Privacy Policy

1.         Introduction

        At Neuroglia Health Private Limited, a company incorporated under the laws of India (“We/Our/Us” which expression shall mean and include its affiliates, successors and permitted assigns), owner of the website https://www.gliacircle.com/ or the equivalent mobile application available on Google Play Store or Apple Store  (“Site/Platform”), We take privacy of Our customers, or any other person visiting Our offices or using any website, portal, application or other platform provided by Neuroglia Health Private Limited or availing the products and services offered by Neuroglia Health Private Limited (“User/You/Your”) very seriously and are committed to protecting Your personal data. This privacy policy (“Privacy Policy”) outlines Neuroglia Health Private Limited’s commitment to protecting the personal data of its customers, and other stakeholders in accordance with applicable privacy laws and regulations. The Privacy Policy sets out how Your personal data is collected, used, stored, disclosed, transferred and shared by Us, ensuring transparency and respect for individuals' privacy rights. This policy establishes procedures for safeguarding personal information, managing data breaches, and ensuring that data subjects can exercise their rights. Adherence to this policy helps the organization maintain trust, reduce the risk of privacy violations, and comply with legal and regulatory obligations. Neuroglia Health Private Limited urges You to read this Privacy Policy carefully before You use Our Platform(s), use or opt to access any services of Neuroglia Health Private Limited or decide to part with any Information (as defined below) to Neuroglia Health Private Limited.      

By using or accessing Our Site/Platform, You acknowledge that You have read, understood, and agreed to the practices described in this Privacy Policy. If You do not agree with any of the terms of this Privacy Policy, please discontinue use of the Site/Platform immediately. If You do not agree with this Privacy Policy in its entirety, You agree to not use the Platform and any products and/or services provided by Neuroglia Health Private Limited on it. If You have any questions or comments regarding this Privacy Policy, please contact Us at support@gliacircle.com

We recommend You review Our Privacy Policy from time to time because Your use of Platform, Our products and Our services means Your acceptance of the prevailing Privacy Policy, including any amendments thereto.          

2.         Applicability and Scope  

        This Privacy Policy applies to all Users of the Site/Platform. We offer a range of services on the Platform either directly or through Our affiliates and/or subsidiaries, and availing such services shall imply acceptance of this Privacy Policy.

This Privacy Policy is a legally binding document between You and Neuroglia Health Private Limited. The terms of this Privacy Policy are effective upon Your acceptance of the same by clicking on the "I Accept” checkbox or by continuing to use the Platform. This Privacy Policy will govern the relationship between You and Neuroglia Health Private Limited for Your use of the Platform. You agree that even if You do not click the "I Accept" checkbox, if You continue to browse, use or access any or all of the Site/Platform, You have accepted the terms of this Privacy Policy.

You may be able to access third party websites directly from the relevant Site/Platform. This Privacy Policy is limited to Neuroglia Health Private Limited and the relevant Site/Platform and the disclosure and use of data collected by Us. If You visit any third party websites through the links on the Site/Platform, We recommend You properly review the privacy policies of each of those websites. Their data collection practices and their policies might be different and Neuroglia Health Private Limited does not have control over any of their policies and Neuroglia Health Private Limited disclaims all responsibility or liability with respect to these policies or the websites.

     3.         Data We Collect

We only collect Information that is relevant and required to meet regulatory compliances in relation to KYC requirements, assess Your demographic profile, conduct Our business or provide You with the relevant product or service.

