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Fittr

PRIVACY POLICY

Updated: June 18th, 2026

Thank you for choosing to be part of our community at Squats Fitness Private Limited, along with its subsidiary Fittr Lifecare Private Limited (“FLPL”) , doing business as Fittr (“Fittr”, “we”, “us”, or “our”). Together, we operate the Fittr ecosystem including coaching services, fitness programs, wellness products (such as the FITTR HART and FITTR SENSE devices), diagnostics services and retreat offerings under www.fittr.com. We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us at support@fittr.com, or reach out to our Data Protection Officer at dpo@fittr.com, whose contact details are listed at the end of this policy.

The use of our Platform which includes Fittr Mobile Application (hereinafter referred to as “Mobile Application”) and Internet pages of Fittr Website – [www.fittr.com] (hereinafter referred to as "Website") and our related Websites, Platforms, Applications, Services, Products, Devices, Diagnostic Services and Content (together with the Mobile Application and Website, collectively referred to as “Services”) is possible without any indication of personal data; however, if a data subject wants to use our services via our website or mobile application, processing of personal data could become necessary. If the processing of personal data is necessary and there is no statutory basis for such processing, we generally obtain consent from the data subject.

These Services include but are not limited to:

  • (a) online coaching, nutrition and fitness programs,

  • (b) wellness devices and related services, including FITTR HART and FITTR SENSE/SENSE PRO; and

  • (c) diagnostic and laboratory testing services provided through the Fittr platform, including through Fittr-operated / in-house laboratories and Partner laboratories and associated medical professionals.

  • (d) nutrition and packaged food products sold through the Platform, including food products offered under brands such as No BS Inside Foods.

  • (e) retreat / experiential wellness offerings, including wellness retreats, yoga retreats, mindfulness retreats, community-led wellness travel experiences, and related retreat booking, coordination, and participation services.

The processing of personal data, such as the name, address, e-mail address, or telephone number of a data subject shall always be in accordance with the Information Technology Act, 2000. This Privacy Policy is published in accordance with the provisions of Rule 4 of the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011. Fittr complies with the applicable provisions of the Digital Personal Data Protection Act, 2023 (“DPDP Act”) and the Digital Personal Data Protection Rules, 2025. Fittr also complies with the The General Data Protection Regulation (GDPR), to the extent applicable to Fittr. By means of these data protection declarations, our enterprise would like to inform the general public of the nature, scope, and purpose of the personal data we collect, use and process. Furthermore, data subjects are informed, by means of this data protection declaration, of the rights to which they are entitled.

When you visit our website, mobile application, and use our services/devices, you trust us with your personal information. We take your privacy very seriously. In this privacy policy, we seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this privacy policy that you do not agree with, please discontinue use of our Sites or Apps and our services and/or you may disagree to provide any further information to us.

This privacy policy applies to all information collected through our website (such as www.fittr.com), mobile application, ("Apps"), chat applications like Whatsapp, social media accounts, email survey forms and/or any related devices, products, services, sales, marketing or events (we refer to them collectively in this privacy policy as the "Services").

Please read this privacy policy carefully as it will help you make informed decisions about sharing your personal information with us.

IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY, PLEASE DO NOT ACCESS THE WEBSITE/MOBILE APPLICATION.

TABLE OF CONTENTS

  1. 1. WHAT INFORMATION DO WE COLLECT?

  2. 2. HOW DO WE USE YOUR INFORMATION?

  3. 3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?

  4. 4. WHO WILL YOUR INFORMATION BE SHARED WITH?

  5. 5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

  6. 6. DO WE USE GOOGLE MAPS?

  7. 7. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

  8. 8. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

  9. 9. HOW LONG DO WE KEEP YOUR INFORMATION?

  10. 10. HOW DO WE KEEP YOUR INFORMATION SAFE?

  11. 11. DO WE COLLECT INFORMATION FROM MINORS?

  12. 12. WHAT ARE YOUR PRIVACY RIGHTS?

  13. 13. CONTROLS FOR DO-NOT-TRACK FEATURES

  14. 14. DO WE MAKE UPDATES TO THIS POLICY?

  15. 15. HOW CAN YOU CONTACT US ABOUT THIS POLICY?

  16. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

1. WHAT INFORMATION DO WE COLLECT?

Information you provide

In Short: We collect certain personal information necessary to provide you services, when you create an account with us.

We collect personal information such as your name and email address when you create an account with us.

