PRIVACY POLICY
By Oros Health
February 13,2024
Your privacy matters to Orostext, LLC, referred to by the terms: the “Company”, “Oros”, “we”, “us”, “our” in this Privacy Policy. Orostext, LLC is a limited liability company formed under the laws of the State of Texas and has its corporate office at (address).
This privacy policy explains how we collect, process, use, share and protect information about you.
This Privacy Policy covers the online services provided by us (e.g., web services including any website owned and operated by us such as https://www.oroshealth.com and our Mobile Application Oros Health). The services that we offer are collectively referred to as the “Services”.
This Privacy Policy applies to your use of interactive features or downloads that:
we own or control.
are available through the Oros Health platform.
interact with the Services.
post or incorporate this Privacy Policy.
By accepting The Terms and Conditions, you are also agreeing to The Terms Of This Privacy Policy. Please review the following carefully so that you understand our privacy practices. If you do not agree to this Privacy Policy, do not accept the Terms and Conditions or use our Services. This Privacy Policy is incorporated by reference into the Terms and Conditions.
1. Definitions
Unless otherwise provided in this Privacy Policy, the terms capitalized in the Privacy Policy shall have the meaning as provided hereunder:
“Co-branded Services” shall have the meaning assigned to the term in paragraph 4(c) hereto.
“Device” shall mean computer, mobile phone or any other device used to access the Services.
“Device Identifier” shall mean IP address or any other unique identifier for the Device.
“Mobile Application” shall mean application provided by us on the Device to access the Services.
“Mobile Device Information” shall have the meaning assigned to the term in paragraph 2(d)(ii) hereto.
“Oros Health” shall mean the Company, its successors, affiliates and permitted assigns.
“Promotion” shall mean any contest or promotion offered by us.
“Protected Information” shall mean such categories of information that could be used to identify you personally, including your name, e-mail address and mobile number.
“TPSP” shall mean a third-party service provider.
“Usage Information” shall have the meaning assigned to the term in paragraph 2(b)(i) hereto.
Sope
The Privacy Policy applies to the Services, Application, or any online application linking to it,The Policy is applicable regardless of whether the Application is accessed via mobile devices or other computer resources.
Oros Health is a public mental health platform. User-generated content, including user handles, profile pictures, and posts, is publicly available and searchable globally.
Users are advised not to post personal or sensitive information on the Application. Updates posted on the Application are visible to other users based on the chosen privacy settings
By providing public content on Oros Health, users authorize the disclosure of that information on the Application for wide circulation
2. What Information Do We Collect?
Information That You Provide To Us
We may ask you to provide us with certain Protected Information. We may collect such information through various means through the Services, including account registration forms, contact us forms or when you otherwise interact with us. When you sign up to use the Services, you create a user profile. We shall ask you to provide only such Protected Information which is for lawful purposes connected with our Services and necessary for us to collect for providing the Services. The current data fields that may be requested for are:
Full name
Email id
Password
Mobile phone number
Zip code
Information That We Collect When You Access And Use Our Services
In addition to any Protected Information or other information that you choose to submit to us, we and our TPSP may use a variety of technologies that automatically (or passively) collect certain information whenever you visit or interact with the Services (“Usage Information”). This Usage Information may include the browser that you are using, the URL that referred you to our Services, the services that you use on our platform and the time of day of usage, among other information. In addition, we collect your Device Identifier for identifying your Device. A Device Identifier is a number that is automatically assigned to your Device used to access the Services. Our computers identify your Device by its Device Identifier.
In case of contacting via call centre, Oros Health may record calls and chat histories for quality and training purposes.
We may automatically gather data about your interactions with the OROS AI chatbot services, including the content you inquire about or interact with. This information is collected to enhance and educate the chatbot for future interactions.
We may collect any additional information or document that you may have shared with us to facilitate the use of our Services.
Tracking information is collected as you use our Services, including, but not limited to geographic areas.
In case you place requests for services organized/ sponsored/ initiated through the Oros Health platform, we may collect some additional information, which may include sensitive personal information, such as medical reports and other such documentary evidence to validate the authenticity of your request for such services.
In case you upload an emergency contact (name and phone number) on your account/ on the Mobile Application, we will be collecting and storing such contact information for use in case of an emergency situation.
