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HappyYou Privacy Policy

Introduction

This PRIVACY POLICY (“Policy”) is effective from 23 May, 2023. Kotak Mahindra Life Insurance Company Limited (hereinafter referred to as “Kotak Life”, “we”, “our” or “us”) is committed to protecting the End User’s (hereinafter referred to as “you” or “your”) privacy and providing you with a secure experience on the HappyYou by Kotak application (hereinafter referred to as “this HappyYou by Kotak app” or “the HappyYou by Kotak app” or “our HappyYou by Kotak app”). All information submitted to us; by you on this HappyYou by Kotak app shall be safeguarded and protected to the extent most reasonably practicable.

This Policy applies to this HappyYou by Kotak app; consequently, the use of this HappyYou by Kotak app by you and also to the services that are offered through it. By using this HappyYou by Kotak app, you agree to the terms of this Policy. By divulging any information to us, you hereby unconditionally agree to the terms and conditions contained in this Policy. This Policy shall broadly describe the method of collection, use and access of your Personal Information.

Personal Data or Information, Sensitive Personal Data or Information shall mean the following:

“Personal Data or Information” means any information that relates to a natural person, which, either directly or indirectly, in combination with other information available or likely to be available with a body corporate, is capable of identifying such person.

“Sensitive Personal Data or Information” of a person means such personal information which consists of information relating to;— (i) password; (ii) financial information such as Bank account or credit card or debit card or other payment instrument details; (iii) physical, physiological and mental health condition; (iv) sexual orientation; (v) medical records and history; (vi) Biometric information; (vii) any detail relating to the above clauses as provided to body corporate for providing service; and (viii) any of the information received under above clauses by body corporate for processing, stored or processed under lawful contract or otherwise: provided that, any information that is freely available or accessible in public domain or furnished under the Right to Information Act, 2005 or any other law for the time being in force shall not be regarded as Sensitive Personal Data or Information for the purposes of this Policy.

Kotak Life may collect your Personal Information including but not limited to your Sensitive Personal Data or Information during the use of our HappyYou by Kotak app and while availing the services listed on the HappyYou by Kotak app. Kotak Life is committed to protecting the privacy, confidentiality, accuracy and security of your Personal Information/ Sensitive Personal Data that it collects, uses, retains and discloses in the course of conducting its business.

What Personal Information we collect:

The Personal Information collected by us shall include but not be limited to information such as your name, date of birth, email address, physical, psychological and mental health conditions, gender, sexual orientation, medical records, family history, lifestyle habits and other information as disclosed by you in the registration page of our HappyYou by Kotak app; or in any other manner provided by you.

You shall be solely responsible to provide/ keep your Personal Information accurate and up to date. All the services/ products provided through our HappyYou by Kotak app work in conjunction with a “User Account” which is created by you on the HappyYou by Kotak app.

You further agree and understand that Kotak Life may already have some information pertaining to you; which was collected in relation to some existing/ past Kotak Life product(s) or service(s). In which case; you hereby explicitly provide Kotak Life the consent to transmit/ store/ copy any and all such information to your User Account at the sole discretion of Kotak Life.

  • When you sign up for a User Account; you are required to provide your mobile number, date of birth, full name and other such details sought from you.
  • To benefit fully from the HappyYou by Kotak app; you are required to add additional personal details to your User Account such as your height, weight, gender, age etc.
  • The HappyYou by Kotak app asks you to authenticate your Google User Account using your Google User credentials, through Google’s Authentication API which ensures complete security and confidentiality. HappyYou by Kotak use and transfer of information received from Google APIs to any other app will adhere to Google API Services User Data Policy, including the Limited Use requirements. To authenticate your Google User Account in the HappyYou by Kotak app is optional and at your discretion. Note that, in the absence of this Authentication, the HappyYou by Kotak app will not have the respective user data.
  • The HappyYou by Kotak app collects your steps data and other data associated with steps and physical activity as available in your Google Account through the FIT API. The data so collected will be used with other user input data to create a health score card for the user with “call to action” interventions.
  • Information (if any) sent from your current or past Kotak Life product(s)/ service(s); to the HappyYou by Kotak app is also stored in your User Account.
  • Additional information that you add manually to the HappyYou by Kotak app is also stored in your User Account.

We will further collect industry standard log data about the browser and the operating system you are using, the address of the external or internal page that referred you, your IP address at the time of User Account creation and a log of the pages that you visit on the HappyYou by Kotak app in association with your IP address. We also collect the IP address associated with the device running our HappyYou by Kotak app; each time you sync.

We collect location data provided by your mobile device post your consent. You must first enable location services when you download our HappyYou by Kotak app or an updated version of the same. You can then turn location services on and off within the HappyYou by Kotak app to activate optional features. You can opt out of location services at any time.

How we use your Personal Information:

The data provided to us, by you may be subsequently used for purposes such as processing your application(s), the assessment and processing of request(s), administrative purposes relevant to any products/ services provided to you by Kotak Life and for any other purposes duly permitted by applicable laws. Kotak Life will not use your Personal Information for purposes other than those listed in this Policy unless we obtain your prior consent.