We require certain personal information to provide you products or services such as- your birth date, gender, phone number, email and shipping address;- Sensitive Personal Data (Health Data): Certain information collected by us, including heart rate, heart rate variability (HRV), respiratory rate, resting heart rate (RHR), blood oxygen (SpO2), sleep data, steps, body temperature, activity data, calories, body composition metrics, medical history, diagnostic reports, weight, height, lifestyle, food preferences, nutrition data workouts, physical activity, photograph and other fitness, wellness, or health-related data, constitutes sensitive personal data / personal health data. We collect and process such data strictly for providing and improving our health, fitness, wellness, and diagnostic services, and in accordance with your consent and applicable law.- For retreat / experiential wellness offerings: booking details, retreat preferences, emergency contact details, accommodation preferences, dietary preferences or restrictions, medical disclosures voluntarily provided by you, fitness / activity suitability information, and any other information reasonably required for retreat planning, safety, coordination, communication, and participation.

Apple App Transparency API: We ask users for explicit consent via Apple App Transparency API and if the user denies the access, then we do not track the users on the Fittr App and we will not ask the users to give their consent at any point.

Your Contributions. Information and content, you provide. We collect the content, communications and other information you provide when you use our Products, including when you sign up for an account, create or share content, and message or communicate with others. This can include any information in or about the content (including without limitation, any text, information, graphics, messages, photos, images, location of a photo, the date a file was created, nutritional information contributed to the Food Database and works of authorship kind), data, questions, comments, suggestions or other content, including personally identifiable information that you upload, send, email, display, perform, distribute, post or otherwise transmit to us, at our request or on your own, on, or through the Services (such as message boards, recipe logging), whether in connection with your use of the Services or through the use of any Third Party Websites or Third Party Services or otherwise, and whether publicly posted or privately transmitted.

Your Messages. We store messages, photos, videos and documents from your chats on our servers so that you can access your chat data from any of your devices anytime without having to rely on third-party backups. All data is stored encrypted. Our developers do not access the user data.

Coaching and Progress Information. When you enrol in coaching services, we may collect information provided by you during check-ins, consultations and communications with your assigned Fittr Coach, including your weight, waist measurements, progress photographs, nutrition intake, activity, training and other health or fitness-related information.Your assigned Fittr Coach or authorised Fittr personnel may record or update your weight and waist measurements in your account on your behalf, solely on the basis of information provided by you through the Platform, chat, call, video check-in or any other authorised communication channel.We may maintain an audit record of such entries and changes, including the identity of the person making the entry, the date and time of the entry, and the previous and updated values. You may review and correct this information through the Platform or by contacting your assigned Coach or Fittr Support.

Payment Data. Payments are processed through authorised third-party payment service providers. Fittr generally receives transaction identifiers, payment status and limited billing or payment-related information required for reconciliation, refunds, fraud prevention and customer support. Fittr does not ordinarily store complete card credentials or card verification values such as CVV. Payment information is processed by the payment service provider selected for the relevant transaction in accordance with its privacy and security practices. All payment data is stored by Cashfree, RazorPay, PayPal, Payglocal, Juspay and Stripe.

Information automatically collected

In Short: Some information – such as IP address and/or browser and device characteristics – is collected automatically when you visit our Services or Apps.

We automatically collect certain information when you visit, use or navigate the Services through our Apps or Website. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services or Apps and other technical information. This information is primarily needed to maintain the security and operation of our Services or Apps, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.

Information collected through our Apps

In Short: We may collect information regarding your geo-location, mobile device, push notifications, when you use our apps.

If you use our Apps, we may also collect the following information:

Geo-Location Information. We may request access or permission to and track location-based information from your mobile device, either continuously or while you are using our mobile application, to provide location-based services like tagging your location to a post. If you wish to change our access or permissions, you may do so in your device’s settings.

Mobile Device Access. We may request access or permission to certain features from your mobile device, including your:

  • Mobile device’s storage to read & write videos, pictures & pdf files from the device,

  • Contacts to find your connections who are already using our services,

  • Camera to capture images & videos to provide services,

  • Record Audio to capture audio while recording a video or live video streaming,

  • Social media accounts to login to your Fittr account.

Screens visited, Interaction patterns (such as screen actions, gestures: taps, scrolls) by recording your screen and Device details (Type, Version, Model, Operating System). We are using the information collected by UXCam/Clarity to improve our apps/website. UXCam/Clarity does not collect personally identifiable information and does not track your browsing habits across apps.

