. What your employer can and cannot see
Your mental health information is never shared with your employer.
Anything you discuss in a counselling, psychological assessment or therapy session, including the fact of what was discussed, any notes, and any clinical observations, is confidential between you and our clinical psychologist. It is never disclosed to your employer, your manager or your HR team, in any form, whether identified or otherwise.
More generally, employers receive reporting only at an aggregated and de-identified level. Your employer can see:
- Overall participation and attendance rates across the organisation or a large team.
- Aggregate, anonymised trends across a group, reported only where the group is large enough that no individual can reasonably be identified.
- Programme delivery information, such as sessions run, tournaments held and formats offered.
Your employer does not receive:
- Any mental health or counselling information whatsoever.
- Your individual health measurements, assessment results or fitness data.
- Any dietary assessment, food diary or nutrition plan prepared for you.
- Notes from your one to one sessions with any of our professionals.
- Any report about you as an identified individual.
The only exceptions are where you give us your specific, informed and freely given consent to share something in particular, or where disclosure is strictly required by law or is necessary to prevent a serious and imminent risk to life or safety. Where such an exception applies, we will limit the disclosure to the minimum necessary and, wherever it is lawful and safe to do so, tell you about it.
6. How we keep your data secure
We take reasonable security safeguards to prevent personal data breaches, including:
- Encryption of data in transit and at rest.
- Role-based access controls, so staff can only reach the data their role requires.
- Separate, more tightly restricted storage for mental wellbeing records.
- Confidentiality agreements binding every member of our team and every professional we work with.
- Logging, periodic access reviews and a defined process for responding to any suspected breach.
If a personal data breach occurs, we will notify the Data Protection Board of India and each affected person in the manner and within the timelines required by the DPDP Act.
7. How long we keep your data
We keep personal data only for as long as it is needed for the purpose it was collected for, or for as long as the law requires. Our retention periods are:
- EDIT ME: contact and enquiry data, for example 24 months from your last contact with us.
- EDIT ME: programme, participation and tournament records, for example for the duration of the programme plus 12 months.
- EDIT ME: health, fitness and dietary assessment data, for example for the duration of the programme plus 12 months.
- EDIT ME: mental wellbeing and clinical records. Confirm the retention period your clinical psychologists are required to observe under applicable professional and legal standards.
- EDIT ME: billing and statutory records, for example 8 years, as required by tax and company law.
When a retention period ends, we securely delete the data or irreversibly anonymise it so that it can no longer be linked to you.
8. Your rights
Under the DPDP Act, as a Data Principal you have the right to:
- Access, meaning you can obtain a summary of the personal data we hold about you and how we process it.
- Correction, meaning you can have inaccurate or incomplete data corrected, completed or updated.
- Erasure, meaning you can ask us to delete your personal data where it is no longer needed for the purpose it was collected for, and where no law requires us to keep it.
- Withdraw consent at any time, as easily as you gave it. Withdrawal does not affect processing that already took place, and may mean we can no longer deliver parts of the programme.
- Grievance redressal, meaning you can raise a complaint with our Grievance Officer about how we have handled your data.
- Nominate another individual to exercise your rights on your behalf in the event of your death or incapacity.
- Complain to the Board, meaning you can escalate an unresolved complaint to the Data Protection Board of India.
To exercise any of these rights, contact our Grievance Officer using the details on this page. We may need to verify your identity before we act on a request.
9. Children and persons with disabilities
Our services are intended for adults in employment. We do not knowingly collect personal data from anyone under the age of 18. Where we ever process the data of a child, or of a person with a disability who has a lawful guardian, we will obtain verifiable consent from the parent or lawful guardian as required by the DPDP Act, and will not carry out tracking, behavioural monitoring or targeted advertising directed at them.
11. Changes to this policy
We may update this policy as our services or the law change. We will update the "last updated" date at the top of this page, and where the change is significant we will notify you directly.
12. Contacting us
For any question about this policy, or about how we handle your personal data, contact our Grievance Officer using the details listed on this page.
Grievance Officer
If you have a question or a complaint about how we handle your personal data, contact our Grievance Officer. We aim to respond EDIT ME, for example within 30 days of receiving your request.
- Name
- EDIT ME: Grievance Officer full name
- Designation
- EDIT ME: designation, for example Data Protection & Grievance Officer
- EDIT ME: grievance@inmarkai.com
- Phone
- EDIT ME: contact number
- Address
- EDIT ME: postal address for written grievances