Privacy Policy

This Privacy Policy outlines how SurgiNatal (referred to as "we", "our", or "us") collects, uses, and protects the personal information of users who visit our website or make purchases through our platform.

This document is published in accordance with the provisions of the Information Technology Act, 2000 and the rules made there-under that require publishing the rules and regulations, privacy policy, and terms of use on an online portal of the Company. By visiting this Platform, providing your information or availing our product/service, you expressly agree to be bound by the terms and conditions of this Privacy Policy, the Terms of Use and the applicable service/product terms and conditions, and agree to be governed by the laws of India including but not limited to the laws applicable to data protection and privacy. If you do not agree please do not use or access our Platform.

The Company is strongly committed to protecting 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.

General Terms:

The Company shall not be held liable for disclosure of any information if such disclosure is in accordance with this Privacy Policy, the Terms of Use, and/or applicable law.

By accessing or using the Platform, or by otherwise giving us your information, you confirm that you have the capacity to enter into a legally binding contract under the laws of India, and 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, sharing, and 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, and any continued use of the Platform, following any such amendments to the Privacy Policy, will be deemed as an implicit acceptance of the Privacy Policy in its amended form.

You are requested to review the Privacy Policy from time to time to keep yourself updated with any changes, or modifications made to the terms here of.

If you are accessing or using this Platform from an overseas location, you do so at your own risk and shall be solely liable for compliance with any applicable local laws.

All capitalized terms used but not defined herein shall have the meaning ascribed to in the Terms of Use.

Information Collection

You (i.e. the User) are the sole owner of your (i.e. User’s) information. The Company just collects your information through the Platform for providing the products and services you have signed up for. We will not sell, share, transfer, or rent any personal information to others in ways different from what is disclosed in this privacy policy and the Terms of Use.

The Company collects information from you on the Register/Log-in page of the Platform. On the signup page, you are required to give your personally identifiable contact information (such as name, mobile number, email ID, credit card/debit card and other payment instrument details etc.).

A verification process is used to confirm your identity through the contact information that you provide. When the Platform requests your identity, the Platform will clearly indicate the purpose of the inquiry before the information is requested.

We use your contact information to send you offers based on your previous orders and your interests. If you choose to post messages on our message boards, chat rooms or other message areas or leave feedback on the Platform or the social media handles maintained by us or if you use voice commands or virtual try and buy or similar features to shop on the Platform, we will collect that information you provide to us. We retain this information as necessary to resolve disputes, provide customer support, troubleshoot problems or for internal research and analysis as permitted by law.

We may track your buying behavior, preferences, and other information that you choose to provide on our Platform. We use this information to do internal research on our users' demographics, interests, and behavior to better understand, protect and serve our users. This information is compiled and analyzed on an aggregated basis. This information may include the URL that you just came from (whether this URL is on our Platform or not), which URL you next go to (whether this URL is on our Platform or not), your computer browser information, and your IP address.

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 platform, 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 Platform.

We will occasionally ask you to participate in optional surveys conducted either by us or through a third-party market research agency. These surveys may ask you for personal information, contact information, date of birth, demographic information (like zip code, age, or income level), attributes such as your interests, household or lifestyle information, your purchasing behavior or history, preferences, and other such information that you may choose to provide. The surveys may involve collection of voice data or video recordings, the participation of which would purely be voluntary in nature. We use this data to tailor your experience at our Platform, providing you with content that we think you might be interested in and to display content according to your preferences.

Children’s And Minor’s Privacy

The Company 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 Platform is not intended for use by minors, the Company respects the privacy of minors who may inadvertently use the Internet or the Platform.

Data Retention

Subject to the other terms contained in this Privacy Policy and the Terms of Use, your information will be retained with the Company until you specifically request the Company to destroy such information by way of a written request. The Company shall, upon receipt of such 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. The data is stored on cloud servers (AWS) in India.

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 info@surginatal.com. If you are using an e-mail forwarding service or other similar service please make sure to include the correct e-mail address or addresses.