Data about health from iOS HealthKit, Health app and Google Fit.The Fittr App (“App”) makes use of Apple’s HealthKit and your HealthKit information. If you grant our App access to HealthKit, our App can read information such as Steps and Sleep data, from HealthKit. Your unique health data you choose to send from HealthKit (including sleep and steps) is not transferred by Fittr App to any third parties for marketing or advertising and not used by Fittr to track the users in any way other than specified in this Privacy Policy. Our App cannot write data to HealthKit. You can remove Apple HealthKit read access to Fittr App at any time inside the Apple Health app.We handle all iOS Health app and HealthKit data in accordance with Apple's development guidelines. To view Apple's HealthKit developer guidelines, go to https://developer.apple.com/app-store/review/guidelines/#health-and-health-research.We handle Google Fit data in accordance with Google Fit Terms of Service. To view Google Fit Terms of Service go to https://developers.google.com/fit/terms.We handle Health Connect data in accordance with Google Health Connect Permissions policy. To view Google Health Connect Permissions policy go to https://support.google.com/googleplay/android-developer/answer/12991134?hl=en.If you wish to change any of our access or permissions, you may do so in your device’s settings. However, revoking these permissions may prevent you from using all or some of the functionality of our services.

Mobile Device Data. We may automatically collect device information (such as your mobile device ID, model and manufacturer), operating system, version information and IP address.

Push Notifications. We may request to send you push notifications regarding your account or the mobile application. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings.

Messages via messaging apps: We may request to send you notifications via Whatsapp and/or other messaging apps. If you wish to opt out from receiving communications on your chat applications, you may decline/disagree when prompted on our platform.

We collect and process health-related data, device-generated wellness data, and data accessed through integrations such as Apple Health/HealthKit, Google Fit, and Health Connect only after obtaining your explicit consent through the application interface, integration permissions, and/or device settings, as applicable. You may withdraw or modify such permissions at any time through your device or application settings, though this may affect certain functionalities of the Services. Data/Information collected on our App via wearable device/s (FITTR HART)

Heart rate

Sleep

Heart Rate Variance (HRV)

Calories

Blood Oxygen

Skin Temperature

Steps and Activity

Data/Information collected on our App via device/s (Fittr Sense)

  • Weight,

  • Body Fat Rate,

  • BMI (Body Mass Index),

  • Muscle Mass, BMR (Basal Metabolic Rate),

  • Recommended Calorie Intake,

  • Heart Rate,

  • Moisture Content,

  • Protein Rate,

  • Fat Mass, Lean Body Mass,

  • Subcutaneous Fat Rate,

  • Skeletal Muscle Rate,

  • Visceral Fat,

  • Bone Mass,

  • Muscle Rate,

  • Muscle Control Quantity,

  • Fat Control Quantity,

  • Standard Weight,

  • Weight Control, Body Type,

  • Obesity Level,

  • Health Assessment,

  • Physical Age,

  • Body Score

Information Collected Through Diagnostic and Lab Services

In Short: When you book or use our diagnostic or lab services, we collect limited personal and health information to facilitate testing, sample collection, report generation and report delivery.

We collect:

  • Identification and contact details (name, phone number, address, email, gender, and date of birth);

  • Health-related data shared for the purpose of diagnostic testing, such as medical history, prescribed tests, doctor referrals and related medical information;

  • Sample collection details, test type, laboratory processing details and diagnostic report data; and

  • Other information reasonably necessary for providing diagnostic lab services though the platform.

All such information may be collected and processed directly by Fittr through Fittr-operated/ in-house laboratories, and/or third party Partner Laboratories, Sample Collection Partners and associated medical professionals strictly to the extent necessary for booking facilitation, sample collection, test administration, report generation, report delivery, customer support, record maintenance and compliance with applicable law. Data related to lab tests and diagnostic services is handled strictly in accordance with the DPDP Act, 2023, and other applicable laws governing health data.

Information Collected Through Retreat / Experiential Wellness Services

In Short: When you register for or book a retreat / experiential wellness offering, we collect limited personal, booking, and health-related information necessary to facilitate your participation, planning, communication, accommodation allocation, safety coordination, and on-ground execution.

We may collect: A. identification and contact details (such as name, phone number, email address, age, gender, and address); B. retreat booking details, preferences, and participation information; C. accommodation preferences, dietary restrictions, allergies, injuries, medical conditions, medications, and emergency contact details, to the extent voluntarily provided by you; D. payment, transaction, and booking confirmation details; and E. communication and coordination data relating to your participation in the retreat.

All such information is collected and processed only to the extent necessary for retreat administration, communication, safety coordination, planning, and execution, in accordance with Applicable Law.

