This Privacy Policy (“Privacy Policy”) is an agreement between You (“You”/ “Your(s)”/ “User(s)”) and M/s Pathfinder LP (“ROHFIT”/ “We”/ “Our” / “Us”), and forms part of the Terms of Use and Terms and Conditions[VP1] . This Privacy Policy explains how we Process and protect Your Personal Data when You use the ROHFIT App, or use services provided by ROHFIT and its Platforms. “ROHFIT” is a wellness-based app that acts as a bridge between the ROHFIT’s Users and Professionals. We are committed to protecting Your privacy and ensuring the security of Your Personal Data. By using the ROHFIT App, You consent to the practices described in this Privacy Policy.

This Privacy Policy is published in compliance with inter alia (“Applicable Laws”):

Digital Personal Data Protection Act, 2023 (“DPDP”), and the Rules made thereunder.
Section 43A of the Information Technology Act, 2000;
Rule 4 of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011 (“SPDI Rules”); and
Rule 3 of the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021 (“Intermediary Rules, 2021”).

Scope: If You have a ROHFIT membership (“Member”), want to get a ROHFIT membership, visit Our website, use Our ROHFIT App or respond to Our social media messages (“Visitor”), We need certain Personal Data from You and may Process Your Personal data. “Personal Data” means any data about an individual who is identifiable by or in relation to such data. “Processing” in relation to Personal Data, means a wholly or partly automated operation or set of operations performed on digital Data, and includes operations such as (i) collection, (ii) recording, (iii) organisation, (iv) structuring, (v) storage, (vi) adaptation, (vii) retrieval, (viii) use, (ix) alignment or combination, (x) indexing, (xi) sharing, (xii) disclosure by transmission, (xiii) dissemination or otherwise making available, (xiv) restriction, erasure or destruction.

This Privacy Policy applies only to information that We collect through electronic or digital means based upon Your consent or any other Legitimate Use, including Our website with URL (https://www.pathfindertech.in/ or https://rohfit.com/) certain ROHFIT affiliated sites accessible through this website, such as Our mobile website, mobile applications, including ROHFIT App, and other electronic and digital means of communication that We control and that contain a link to this Privacy Policy (collectively referred to in this Policy as Our “Platforms”). Unless disclosed otherwise, Our affiliated sites are governed by this Privacy Policy.

Our Platforms may contain links to third party sites or are hosted on platforms or devices that are not owned or controlled by ROHFIT. Please be aware that We are not responsible for the privacy or other practices of such other sites. We encourage You to be aware when You leave Our Platforms and to read the privacy statements of each and every website that You visit.

2. Information We collect: We at ROHFIT, collect and process Your Personal Data only once You agree to consent to the terms of this Privacy Policy. We Process Your Personal Data with utmost care and comply with the Applicable Laws and regulations relating to the protection of personal data, including the Digital Personal Data Protection Act, 2023 (“DPDP”), and any rules made thereunder.

If You are a Member, we may collect the following information:

Basic information You Provide: Your name, residential address, contact number, email address, gender, height and weight, date of birth, food preferences, goals, payment processing information like credit, debit, UPI, digital wallet, pay later/ post-paid account details, or other payment account number and related information.
Synchronized apps/device data: any activity and other information collected by any fitness devices (example: sensors, wearable devices) or a third-party fitness data platform (example: Jio Health, Apple Health, Google Fit, Samsung Health) that You choose to connect to the ROHFIT App. Such information may include, for example, body measurements and activity types and data (e.g., steps, heart rate, distance, speed, sleep, location covered, or any other activity performed). You may revoke Your consent to such sharing by accessing the settings for the relevant platform.
Log Information collected automatically: IP (Internet Protocol) address, browser type, computer type, type of mobile device (if used), the carrier for Your mobile device, Your computer operating system, the version of the Platforms that You access, the site from where You navigated to Our Platforms, the time and date of using the Platforms, whether You are a repeat visitor, how long You use the Platforms and the pages that You view. We may derive Your approximate location from Your IP address.
App / Website Usage Data. When You download and use any of Our mobile applications, We and Our service providers may track and collect app usage data, such as the date and time the app on Your device accesses Our servers.
User Preferences, activities, and other information collected through Cookies and Web Beacons. When You visit or use Our Platforms, We send one or more “cookies” to Your computer or other device. A Cookie is a small file containing a string of characters that is sent to Your computer when You visit a website. When You visit the website again, the cookie allows that site to recognize Your browser. Cookies may store unique identifiers, user preferences and other information. You can reset Your browser to refuse or restrict most cookies or to indicate when a cookie is being sent. However, some website or app features or services may not function properly without cookies. Cookie based opt-outs must be performed on each device and browser that You wish to have opted-out. You must separately opt out in each browser on each device. We use cookies to improve the quality of Our service, including for storing user preferences, tracking user trends and providing relevant advertising to You based on Your activities on the Platforms and on other websites.

