This document is an electronic record in terms of Information Technology Act, 2000 and rules there under as applicable and the amended provisions pertaining to electronic records in various statutes as amended by the Information Technology Act, 2000. This electronic record is generated by a computer system and does not require any physical or digital signatures.

This document is published in accordance with the provisions of Rule 3(1) of the Information Technology (Intermediaries guidelines) Rules, 2011 that require publishing the rules and regulations, privacy policy and Terms & Conditions for access or usage of GRAYCELLSMATTER.COM website and other associated websites or web pages operated by the firm GRAYCELLSMATTER (“the Company”, “the firm”,“we”, “us”, or “our”) operates the website located at GRAYCELLSMATTER.COM and other related websites and mobile applications with links to these Terms & Conditions (collectively, the “Site”). We facilitate mental wellness services to our users though our website using our employee counsellors/therapists and freelance counsellors engaged by the firm.

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 & Conditions, which may be accessed on the website, the End-Users (as defined in the Terms & Conditions), 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 and our Terms & Conditions. 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.

1.0  NEED FOR THIS PRIVACY POLICY

This Privacy Policy is published in compliance with, inter alia:
Section 43A of the Information Technology Act, 2000;
Regulation 4 of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011 (the “SPI Rules”);
Regulation 3(1) of the Information Technology (Intermediaries Guidelines) Rules, 2011.
This Privacy Policy states the following:
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;
The purpose, means and modes of collection, usage, processing, retention and destruction of such information and how and to whom GRAYCELLSMATTER.COM will disclose such information.

• PRIVACY STATEMENTS

2.1 GRAYCELLSMATTER.COM does not control or endorse the content, messages or information found in any Services and, therefore, we specifically disclaim 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 GRAYCELLSMATTER.COM relating to same, and to the extent such waiver may be ineffective, you agree to release any claims against GRAYCELLSMATTER.COM relating to the same.
2.2 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 support@GRAYCELLSMATTER.COM. We will make good faith efforts to make requested changes in our 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 GRAYCELLSMATTER.COM has reasonable grounds to suspect that the information provided by you is untrue, inaccurate, out of date or incomplete, GRAYCELLSMATTER.COM may, at its sole discretion, discontinue the provision of the Services to you. GRAYCELLSMATTER.COM will not be responsible for any consequences and will not be held liable under the law in case of any assessment or treatment given by the psychologist on the basis of wrong/incorrect information provided by the patient knowingly or unknowingly. There may be circumstances where GRAYCELLSMATTER.COM 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.
2.3 If you wish to cancel your account or request that we no longer use your information to provide you Services, contact us through support@GRAYCELLSMATTER.COM . We will retain your information for as long as your account with the Services is active and as needed to provide you 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 GRAYCELLSMATTER.COM being unable to provide you with its Services or to terminate any existing relationship we may have with you.
2.4  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@GRAYCELLSMATTER.COM
2.5  We may require the User to pay with a credit card, wire transfer, debit card or UPI (Unified Payment Interface) for Services for which subscription amount(s) is/are payable. GRAYCELLSMATTER.COM 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.
2.6   Due to the communications standards on the Internet, when a User or the End-User or anyone who visits the Website, GRAYCELLSMATTER.COM automatically receives the URL of the site from which anyone visits. GRAYCELLSMATTER.COM 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 us improve our Services. 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, GRAYCELLSMATTER.COM 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.
2.7   The Website uses temporary cookies to store certain (that is not sensitive personal data or information) that is used by GRAYCELLSMATTER.COM 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, GRAYCELLSMATTER.COM 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.

• Information Collection, Use, and Disclosure

To let us operate the Platform effectively and to let you use the Platform, including the Counselor Services, we may have to collect your personally identifiable information (such as, but not limited to, your name, phone number and email address.), information related to the Counselor Services or your need for Counselor Services, and any information which is exchanged between you and your Counselor (collectively the “Information”). In some cases, some of the Information that you give to us is considered health related data. You may decide which Information, if any, you would like to share with us, but some functions of the Platform may not be available to you without providing us the necessary Information. By deciding to provide the Information you agree to our methods of collections and use, as well to other terms and provisions of this Privacy Policy.