Information Collected for Additional Members / Family Profiles

Where you add, book, or manage another person under your account, including a family member, friend, dependent, or minor, we may collect, receive, store, and process such added member’s personal information and health-related information for the purpose of providing services through the Platform. This may include identification and contact details, demographic details, medical history, uploaded medical records, diagnostic and lab test details and reports, booking details, status updates, and device-generated or app-generated health and wellness data, including data collected through FITTR HART, FITTR Sense, and FITTR Sense Pro devices, where applicable. Such data may be used to generate, display, maintain, and make available the added member’s health records, reports, medical history, body composition data, wellness data, and health insights within the “My Health” section or other relevant sections of the account through which such member was added, booked, or managed.

Where you use your account to add, book, or manage another person, you represent and warrant that you are duly authorised by such person or, where applicable, by such person’s parent or lawful guardian, or you are acting in your capacity as the parent or lawful guardian of such minor, and have the authority to provide such personal information and consent on their behalf for the purposes described in this Privacy Policy.

You further acknowledge and agree that the booking details, status updates, diagnostic reports, uploaded records, medical history, health insights, and related health information of such added member may be made available through the account used to add, book, or manage such member. By proceeding with such addition or booking, you confirm that the concerned adult member has consented, or in the case of a minor, the parent or lawful guardian has consented, to the collection, processing, use, storage, display, and sharing of such personal and health-related information with the account holder for the purposes of facilitating bookings, accessing reports and records, receiving updates, obtaining support, managing related services, and enabling profile-level health tracking through the Platform.

The account holder shall be solely responsible for obtaining and maintaining all necessary consents and authorisations from the added member, or from the parent / lawful guardian in case of a minor, prior to submitting their details, adding them under the account, or booking any service on their behalf. FITTR shall be entitled to rely on such confirmation and shall not be responsible for independently verifying such authority, except where required under applicable law.

Information Collected for Packaged Food Orders and Related Services

Where you purchase packaged food products through the Platform, we may collect and process personal information such as your name, phone number, email address, billing address, shipping address, order details, payment details, transaction history, customer support communications, and any information you provide in relation to product preferences, complaints, refund or replacement requests, or delivery issues, for the purpose of processing and fulfilling your orders and providing related support services.

2. HOW DO WE USE YOUR INFORMATION?

In Short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.

We use personal information collected via our Services or Apps for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.

We use the information we collect or receive:

To facilitate account creation and logon process. If you choose to link your account with us to a third-party account *(such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process for the performance of the contract. See the section below headed " HOW DO WE HANDLE YOUR SOCIAL LOGINS " for further information.

To send you marketing and promotional communications. We and/or our third-party marketing partners, after taking explicit consent from you, may use the personal information you send to us such as name and email for our marketing purposes, if this is in accordance with your marketing preferences. You can opt-out of our marketing emails at any time (see the " WHAT ARE YOUR PRIVACY RIGHTS " below).

To send administrative information to you. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.

To facilitate booking and administration of diagnostic tests. We use your provided details to process your request for diagnostic tests, coordinate sample collection, and enable testing through Fittr-operated / in-house laboratories and/or selected NABL-certified or other qualified diagnostic partner laboratories.

To deliver your diagnostic reports. We use your account details to securely make your test results available to you.

To manage health profiles and records of added members. We use the information of added members, including family members, friends, dependents, and minors, to create and maintain their profiles, facilitate services requested through the Platform, and enable account-level management of such profiles.

To display reports, records, body metrics, and health insights for added members. We use personal information and health-related information, including uploaded records, lab reports, medical history, and device-generated data from FITTR HART, FITTR Sense, and FITTR Sense Pro, to generate, organise, store, and display health records, body composition metrics, wellness data, and health insights relating to added members in the relevant user account, including within the “My Health” section.

To facilitate services booked or used on behalf of added members. We use such information to coordinate diagnostic bookings, sample collection, report delivery, body measurement tracking, device syncing, customer support, and related health and wellness services requested through the Platform.

To process and fulfil packaged food product orders. We use your personal information to process purchases of packaged food products, coordinate order fulfilment, shipping, delivery, returns, replacements, refunds, customer support, and related service communications.

To facilitate retreat bookings and participation. We may use your information to process your retreat registration, booking, payment, confirmation, planning, communication, accommodation coordination, and participation management.

To coordinate retreat execution and participant safety. We may use information provided by you, including dietary, emergency contact, and health-related information voluntarily disclosed by you, for retreat planning, participant communication, accommodation allocation, safety coordination, and on-ground execution.

To communicate retreat-related updates. We may use your information to send booking confirmations, itinerary updates, pre-retreat instructions, schedule changes, safety information, and other retreat-related operational communications.

To track your nutrition intake, weight and fitness routine. Fittr Coaches require information about your eating habits, changes in your body weight and your fitness regime to craft a personalised Nutrition and Training Plans and to monitor your progress.

