With effect from 15th November 2019
Welcome to Naima (the “Application”) containing information, material, the suite of products and services which are solely owned and operated by Matra Technologies Private Limited, a company incorporated and registered as per provisions of Companies Act, 2013 and having its registered office at FLAT NO 1101, FRANGIPANI NAHAR AMRIT SHAKTI, CHANDIVALI ROAD, POWAI MUMBAI MUMBAI CITY MH 400072 (hereinafter referred to as the “Company” or “us” or “we”, which expression shall mean and include its officers, successors and permitted assigns).
The Company is engaged in the business providing a variety of services, through a combination of artificial intelligence and pregnancy coaches in the context of health and lifestyle modifications including human coaching support, structured content support, chatbot coaching support, medication reminders and other related services which may be specified by the Company from time to time (“Services”).
A) Information Collection
The Company will endeavor to protect the privacy of its users and has taken all necessary and reasonable measures to protect the confidentiality of the user information and its transmission through the internet.
The Registration process is entailed in detail in Terms and Conditions, to which you have agreed to while entering this Application.
The Company collects information from you on the Register/Log-in page of the Application. In the sign-up page, you are required to give your personally identifiable contact information including but not limited name, mobile number, health details, pregnancy details, email ID and such other details. A verification process is used to confirm your identity through the contact information that you provide. When the Application requests your identity, the Application will clearly indicate the purpose of the inquiry before the information is requested and seek your consent.
Once a registered participant, you have the option of providing additional personally identifiable, health and other information including but not limited to age, height, weight, occupation, name of your doctor, hospital or other healthcare providers, location, data relating to your current and previous pregnancy conditions and outcomes, diet, activity levels, exercise, medical reports (if any), medical history and outcomes, mobile number, email ID, name of a primary caregiver, contact details of the primary caregiver and other personal information to avail of the Services provided through the Application. We assume that any information provided by you relating to a primary caregiver has been provided after obtaining due consent of such primary caregiver or health practitioner including doctor, doula/midwife or trained medical personnel. In such a case, consent is deemed to be provided by them.
Every computer/mobile device connected to the Internet is given a domain name and a set of numbers that serve as that computer's Internet Protocol or "IP" address. When you request a page from any page within the Company Application, our web servers automatically recognize your domain name and IP address. The domain name and IP address reveal nothing personal about you other than the IP address from which you have accessed the Application.
B) Children's And Minor's Privacy
The Application is not intended for minors. These tools also can prevent minors from disclosing their name, address, and other personally identifiable information online without parental permission. Although the Application is not intended for use by minors, the Company respects the privacy of minors who may inadvertently use the internet or the Application. It is, however, the parent/users' responsibility to prevent the minor from accessing any information on the Application.
C) Data Retention
Please note that subject to termination or expiry of your account on Application, Company shall retain your information including your personal data for a period of 5 years, unless you provide a justifiable reason to delete or destroy the same.
The Company shall, upon receipt of such a request from you, proceed to delete such information after carrying on internal verification procedures. Notwithstanding the foregoing, the Company will retain and use your information as necessary to comply with its legal obligations, resolve disputes, carry on audits, and enforce its agreements or for other business purposes. You are aware that Company shall be required to provide such information to a third party if required as per provisions of law. The data is stored on cloud servers (AWS) in India.
D) Opt-Out Procedures
Upon initial communication from the Company, you may opt-out of receiving further communications from the Company. To be completely removed from the Company subscription list, you may contact us at email@example.com. If you are using an e-mail forwarding service or other similar services please make sure to include the correct e-mail address or addresses.
E) Company as a Pass-Through Facilitator
The Company may be a pass-through facilitator for data under a contract with a client or partner and the Company shall not be deemed to be the owner of such information. The Company may, as part of the agreement with such clients, use the information collected from such clients to provide the relevant services to the user. The Company may continue to use the data for the purposes identified in this statement and the Terms and Conditions.
Please note, however, that in respect of any information received by the Company under certain specific pregnancy coaching program: (a) the Company shall retain identified data for a period of 5 (Five) years from the date of termination of such agreement, for the performance of its contractual obligations, audits, diligence thereunder; and (b) the Company shall thereafter be permitted to retain only de-identified data for such period of time as may be necessary. The de-identified data at any point in time will be used for the purpose of compliance with applicable law, carrying on its contractual obligations, for adverse circumstances, in case of emergencies, for carrying on audits and for improvement of its technology and strengthening its AI engine.