We use web beacons to manage cookies, record visits, and to learn marketing metrics. We also use web beacons to track and monitor email opening rates as well as link clicks. “Web beacon” (also known as Clear GIF, Web Bugs or Pixel Tag) is a tiny picture file embedded on the Website/App that tracks Your behaviour and navigation. It is similar to a cookie in what it does, but it does not get downloaded on to Your device.

Physical location. Your device location may be collected if You opt to turn on GPS, to provide location-based services, content and alerts and to learn when You have checked out Our products or services.
Wellness Information and Medical Conditions: We may collect Your wellness and medical information that You may provide Us upon availing certain ROHFIT’s services, which may include information related to six vital wellness aspects of life including physical, mental spiritual, social, occupational, and intellectual aspects (“Wellness Categories”):

Wellness Categories

Physical activity and exercise
Food preferences and nutrition
Stress level
Yoga and body movement
Sleep cycle
Sports driven wellness (if any)
illness, and any physical injury, and subsequent physical rejuvenation.
sexual health and wellness

Intellectual

Skills
Resource management
Hobbies
Experimentation
Travel blogging and exploration.
Philosophy and historic infotainment
Practical and theoretical knowledge
Speech and text practices / learning
Creativity expansion and memory
Gym activities (if any)
Cognition and brain related information.
Work clarity
Mental fortitude

Occupational

Work and life balance
Leisure and recreational activities (if any)
Motivation and inspirational content
Communication and collaboration in the workplace
Mental focus hours
Time and energy management
Career goals and life planning
Application of education in the corporate world.
Views on workplace etiquette and culture.
Views relating to entrepreneurship and idea sparking

Social

Behavioral and physiological practices
Personal views and outlook towards group relationships
Likes and Interests
Self-confidence level
Community building & inclusivity practices.
Society and event work
Presentation, styling and fashion preferences
Languages known for conversation and interaction tips

Meditation and breath-work
Mindfulness routines
Self-care and unwinding practices
State of mind (example: anxiety, fear, palpitations, mood)
Trauma and depression (if any)
Rehab and addiction (if any) - relationship difficulties (if any)

Spiritual

Views on astrology and numerology
Spiritual meditation practices
Views on Mystical spirituality
Detachment and self-reflection
Peace, joy & positivity practices.
Views on self-exploration and Enlightenment
Views on compassion and community service undertaken.
Views on intellectual spirituality and nature driven spirituality

If You are a Visitor, we may collect the following information:

Your IP Address;
Your location;
User Behaviour: How You behave on the Platforms, (what pages You land on, how much time You spend, etc.);
What device You use to access the Platforms and its details (model, operating system, etc.); and
Cookies and Web Beacon data.

How We Use Your Information

To Provide Products, Services, and Information. As described above in Clause 2, We collect information from You so that We can provide products and services that You purchase or otherwise request using the Platforms and information that You request from us. For example, We use Your personal information to:
1. Set-up Your membership.
2. Provide services and products to You.
3. Process payments for Your membership and services, including credit card, debit card and bank account debit (ACH) transactions.
4. Contact You regarding Your membership and services, and other administrative information.
5. Track member and guest use of Our facilities.
6. Respond to Your inquiries, comments, reviews, and ratings.
7. Provide advertisements, newsletters, or other marketing or promotional and other information relating to materials to You regarding products and services that We provide or otherwise offer for sale.