Fulfill and manage your orders. We may use your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services or Apps to deliver products to you, including through our delivery partners.

To post testimonials. We post testimonials on our Services or Apps that may contain personal information. Prior to posting a testimonial, we will obtain your consent to use your name and testimonial. If you wish to update, or delete your testimonial, please contact us at support@fittr.com and be sure to include your name, testimonial location, and contact information.

Administer prize draws and competitions. We may use your information to administer prize draws and competitions when you elect to participate in competitions.

Request Feedback. We may use your information to request feedback via calls/emails/survey tools and to contact you about your use of our Services or Apps.

To protect our Services. We may use your information as part of our efforts to keep our Services or Apps safe and secure (for example, for fraud monitoring and prevention).

To enable user-to-user communications. We may use your information in order to enable user-to-user communications with each user's consent.

To enforce our terms, conditions and policies for Business Purposes, Legal Reasons and Contractual.

To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.

To manage user accounts. We may use your information for the purposes of managing our account and keeping it in working order.

To deliver services to the user. We may use your information to provide you with the requested service.

To respond to user inquiries/offer support to users. We may use your information to investigate complaints, process refunds, coach change or product replacements, respond to your inquiries, address quality related concerns and solve any potential issues you might have with the use of our Products or Services and comply with applicable legal and regulatory obligations..

For Marketing, Publicity & Promotions. Fittr may also publish User’s name, voice, likeness and other Personal Information that is part of User’s User Content, and Fittr may use the content, or any portion of the content, for advertising, marketing, publicity and promotional activities, provided that Fittr will not exercise such rights as to any User Content which identifies User in a public manner unless User provides a separate consent to Fittr in writing (email is sufficient) authorizing such use. For full terms and conditions regarding User Content User submits to the Service, please review Fittr’s Terms & Conditions.

Fittr or others may store, display, reproduce, publish, distribute or otherwise use User Content online or offline in any media or format (currently existing or hereafter developed) and may or may not attribute it to User. Others may have access to this User Content and may have the ability to share it with third parties. Please think carefully before deciding what information User shares, including Personal Information, in connection with User’s User Content. Be aware that public postings are not confidential. Please note that Fittr does not control who will have access to the information that User chooses to make public and cannot ensure that parties who have access to such publicly available information will respect User’s privacy or keep it secure. Fittr is not responsible for the privacy or security of any information that User makes publicly available on the Service, the Mobile App or Website or what others do with information User shares with them on the Mobile App and Website. Fittr is not responsible for the accuracy, use or misuse of any User Content that User discloses or receives from third parties through the Service.

For other Business Purposes. We may use your information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Services or Apps, products, marketing and your experience. We may use and store this information in aggregated and anonymized form so that it is not associated with individual end users and does not include personal information. We will not use identifiable personal information without your consent.

3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?

In Short: We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations. We may process or share data based on the following legal basis:

Consent: We process your sensitive personal data or information if you have given us specific consent to use it for a specific purpose.

Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.

Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.

Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).

Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

More specifically, we may need to process your data or share your personal information in the following situations:

Diagnostic Laboratories and Healthcare Providers: Your personal information and health-related information may be shared with:

FITTR-operated / in-house laboratories, NABL-certified or other qualified third-party diagnostic laboratories, and sample collection partners, strictly for the purpose of facilitating bookings, sample collection, conducting diagnostic tests, processing samples, generating and sharing reports;

Registered Medical Practitioners and healthcare professionals, only to the extent necessary for interpreting reports, consultations, or providing health-related services requested by you; and

Authorised personnel within Squats Fitness Private Limited and Fittr Lifecare Private Limited, including limited teams such as diagnostics operations, customer support, and relevant technology personnel, strictly on a need-to-know basis for purposes including report access facilitation, customer support, technical troubleshooting, service improvement, and compliance with applicable law.

Added Members / Account Holder Access and Internal Service Access. Where a user adds, books, or manages another person under their account, the personal information and health-related information of such added member, including uploaded medical records, diagnostic reports, medical history, FITTR HART data, FITTR Sense / Sense Pro data, body composition metrics, booking details, status updates, and health insights, may be made accessible through the account used to add, book, or manage such member, based on the account holder’s confirmation that they are duly authorised and have obtained all necessary consents from the concerned adult member or, in the case of a minor, the parent or lawful guardian. Such information may also be accessed on a strict need-to-know basis by authorised personnel within Squats Fitness Private Limited and Fittr Lifecare Private Limited, including relevant operations, customer support, diagnostics, product, and technology teams, solely for the purposes of service delivery, troubleshooting, report access facilitation, profile management, and compliance with applicable law. We implement role-based access controls and appropriate internal safeguards to restrict such access.

