Sysmine Tech Private Limited (“us”, “we”, or “KESHAH”, which also includes its affiliates) is the author

and publisher of the internet resource www.KESHAH.com (“Website”) on the world wide web as well

as the software and applications provided by KESHAH, including but not limited to the mobile

application ‘KESHAH’

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This privacy policy (“Privacy Policy”) explains how we collect, use, share, disclose and protect Personal

information about the Users of the Services, including the Practitioners (as defined in the Terms of Use,

which may be accessed via the following weblink https://KESHAH.com/privacy (the “Terms of Use”)),

the End-Users (as defined in the Terms of Use), and the visitors of Website (jointly and severally

referred to as “you” or “Users” in this Privacy Policy). We created this Privacy Policy to demonstrate

our commitment to the protection of your privacy and your personal information. Your use of and

access to the Services is subject to this Privacy Policy.

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BY USING THE SERVICES OR BY OTHERWISE GIVING US YOUR INFORMATION, YOU WILL BE

DEEMED TO HAVE READ, UNDERSTOOD AND AGREED TO THE PRACTICES AND POLICIES

OUTLINED IN THIS PRIVACY POLICY AND AGREE TO BE BOUND BY THE PRIVACY POLICY. YOU

HEREBY CONSENT TO OUR COLLECTION, USE AND SHARING, DISCLOSURE OF YOUR

INFORMATION AS DESCRIBED IN THIS PRIVACY POLICY. WE RESERVE THE RIGHT TO CHANGE,

MODIFY, ADD OR DELETE PORTIONS OF THE TERMS OF THIS PRIVACY POLICY, AT OUR SOLE

DISCRETION, AT ANY TIME. IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY AT ANY TIME,

DO NOT USE ANY OF THE SERVICES OR GIVE US ANY OF YOUR INFORMATION. IF YOU USE THE

SERVICES ON BEHALF OF SOMEONE ELSE (SUCH AS YOUR CHILD) OR AN ENTITY (SUCH AS

YOUR EMPLOYER), YOU REPRESENT THAT YOU ARE AUTHORISED BY SUCH INDIVIDUAL OR

ENTITY TO (I) ACCEPT THIS PRIVACY POLICY ON SUCH INDIVIDUAL’S OR ENTITY’S BEHALF, AND

(II) CONSENT ON BEHALF OF SUCH INDIVIDUAL OR ENTITY TO OUR COLLECTION, USE AND

DISCLOSURE OF SUCH INDIVIDUAL’S OR ENTITY’S INFORMATION AS DESCRIBED IN THIS

PRIVACY POLICY.

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1. Why this Privacy Policy?

This Privacy Policy is published in compliance with, inter alia:

i. Section 43A of the Information Technology Act, 2000;

ii. Regulation 4 of the Information Technology (Reasonable Security Practices and

Procedures and Sensitive Personal Information) Rules, 2011 (the “SPI Rules”);

iii. Regulation 3(1) of the Information Technology (Intermediaries Guidelines) Rules,

2011.

This Privacy Policy states the following:

iv. The type of information collected from the Users, including Personal Information

(as defined in paragraph 2 below) and Sensitive Personal Data or Information (as

defined in paragraph 2 below) relating to an individual;

v. The purpose, means and modes of collection, usage, processing, retention and

destruction of such information; and

vi. How and to whom KESHAH will disclose such information.

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2. Collection of Personal Information

Generally some of the Services require us to know who you are so that we can best meet

your needs. When you access the Services, or through any interaction with us via emails,

telephone calls or other correspondence, we may ask you to voluntarily provide us with

certain information that personally identifies you or could be used to personally identify

you. You hereby consent to the collection of such information by KESHAH. Without

prejudice to the generality of the above, information collected by us from you may include

(but is not limited to) the following:

vii. contact data (such as your email address and phone number);

viii. demographic data (such as your gender, your date of birth and your pin code);

ix. data regarding your usage of the services and history of the appointments made by

or with you through the use of Services;

x. insurance data (such as your insurance carrier and insurance plan);

xi. other information that you voluntarily choose to provide to us (such as information

shared by you with us through emails or letters) including any images and other

documents/files.

The information collected from you by KESHAH may constitute ‘personal information’ or

‘sensitive personal data or information’ under the SPI Rules.