Marketing Communications. We may use Your information to send You marketing communications that We believe may be of interest to You. You can always opt-out of receiving marketing emails by using the opt-out feature provided with the email communications.

Our Business Purposes. We may use Your information for Our business purposes, such as data analysis, research, audits, fraud monitoring and prevention, developing new products and services, enhancing, improving, or modifying Our Platforms, identifying usage trends, determining the effectiveness of Our promotional campaigns, and operating and expanding Our business activities.

Other Legitimated Uses: We may further Process Your Personal Data for certain Legitimate Uses as specified in the DPDP (“Legitimate Use(s)”):

You voluntarily provided Your Personal Data to ROHFIT, and did not indicate non-consent to the use of Your Personal Data;
for fulfilling any obligation under any law for the time being in force in India on any person to disclose any information to the State or any of its instrumentalities, subject to such Processing being in accordance with the provisions regarding disclosure of such information in any other law for the time being in force;
for compliance with any judgment or decree or order issued under any law for the time being in force in India, or any judgment or order relating to claims of a contractual or civil nature under any law for the time being in force outside India;
for responding to a medical emergency involving a threat to the life or immediate threat to Your health or any other individual;
for taking measures to provide medical treatment or health services to any individual during an epidemic, outbreak of disease, or any other threat to public health;
for taking measures to ensure safety of, or provide assistance or services to, any individual during any disaster, or any breakdown of public order.

Third Party Sharing of Personal Data: We may share Your Personal Data with third parties who implement the same level of data protection that is adhered to by Us, only as described below, in compliance with the Applicable Laws:

Other Data Fiduciaries: In case any other Data Fiduciary, for instance any affiliated businesses, or third-party websites affiliated to Us, provide products or services to You through ROHFIT’s Platforms (either alone or jointly with Us), and You consent to avail such products or services, or sync Your ROHFIT account to such third party devices or applications, then and we will share Your Personal Data with such other Data Fiduciaries only to the extent that it is related to such transaction or services.
Data Processors: We may share Your Personal Data with certain individuals or organizations on-boarded by Us to process Your Personal Data on Our behalf in order to provide You Services, and shall ensure that such Data Processors complies with the Applicable Laws, while processing Your Data other individuals or to perform tasks on our behalf and need to share Your information with them to provide products or services to You.
Public submissions: We may put up certain information publicly, which is voluntarily provided or disclosed by You to post or upload for public views, such as on discussion boards, public chats, or on any other public interface on Our Platforms.
Business transfers: We reserve the right to transfer any data We have about You in the event We sell or transfer all or a portion of Our business or assets. Should such a sale or transfer occur, We will use reasonable efforts to ensure that the transferee uses the data You have provided to us in a manner that is consistent with this Privacy Policy. Following such a sale or transfer, You may contact the transferee with any inquiries concerning the processing of this information.
In compliance with Laws or certain legitimate uses a specified in Section 3(iv) of this Privacy Policy.
In response to requests by government agencies, law enforcement authorities;
With Your consent: Except as set forth above, You will be notified when Your personal information may be shared with third parties and will be able to prevent the sharing of this information.
Users may, however, visit Our Platforms anonymously. We will collect personal data from users only if they voluntarily submit such information to us. Users can always refuse to supply these data, except that it may prevent them from engaging in certain Platform related activities.

Know Your Rights: As a Data Principal, You shall have the following rights with respect to Your Personal Data:

Right to Access Information regarding Personal Data: Except as authorized by law for the purpose of prevention or detection or investigation of offences or cyber incidents, or for prosecution or punishment of offences, You shall have the right to access information about Your Personal Data including:

a summary of Personal Data being Processed, and the processing activities undertaken by Us;
the identities of all other Data Fiduciaries and Data Processors with whom We have shared Your Personal Data, along with a description of the Personal Data so shared; and
any other information related to Your Personal Data of such Data Principal and its processing, as may be prescribed.