In case you refer a friend to our Services, we will be collecting and storing such contact information (name and phone number) to get in touch with your friend for promoting our Services.
Usage Information may be collected using a cookie. In case you do not want your information to be collected through the use of cookies, your browser allows you to deny or accept the use of cookies. Cookies can be disabled or controlled by setting a preference within your web browser or on your Device. If you choose to disable cookies or flash cookies on your Device, some features of the Services may not function properly or we may not be able to customize the delivery of information to you. The Company cannot control the use of cookies (or the resulting information) by third parties. The use of third-party cookies is not covered by our Privacy Policy.
Information That Third Parties Provide About You
We may, from time to time, supplement the information we collect about you through our website or Mobile Application or Services with outside records from third parties.
Information Collected By Mobile Applications
Our services are primarily provided through our Mobile Application. We may collect and use technical data and related information, including but not limited to technical information about your device, system and application software and peripherals that is gathered periodically to facilitate the provision of software updates, product support and other services to you (if any) related to our Mobile Applications.
When you use any of our Mobile Applications, the Mobile Application may automatically collect and store some or all of the following information from your mobile device (“Mobile Device Information”), in addition to the Device Information, including without limitation:
Your location
Your preferred language
The manufacturer and model of your mobile device.
Your mobile operating system
The type of mobile internet browsers that you are using
Your geolocation
Information about how you interact with the Mobile Application and any of our websites to which the Mobile Application links, such as how many times you use a specific service on our Mobile Application over a given time period, the amount of time you spend using the Mobile Application, how often you use the Mobile Application, actions you take in the Mobile Application and how you engage with the Mobile Application Information to allow us to personalize the services and content available through the Mobile Application.
Data from SMS/ text messages upon receiving Device permission for the purposes of:
issuing and receiving one-time passwords and other device verification and
automatically filling verification details during financial transactions, either through us or through a third-party service provider, in accordance with applicable law.
We do not share or transfer SMS/ text message data to any third party other than as provided under this Privacy Policy.
E. Information Collected By TPSP Advertising On Oros Website Or Mobile Applications
Oros Health may advertise TPSP services or products on its website or Mobile Application.
3. Use Of Information Collected
Our primary goal in collecting your information is to provide you with an enhanced experience when using the Services. We use your information to closely monitor which features of the Services are used the most. We monitor usage patterns and geographic locations to improve the Services, features and/ or resources.
Based on the Protected Information that you provide us when registering for an account, we will send you an email to verify your username and password.
We use the information collected from our Mobile Application to provide you with the correct app version depending on your device type, for troubleshooting and in some cases, marketing purposes.
We use your Internet Protocol (IP) address to help diagnose problems with our computer server, and to administer our web site(s). Your IP address is used to help identify you, but contains no personal information about you.
We will send you strictly service-related announcements on rare occasions when it is necessary to do so. For instance, if our Services are temporarily suspended for maintenance, we may send you an email. If you do not wish to receive emails from us, you have the option to deactivate your account.
We may use the information obtained from you to prevent, discover and investigate violations of this Privacy Policy or any applicable terms of service or terms of use for the Mobile Application and to investigate fraud, chargeback or other matters.
We use the geo-location information to send you promotions and offers.
In addition, we may use the Protected Information or Usage Information that we collect about you:
to provide you with information or services or process transactions that you have requested or agreed to receive such as electronic newsletters, or to provide you with special offers or promotional materials on behalf of us or third parties.
to enable you to participate in a variety of the Service’s features such as online or mobile entry contests or other promotions.
to contact you with regard to your use of the Services and/ or the Services’ policies.
for internal business purposes
for inclusion in our data analytics and
for purposes disclosed at the time you provide your information or as otherwise set forth in this Privacy Policy.
We may share the information collected from you with any such third parties if you choose to avail any service offered by Oros Health or a third party on the Mobile Application. We may use the information collected from you for targeted advertising. This involves using information collected on an individual’s web or mobile browsing behaviour such as the pages they have visited or the searches they have made. This information is then used to select which advertisements should be displayed to a particular individual on websites other than our website(s). The information collected is only linked to an anonymous cookie ID (alphanumeric number); it does not include any information that could be linked to a particular person, such as their name, address or credit card number.