Protecting this Information is a top priority for us. We will never sell or rent any Information you shared in the Platform. Other than in the limited ways detailed in this Privacy Policy, we will never use or disclose any Information unless you specifically and explicitly requested or approved us to do so.

The Information may be used for the following purposes:

• To contact you or provide you with information, alerts and suggestions that are related to the service.
• Billing-related purposes.
• To reach out to you, either ourselves or using the appropriate authorities, if either we or a Counselor have a good reason to believe that you or any other person may be in danger or may be either the cause or the victim of a criminal act.
• To match you with a Counselor.
• To enable and facilitate the Counselor Services.
• To supervise, administer and monitor the service.
• To measure and improve the quality, the effectiveness and the delivery of our services.
• Cookies

Like many websites, we use “cookies” to collect information. A “cookie” is a small data file that is transferred to your computer’s hard disk for record-keeping purposes. You can change your browser’s settings so it will stop accepting cookies or to prompt you before accepting a cookie. However, if you do not accept cookies you may not be able to use the Platform.

• Phishing

Online identity theft and account hacking, including the practice currently known as “phishing”, are of great concern. You should always be diligent when you are being asked for your account information and you must always make sure you do that in our secure system. We will never request your login information or your credit card information in any non-secure or unsolicited communication (email, phone or otherwise).

• Links

The Platform may contain links to other websites, services or offers which are owned, operated or maintained by third parties. If you click on a third-party link, you will be directed to that third website or service. The fact that we link to a website or service is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not have control over third party websites and services and we do not have control over their privacy policies and Terms & Conditions.

• Security

While using any Internet-based service carries inherent security risks that cannot be 100% prevented, our systems, infrastructure, encryption technology, operation and processes are all designed, built and maintained with your security and privacy in mind. We apply industry standards and best practices to prevent any unauthorized access, use, and disclosure. We comply with or exceed all applicable federal laws, state laws, and regulations regarding data privacy.

• Service Providers

We may employ third party companies and individuals to facilitate our Platform, to perform certain tasks which are related to the Platform, or to provide audit, legal, operational or other services for us. These tasks include, but not limited to, customer service, technical maintenance, monitoring, email management and communication, database management, billing and payment processing, reporting and analytics. We will share with them only the minimum necessary information to perform their task for us and only after entering into appropriate confidentiality agreements.

• International Transfer

Your information may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction. Regardless of where your data is stored, it will be maintained securely as outlined in this policy. Your consent to our Terms and Conditions followed by your submission of such information represents your agreement to such transfers.

• Compliance with Laws and Law Enforcement

We cooperate with government and law enforcement officials to enforce and comply with the law. We may disclose information necessary or appropriate to protect the safety of the public or any person, to respond to claims and legal process (including but not limited to subpoenas), and to prevent or stop activity that may be illegal or dangerous. You should also be aware that Counselors may be obliged to disclose information to law enforcement or other authorities to conform to their professional and legal responsibilities. Specifically, and without limitation, you should be aware that the law requires mental health professionals to disclose information and/or take action in the following cases: (a) reported or suspected abuse of a child or vulnerable adult; (b) serious suicidal potential; (c) threatened harm to another person; (d) court-ordered presentation of treatment.

• General Data Protection Regulation (GDPR) Notice

This section provides additional information about our Privacy Policy relevant to users from the European Union. It is necessary for us to use your personal information:

• To perform our obligations in accordance with any contract that we may have with you.
• It is in our legitimate interest or a third party’s legitimate interest to use personal information in such a way to ensure that we provide the Services in the best way that we can.
• It is our legal obligation to use your personal information to comply with any legal obligations imposed upon us.

GRAYCELLSMATTER.COM is the Controller with respect to your Personal Data. You can contact our Data Protection Officer with questions, concerns or objections about this policy, or about your data by writing to:

Aparna Gupta

Data Protection Officer

info@graycellsmatter.com

• Changes to the Privacy Policy

We may update this privacy statement at our sole discretion. The date of the last revision of this policy appears at the end of this page. We encourage you to periodically review this page for the latest information on our Privacy Policy and practices. Regardless of changes to our Privacy Policy, we will never use the information you submit under our current privacy notice in a new way without first notifying you and giving you the option to opt out.