Privacy Policy

THIS PRIVACY POLICY (“PRIVACY POLICY”) SETS FORTH THE MANNER IN WHICH USEKIWI INFOLABS PRIVATE LIMITED (“COMPANY”, “AFFORDPLAN”, “WE”, “US”, OR “OUR”) COLLECTS, USES, STORES, SHARES, AND PROTECTS INFORMATION, INCLUDING PERSONAL DATA, GATHERED THROUGH ITS DIGITAL PLATFORMS AND RELATED SERVICES (COLLECTIVELY REFERRED TO AS THE “AFFORDPLAN ECOSYSTEM”).

The Affordplan Ecosystem includes:

• The Affordplan website accessible at www.affordplan.com (“Website”);
• The Affordplan Swasth mobile application (“Swasth Platform”); and
• The Affordplan Wellness e-commerce platform (“Wellness Platform”), operated and managed by our wholly owned subsidiary, Usekiwi Infosolutions Private Limited.

Please read this Privacy Policy carefully to understand our practices regarding the collection, use, disclosure, and protection of your information. By accessing or using any part of the Affordplan Ecosystem, registering an account, or availing any services offered through the Website, Swasth Platform, or Wellness Platform (collectively referred to as the “Services”), you acknowledge that you have read, understood, and agree to be bound by the terms of this Privacy Policy. If you do not agree with the terms of this Privacy Policy, you should refrain from accessing or using the Affordplan Ecosystem or availing any Services.

This document is an electronic record generated under and in accordance with the Information Technology Act, 2000, the rules made thereunder, and other applicable laws governing electronic records, as amended from time to time.This Privacy Policy is published in compliance with:

• Rule 3(1) of the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021 (formerly the 2011 Rules); and
• Applicable provisions of the Digital Personal Data Protection Act, 2023, and any rules or regulations made thereunder.

This Privacy Policy explains how Affordplan and its subsidiaries handle personal data and other information relating to You, our Customers, and other users of the Affordplan Ecosystem.

• Visitors, users, and registered members of the Affordplan Ecosystem;
• Service providers, merchants, and business partners onboarded on either platform; and
• Any third parties interacting with the Affordplan Ecosystem or availing Services, to the extent applicable.

The terms of this Privacy Policy are between the Company and the visitors, Customers, Permitted Users, and End Users (collectively referred to as “User”, “You”, or “Your”) of the Affordplan Ecosystem.

References to “We”, “Us”, or “Our” shall mean the Company and/or its affiliates. The Company provides digital and platform-based Services through its Website, Applications, and associated systems.

WELLNESS PLATFORM-SPECIFIC APPLICATION OF THIS PRIVACY POLICY

This Privacy Policy also applies to the Wellness Platform, an e-commerce platform forming part of the Affordplan Ecosystem. It governs the collection, use, disclosure, and protection of Personal Data when You access or use the Wellness Platform.

However, this Privacy Policy does not apply to the websites, applications, or digital services of our merchants, business partners, corporate affiliates, or third parties, even if such websites or services are linked to or accessible from the Affordplan Ecosystem. You are encouraged to review the respective privacy policies of those entities to understand how they collect and use Your data.

By accessing the Affordplan Ecosystem , You expressly consent to Our collection, storage, use and disclosure of the User Data in accordance with the terms of this Privacy Policy. All information in this Privacy Policy applies to You unless otherwise indicated.

Please note: All information in this Privacy Policy applies to You unless otherwise indicated. In this Policy, the term “Personal Data” shall mean any data of an individual/ organization/ company who is identifiable by or in relation to such data.

Unless otherwise indicated, all provisions of this Privacy Policy apply equally to both the Swasth Platform and the Wellness Platform.

Further, any and all terms not defined herein but capitalized shall derive the meaning from the Terms of Use or the Merchant Agreement or the User Agreement as the context so requires.

1. COLLECTION, STORAGE AND USE OF INFORMATION RELATED TO YOU

1.1 For Swasth Platform

When the End User access or utilize the Swasth Platform, these Users are required to provide certain Personal Data and non-personal information which may include (such information and correspondences hereinafter collectively referred to as “User Data”):

• Information about Your identity, including but not limited to, Your name/guest name, nationality, gender, marital status, age, email address, product details and particulars thereof (if any);
• KYC details including Aadhaar, Pan, etc.;
• Your financial information, such as Your banking details and any information relating to Your income;
• Your contact details such as Your physical addresses, postal addresses, telephone and fax numbers and the like;
• Your medical details such as details of disease or ailment, previous medical history or records etc.;
• Payment and Account Information: Your account history with Us including (without limitation) all billing information and communications, payment history etc.;
• Content, information about Your correspondents, and the destination/origin of communications between You and any other person using Our Services, which include email communications, blog, chat room and discussion board communications, instant message communications, experts forum communications, fax mail communications, membership of mailing lists etc. as applicable;
• Your usernames, passwords, email addresses and other security-related information used by You in relation to Our Services.