        We collect several types of information during Your use of the Platform, including Your personal information (i.e., the information which identifies a User i.e., first and last name, identification number, email address, age, gender, location, photograph and/or phone number, device information, demographic information and other preferences and interests provided at the time of registration or any time thereafter on the Platform) from and about Users of Our Site, including:

3.1         Information You Provide Directly

        You may provide personal information directly to Us, including but not limited to:

3.2         Information Collected Automatically

        We use various technologies to collect information about Your device and Your activities on the Site automatically upon You visiting Our Site:

3.3         Information from Third Parties

        We also collect non-sensitive data from you, such as Your

● browser type,

● the URL of the previous website You visited,

● information about the pages viewed on the Site/Platform,

● how You navigate through the Site/Platform and interact with webpages etc.,

● your ISP,

● operating system types, clickstream patterns, and

● Your Internet protocol (IP) Address,

(“Non-Sensitive Personal Data or Information/Personal Information”).

Non-Sensitive Personal Data or Information/Personal Information cannot be used to personally identify You or the computer resource You are using.

We also contract with several online partners to help manage, monitor and optimize Our Site/Platforrm, and any services provided by Us and to help Us measure the effectiveness of Our advertising, communications and how visitors use Our Site/Platform. To do this, We may use web beacons and cookies, and We may collect data about You from third-party sources, including:

     

It is hereby clarified that while We do not intend to collect Your sensitive personal data or information (“SPDI”) (such as passwords, financial information, biometric information, sexual orientation, medical records and history or information about physical, physiological and mental health condition) during Our interactions with You; however We may require You to provide SPDI for verification purposes. A one-time access may be taken for camera, microphone, location or such other information as may be necessary for the purpose of such verification or as may be required pursuant to any regulatory or statutory requirement. The information collected in the course of Your verification shall solely be used for completing the verification and authenticating Your transactions on the Platform. However, if We are required to collect Your SPDI, We will process it only in accordance with the data protection laws of India (including obtaining express written consent, where required).

4.         How We Use Your Data

Any Information shared by You is used by Us and/or Our authorized third parties/service partners of [Company Name] to support Your interaction with us, to offer You services in the best possible manner and to contact You again about other services and products that We offer and/or the services and products offered by Our authorised third parties/ service partners which may be beneficial to youi, including:

4.1         Service Provision

        We use Your personal data to provide and maintain the Site’s features, including:

4.2         Personalization & User Experience

We process Your Information to provide You with better customer service, browsing experience and the relevant product or service, such as:

4.3         Marketing & Communication

        We may use Your data to communicate with You and promote Our services, including:

4.4         Security & Fraud Prevention

        We use personal data to detect, prevent, and mitigate fraud, abuse, or any unauthorized use of the Site. We also monitor for security breaches and may take proactive steps to safeguard Our systems and Users’ data.

5.         Legal Compliance

        We process personal data to comply with legal and regulatory obligations, including responding to court orders, subpoenas, and other lawful requests from government authorities. We may use personal information (including SPDI) to resolve disputes that may arise with the use of Our services, help promote a safe service to all the customers, measure consumer interest in Our services, customize Your experience, detect and protect Us against error, fraud and other criminal activity, and to enforce Our terms of use.

6.         Legal Basis for Processing Your Data

        We process Your personal data under the following legal basis:

7.         Data Sharing and Disclosure

Neuroglia Health Private Limited does not sell Your information to third parties.

Unless prohibited by laws and regulations, We may disclose Your Information to Our affiliates or to agents or third-party service providers appointed by Us in order to provide You with a better customer service and / or the relevant service and products. Notwithstanding the above, Your Sensitive Personal Data or Information will only be disclosed with Your explicit consent.

We may share Your personal data with the following categories of recipients:

7.1         With Service Providers

        We work with third-party service providers to facilitate certain services on Our behalf, including:

        These third parties are obligated to protect Your data and may only process it on Our instructions.

7.2         With Business Partners

        To provide discounts and offers, We may share Your data with business partners, including:

        These partners will only receive the minimum amount of data required to provide their services.

7.3         For Legal Purposes

        We may disclose Your Information to the Government, governmental entities or regulatory agencies as required by law, but We will only do so under proper authority. We may disclose Your information when required by law, regulation, or a valid legal process, including:

7.4         In Business Transactions

        In the event of a merger, acquisition, bankruptcy, or other significant business transaction, Your data may be transferred to the new owner or acquiring entity, provided they will be under an obligation to continue to protect Your personal data in accordance with their privacy policy.

