KRIVI.AI APP PRIVACY POLICY LAST UPDATED: July 3, 2025 INTRODUCTION At Ability Advocacy Private Limited (“Ability Advocacy,” “we,” “us,” or “our”), we prioritise your privacy and are committed to protecting the personal information of all individuals who interact with our KRIVI.AI mobile application and related services. This Privacy Policy (“Policy”) is designed to provide a transparent explanation of how Ability Advocacy collects, uses, stores, and discloses personal information you share with us or that we obtain when you use our KRIVI.AI mobile application, online portals, or related services (collectively, the “Services”). This Policy reflects our commitment to upholding the highest standards of privacy protection, compliance with global and local laws, and fostering trust with all who engage with our Services. SCOPE & APPLICATION This Policy applies to information collected through the KRIVI.AI mobile application and any online or mobile-enabled technology or digital tools that link to this Policy (collectively, our “Platform”). This Policy also applies to information shared with us by our approved partners and other third-party sources. This Policy does not apply to information collected offline or through websites and other online services that do not display or link to this Policy, including third-party websites to which our Platform may link. By using our Services, you (as the parent or legal guardian) agree to the collection and use of information in accordance with this Policy. COLLECTION & USE OF INFORMATION When you view and/or interact with our Platform, we may collect and combine information about you, how you engage with our Platform, and the devices you use to view and/or interact with our Platform for the legitimate purposes outlined below. This includes information that you directly provide to us in connection with your use of the Platform and information collected automatically when you view and/or interact with our Platform. Some of the information we collect may be personally identifiable information (“Personal Data”), which includes, but is not limited to, information like your name, email address, postal address, phone number, and other information that can identify you. We also collect sensitive personal data or information (“SPDI”) as defined under applicable laws, which includes, but is not limited to, health records, medical history, biometric data, genetic data, and other health-related information of children under your care. We do not collect information that would personally identify you unless you choose to provide it or as otherwise provided in this Policy. You can access and browse certain parts of our Platform at any time without providing any personally identifying information. INFORMATION YOU PROVIDE TO US We collect a variety of information that you provide directly to us. For example, we may collect information about you when you: Sign up for an account on our Platform. Provide information about your child for diagnosis, assessment, or rehabilitation purposes. Upload medical records, assessments, videos, or other content related to your child’s therapy. Interact with medical practitioners, therapists, and experts through our Platform. Make a request or submit a question to us via online forms, email, or otherwise. Participate in surveys or feedback sessions. Provide reviews or testimonials about our Services. Request customer support or technical assistance. Provide any other information to us. This information may include: Your Personal Data (Parent/Guardian): Your name, email address, phone number, postal address, and other contact details. Child’s Sensitive Personal Data (SPDI): Name, age, gender, medical history, diagnosis, treatment plans, assessments, therapy notes, videos, and other health-related information. This data is collected solely for the purpose of enabling personalized therapy, progress tracking, and secure communication with Therapists via the App. User Content: Any content you upload or post to our Platform, including messages, files, and other materials related to your child’s therapy. The information you provide to us will be used to: Set up and manage your account. Facilitate the provision of Services, including connecting you with independent medical practitioners and experts. Securely store and manage your child’s medical records and related content within the Platform. Improve the Platform and our Services. Respond to your inquiries and requests. Send you communications related to your account and our Services. Fulfill any other purpose for which you provided the information, with your explicit consent. We will not use the information you provide for any purposes other than as described in this Policy or as explained to you at the point where the information was collected. INFORMATION COLLECTED THROUGH AUTOMATED MEANS We may also automatically collect certain technical information about your visit to our Platform, including pages you visit, your general geographic location based solely on your Internet Protocol (“IP”) address, and how you interact with the Platform’s features. This information is collected for the purpose of improving the Platform’s functionality, performance, and user experience, as well as for internal analytics and security. We, or our partners, may also gather certain information automatically, including but not limited to: IP addresses Browser type Internet Service Provider (ISP) Operating system Date/time stamp Mobile device type Limited, aggregated usage data (e.g., features used, session duration) This information may be collected via cookies, web beacons, and/or similar technologies that help us serve you better, for example, by making your interactions with our Platform faster or more personalised. The information we collect automatically through these technologies may be linked to and/or combined with other information we collect about you. CRITICAL NOTE ON CHILDREN’S DATA & AUTOMATED COLLECTION: In compliance with the Digital Personal Data Protection Act, 2023 (DPDP Act) and Google Play Store policies, Ability Advocacy strictly prohibits and does not engage in any tracking, behavioural monitoring, or targeted advertising directed at children. Any automated data collection related to a child’s profile is solely for the purpose of providing and improving the core functionality of the therapy services facilitated by the App, and is not used for individual profiling or advertising. When interacting with Ability Advocacy via social media platforms (if applicable), we may obtain information stored within social media or authorised by you to be collected by us within such social media. This information may include your contact information, email address, friend information, and other