Retreat execution and facilitation partners. In connection with retreat / experiential wellness offerings, we may share relevant personal data with designated retreat execution, facilitation, venue, accommodation, logistics, or operational partners, including Turiya, strictly to the extent required for retreat planning, coordination, communication, participant management, accommodation allocation, safety coordination, and on-ground execution. Such partners are authorised to use such information only for these limited purposes and not for independent marketing or unrelated use.

Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: Fittr Coaches’, Registered Medical Practitioners, sample collection partners, payment processing, data analysis, email delivery, delivery partners, hosting services and marketing efforts. Fittr Coaches and authorised personnel may access only such personal and progress information as is reasonably necessary to provide the coaching, progress-tracking, customer-support or administrative services assigned to them. We may allow selected third parties to use tracking technology on the Services or Apps, which will enable them to collect data about how you interact with the Services or Apps over time. This information may be used to, among other things, analyse and track data, determine the popularity of certain content and better understand online activity. Unless described in this Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes. We have contracts in place with our data processors, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organization apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct.

Other Users. When you share personal information (for example, by posting comments, contributions or other content to the Services) or otherwise interact with public areas of the Services, such personal information may be viewed by all users and may be publicly made available outside the Services in perpetuity. If you interact with other users of the Website/Mobile Application, those users may see your name, profile photo, and descriptions of your activity, including sending invitations to other users, chatting with other users, liking posts, posting comments, posting reviews, following Forums.

Online Postings. When you post comments, contributions or other content to the Website/Mobile Application, your posts may be viewed by all users and may be publicly distributed outside the Website/Mobile Application in perpetuity.

Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

Third-Party Advertisers. We may use third-party advertising companies to serve ads when you visit the Services or Apps. These companies may use information about your visits to our Website(s) and other websites that are contained in web cookies and other tracking technologies in order to provide advertisements about goods and services of interest to you.

Offer Wall. Our Apps may display an offer wall (“FitShop”). Such an offer wall allows us to offer gifts, or other third-party items to users in return for exchange of virtual currency (“FitCoin”). Such an offer wall may appear in our website and mobile application and be displayed to you based on certain data, such as your geographic area or demographic information. When a user redeems any products from the offer wall, the user's name, address and phone number is shared with the third party to deliver the products redeemed by the user through the offer wall.

Third-party Websites. The Website/Mobile Application may contain links to third-party websites and applications of interest, including advertisements and external services, that are not affiliated with us. Once you have used these links to leave the Website/Mobile Application, any information you provide to these third parties is not covered by this Privacy Policy, and we cannot guarantee the safety and privacy of your information. Before visiting and providing any information to any third-party websites, you should inform yourself of the privacy policies and practices (if any) of the third party responsible for that website, and should take those steps necessary to, in your discretion, protect the privacy of your information. We are not responsible for the content or privacy and security practices and policies of any third parties, including other sites, services or applications that may be linked to or from the Website/Mobile Application.

4. WHO WILL YOUR INFORMATION BE SHARED WITH?

In Short: We only share information with the following third parties.

We only share and disclose your information with the following third parties. We have categorized each party so that you may easily understand the purpose of our data collection and processing practices. If we have processed your data based on your consent and you wish to revoke your consent, please contact us using the contact details provided in the section below titled "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?".

Cloud Computing Services

Amazon Web Services (AWS) (Privacy Policy) (GDPR Compliance)

Communicate and Chat with Users

Zendesk Chat (Privacy Policy) (GDPR Compliance)

Whatsapp (Privacy Policy)

Google Forms (Privacy Policy)

Invoice and Billing

PayPal (Privacy Policy) (GDPR Compliance)

Stripe (Privacy Policy) (GDPR Compliance)

RazorPay (Privacy Policy)

CashFree (Privacy Policy)

Paytm (Privacy Policy)

Payglocal (Privacy Policy)

Juspay (Privacy Policy)

Bulk Mail Service

Mailchimp (Privacy Policy) (GDPR Compliance)

Mailgun (Privacy Policy) (GDPR Compliance)

Sendy (Privacy Policy)

User Account Registration and Authentication

Facebook Login

Google Sign-In

Sign in with Apple (Privacy Policy)

Web and Mobile Analytics

Google Analytics (Privacy Policy) (GDPR Compliance)

CleverTap (Privacy Policy) (GDPR Compliance)

UXCam (Privacy Policy) (GDPR Compliance)

Clarity (Privacy Policy) (GDPR Compliance)

AI-bot to Answer User Queries

ChatGPT (Privacy Policy) (Terms of Use) (API data usage policies)

App Testing

TestFlight

Google Play Console

Planning Nutrition & Fitness Plan

FITTR Coach

Manage App

FITTR Admins

FITTR HART API

Spren

Lab Test Reports

Healthians (Privacy Policy)

Registered Medical Practitioners

AI Tools

OpenAI (Privacy Policy) (Data Processing Addendum)

Retreat Planning / Execution / Facilitation Partners

Turiya; venue, accommodation, facilitation, and operational partners engaged for a particular retreat

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information.