“Personal Information” is defined under the SPI Rules to mean any information that relates

to a natural person, which, either directly or indirectly, in combination with other

information available or likely to be available to a body corporate, is capable of identifying

such person.

The SPI Rules further define “Sensitive Personal Data or Information” of a person to mean

personal information about that person relating to:

xii. passwords;

xiii. financial information such as bank accounts, credit and debit card details or other

payment instrument details;

xiv. physical, physiological and mental health condition;

xv. sexual orientation;

xvi. medical records and history;

xvii. biometric information;

xviii. information received by body corporate under lawful contract or otherwise;

xix. visitor details as provided at the time of registration or thereafter; and

xx. call data records.

KESHAH will be free to use, collect and disclose information that is freely available in the

public domain without your consent.

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3. Privacy Statements

3.1ALL USERS NOTE:

This section applies to all users.

3.1.1 Accordingly, a condition of each User’s use of and access to the Services is

their acceptance of the Terms of Use, which also involves acceptance of the terms

of this Privacy Policy. Any User that does not agree with any provisions of the same

has the option to discontinue the Services provided by KESHAH immediately.

3.1.2An indicative list of information that KESHAH may require you to provide to

enable your use of the Services is provided in the Schedule annexed to this Privacy

Policy.

3.1.3All the information provided to KESHAH by a User, including Personal

Information or any Sensitive Personal Data or Information, is voluntary. You

understand that KESHAH may use certain information of yours, which has been

designated as Personal Information or ‘Sensitive Personal Data or Information’

under the SPI Rules, (a) for the purpose of providing you the Services, (b) for

commercial purposes and in an aggregated or non-personally identifiable form for

research, statistical analysis and business intelligence purposes, (c) for sale or

transfer of such research, statistical or intelligence data in an aggregated or non-

personally identifiable form to third parties and affiliates (d) for communication

purpose so as to provide You a better way of booking appointments and for

obtaining feedback in relation to the Practitioners and their practice, (e) debugging

customer support related issues,.. (f) for the purpose of contacting you to complete

any transaction if you do not complete a transaction after having provided us with

your contact information in the course of completing such steps that are designed

for completion of the transaction. KESHAH also reserves the right to use

information provided by or about the End-User for the following purposes:

I. Identifying You.

II. Publishing such information on the Website.

III. Contacting End-Users for offering new products or services.

IV. Contacting End-Users for taking product and Service feedback.

V. Analyzing software usage patterns for improving product design

and utility.

VI. Analyzing anonymized practice information for commercial use.

VII. Processing payment instructions including those through

independent third party service providers such as payment

gateways, banking and financial institutions, pre-paid instrument

and wallet providers for processing of payment transaction or

deferral of payment facilities.

If you have voluntarily provided your Personal Information to

KESHAH for any of the purposes stated above, you hereby consent

to such collection and use of such information by KESHAH.

However, KESHAH shall not contact You on Your telephone

number(s) for any purpose including those mentioned in this sub-

section 4.1(iii), if such telephone number is registered with the Do

Not Call registry (“DNC Registry”) under the PDPA without your

express, clear and un-ambiguous written consent.

3.1.4 Collection, use and disclosure of information which has been designated as

Personal Information or Sensitive Personal Data or Information’ under the SPI

Rules requires your express consent. By affirming your assent to this Privacy

Policy, you provide your consent to such use, collection and disclosure as required

under applicable law.

3.1.5 KESHAH does not control or endorse the content, messages or information

found in any Services and, therefore, KESHAH specifically disclaims any liability

with regard to the Services and any actions resulting from your participation in any

Services, and you agree that you waive any claims against KESHAH relating to

same, and to the extent such waiver may be ineffective, you agree to release any

claims against KESHAH relating to the same.

3.1.6 You are responsible for maintaining the accuracy of the information you

submit to us, such as your contact information provided as part of account

registration. If your personal information changes, you may correct, delete

inaccuracies, or amend information by making the change on our member

information page or by contacting us through info@KESHAH.com. We will make

good faith efforts to make the requested changes in our then active databases as

soon as reasonably practicable. If you provide any information that is untrue,

inaccurate, out of date or incomplete (or becomes untrue, inaccurate, out of date or

incomplete), or KESHAH has reasonable grounds to suspect that the information

provided by you is untrue, inaccurate, out of date or incomplete, KESHAH may, at

its sole discretion, discontinue the provision of the Services to you. There may be

circumstances where KESHAH will not correct, delete or update your Personal

Data, including (a) where the Personal Data is opinion data that is kept solely for

evaluative purpose; and (b) the Personal Data is in documents related to a

prosecution if all proceedings relating to the prosecution have not been completed.