information stored within social media. COOKIES & INFORMATION COLLECTED BY THIRD-PARTY TOOLS To collect the information in the “Information Collected Through Automated Means” section above, we and our third-party service providers may use Internet server logs, cookies, tracking pixels, and other similar tracking technologies. Cookies are small text files that do not damage a visitor’s system or files. We may use cookies to: Store visitors’ preferences and recognize visitors’ devices. Customise Platform content based on user preferences. Record past activity in order to provide better Services. Assist with security and administrative functions. Most Internet browsers and mobile devices allow users to accept or deny cookies. Please note that you can change your settings to notify you when a cookie is being set or updated, or to block cookies altogether. Please consult the “Help” or “Settings” section of your browser or device for more information. If you reject our cookies, you may still use our Platform, but some features or offerings may not function properly. We may also use certain third-party products or services (“Third-Party Tools”), such as Google Analytics, to better understand the use of our Platform. These Third-Party Tools may collect information such as how often users visit our Platform, what pages they visit, and the websites which referred you to our Platform. These tools are used for aggregated, de-identified internal product improvement and analytics only, and are not used for individual profiling or targeted advertising, especially concerning children’s profiles. The Third-Party Tools’ ability to use and share information they collect about your visits to the Platform is governed by their own privacy policies and terms of use, which Ability Advocacy is not responsible for. Additional information about the Third-Party Tools we use can be provided by contacting us, as explained further below. DO NOT TRACK DISCLOSURES Our Platform does not respond to “Do Not Track” signals. Currently, there is no universally accepted standard for how to interpret such signals, and we do not alter our data collection and usage practices when we detect such signals from your browser. LEGAL BASIS FOR USE OF YOUR INFORMATION We process your Personal Data and SPDI in accordance with applicable laws and rely on the following legal bases under Indian data protection regulations, including the Digital Personal Data Protection Act, 2023 (DPDP Act), and other applicable global data protection regulations: Consent: By using our Services and providing your information, particularly your Client’s Sensitive Personal Data, you provide your free, specific, informed, unconditional, and unambiguous verifiable consent for the collection, use, storage, and disclosure of your information as described in this Policy. You may withdraw your consent at any time by contacting us; however, such withdrawal may affect your ability to use the Services. Performance of a Contract: Processing is necessary for the performance of a contract with you or to take steps to enter into a contract, such as providing our Services to you (e.g., account management, facilitating Therapist connections). Compliance with Legal Obligations: We may process your information where it is necessary to comply with a legal obligation under applicable laws (e.g., maintaining medical records as required by law). Legitimate Interests: We may process certain information where it is necessary for our legitimate interests or those of a third party (e.g., for internal product improvement, security, fraud prevention), provided that such processing does not override your rights and freedoms, and specifically does not involve tracking, behavioral monitoring, or targeted advertising of children. SHARING OF INFORMATION We may share the information described above as set forth in this Policy or as otherwise described at the time such information is collected from you. We will not sell, rent, or swap this information, nor will we authorize any of our service providers or business partners to use this information for their own commercial purposes without your explicit permission. INFORMATION SHARED BY US With Service Providers: We may share your information with third-party service providers that perform services on our behalf, such as hosting, data storage, analytics, payment processing, and customer support. These service providers are contractually required to maintain the confidentiality and security of your information and are restricted from using your information for any purpose other than as instructed by us. With Independent Medical Practitioners and Experts: We may share your information, including your child’s SPDI, with independent medical practitioners, therapists, and experts who are engaged in providing services to you through our Platform. These professionals (and their associated Therapy Service Centres, where applicable) are also contractually bound by strict confidentiality and data protection obligations with Ability Advocacy, ensuring the security and privacy of your child’s SPDI. Legal Compliance and Protection: We may disclose your information if required to do so by law or in the good faith belief that such action is necessary to: Comply with a legal obligation or government request. Protect and defend our rights or property. Prevent or investigate possible wrongdoing in connection with the Services. Protect the personal safety of users of the Services or the public. Protect against legal liability. Business Transfers: In the event of a merger, acquisition, restructuring, or sale of assets, your information may be transferred to the acquiring entity. We will provide notice before your Personal Data is transferred and becomes subject to a different privacy policy. Aggregated and De-identified Data: We may maintain and use aggregate or de-identified data (data that does not identify a specific individual) for analytics, research, or other business purposes. This data does not identify any individual child or parent and is used for research, service improvement, and reporting without re-identification. We may disclose such aggregated or de-identified data to third parties without restriction. With Your Consent: We may share your information with third parties when we have your explicit consent to do so. SECURITY The security of your information is important to us. We implement reasonable security practices and procedures, as required under applicable data protection laws (including the DPDP Act), to protect your information from unauthorized access, use, alteration, and disclosure. These measures include administrative, technical, and physical safeguards. However, please keep in mind that no method of transmission over the