Cookies and Web Beacons

You can visit our website without giving away your personal information. We may use cookies, Google Analytics, web beacons, tracking pixels, and other tracking technologies on the Website/Mobile Application to help customize the Website/Mobile Application and improve your experience and analyse how the Website/Mobile Application is used. The information collected by Google Analytics is anonymous Traffic Data on the website. We do not collect any additional information such as name, age, gender, etc upon your usage of the Website without the need to create an account. The data subject may, at any time, prevent the setting of cookies through our website by means of a corresponding setting of the Internet browser used, and may thus permanently deny the setting of cookies. Furthermore, already set cookies may be deleted at any time via an Internet browser or other software programs. This is possible in all popular Internet browsers. If the data subject deactivates the setting of cookies in the Internet browser used, not all functions of our website may be entirely usable.

For more information on how we use cookies, please refer to our Cookie Policy posted on the Website/Mobile Application, which is incorporated into this Privacy Policy. By using the Website/Mobile Application, you agree to be bound by our Cookie Policy.

Website Analytics

We may also partner with selected third-party vendors, such as Google Analytics, to allow tracking technologies and remarketing services on the Website through the use of first party cookies and third-party cookies, to, among other things, analyze and track users’ use of the Site, determine the popularity of certain content and better understand online activity. By accessing the Website, you consent to the collection and use of your information by these third-party vendors. You are encouraged to review their privacy policy and contact them directly for responses to your questions. We do not transfer personal information to these third-party vendors. However, If you do not want any information to be collected and used by tracking technologies, you can find The Google Analytics privacy policy here. You can learn more about how to opt-out of tracking in Google Analytics here or Network Advertising Initiative Opt-Out Tool or Digital Advertising Alliance Opt-Out Tool.

You should be aware that getting a new computer, installing a new browser, upgrading an existing browser, or erasing or otherwise altering your browser’s cookies files may also clear certain opt-out cookies, plug-ins, or settings.

6. DO WE USE GOOGLE MAPS?

In Short: Yes, we use Google Maps for the purpose of providing better service.

This website and mobile application uses Google Maps APIs. You may find the Google Maps APIs Terms of Service here. To better understand Google’s Privacy Policy, please refer to this link. By using our Maps API Implementation, you agree to be bound by Google’s Terms of Service.

7. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

In Short:

Our Services or Apps offer you the ability to register and login using your third-party social media account details (like your Facebook or Google logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile Information we receive may vary depending on the social media provider concerned, but will often include your name, e-mail address, friends list, profile picture as well as other information you choose to make public. We will use the information we receive only for the purposes that are described in this privacy policy or that are otherwise made clear to you on the Services or Apps. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy policy to understand how they collect, use and share your personal information, and how you can set your privacy preferences on their sites and apps.

8. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

In Short: We may transfer, store, and process your information in countries other than your own. All web servers and hosting are managed by our team using Amazon Web Services in EU Region. This includes website hosting, backups, web database, file storage, APIs, and log files. Amazon’s privacy policy can be found here: https://aws.amazon.com/privacy/.

If you are accessing our Services or Apps from outside EU Region, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information (see " WILL YOUR INFORMATION BE SHARED WITH ANYONE? " above), in India, and other countries.

If you are a resident in the European Economic Area, then these countries may not have data protection or other laws as comprehensive as those in your country. We will however take all necessary measures to protect your personal information in accordance with this privacy policy and applicable law.

9. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy policy unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). We retain your personal information for the period necessary to provide the relevant Services and fulfil the purposes described in this Privacy Policy. Following completion of the relevant Service or transaction, we will retain the personal data, associated traffic data and processing logs for a minimum period of one year from the date of the relevant processing, or for such longer period as may be required under applicable law.

Certain categories of information, including transaction, payment, accounting, tax, coaching, diagnostic, medical, grievance, fraud-prevention and dispute-related records, may be retained for longer periods where such retention is required or permitted under applicable law or is necessary for the establishment, exercise or defence of legal claims.

Upon expiry of the applicable retention period, we will delete or anonymise the personal information. Where immediate deletion is not technically feasible, including where the information is stored in backup archives, we will securely isolate the information from further processing until deletion is possible.