4. How And When Do We Disclose Information To Third Parties
We do not sell, share, rent or trade the information we have collected about you, other than as disclosed within this Privacy Policy or at the time you provide your information. Following are the situations when information may be shared:
a) When You Agree to Receive Information From Third Parties:
You may be presented with an opportunity to receive information and/ or marketing offers directly from third parties. If you do agree to have your Protected Information shared, your Protected 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 before agreeing to receive information or services from them. If you later on decide that you no longer want to receive communication from a third party, you will need to contact that third party directly.
b) Third Parties Providing Services On Our Behalf:
We use third party companies and individuals to facilitate our Services and to provide or perform certain services on our platform- such as therapists that provide their services on our platform and other third parties that:
host the Services
design and/ or operate the Services’ features
track the Services’ analytics
process payments
engage in anti-fraud and security measures
provide customer support
provide geo-location information
enable us to send you special offers
host our job application form
perform technical services (e.g., without limitation, maintenance services, database management, web analytics, and improvement of the Services’ features)
perform other administrative services.
These third parties will have access to User Information including Protected Information to only carry out the services that they are performing for you or for us. Each of these third parties are required to ensure the same level of data protection as us and are obligated not to disclose or use Protected Information for any other purpose.
TPSPs may set and access their own cookies, web beacons and embedded scripts on your Device and they may otherwise collect or have access to information about you, including non-personally identifiable information. We use a third-party hosting provider who hosts the support section of our platform. Information collected within this section of our platform by such third-party is governed by our Privacy Policy.
c) Co-Branded Services:
Certain aspects of the Services may be provided to you in association with third parties (“Co-Branded Services”) such as sponsors and charities and may require you to disclose Protected Information to them. Such Co-Branded Services will identify the third party. If you elect to register for products and/ or services through the Co-Branded Services, you shall have deemed to consent to providing your information to both us and the third party. Further, if you sign in to a Co-Branded Service with a username and password obtained through our Services, your Protected Information may be disclosed to the identified third parties for that Co-Branded Service and will be subject to their posted privacy policies.
d) Contests And Promotions
We may offer Promotions through the Services that may require registration. By participating in a Promotion, you are agreeing to the official rules that govern that Promotion, which may contain specific requirements of you, including, allowing the sponsor of the Promotion to use your name, voice and/ or likeness in advertising or marketing associated with the Promotion. If you choose to enter a Promotion, you agree that your Protected Information may be disclosed to third parties or the public in connection with the administration of such Promotion, including, in connection with winner selection, prize fulfilment, and as required by law or permitted by the Promotion’s official rules, such as on a winners list.
e) Administrative And Legal Reasons:
We cooperate with Government and law enforcement officials and private parties to enforce and comply with the law. Thus, we may access, use, preserve, transfer and disclose your information (including Protected Information, IP address, Device Information or geo-location data) to Government or law enforcement officials or private parties as we reasonably determine is necessary and appropriate:
to satisfy any applicable law, regulation, subpoenas, Government requests or legal processes,
to protect and/ or defend the Terms and Conditions for online and mobile Services, including investigation of potential violations thereof,
to protect the safety, rights, property or security of the Company, our Services or any third party,
to protect the safety of the public for any reason,
to detect, prevent or otherwise address fraud, security or technical issues and/ or
to prevent or stop activity we may consider to be or to pose a risk of being an illegal, unethical or legally actionable activity.
f) When You Share Information:
Protected Information may be collected and shared with third parties if there is content from the Mobile Application that you specifically and knowingly upload to, share with or transmit to an email recipient, online community, website or to the public (e.g., uploaded photos, posted reviews, comments or information about your experience with our Services that you choose to share with others through features which may be provided on our Services). This uploaded, shared or transmitted content will also be subject to the privacy policy of the email, online community website, social media or any platform to which you upload, share or transmit the content.
g) Business Transfer:
We may share your information including your Protected Information and Usage Information with our parent, subsidiaries and affiliates for internal reasons, including business and operational purposes. We also reserve the right to disclose and transfer all such information:
to a subsequent owner, co-owner or operator of the Services or applicable database, or
in connection with a corporate merger, consolidation, restructuring, the sale of substantially all of our membership interests and/ or assets of other corporate change, including, during the course of any due diligence process.
h) Market Study And Other Benefits:
We may share your information including your Protected Information and Usage Information with third parties for any purpose, including but not limited to undertaking market research/ study, conducting data analysis, determining or customizing product or service offerings, to improve the products or Services or to make any other benefit/ products/ services available to you.