Internet or method of electronic storage is 100% secure. We cannot guarantee absolute security. You are responsible for keeping your account credentials secure and not sharing them with others. If you believe your account has been compromised, please contact us immediately. INTERNATIONAL DATA TRANSFERS Your information may be transferred to and processed in countries other than the country in which you are resident. These countries may have data protection laws that are different from the laws of your country. By using our Services, you consent to the transfer of your information to countries outside of your country of residence, including India, where our primary servers are located. When we transfer Personal Data internationally, we will ensure that appropriate safeguards are in place to protect your Personal Data, and such transfers will only occur to such countries or territories as may be notified by the Central Government of India under the Digital Personal Data Protection Act, 2023, or with other prescribed safeguards. RETENTION OF YOUR INFORMATION We will retain your Personal Data and SPDI for as long as necessary to fulfill the purposes for which it was collected, to comply with our legal obligations (e.g., record-keeping for medical data), for legitimate business purposes (e.g., resolving disputes, enforcing agreements, audit purposes), or as otherwise required or permitted under applicable laws. YOUR RIGHTS (DATA PRINCIPAL RIGHTS UNDER DPDP ACT) Depending on your jurisdiction, you may have certain rights regarding your Personal Data and your Client’s Sensitive Personal Data under applicable data protection laws, including the Digital Personal Data Protection Act, 2023 (DPDP Act): Right to Access: You have the right to request access to the Personal Data we hold about you and your Client, including a summary of the Personal Data being processed, processing activities, and identities of all other Data Fiduciaries and Data Processors with whom Personal Data has been shared. Right to Rectification: You have the right to request that we correct any inaccuracies in your or your Client’s Personal Data. Right to Erasure: You have the right to request the deletion of your or your Client’s Personal Data under certain circumstances. Right to Restrict Processing: You have the right to request that we restrict the processing of your or your Client’s Personal Data under certain conditions. Right to Data Portability: You have the right to receive your Personal Data in a structured, commonly used, and machine-readable format, and to have it transmitted to another controller. Right to Object: You have the right to object to the processing of your or your Client’s Personal Data under certain circumstances, including for direct marketing purposes (though we do not engage in targeted marketing for children). Right to Withdraw Consent: If we are processing your Personal Data based on your consent, you have the right to withdraw your consent at any time. Such withdrawal may affect your ability to use the Services. Right of Grievance Redressal: You have the right to register a grievance with Ability Advocacy regarding our processing of your or your Client’s Personal Data. Right to Nominate: You have the right to nominate another individual to exercise your rights under the DPDP Act in the event of your death or incapacity. To exercise your rights, please contact our Grievance Officer using the contact information provided below. We will respond to your request in accordance with applicable laws. CHILDREN’S PRIVACY The KRIVI.AI App and our Services are intended for use by parents or legal guardians (who must be 18 years or older) of children with autism spectrum disorder and related conditions. Ability Advocacy does not knowingly collect Personal Data directly from children. All Personal Data and Sensitive Personal Data related to a child (an individual under 18 years of age, as per the Digital Personal Data Protection Act, 2023) is collected from their parent or legal guardian based on their verifiable consent. In strict compliance with the DPDP Act, Ability Advocacy does not engage in any tracking, behavioral monitoring, or targeted advertising directed at children. Furthermore, we do not process children’s data in any manner likely to cause detrimental effect to their well-being. If you are a parent or guardian and become aware that your child has provided us with Personal Data without your verifiable consent, please contact us immediately. If we become aware that we have collected Personal Data from a child under the age of 18 without verifiable parental consent, we will take steps to remove that information from our servers promptly. THIRD-PARTY LINKS Our Platform may contain links to other websites or services that are owned or operated by third parties. We are not responsible for the privacy and security practices of sites not owned by Ability Advocacy. We encourage our users to be aware when they leave our Platform and to read the privacy policies of any site that collects personally identifiable information. CHANGES TO THIS POLICY We reserve the right to modify this Policy at any time. Any changes to this Policy will be posted on this page within the App or on our website with an updated “Last Updated” date. Any changes will become effective when posted unless indicated otherwise. Your continued use of our Services subsequent to changes in this Policy will signify your acceptance of the changes. We encourage you to review this Policy periodically for any updates. ACCEPTANCE OF THESE TERMS This Policy is incorporated into and subject to the KRIVI.AI App User Agreement, which can be accessed within the App. Each time that you view and/or interact with our Platform, you signify that you have read, understood, and agree to be bound by the App User Agreement, which incorporates this Policy. If you do not agree to the terms of this Policy or to the use of your information as set forth in this Policy, please do not use our Services. GRIEVANCE REDRESSAL & CONTACT US If you have any questions or concerns about this Policy, your data, our privacy practices, or wish to exercise your rights, please contact our designated Grievance Officer: Grievance Officer: Shivendra Upadhyay, CEO & Co-Founder Email: [email protected] Phone: 8970001204 General Contact: Email: [email protected] Address: FLAT A-012, GROUND FLOOR, VP Apartment, SY No. 94/1A, Carmelram, Bangalore South, Karnataka, India, 560035 Ability Advocacy is dedicated to assisting parents of children with autism in managing their learning, diagnosis, and rehabilitation. We are committed to protecting your privacy and ensuring that your personal information is handled responsibly.
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