Other information may include:

• Cookies and electronic tools to gather data on individual interests for enhanced responsiveness. This includes server logs with details like web requests, IP addresses, browser type, language, date, time, and unique browser identifiers primarily for user authentication;
• Location and device information while using the Application, using it to provide service-related suggestions if needed;
• Emails and other communications sent to Us are retained to process inquiries, respond to requests, and enhance services.

1.2 We may also collect payment information such as Your payment card number, expiration date, billing and shipping address. By using the Service, You consent to the recording, storage, and disclosure of such communications You send or receive for these purposes. We may also store and process prescriptions, treatment notes, recommendations and other data generated by merchants on or through the Swasth Platform, and data shared by third parties such as diagnostics-related information; prescription-related information etc. and may retain such material for Our records for the duration of You availing the Services or for any such period required or permitted under applicable law in the form of images.

1.3 We collect only the User Data that We believe to be relevant and is required to provide effective Services that You voluntarily elect to provide Us. You may, at any instance, choose not to provide Us the User Data, however, in such a case We may not be able to offer You (partially or entirely, as the case may be) the Services provided by Us. Additionally, We collect Your User Data in order to record, support and facilitate the provision of Services to You, including, via third parties whom You agree to engage with through the use of the Affordplan Ecosystem, to assist You with insurance services, customer services, technical support issues, to follow up with You, to otherwise support Your relationship with Us and/or to prevent fraud and unlawful activities.

Please note: To make it easier to manage Your buying, You can open a User Account. This allows You to save Your personal settings; review previous plans availed and manage future planning. When You visit Our Affordplan Ecosystem, even if You do not make a purchase, We may collect certain information, such as data that identifies Your computer/mobile device, device-specific settings and characteristics and latitude/longitude details etc.

1.4 For Wellness platform (Access via Single Sign-On)

The Affordplan Ecosystem enables Users registered on the Swasth Platform to access the Wellness Platform through a secure Single Sign-On (“SSO”) authentication process. This feature allows Users to navigate seamlessly between the Swasth Platform and the Wellness Platform without the need for separate registration or repeated login credentials.

Through this SSO integration, only limited Personal Data of the User required for authentication and continuity of service will be securely shared between the Swasth Platform and the Wellness Platform. Such data may include:

• Basic identification information (such as name, registered mobile number, and email address);
• Login credentials or unique identifiers generated by the SSO system; and
• Preference settings or session-related information necessary for ensuring seamless access between the platforms.

This limited information is processed solely to facilitate authentication, account linkage, and enable smooth transition between the Swasth Platform and the Wellness Platform. The Company does not transmit or share any financial, medical, or other sensitive personal data with the Wellness Platform unless such transfer is specifically required for a Service initiated by the User and with the User’s express consent.

Once the User accesses the Wellness Platform, the collection, processing, and use of any Personal Data on that platform shall be governed by the Privacy Policy of the Wellness Platform. The User is advised to review and acquaint themselves with the applicable terms and privacy practices of the Wellness Platform before proceeding to use its services.

2. PURPOSE OF USERS DATA

2.1 Swasth Platform

Swasth Platform uses Your Data to complete and administer Your online transactions through the Affordplan Ecosystem.

Swasth Platform offer the User Account facility on Our Affordplan Ecosystem. We use the information You give Us to administer this, allowing You to manage Your Transactions, take advantage of special offers, make future Transactions more easily and manage Your personal settings. Managing personal settings allows You to see Transactions that You have undertaken using the Affordplan Ecosystem before.

We also use Your information as permitted by applicable laws, such as the following:

• When You undertake Transactions using the Swasth Platform or set up the User Account, We may use Your contact information to send You news about similar offers and plans. We may also send to the Users regular newsletters by email. You can opt- out, or unsubscribe, from marketing communication at any time.
• Based on the information You share with Us, individualized offers may be shown to You on the Swasth Platform, in mobile apps or on third-party applications, including social media websites.

We may use the User’s Data for the detection and prevention of fraud and other illegal or unwanted activities or disclose the User’s Data if required as per applicable laws.

The Swasth Platform collects personal information such as name, phone number, address, and age, as well as, on occasions, including government ID as per healthcare and tax laws and regulations in the country for authentication of user/consumer and verification of authentic payment.

2.2 Wellness Platform

The limited Personal Data and non-personal information shared with or collected by the Wellness Platform through the integrated Affordplan Ecosystem, including the SSO authentication mechanism, shall be processed solely for the following lawful and specific purposes:

• To enable seamless user authentication and secure access to the Wellness Platform without requiring a separate registration process;
• To facilitate account linkage, transaction continuity, and unified user experience across the Swasth and Wellness Platforms;
• To provide personalized wellness-related content, recommendations, and promotional offers based on lawful and consent-based processing of non-sensitive data;
• To communicate essential updates, confirmations, and service-related notifications to the User;
• To comply with applicable legal and regulatory obligations, including maintaining records as required by law.
• To maintain the security and integrity of the Wellness Platform, prevent unauthorized access, detect fraud, and enforce its terms of use; and
• To analyze usage patterns and feedback for improving service delivery, operational efficiency, and customer satisfaction.

Any processing of sensitive personal data, including detailed health or medical information, shall be undertaken by the Wellness Platform only upon obtaining the User’s explicit, informed, and specific consent, and strictly in compliance with applicable laws and data protection standards.