We may additionally use your Personal Information to:

  • Provide you access to the HappyYou by Kotak app;
  • Analyze the HappyYou by Kotak app’s usage and improve it;
  • Deliver to you any administrative notices and communications relevant to your use of Kotak Life’s product(s)/service(s);
  • Provide you with updates regarding Kotak Life’s product(s)/ service(s);
  • Perform internal market research, project planning, troubleshooting problems, and to detect and protect against error, fraud or other criminal activity;
  • Enforce the HappyYou by Kotak app’s - Terms of Use (herein also referred to as the “Terms”) .

Disclosure of your Personal Information/ other information:

Kotak Life may share your Personal Information/ other information for the purpose of providing its product(s) and service(s) and its related activities or for any other purposes permitted by law. Additionally, your Personal Information/ other information may be shared in accordance with your consent provided to Kotak Life from time-to-time through various modes. Kotak Life may disclose your Personal Information/ other information to any of its associates and affiliates, without any limitation.

Kotak Life may from time-to time share your Personal Information/ other information with its strategic partners/ service providers that; together with Kotak Life are responsible to provide the products and services to you. In such cases, your respective account(s) with such third parties and its use shall be governed by that third party’s privacy policy; and your Kotak Life’s User Account shall continue to be governed by this Policy.

Kotak Life may also be required to share your Personal Information/ other information with companies who have developed the HappyYou by Kotak app for Kotak Life and provide services such as information processing, rewards fulfillment, customer data management, customer research and others.

We may also disclose certain information about you to third parties; if we determine that such disclosure is reasonably necessary to - (i) enforce the Policy and/ or the Terms; (ii) protect our operations or users; (iii) if we are required to do so by any applicable law, rule, regulation, subpoena or any other statutory/ regulatory process or directives; (iv) enforce the terms and conditions of the product(s)/ service(s); (v) protect or defend our rights, interests and property or that of our associates and affiliates, or that of our or our affiliate's employees, consultants etc.; (vi) fraud prevention purposes; (vii) outsource such activities which are not prohibited to be outsourced by law. In the event of a re-structuring exercise which includes reorganization, merger etc. of Kotak Life; we may transfer any and all of your Personal Information we collect to the then relevant party or our affiliate; without your approval.

Kotak Life shall under no circumstances be held liable for any disclosure of your Personal Information/ other information in accordance with this Policy or as per the terms of any other agreement we may have with you.

Contest, surveys and giveaways:

While the activities’ details provided by you through the HappyYou by Kotak app would be rewarded as per the eligibility and applicable rewards criteria as decided from time-to-time, Kotak Life may offer you the opportunity to participate in contests, giveaways and other promotions. Any information submitted in connection with such activities will be treated in accordance with this Policy, unless specifically set forth in the terms and conditions/ rules of those contests, giveaways or promotions. From time-to-time, Kotak Life may also ask you to participate in surveys designed to help us improve the HappyYou by Kotak app.

Disclaimer for products/ provision of services:

While using the HappyYou by Kotak app and consequently availing the products/ services made available to you thereunder; you are advised/ informed that all such products/ services are being provided by third party service providers and you are availing the same at your own risk/ volition. Kotak Life disclaims any and all liability arising out of/ related to such products/ services in any manner whatsoever in nature.

Authorization to contact:

You authorize Kotak Life to contact you through means such as (i) call; (ii) short messaging service (SMS); (iii) email; (iv) other similar means using the contact information (made available by you on our HappyYou by Kotak app either at the time of subscription/ making an inquiry/ application for any of the offerings provided or otherwise). You agree to receive offer communications from us for the offerings you have opted for and/ or with regards to our other offerings which we feel you may be interested in. You authorize us to contact you by way of any other similar means for the mentioned purpose; irrespective of you being registered with the National Do Not Call (NDNC) registry for a period of 30 (thirty) days from you furnishing the information or not.

Data Security:

We intend to use a combination of firewall barriers, encryption techniques and authentication procedures among others to maintain the security of your data and to protect Kotak Life’s User Accounts, systems from unauthorized access.

While Kotak Life has taken reasonable measures to protect your Personal Information/ other information in accordance with this Policy; the internet as such cannot be guaranteed to be completely secure and safe. Kotak Life hence does not warrant the security of any Personal Information/ information provided by you.

It is important to understand that these precautions only apply to our HappyYou by Kotak app. We exercise no control over how your information is stored, maintained or displayed by third parties or on third party sites.

Registration and password:

When you register for the HappyYou by Kotak app, Kotak Life shall seek a one-time password (“OTP”) from you for your privacy and security. The said OTP shall be shared with you on the mobile number registered with Kotak Life. This OTP is stored in an encrypted manner on our systems.

You shall be solely responsible for maintaining the confidentiality of your login information and OTP. You shall also be responsible for all uses of your login information, whether or not authorized by you. You agree to immediately notify us of any unauthorized use of your login information/ password/ User Account. Kotak Life cannot and does not assume any responsibility or liability for any information submitted by another person who has fraudulently accessed your User Account or any third party's fraudulent use/ misuse of your login information/ password/ your User Account.

You represent and warrant that the information that you provide about yourself; as requested in the HappyYou by Kotak app is accurate and complete. You agree to update your information as necessary; including providing Kotak Life your current email address and mobile number, so that you may receive timely notifications and other account related communications.

Amendments to the Policy:

Kotak Life reserves the right to update/ amend/ replace this Policy at any time without any notice and your continued use of your User Account shall be deemed to be your consent to such updated/ amended/ replaced Policy.