Your Rights Under the Digital Personal Data Protection Act (DPDP), 2023

You have the right to access, correct, update, or withdraw consent for processing of your personal data at any time, by writing to dpo@fittr.com. Upon receiving a valid request, we will act on it within a reasonable time frame not exceeding thirty (30) days, unless an extension is required by law.

10. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented an appropriate Information Security Management System (ISMS) designed to protect the security of any personal information we process. This ISMS is established and managed in alignment with global best practices and certified towards ISO 27001:2013 standard. Additionally, our ISMS is certified by a CERT-In Empaneled IT Security Auditing Organization, underscoring our commitment to robust cybersecurity measures. The system is subject to strong controls including ongoing monitoring, periodic security testing, internal/external audits and verifications. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Services or Apps is at your own risk. You should only access the services within a secure environment.

Fittr is committed to maintaining the highest standards of data privacy and security. In addition to following global best practices, our operations comply with the applicable provisions of the Health Insurance Portability and Accountability Act (HIPAA), the General Data Protection Regulation (GDPR), and the Digital Personal Data Protection Act (DPDPA). These compliance measures ensure the robust protection of sensitive personal and health-related information across our services.

11. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

Fittr does not permit a person under 18 years of age to independently create or operate an account, unless expressly permitted for a particular Service under applicable law. Where Fittr expressly provides a service intended for children or teenagers, the account or service must be initiated, managed or authorised by the child’s parent or lawful guardian. By using the Services or Apps, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services or Apps. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 18, please contact us at support@fittr.com.

12. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: Subject to applicable law, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

Digital Personal Data Protection Act, 2023 (“DPDP ACT”), Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011 permits our users who are Indian residents and The General Data Protection Regulation (EU) permits our users who are EU residents the right to review or amend the Sensitive Personal Data or Information (SPDI) and give the information provider an option to retract consent at any point of time, in relation to the information that has been so provided.

In some regions (like the European Economic Area), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws.

If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal.

If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

Account Information: If you would at any time like to review or change the information in your account or terminate your account, you can:

  • Log into your account settings and update your user account.

  • Contact us using the contact information provided

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with legal requirements.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services or Apps. To opt-out of interest-based advertising by advertisers on our Services or Apps visit http://www.aboutads.info/choices/ .

Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list – however, we will still need to send you service-related emails that are necessary for the administration and use of your account. To otherwise opt-out, you may:

  • Note your preferences when you register an account with the site.

  • Access your account settings and update preferences.

  • Contact us using the contact information provided.

Google forms: We also collect data through Google Forms and our surveys are designed to be anonymous. However, respondents should be aware that in responding to surveys, they could be disclosing information that could make them personally identifiable to Fittr. Respondents to surveys should be aware that they alone are responsible for the content of their responses.

We are specifically collecting information from our respondents so that we can better serve each of you and the Fittr community as a whole. We map the feedback given by you through these surveys to our internal variables in order to enhance our services provided to you. This information is for our internal purposes only and will not be shared with outside parties without your consent. We do ensure that only authorised people within the organisation have access to the personal data harvested from Google Forms and they respect the company’s code of conduct regarding data protection.

For more details on terms of use & privacy policy practices of Google, please visit the Google Privacy & Terms web page at http://www.google.com/intl/en/policies/privacy/ Subject to applicable law and retention requirements, you may also request deletion of your personal information, including health data, diagnostic reports, uploaded medical records, and device-generated data, by contacting us at support@fittr.com or dpo@fittr.com.

13. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy policy.

14. DO WE MAKE UPDATES TO THIS POLICY?

In Short: Yes, we will update this policy as necessary to stay compliant with relevant laws.

We may update this privacy policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting a policy of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.

15. HOW CAN YOU CONTACT US ABOUT THIS POLICY?

If you have questions or comments about this policy, you may contact our Data Protection Officer (DPO), by email at dpo@fittr.com, or by post to:

Squats Fitness Private Limited

7th Floor, Goodwill B’Yond,

Kharadi, Maharashtra - 411014

For any product, device, or diagnostic-related data inquiries, you may also reach our support desk at support@fittr.com.

Squats Fitness Private Limited is responsible for personal data processed in connection with the core Fittr Platform and coaching services. Fittr Lifecare Private Limited is responsible for personal data processed in connection with the products, devices and diagnostic services operated or provided by it. Where both entities jointly determine the purposes and means of a particular processing activity, they may act together as data fiduciaries for that specific activity.

HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please visit: support@fittr.com. We will respond to your request within 30 days.