8.         Data Retention

        We retain personal data for as long as necessary to fulfill the purposes for which it was collected or to comply with legal obligations. When the data is no longer required, We will take reasonable steps to delete or anonymize it in accordance with applicable legal requirements.    

We may retain the Information about You as long as Your User account is active or as needed to provide services to You.

If You wish to cancel Your account or request that Neuroglia Health Private Limited no longer use Your information to provide services, You may contact Us at support@gliacircle.com. Neuroglia Health Private Limited will then delete the Information as per Your request, unless such Information has to be retained to comply with [Company Name]’s legal obligations, resolve disputes, and for enforcing its agreements.

If You are no longer a User/customer of Neuroglia Health Private Limited, We will not retain Your Information longer than is necessary for the purposes for which it was obtained, unless it is required to be retained under applicable law.

9.        Inactive Accounts

        We may deactivate accounts that have been inactive for a prolonged period. In such cases, personal data will be securely archived or anonymized.

10.        Security Measures

        We protect Your Information using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure, and alteration. Some of the safeguards We use are firewalls, data encryption using SSL in transit, data at rest and information access authorization controls. We maintain strict security systems designed to prevent unauthorized access to Your Information by anyone, including Our employees, affiliates, agents or appointed third party service providers. We store and process Your Information on reputed web service cloud servers. We store Information using industry standard, reasonable and technically feasible, physical, technical and administrative safeguards against foreseeable risks, such as unauthorized access.

        While We strive to protect Your data, no system can be completely secure. You understand and accept that there is no guarantee that data transmission over the Internet will be completely secure and that any information that You transmit to Us is at Your own risk. You are responsible for safeguarding Your account credentials and ensuring that Your devices are secure. We directly or indirectly through third party service providers maintain electronic and procedural safeguards in connection with the collection, storage, and disclosure of Your information. Our security procedures mean that We may occasionally request proof of identity before We disclose any information to You that belongs to You. Subject to applicable laws, We assume no liability for any disclosure of Your Information due to transmission errors, unauthorized third-party access to the Site/Platform and Our databases or other acts of third parties or acts or omissions beyond Our reasonable control and You shall not be entitled to hold Neuroglia Health Private Limited responsible for any breach of security.

11.         How can You protect Your Information?

You should be careful that Your user ID(s) and/or passwords/personal identification numbers (PIN) are not compromised by ensuring that You do not knowingly or accidentally share, provide or facilitate unauthorized use of it. Please do not share Your OTPs, user ID and/or password or allow access or use of it by others. We endeavour to put in place high standards of security to protect Your interests.

     

You should safeguard Your unique user ID(s) and Passwords/PINs by keeping them secret and confidential. Kindly never write them down or share these details with anyone. If a password is used to help protect Your accounts and Information, You are responsible for keeping Your password confidential. Do not share this information with anyone. If You are sharing a computer with anyone You should always log out before leaving the Site or service to protect access to Your information from subsequent users.

     

Except in the course of a transaction done by You, Neuroglia Health Private Limited will never ask You for Your passwords/PINs, to ensure that You are the only person who knows this information. When choosing Your unique User ID and password for the first time, do not create it using easily identifiable information such as Your birthday, telephone number or a recognizable part of Your name. If You think Your User ID and/or passwords/PINs have been disclosed to the third party are lost or stolen and unauthorized transactions may have been conducted, You are responsible for informing Us immediately.    

12.         Your Data Protection Rights

You may, at any time, not provide Neuroglia Health Private Limited with the Information that Neuroglia Health Private Limited seeks to collect.

You have the option to ‘opt-out’ of all Neuroglia Health Private Limited newsletters and other general e-mail marketing communications by way of links provided at the bottom of each mailer.