Company as a Pass-Through Facilitator

The Company may be a pass-through facilitator for data under a contract with a client or partner (“Enterprise Client”).In such cases, the Company shall not be deemed to be the owner of such information. The Company may, as part of the agreement with such Enterprise Clients, use the information collected from such Enterprise 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 of Use.

Please note however, that in respect of any information received by the Company under certain specific patient support program:

The Company shall retain identified data for a period of 5 (Five) years from the date of termination of such agreement, for performance of its contractual obligations, audits, diligence there-under; and
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 of time will be used for the purpose of compliance with applicable law, carrying on its contractual obligations, for carrying on audits and improvement of its technology, and strengthening its AI engine. All personal identification data will be deleted after a period of 5 years from the date of termination of the agreement.

Use of the Information Collected

Use of Information for Services - The primary goal of the Company in collecting the information is to provide you the Services as defined in the Terms of Use. 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 Platform via telephone or email;
Provide you with further information, products and services;
Better understand of users’ needs and interests;
Personalize your experience and customize experience;
Diagnosing and assisting you in your clinical, health, and general well-being 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 Platform, including but not limited to the algorithms, logic systems, content, decision support, engineering, and artificial intelligence;
Providing access to your information to healthcare practitioners and partners;
Providing data to clients or partners under the terms of agreement with them;
Providing access to your “User Profile” to other users of the Platform, Company administrators, Company moderators, Health Coaches and Primary Caregivers;
For carrying on audits, due diligence for effecting investments in the company
Detect and protect us against error, fraud, and other criminal activity;
Make disclosures as may be required under applicable law.
Improve our Platform in order to better serve the user;
Allow us to better service 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

Sale of Assets, Merger, Acquisition

The Company may share your information, including your information with our parents, subsidiaries and affiliates for internal purposes. The Company also reserves the right to disclose and transfer all such information:

To a subsequent owner, co-owner or operator of the Platform, Website or applicable database.
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 Platform 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.

Ownership of work Products

Any information provided by you through the Platform may be utilized by the Company for carrying on data analytics, derivatives, and other work products. The Company shall be deemed to be the sole owner of any and all such data analytics, derivatives, and work products, and may use all such data analytics, derivatives and work products for each of the purposes identified in this Privacy Policy and the Terms of Use.

Non-disclosure of Information

Subject to the provisions of this Privacy Policy and the Terms of Use, the Company pledges that it will not sell or rent your personal details to anyone and your personal information will be protected and maintained strictly confidential by the Company except in the following cases:

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 in order to provide you the Services, enforce or apply the Terms of Use, or to protect the rights, property or safety of the Company, its users or others. This includes exchanging information with other companies/agencies that work for fraud prevention;
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 entities.

Sharing of Information

Sharing - 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 may be on an identified or unidentified basis, based on the terms agreed by the Company with such partner/client. 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 the 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.
Consulting and Sub Contracting - The Company may sub-contract all or part of the Services to a third-party sub-contractor, or 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

Cookies

We use data collection devices such as "cookies" on certain pages of the Platform to help analyze our web page flow, measure promotional effectiveness, and promote trust and safety. "Cookies" are small files placed on your hard drive that assist us in providing our services. Cookies do not contain any of your personal information. We offer certain features that are only available through the use of a "cookie". We also use cookies to allow you to enter your password less frequently during a session. Cookies can also help us provide information that is targeted to your interests.

Most cookies are "session cookies," meaning that they are automatically deleted from your hard drive at the end of a session. You are always free to decline/delete our cookies if your browser permits, although in that case you may not be able to use certain features on the Platform and you may be required to re-enter your password more frequently during a session.

Additionally, you may encounter "cookies" or other similar devices on certain pages of the Platform that are placed by third parties. We do not control the use of cookies by third parties. We use cookies from third-party partners such as Google Analytics for marketing and analytical purposes. Google Analytics helps us understand how our customers use the site. You can read more about how Google uses your personal information here: https://www.google.com/intl/en/policies/privacy/. You can opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout. You can also control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on the services.

Spam

The Company maintains a strict “No-Spam” policy, which means that the Company does not intend to sell, rent, or otherwise give your e-mail address to a third party without your consent.