3.1.7If you wish to cancel your account or request that we no longer use your

information to provide you Services, contact us through support@KESHAH.com.

We will retain your information for as long as your account with the Services is

active and as needed to provide you with the Services. We shall not retain such

information for longer than is required for the purposes for which the information

may lawfully be used or is otherwise required under any other law for the time

being in force. After a period of time, your data may be anonymized and

aggregated, and then may be held by us as long as necessary for us to provide our

Services effectively, but our use of the anonymized data will be solely for analytic

purposes. Please note that your withdrawal of consent, or cancellation of account

may result in KESHAH being unable to provide you with its Services or to

terminate any existing relationship KESHAH may have with you.

3.1.8 If you wish to opt-out of receiving non-essential communications such as

promotional and marketing-related information regarding the Services, please

send us an email at support@KESHAH.com .

3.1.9 KESHAH may require the User to pay with a credit card, wire transfer, debit

card or cheque for Services for which subscription amount(s) is/are payable.

KESHAH will collect such User’s credit card number and/or other financial

institution information such as bank account numbers and will use that information

for the billing and payment processes, including but not limited to the use and

disclosure of such credit card number and information to third parties as necessary

to complete such billing operation. Verification of credit information, however, is

accomplished solely by the User through the authentication process. User’s credit-

card/debit card details are transacted upon secure sites of approved payment

gateways which are digitally under encryption, thereby providing the highest

possible degree of care as per current technology. However, KESHAH provides you

an option not to save your payment details. User is advised, however, that internet

technology is not full proof safe and User should exercise discretion on using the

same.

3.1.10 Due to the communications standards on the Internet, when a User or the

End-User or anyone who visits the Website, KESHAH automatically receives the

URL of the site from which anyone visits. KESHAH also receives the Internet

Protocol (IP) address of each User’s computer (or the proxy server a User used to

access the World Wide Web), User’s computer operating system and type of web

browser the User is using, email patterns, as well as the name of User’s ISP. This

information is used to analyze overall trends to help KESHAH improve its Service.

The linkage between User’s IP address and User’s personally identifiable

information is not shared with or disclosed to third parties. Notwithstanding the

above, KESHAH may share and/or disclose some of the aggregate findings (not the

specific data) in anonymized form (i.e., non-personally identifiable) with

advertisers, sponsors, investors, strategic partners, and others in order to help

grow its business.

3.1.11 The Website uses temporary cookies to store certain (that is not sensitive

personal data or information) that is used by KESHAH and its service providers for

the technical administration of the Website, research and development, and for

User administration. In the course of serving advertisements or optimizing services

to its Users, KESHAH may allow authorized third parties to place or recognize a

unique cookie on the User’s browser. The cookies however, do not store any

Personal Information of the User. You may adjust your internet browser to disable

cookies. If cookies are disabled you may still use the Website, but the Website may

be limited in the use of some of the features.

3.1.16KESHAH maintains a strict "No-Spam" policy, which means that KESHAH

does not intend to sell, rent or otherwise give your e-mail address to a third party

without your consent.

3.1.17 KESHAH has implemented best international market practices and security

policies, rules and technical measures to protect the personal data that it has under

its control from unauthorised access, improper use or disclosure, unauthorised

modification and unlawful destruction or accidental loss. However, for any data

loss or theft due to unauthorized access to the User’s electronic devices through

which the User avails the Services, KESHAH shall not be held liable for any loss

whatsoever incurred by the User.

3.1.18 KESHAH implements reasonable security practices and procedures and has

a comprehensive documented information security programme and information

security policies that contain managerial, technical, operational and physical

security control measures that are commensurate with respect to the information

being collected and the nature of KESHAH’s business.

3.1.19 KESHAH takes your right to privacy very seriously and other than as

specifically stated in this Privacy Policy, will only disclose your Personal

Information in the event it is required to do so by law, rule, regulation, law

enforcement agency, governmental official, legal authority or similar requirements

or when KESHAH, in its sole discretion, deems it necessary in order to protect its

rights or the rights of others, to prevent harm to persons or property, to fight fraud

and credit risk, or to enforce or apply the Terms of Use.