The Company and/or its subsidiary managing the Wellness Platform shall not process or use User Data for any purpose beyond those stated above, unless the User provides additional, explicit consent or such processing is otherwise permitted under applicable law.

3. LINKS TO THIRD-PARTY WEBSITES AND ADVERTISING

We may use third-party service providers to process the End User’s Data on Our behalf for the purposes specified above. To further elaborate in this regard, We may instruct third parties to contact You. We also work with third-party payment service providers to facilitate payment or payment guarantees. We also work with third-party advertisement networks to market Our services on other platforms or involve third-party providers for analytical purposes. These third parties involved in any of these services will, as far as may be feasible, be bound by confidentiality agreements and will not be allowed to use the End User’s Data for any purposes other than those specified herein.

We may share information with Our business partner, for example, as part of the administration of Your account, in order to manage Your plan, so that they can address queries related to Your transaction and for marketing purposes. In this context, Your information is governed by the privacy policies of the respective business partners.

4. END USER’S DATA SECURITY SAFEGUARDS

We use reasonable security measures to protect information from unauthorized access, maintain data accuracy and help ensure the appropriate use/disclosure of information. We host the Website in a secure server environment that uses firewalls and other advanced technology to prevent interference or access from outside intruders.

We have implemented meticulous technical, organizational, and security protocols to avert the inadvertent loss, misuse, or unauthorized access, alteration, or disclosure of Your Personal Data. Furthermore, access to Your Personal Data is restricted to individuals such as employees, agents, contractors, and selected third parties, only when essential for legitimate business purposes and on a need-to-know basis. These authorized entities will exclusively process Your Personal Data based on Our explicit instructions and are strictly bound by rules of confidentiality.

Additionally, We have established comprehensive procedures to address any suspected data security breaches. In situations where legal obligations dictate, We commit to promptly notifying You and relevant regulatory bodies of any suspected breaches.

5. LOYALTY PROGRAM

The End Users authorize the Company to collect, process, facilitate and remit payment collected electronically or through cash on pick-up for the facilitation of transactions between Merchant and the End User.

The End User expressly agrees and opts in for the Company to send any promotional and transactional messages by phone, email other means (even if listed in the TRAI’s DND list).

6. DATA RETENTION

We keep Your Personal Data and other information to enable Your continued use of the Affordplan Ecosystem, for as long as it is required to fulfil the relevant purposes described in this Privacy Policy, like an ongoing contractual relationship or accounting needs, or when there is a legal storage need, like bookkeeping regulations or as may be required by law (including for tax and accounting purposes), or as otherwise communicated to You.

Users reserves the right to withdraw their consent for personal data sharing via SSO at any time. Withdrawal can be effectuated by disabling SSO access in their account settings on Affordplan Ecosystem, or by contacting customer support. After withdrawal, SSO services will be discontinued for the User.

Users wishing to unlink their accounts between Affordplan Ecosystem i.e. Swasth Platform, and Wellness Platform may do so through the account management or settings section on of this platform. Alternatively, users may contact our customer support team at swasth@affordplan.com swasth@affordplan.com for assistance. Unlinking will remove the linkage allowing independent access to each platform but may limit seamless access or personalized features.

Data will be retained by the Company as suggested hereinabove, however, no claim shall be made by You or any stakeholder for the destruction of the Personal Data and other information.

7. NOTICE

Every request made to the User for consent with regard to the processing of the Personal Data shall be accompanied or preceded by a notice given by the Company to the User, informing the User of the Personal Data and the purpose for which the Personal Data is proposed to be processed.

Further, the notice shall include the right to withdraw and the right to seek grievance redressal by the User.

The notice shall also include the manner in which the User may make a complaint to the Data Protection Board as may be prescribed under the provisions of law time being in force.

8. CHANGES TO THIS PRIVACY POLICY

As We update, improve and expand the Affordplan Ecosystem, we may change this Privacy Policy from time to time, so please refer back to it periodically as You will be deemed to be governed by the terms of such modified Privacy Policy, as it comes into effect from time to time.

9. DISCLAIMER

The Company does not store any account-related information or any credit/debit card details. The Company shall not be liable for any loss or damage sustained by Users as a result of any disclosure (inadvertent or otherwise) of any information concerning the User's account, credit cards or debit cards in the course of any online transactions or payments made for any products and/or services offered through the Affordplan System.

In case any Personal Data is shared by You with the Company, which is not requested by the Company during registration, (whether mandatorily or optionally), the Company will not be liable for any information security breach or disclosure in relation to such information.

In no event will any delay, failure or omission (in whole or in part) in enforcing, exercising or pursuing any right, power, privilege, claim or remedy conferred by or arising under this Privacy Policy or by law, be deemed to be or construed as a waiver of that or any other right, so as to bar the enforcement of that, or any other right, power privilege, claim or remedy, in any other instance at any time or times subsequently.

10. CONTACT US

If You have any questions, concerns, or requests regarding this Privacy Policy or Our data practices, please contact Us at swasth@affordplan.com or +91-92500 50501.

Thank You for using the Website!