Right to correction and erasure of Personal Data. You shall have the right to correction, completion, updating and erasure of Your personal data, which You consented to be processed by Us, or Our Data Processors. Unless retention is necessary in compliance with any law in force, and post completion of a period of one hundred and eighty days after any cancellation or withdrawal request, We shall and cause Our Data Processors to delete or erase Your Personal Data. Upon receiving request from You for correction or updating of Your Personal data, We and Our Data Processors shall further (a) correct the inaccurate or misleading Personal Data; (b) complete the incomplete personal data; and (c) update the personal data.

Right of grievance redressal. You shall have the right to have readily available means of grievance redressal in respect of any act or omission on Our part in the performance of Our obligations in relation to Your Personal Data or the exercise of Your rights under the provisions of DPDP, other Applicable Laws and the rules made thereunder.

We shall respond to any grievances and acknowledge Your complaint within twenty-four hours and dispose off such complaint within a period of fifteen days from the date of its receipt;

We shall take all reasonable and practicable measures to remove or disable access to any content which is prima facie in the nature of any material which exposes the private area of such individual, shows such individual in full or partial nudity or shows or depicts such individual in any sexual act or conduct, or is in the nature of impersonation in an electronic form, including artificially morphed images of such individual which is hosted, stored, published or transmitted on Our Platforms within twenty-four hours from the receipt of a complaint made by Your or any person on Your behalf Right to nominate.

You can submit Your grievance via email to:

Name: Pathfinder Technologies

EMAIL ID: therohfit@gmail.com

Right to Nominate: You shall have the right to nominate, any other individual, who shall, in the event of Your death or incapacity, exercise the rights on Your behalf in accordance with the provisions of this Applicable Laws, by reaching out to Us at INSERT EMAIL ADDRESS.

Know Your Duties:

You shall perform the following duties, namely: —

comply with the provisions of all Applicable Laws for the time being in force while exercising rights under the provisions of the Applicable Laws;
to ensure not to impersonate another person while providing Your Personal Data for a specified purpose;
to ensure not to suppress any material information while providing Your Personal Data for any document, unique identifier, proof of identity or proof of address issued by the State or any of its instrumentalities;
to ensure not to register a false or frivolous grievance or complaint with Your or the Board of Data Protection; and
to furnish only such information as is verifiably authentic, while exercising the right to correction or erasure under the provisions of Applicable Laws.

Transfer of Personal Data outside India: Unless the Central Government may, by notification, restrict the transfer of Personal Data for processing to such country or territory outside India, subject to Applicable Laws, We may at our sole discretion, transfer Your Personal Data to any third party that ensures at least the same level of data protection as is provided by Us under the terms hereof, located in India or any other country. By using our Platforms, You accept the terms hereof and hereby consent to Processing of Your Personal Data by third parties located in India or outside India.

Is Your Personal Data Safe With Us?

We at ROHFIT, are committed to safeguard Your Personal Data and adhere to all Applicable Laws in compliance of the same. We ensure to protect Your Personal Data in our possession or under our control, including in respect of any processing undertaken by our Data Processor, by taking reasonable security safeguards to prevent any personal data breach, as per the Applicable Laws.

While processing Your Personal Data We shall ensure its completeness, accuracy, and consistency, where the Personal Data processed by Us is likely to be— (a) used to make a decision that affects You; or (b) disclosed to another Data Fiduciary.

We further implement appropriate technical and organisational measures to ensure effective observance of the provisions of the Applicable Laws.

Processing of Personal Data of Children and Persons with Disability:

Unless as otherwise notified by the Central Government, We shall, before processing Personal Data of a child’s (below 18 years of age) or a person with disability shall obtain verifiable consent of the parent or guardian of such child or the lawful guardian of a person with disability, as the case may be.

Unless as otherwise notified by the Central Government, We shall further not undertake tracking or behavioural monitoring of children or targeted advertising directed at children.

Furthermore, We shall not undertake such processing of personal data that is likely to cause any detrimental effect on the well-being of a child.

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