3.3END-USERS NOTE:

This section applies to all End-Users.

3.3.1As part of the registration/application creation and submission process that is

available to End-Users on this Website, certain information, including Personal

Information or Sensitive Personal Data or Information is collected from the End-

Users.

3.3.2All the statements in this Privacy Policy apply to all End-Users, and all End-

Users are therefore required to read and understand the privacy statements set

out herein prior to submitting any Personal Information or Sensitive Personal Data

or Information to KESHAH, failing which they are required to leave the KESHAH

immediately.

3.3.3If you have inadvertently submitted any such information to KESHAH prior to

reading the privacy statements set out herein, and you do not agree with the

manner in which such information is collected, processed, stored, used or disclosed,

then you may access, modify and delete such information by using options provided

on the Website. In addition, you can, by sending an email to

support@KESHAH.com, inquire whether KESHAH is in possession of your personal

data, and you may also require KESHAH to delete and destroy all such information.

3.3.4 End-Users’ personally identifiable information, which they choose to provide

on the Website is used to help the End-Users describe/identify themselves. Other

information that does not personally identify the End-Users as an individual, is

collected by KESHAH from End-Users (such as, patterns of utilization described

above) and is exclusively owned by KESHAH. KESHAH may also use such

information in an aggregated or non-personally identifiable form for research,

statistical analysis and business intelligence purposes, and may sell or otherwise

transfer such research, statistical or intelligence data in an aggregated or non-

personally identifiable form to third parties and affiliates. In particular, KESHAH

reserves with it the right to use anonymized End-User demographics information

and anonymized End-User health information for the following purposes:

Analyzing software usage patterns for improving product design and utility.

Analyzing such information for research and development of new

technologies.

Using analysis of such information in other commercial product offerings of

KESHAH.

Sharing analysis of such information with third parties for commercial use.

3.3.5 KESHAH will communicate with the End-Users through email, phone and

notices posted on the Website or through other means available through the

service, including text and other forms of messaging. The End-Users can change

their e-mail and contact preferences at any time by logging into their "Account" at

www.KESHAH.com and changing the account settings.

3.3.6At times, KESHAH conducts a User survey to collect information about End-

Users' preferences. These surveys are optional and if End-Users choose to respond,

their responses will be kept anonymous. Similarly, KESHAH may offer contests to

qualifying End-Users in which we ask for contact and demographic information

such as name, email address and mailing address. The demographic information

that KESHAH collects in the registration process and through surveys is used to

help KESHAH improve its Services to meet the needs and preferences of End-

Users.

3.3.7 KESHAH may keep records of electronic communications and telephone calls

received and made for making appointments or other purposes for the purpose of

administration of Services, customer support, research and development and for

better listing of Practitioners.

3.3.8 All KESHAH employees and data processors, who have access to, and are

associated with the processing of sensitive personal data or information, are

obliged to respect the confidentiality of every End-Users’ Personal Information or

Sensitive Personal Data and Information. KESHAH has put in place procedures and

technologies as per good industry practices and in accordance with the applicable

laws, to maintain security of all personal data from the point of collection to the

point of destruction. Any third-party data processor to which KESHAH transfers

Personal Data shall have to agree to comply with those procedures and policies, or

put in place adequate measures on their own.

3.3.9KESHAH may also disclose or transfer End-Users’ personal and other

information provided by a User, to a third party as part of reorganization or a sale

of the assets of a KESHAH corporation division or company. Any third party to

which KESHAH transfers or sells its assets to will have the right to continue to use

the personal and other information that End-Users provide to us, in accordance

with the Terms of Use

3.3.10 To the extent necessary to provide End-Users with the Services, KESHAH

may provide their Personal Information to third party contractors who work on

behalf of or with KESHAH to provide End-Users with such Services, to help

KESHAH communicate with End-Users or to maintain the Website or independent

third party service providers to process payment instructions including providing a

payment deferral facility to End-Users in relation to the Services. These third-party

service providers have access to information needed to process payments, but may

not use it for other purposes. Generally these contractors do not have any

independent right to share this information, however certain contractors who

provide services on the Website, including the providers of online communications

services, may use and disclose the personal information collected in connection

with the provision of these Services in accordance with their own privacy policies.

In such circumstances, you consent to us disclosing your Personal Information to

contractors, solely for the intended purposes only.