F) Use of The Information Collected For Services
The primary goal of the Company in collecting the information is to provide you / allow your access, to the Application and provide the Services as defined in the Terms and Conditions. The Company may use the personal and non-personal information provided by you, including but not limited to, the following ways:
Identify and reach you.
Resolve technical issues of access to the Application via telephone or email.
Provide you with further information, products, and services.
Better understand users’ needs and interests.
Personalize your experience and customizing experience.
Understanding and assisting you in your clinical, health and general wellbeing progress.
Run statistical research and undertake scientific publications.
Improving the product and services offered to current and future users and partners by improving parts of the Application, including but not limited to the algorithms, logic systems, content, decision support, engineering, artificial intelligence.
Anonymized information for research and improving features on the application.
Providing data to clients or partners under the terms of agreement with them.
Providing access to your “User Profile” to other users of the Application, Company administrators, Company moderators, Pregnancy Coaches, and Primary Caregivers.
For carrying on audits, due diligence for effecting investments in the Company.
For emergency purposes or in case of any adverse circumstances.
Detect and protect us against error, fraud, and other criminal activity.
Make disclosures as may be required under applicable law.
Improve our Application in order to better serve the user.
Allow us to better serve the user in responding to customer service requests.
Administer a contest, promotion, survey or other site feature; and
Provide access to other users as part of a social feed, in order to provide motivation or assistance to such other users.
G) Disclosure to the Primary Caregiver
Information collected from you may be transferred to your primary caregiver (as identified by you), as part of the Services.
The Company may, at its sole discretion, be entitled to contact the primary caregiver (as identified by you) at scheduled intervals and at unscheduled times and collect or provide any information relating to you, as may be deemed beneficial or essential by the Company. The Company shall periodically update the primary caregiver relating to your health and progress based on the statistics available in the Application, and any other relevant information that the Company believes is relevant to improve your health, clinical and general wellbeing outcomes. The Company may also reach out to the primary caregivers at unscheduled times upon occurrence of an Adverse Event, emergency event, or if you have not engaged with the Application or your Pregnancy Coach for a duration deemed necessary by the Company or a Pregnancy Coach.
H) Sale of Assets, Merger, Acquisition
The Company may share your information, including your information with our parent, subsidiaries, and affiliates for internal purposes. The Company also reserves the right to disclose and transfer all such information: (i) to a subsequent owner, co-owner or operator of the Application, Website or applicable database; or (ii) in connection with a corporate merger, consolidation, restructuring, the sale of substantially all of our membership interests and/or assets or other corporate change, including, during the course of any due diligence process.
You will be notified via email and/or a prominent notice on our Application and/ or Website of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information. If you fail to provide any issues within ten (10) working days of receipt of any notice, consent is deemed to be given.
J) Ownership of Work Products
Please note that your pre-existing owned work product shall not be transferred to the Company.
K) Non-disclosure of Information
The Company may disclose your personal information in the event it is required to do so by law, rule, regulation, law, enforcement, governmental official, legal or regulatory authorities and, or, to such other statutory bodies who have appropriate authorization to access the same for any specific legal purposes;
The Company may disclose your information to such third parties to whom it transfers its rights and duties under any agreement entered into with such third parties; and
The Company may disclose your information to any of its affiliates or related entity.
L) Sharing of Information
The Company may share aggregated personal information with the Company's partners/clients as per the terms of any agreement with such partner/client. The data shared de-identified/anonymized basis, based on the terms agreed by the Company with such partner/client. The information available with the Company may be shared by the Company even after completion of the Services. The Company shall not be liable for the transfer of any personal identification information resulting from loss or distribution of data, the delineation or corruption of storage media, power failures, natural phenomena, riots, acts of vandalism, sabotage, terrorism or any other event beyond the Company's control.
M) Consulting and Sub-Contracting
The Company may sub-contract all or part of the Services to a third party sub-contractor, partner with another party to provide specific services. When you sign up for these services, the Company will share names or other contact information that is necessary for the third party to provide these services. Per the Company's contractual arrangements with parties, these parties are not allowed to use personally identifiable information except for the explicit purpose of providing these services.