Exclusion

This Privacy Policy does not apply to any information other than information collected by the Company via any means, including the Platform, including such information collected in accordance with the clause on “Use of the Information Collected” above. This Privacy Policy will not apply to any unsolicited information provided by you through this Platform or through any other means. This includes but is not limited to, information posted on any public areas of the Platform. All such unsolicited information shall be deemed to be non-confidential and the Company will be free to use, and disclose such unsolicited information without limitation.

The Company also protects your personal information offline other than as specifically mentioned in this Privacy Policy. Access to your personal information is limited to employees, agents, consultants or partners and third parties, who the Company reasonably believes will need that information to enable the Company to provide Services to you. The Company will make best efforts to ensure that your personal contact information is protected. However, the Company 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.

Confidentiality

The Company takes all necessary precautions to protect your personal information both online and offline. No administrator at the Company will have knowledge of your password.

Third-party Links

The Platform may contain links to other sites, products, platforms and services. 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 website that collects personally identifiable information. If you decide to access any of the third-party sites linked to the Platform, you do this entirely at your own risk. Any links to any partner of the Platform 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 Platform. You further acknowledge and agree that we are not liable for any loss or damage which may be incurred by you as a result of the collection and/or disclosure of your information via Third Party Links, as a result of any reliance placed by you on the completeness, accuracy or existence of any advertising, products services, or other materials on, or available via such Third Party Links. This will include all transactions, and information transmitted therein, between you and any such third-party sites or applications or resources, such transactions are strictly bi-partite. We shall not be liable for any disputes arising from or in connection with such transactions between you and the aforementioned third parties. We recommend that you exercise reasonable diligence, as you would in traditional offline channels and practice judgment and common sense before committing to any transaction or exchange of information, including but not limited to reviewing the third-party website or application’s privacy policy.

Notification of Changes

We may update this Privacy Policy at any time, with or without advance notice. In the event there are significant changes in the way we treat your personally identifiable information, or in the Privacy Policy document itself, we will display a notice on the Company website or send you a notification or update of the same through electronic means either within or outside the Platform, so that you may review the changed terms. As always, if you object to any of the changes to our terms, and you no longer wish to use the Platform, you may contact info@surginatal.com to deactivate your account. Unless stated otherwise, our current Privacy Policy applies to all information that the Company has about you and your account.

Using the Company Services or accessing the Platform after a notice of changes has been sent to you or published on our website shall constitute your consent to the changed terms.

Consent To This Policy

The Terms of Use Agreement is incorporated herein by reference in its entirety.

Grievance Officer

If you have any grievance with respect to the Platform or the Services, including any discrepancies and grievances with respect to the processing of information, you can contact our Grievance Officer at: ANUPAM KUMAR GARG

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.

Contact person in data protection matters

If you have any questions regarding the processing of your personal data, please contact us via the following: Data Protection Officer: ANUPAM KUMAR GARG, E-mail: info@surginatal.com

Consent

By consenting to the terms under this Privacy Policy, you hereby provide express consent to the Company to collect, share, transfer, store, retain, disseminate or use the information collected by the Company from your usage of the Platform in accordance with the terms of the Privacy Policy. The Company will continue to retain information provided by you until you specifically request the Company to destroy such information. You may, at any time, withdraw consent for the collection or processing of any information provided by you, by sending an email to info@surginatal.com Upon verification of such 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. 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.

Miscellaneous

Indemnity: You agree and undertake to indemnify us in any suit or dispute by any third party arising out of disclosure of information by you to third parties either through our Platform or otherwise and your use and access of websites, applications and resources of third parties. We assume no liability for any actions of third parties with regard to your personal information which you may have disclosed to such third parties.
Severability: Each clause of this Privacy Policy shall be and remain separate from and independent of and severable from all and any other clauses herein except where otherwise expressly indicated or indicated by the context of the Privacy Policy. The decision or declaration that one or more clauses are null and void shall have no effect on the remaining clauses of this Privacy Policy.

Last Updated: 15th May 2025