3.4 CASUAL VISITORS NOTE:

3.4.1 No sensitive personal data or information is automatically collected by

KESHAH from any casual visitors of this website, who are merely perusing the

Website.

3.4.2 Nevertheless, certain provisions of this Privacy Policy are applicable to even

such casual visitors, and such casual visitors are also required to read and

understand the privacy statements set out herein, failing which they are required

to leave this Website immediately.

3.4.3 If you, as a casual visitor, have inadvertently browsed any other page of this

Website prior to reading the privacy statements set out herein, and you do not

agree with the manner in which such information is obtained, collected, processed,

stored, used, disclosed or retained, merely quitting this browser application should

ordinarily clear all temporary cookies installed by KESHAH. All visitors, however,

are encouraged to use the “clear cookies” functionality of their browsers to ensure

such clearing / deletion, as KESHAH cannot guarantee, predict or provide for the

behavior of the equipment of all the visitors of the Website.

3.4.4 You are not a casual visitor if you have willingly submitted any personal data

or information to KESHAH through any means, including email, post or through the

registration process on the Website. All such visitors will be deemed to be, and will

be treated as, Users for the purposes of this Privacy Policy, and in which case, all

the statements in this Privacy Policy apply to such persons.

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4. Confidentiality and Security

4.1Your Personal Information is maintained by KESHAH in electronic form on its

equipment, and on the equipment of its employees. Such information may also be

converted to physical form from time to time. KESHAH takes all necessary precautions to

protect your personal information both online and off-line, and implements reasonable

security practices and measures including certain managerial, technical, operational and

physical security control measures that are commensurate with respect to the information

being collected and the nature of KESHAH’s business.

4.2 No administrator at KESHAH will have knowledge of your password. It is important for

you to protect against unauthorized access to your password, your computer and your

mobile phone. Be sure to log off from the Website when finished. KESHAH does not

undertake any liability for any unauthorized use of your account and password. If you

suspect any unauthorized use of your account, you must immediately notify KESHAH by

sending an email to support@KESHAH.com You shall be liable to indemnify KESHAH due

to any loss suffered by it due to such unauthorized use of your account and password.

4.3 KESHAH makes all User information accessible to its employees, agents or partners

and third parties only on a need-to-know basis and binds only its employees to strict

confidentiality obligations.

4.6Notwithstanding the above, KESHAH is not responsible for the confidentiality, security

or distribution of your Personal Information by our partners and third parties outside the

scope of our agreement with such partners and third parties. Further, KESHAH shall not be

responsible for any breach of security or for any actions of any third parties or events that

are beyond the reasonable control of KESHAH including but not limited to, acts of

government, computer hacking, unauthorized access to computer data and storage device,

computer crashes, breach of security and encryption, poor quality of Internet service or

telephone service of the User etc.

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5. Change to Privacy Policy

KESHAH may update this Privacy Policy at any time, with or without advance notice. In the

event there are significant changes in the way KESHAH treats User’s personally

identifiable information, or in the Privacy Policy itself, KESHAH will display a notice on the

Website or send Users an email, as provided for above, so that you may review the changed

terms prior to continuing to use the Services. As always, if you object to any of the changes

to our terms, and you no longer wish to use the Services, you may contact

support@KESHAH.com to deactivate your account. Unless stated otherwise, KESHAH’s

current Privacy Policy applies to all information that KESHAH has about you and your

account.

If a User uses the Services or accesses the Website after a notice of changes has been sent

to such User or published on the Website, such User hereby provides his/her/its consent to

the changed terms.

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6. Children’s and Minor’s Policy

KESHAH strongly encourages parents and guardians to supervise the online activities of

their minor children and consider using parental control tools available from online

services and software manufacturers to help provide a child-friendly online environment.

These tools also can prevent minors from disclosing their name, address, and other

personally identifiable information online without parental permission. Although the

KESHAH Website and Services are not intended for use by minors, KESHAH respects the

privacy of minors who may inadvertently use the internet or the mobile application.

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7. Consent to this Policy

You acknowledge that this Privacy Policy is a part of the Terms of Use of the Website and

the other Services, and you unconditionally agree that becoming a User of the Website and

its Services signifies your (i) assent to this Privacy Policy, and (ii) consent to KESHAH using,

collecting, processing and/or disclosing your Personal Information in the manner and for the purposes set out in this  Privacy Policy. Your visit to the Website and use of the Services

is subject to this Privacy Policy and the Terms of Use.