The Company maintains a strict "No-Spam" policy, which means that the Company does not intend to sell, rent or otherwise give your phone number or e-mail address to a third party without your consent.
P) The Company Forums
When you interact with our Application or avail the Services, your comments, your name, your mobile number, and IP address may be recorded for purposes of maintaining your own account within the Application. This information is not used to personally identify you outside the Company Application and Services. In order to diffuse the information in the Company forum to a wider audience, the Company may, from time to time, collect some of your comments to use in a specific publication, print, electronic mailing or other public dissemination. At no point, however, will your name, your mobile number or IP address be revealed without your consent. In addition, when your comments are used in this fashion, they may be edited to fit with the general content of the publication being prepared.
Q) Protection Of Information
Security of Information- The Company takes the security of your information very seriously. The Company protects your information from loss, misuse and unauthorized access, disclosure, alteration, and destruction by using a microservices architecture. It is an architectural style that structures an application as a collection of loosely coupled services, which implement business capabilities. for e.g. having separate services for user profile related operations and user’s health details related operations, these services reside on different servers having their own databases. Our core chat service is HIPAA (Health Information Portability Act) compliant, and EU-US Privacy Shield, and SOC-2 compliant. The core chat service also has Point-to-point network TLS encryption and end-to-end message AES encryption.
The Company has put in place appropriate methods and managerial procedures to safeguard and secure such information. It only processes personal information in a way that is compatible with and relevant for the purpose for which it was collected or authorized by the individual. The Application allows users access to their personal information and allows them to correct, amend or delete inaccurate information.
The Company uses commercially reasonable precautions to preserve the integrity and security of your information against loss, theft, unauthorized access, disclosure, reproduction, use or amendment.
In using the Application, you accept the inherent security implications of data transmission over the internet. Therefore, the use of the Application will be at your own risk and the Company assumes no liability for any disclosure of information due to errors in transmission, unauthorized third-party access or other acts of third parties, or acts or omissions beyond its reasonable control and you agree not to hold the Company responsible for any breach of security.
In the event the Company becomes aware of any breach of the security of your personal information, it will promptly notify you and take appropriate action to the best of its ability to remedy such a breach.
The Company takes all necessary precautions to protect your personal information both online and off-line. No administrator at the Company will have knowledge of your password.
The Application may contain links to other sites, products, applications, and services to enhance the value you derive as a user. These are not necessarily under the control of the Company. Please be aware that the Company is not responsible for the privacy practices of such other sites. The Company encourages you to read the privacy policies of each and every web site that collects personally identifiable information. If you decide to access any of the third-party sites linked to Application, you do this entirely at your own risk. Any links to any partner of the Application should be the responsibility of the linking party, and the Company shall not be responsible for notification of any change in name or location of any information on the Application.
S) Notification of Changes
Using the Company Services or accessing the Application after a notice of changes has been sent to you or published on our website shall constitute your consent to the changed terms.
T) Consent To This Policy
U) Grievance Officer
If you have any grievance with respect to the Application or the Services, including any discrepancies and grievances with respect to the processing of information, you can contact our Grievance Officer at
The Grievance Officer shall redress your grievances expeditiously, within 1 (one) month from the date of receipt of the grievance. Except where required by law, the Company cannot ensure a response to questions or comments regarding topics unrelated to this policy or the Company's privacy practices.
You may, at any time, withdraw consent for the collection or processing of any information provided by you, by sending an email to firstname.lastname@example.org. Please note that it will take around forty-five (45) days to process your request.
Upon verification of such a request, the Company may, subject to its obligations pursuant to law, destroy all information provided by you from its servers. However, please note that the Company shall continue to retain a copy of the information provided by you for the purpose of carrying out periodic audits or required as per provisions of law. In such a case, the Company shall also instruct its partners/ clients to delete any copy of your information. However, the Company shall not have the obligation to validate or enforce any such deletion by the partner/client.
You are aware that this Application is owned by a company incorporated and registered in India. Further, you are aware that the server where your information is based is in India. In the event, you have provided express consent to use, store, transfer and collect your personal data out of your free consent.
In case, any terms hereof are not as per your local laws and/ or there are any non-compliances in respect of your local laws, you as a user agree to indemnify and save harmless the Company in respect thereof.