5. Third-Party Content And Links To Third Party Services:
The Service may contain content that is supplied by a third party and such third parties may collect website usage information and your Device Identifier when web pages from any online or mobile Services are served to your browser. In addition, when you are using the Services, you may be directed to other sites or applications that are operated and owned by third parties that we do not control.
We are not responsible for the privacy practices employed by any of these third parties. For example, if you click on a banner advertisement, you may be directed away from our platform onto a different website. These other websites may send their own cookies to you, independently collect data or solicit Protected Information and may or may not have their own published privacy policies. We encourage our users to note when you leave our Services and to read the privacy statements of all third-party websites or applications before submitting any Protected Information to third parties.
6. Social Media Feature And Widgets:
Our online and mobile Services may include social media features such as the Facebook like button and widgets such as a “Share This” button, or interactive mini-programs that run on our online and mobile Services. These features may collect your IP address, photograph, details about the pages you visited on our online or mobile Services and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our online Services. Your interactions with these features and widgets are governed by the privacy policy of the company providing them.
7. Information Collected By Other Users
This privacy policy shall not cover the usage of any information about you which is obtained by other Registered Users on our Platform while communicating with you.
8. Information Collected By Therapists:
This Privacy Policy shall not cover the usage of any information about you which is obtained by a therapist or the company to which they belong to while providing you their services on our platform.
9. Change of Information Or Cancellation of Account:
You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information provided as part of account registration. If your Protected Information changes, you may correct or delete inaccuracies or amend information by making the change on our member information page. We will make efforts to make the requested changes in our then active databases as soon as possible.
You may also cancel or modify your communications that you have elected to receive from the Services by following the instructions contained within an email from us or by logging into your user account and changing your communication preferences.
If upon modifying or changing the information earlier provided to us, we find it difficult to permit access to our Services to you due to insufficiency/ inaccuracy of the information, we may, in our sole discretion terminate your access to the Services by providing you a written notice to this effect on your registered email id.
If you wish to cancel your account or request that we no longer use your information to provide you the Services, contact us through the email address mentioned on our website or Mobile Application. We will retain your Protected Information and Usage Information for as long as your account with the Services is active and needed to provide you the Services. Even after your account is terminated, we will retain your Protected Information and Usage Information (including transaction history) as needed to comply with our legal and regulatory obligations, resolve disputes, conclude any activities related to cancellation of an account, investigate or prevent fraud and other inappropriate activity, to enforce our agreements, and for other business reasons. After a period of time, your data may be anonymized and aggregated, and then may be held by us as long as necessary for us to provide our Services effectively. However, our use of the anonymized data will be solely for analytic purposes.
10. Security
The Protected Information and Usage Information that we collect is securely stored within our databases, and we use standard, industry-wide, commercially reasonable security practices such as encryption, firewalls and SSL (Secure Socket Layers) for protecting your information. However, as effective as encryption technology is, no security system is impenetrable. We cannot guarantee that the information you supply to us won’t be intercepted while being transmitted to us over the internet or wireless communication, and any information you transmit to the Company, you do at your own risk. We recommend that you do not disclose your password to anyone.
11. Grievance Officer
Oros Health hereby appoints Oros Support Manager as the grievance officer for the purposes of the rules drafted under the Information Technology Act, 2000, who may be contacted at (support@__________.com). You may address any grievances you may have in respect of this Privacy Policy or usage of your Protected Information or other data to them.
12. Changes To The Privacy Policy:
From time to time, we may update this Privacy Policy to reflect changes to our privacy practices. Any change will be effective immediately upon the posting of the revised Privacy Policy. If we make any material changes, we will notify you by email (sent to the email address specified in your Oros Health Account) or by means of a notice on our Platform prior to the change becoming effective. We encourage our users to periodically review this page for the latest information about our privacy practices.
If you have any questions about this Privacy Policy, please contact us through the email address provided on our website and/ or on our mobile application.