Neuroglia Health Private Limited respects Your privacy and in the event that You choose to not receive such mailers, it shall take all adequate steps to remove You from such lists. However, You will not be able to opt-out of receiving administrative messages, customer service responses or other transactional communications. Right to Access: Request a copy of the personal data we hold about you.

Right to Correction: Request the correction of inaccurate or incomplete data.

Right to Withdraw Consent: Where data is processed based on consent, you can withdraw your consent at any time. Even after You have provided Neuroglia Health Private Limited with any Information, You may withdraw the consent given earlier by writing to Us at [insert relevant contact details]. In such cases, Neuroglia Health Private Limited reserves the right to not provide or discontinue the provision of any product or service or Platform that is linked with such Information.     We may display personal testimonials of satisfied customers on the Site/Platform in addition to other endorsements with consent of the relevant User. If You wish to update or delete Your testimonial, You can contact Us at support@gliacircle.com

To exercise these rights, contact Us at support@gliacircle.com. We may require You to verify Your identity before fulfilling Your request.

13.         Children’s Privacy

        Our Site is not directed toward individuals under the age of 18 years, and We do not knowingly collect personal data from anyone under this age. If You believe We have inadvertently collected such data, please contact Us, and We will take steps to delete/destroy the information. Our Site is not intended for use by children and minors. Parents are requested to ensure that personal information is not provided by minors.

14.         Third-Party Websites

        Our Site may contain links to third-party websites or services. We are not responsible for the privacy practices or content of these third parties. We recommend reviewing the privacy policies of any third-party websites You visit before providing personal information. We will not be liable for breach of personal information by such third party websites or services.

15.         Data Breach Notification

        In the unlikely event of a data breach, We will notify You and the relevant supervisory authority where legally required. We will provide details of the breach, its potential impact, and the measures We are taking to mitigate the risks and prevent future breaches.

16.         Changes to This Privacy Policy

        We may modify/change/update this Privacy Policy at any time to reflect changes in Our business practices, legal obligations, or regulatory requirements. We will post any updates on this page, and where necessary, We will notify You via email or other communication methods. However, any failure or delay by [Company Name] to update You of the changes to the Privacy Policy will not impact the validity and effectiveness of those changes. Your continued use of the Site following any changes indicates Your acceptance of the revised policy.    

Users are encouraged to periodically review this page for the latest information on its privacy practices.

Each time You access, use or browse the Site, You signify Your acceptance of the then-current changes to the Privacy Policy applying to Your Information collected by us, on and from the effective date of such changes.

17.         Severability

Neuroglia Health Private Limited has made every effort to ensure that this Privacy Policy adheres to the applicable laws. The invalidity or unenforceability of any part of this Privacy Policy shall not prejudice or affect the validity or enforceability of the remainder of this Privacy Policy. 

18.         Limitation of Liability

Notwithstanding anything contained in this Privacy Policy or elsewhere but subject to applicable law, [Company Name] shall not be responsible for any loss, damage or misuse of Your Information, if such loss, damage or misuse is attributable to a Force Majeure Event.  A “Force Majeure Event” shall mean any event that is beyond the reasonable control of [Company Name] and shall include, without limitation, sabotage, fire, flood, explosion, acts of God, civil commotion, strikes, lockouts or industrial action of any kind, riots, insurrection, war, acts of government, pandemic, computer hacking, civil disturbances, unauthorised access to computer data and storage device, computer crashes, breach of security and encryption, and any other similar events not within the control of Neuroglia Health Private Limited and which Neuroglia Health Private Limited is not able to overcome.

19.         Contact Us

        If You have any questions, concerns, or requests related to this Privacy Policy, please contact Us using the following details:

20.         All other terms and conditions as applicable under the Terms and Conditions of Service at https://www.gliacircle.com/terms-and-conditions will be applicable to You and will be read along with this Privacy Policy.