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Privacy Policy

1. Introduction

Thremear is committed to safeguarding your privacy. This Privacy Policy outlines how we collect, use, disclose, and protect your personal information when you use Hormoon (the “App”). By using the App, you agree to the terms of this Privacy Policy.

2. Information We Collect

2.1. Personal Information

We collect personal information that you provide to us, including but not limited to:

  • Identity Data: Full name, date of birth, gender.
  • Contact Data: Email address, phone number.
  • Account Credentials: Username, password.

2.2. Health and Wellness Information

To provide personalized insights, we collect:

  • Menstrual Cycle Data: Start and end dates, flow intensity.
  • Symptom Tracking: Mood, physical symptoms, sexual activity.
  • Lifestyle Information: Sleep patterns, exercise routines, dietary habits.

2.3. Device and Usage Data

We automatically collect information about your device and how you interact with the App, such as:

  • Device Information: Device type, operating system, and unique device identifiers.
  • Usage Data: Features used, time spent on the App, interaction patterns.
  • Location Data: Approximate geographic location based on IP address.

2.4. Cookies and Tracking Technologies

We use cookies and similar technologies to enhance user experience, analyze usage patterns, and deliver personalized content. You can manage your cookie preferences through your device settings.

3. How We Use Your Information

We use the collected information to:

  • Provide, maintain, and improve the App’s functionality.
  • Personalize user experience and deliver tailored insights.
  • Communicate with you, including sending notifications and promotional messages.
  • Conduct research and analysis to enhance our services.
  • Ensure compliance with legal and regulatory obligations.

4. Legal Basis for Processing

We process your data based on the following legal grounds:

  • Consent: We rely on your explicit consent to process health-related data. You can withdraw your consent at any time through the App settings.
  • Legitimate Interests: For purposes such as improving the App, ensuring security, and conducting research.
  • Legal Obligations: Compliance with applicable laws and regulations.

5. Data Sharing and Disclosure

5.1. With Your Consent

We may share your information with third parties when we have obtained your explicit consent. Service Providers

We engage third-party service providers to perform functions on our behalf, such as data hosting, analytics, and customer support. These providers are contractually obligated to protect your information and use it solely for their services.

5.3. Legal Requirements

We may disclose your information if required to do so by law or in response to valid requests by public authorities.

5.4. Business Transfers

In the event of a merger, acquisition, or sale of assets, your data may be transferred to the involved parties. We will notify you of any such change in ownership.

6. Data Security

We implement appropriate technical and organizational measures to protect your data against unauthorized access, alteration, disclosure, or destruction. These measures include encryption, access controls, and secure data storage.

7. Data Retention

We retain your data only as long as necessary to fulfill the purposes outlined in this Privacy Policy. When we no longer need to use your information, we will securely delete or anonymize it.

8. Your Rights

Under applicable data protection laws, you have the following rights:

  • Access: Request a copy of the personal data we hold about you.
  • Correction: Request correction of inaccurate or incomplete data.
  • Deletion: Request deletion of your data, subject to certain exceptions.
  • Objection: Object to the processing of your data in certain circumstances.
  • Data Portability: Request transfer of your data to another service provider.

To exercise these rights, please contact us at [Contact Information].

9. Children’s Privacy

The App is not intended for use by individuals under the age of 18. We do not knowingly collect personal data from children without parental consent. If we become aware that we have collected data from a child without verification of parental consent, we will take steps to delete that information.

10. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence. These countries may have data protection laws that differ from those in your jurisdiction. We ensure that such transfers comply with applicable legal requirements and that your data remains protected.

11. Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our practices or legal requirements. We will notify you of any significant changes by posting the new policy on our website and updating the “Last Updated” date. Your continued use of the App after such changes constitutes your acceptance of the revised policy.

12. Contact Us

If you have any questions or concerns about this Privacy Policy or our data practices, please contact us at:

Thremear Private Limited

Pl.No.672, II Cross Street, Sridevi Karumariamman Nagar, Nandampakkam, Kancheepuram, Tamil Nadu- 600069, India

thremear@gmail.com

9025203460

13. Governing Law

This Privacy Policy is governed by and construed by the laws of India, without regard to its conflict of law principles.

14. Additional Information for Indian Users

In compliance with the Digital Personal Data Protection Act, 2023 (DPDP Act), we adhere to the following principles:

  • Data Minimization: We collect only the data necessary to provide our services.
  • Purpose Limitation: We process data solely for the purposes specified in this policy.
  • Storage Limitation: We retain data only for as long as necessary to fulfill the stated purposes.
  • Data Fiduciary Responsibilities: Since your app collects health data, it is classified as Sensitive Personal Data (SPD) under the DPDP Act. You must explicitly define how consent is collected, stored, and withdrawn to ensure compliance.
  • Grievance Redressal Mechanism: Include an appointed Data Protection Officer (DPO) or Grievance Officer with contact details for handling data-related complaints.

For more information about your rights under the DPDP Act, please visit [Link to DPDP Act Information].

15. Compliance with Medical Device Regulations

As a health-related application, we comply with the Medical Device Rules, 2017, and guidelines set forth by the Central Drugs Standard Control Organization (CDSCO) in India. This includes ensuring the safety and efficacy of our services and maintaining appropriate records.

  • Clinical Validation Statement: If your app is classified under In Vitro Diagnostic (IVD) Class B, you must mention that the data collected is used for clinical research purposes in compliance with CDSCO’s Clinical Evaluation Report (CER) guidelines.
  • Data Sharing with Regulators: Clearly state that personal data may be shared with CDSCO or other regulatory bodies for licensing, audits, or safety compliance.
  • Third-party lab integration: If your app integrates with diagnostic labs or wearable devices, you need a section explaining how third-party entities handle health data.

16. Research and Development

With your explicit consent, we may use de-identified data for research and development purposes to improve our services and contribute to scientific knowledge. Participation in such research is voluntary, and you may withdraw your consent at any time.

  • Institutional Ethics Committee (IEC) Approval: Any research using user data should comply with ICMR (Indian Council of Medical Research) guidelines, ensuring ethical approval before data use.
  • Biometric and AI Data Governance: If your app uses AI for predictions, mention how AI models are trained while ensuring data security.

17. Third-Party Links

The App may contain links to third-party websites or services. We are not responsible for the privacy practices of such third parties. We encourage you to read their privacy policies before providing any personal data.

18. In-App Purchases

If you make in-app purchases, payment information is processed by third-party payment processors. We do not store your payment card details. These transactions are subject to the privacy policies of the payment processors.

19. User Testimonials

With your consent, we may post your testimonials along with your name. If you wish to update or delete your testimonial, please contact us.

20. Social Media Features

Our App may include social media features, such as sharing buttons. These features may collect your IP address and the page you are visiting, and may set a cookie to enable the feature to function properly. Your interactions with these features are governed by the privacy policy of the providing company.

21. Push Notifications

We may send you push notifications to inform you about updates or promotional offers. You can opt out.

22. Additional Strengthening for Legal and Compliance Framework

🔹 Standard Operating Procedures (SOPs) for Data Breach Response
Clearly define:

  • How will users be notified in case of a data breach?
  • Timeframe for reporting breaches to CERT-In (Indian Cybersecurity Agency).

🔹 Informed Consent for Biometric Data Collection

  • If the app collects heart rate, body temperature, or other biometric markers, you need an explicit consent mechanism (as per the IT Act, 2000, and DPDP 2023).