Privacy Policy

Introduction

Last updated: April 2025

Thank you for choosing to be part of our community at Virtus Growth Labs Pvt. Ltd., operating through our health and wellness website www.thepivothealth.com ("Virtus", "Pivot", "Pivot Health", "we", "us", or "our"). We are committed to protecting your personal information and your right to privacy.

This privacy policy applies to all information collected through our website (www.thepivothealth.com), mobile application, chat applications (e.g., WhatsApp), social media accounts, email survey forms, email, and/or any related services, sales, marketing, or events, website of the parent Virtus called www.velocityx.in and/or buying our Program(s) and/or plans, and using our products (we refer to them collectively in this Privacy Policy as the "Services").

This document is an electronic record in terms of the Digital Personal Data Protection Act, 2023 and rules made there under as applicable. No physical or digital signatures are required, being an electronic record.

By using our Services, you trust us with your personal information and agree to all the terms of this Privacy Policy. We take your privacy very seriously. We hope you take some time to read through this document carefully, as it is important. If you do not agree with the terms under this Privacy Policy, please discontinue use of our website(s) and/or our Services.

1. What Information Do We Collect?

• Personal identification data (e.g., name, email address, phone number, birth date, gender, picture, photographs, mailing address)
• Health-related data (e.g., blood reports data, weight, height, food preferences, nutrition data, workouts, steps, sleep data, SPO2, HRV, body temperature, medical conditions, health goals)
• Payment information (only name and billing address, not card details)
• Automatically collected data (e.g., IP address, device and browser information, usage patterns, location, metadata)
• Data from third party devices, mobile and messaging apps (e.g., geo-location, device access, push notifications)
• Usage data (e.g., cookies, pixel tags, analytics tools, mobile and web logs, timestamps, interaction data)
• Information from third-party integrations (e.g., HealthKit, Google Fit, Apple Health, email, social media login data)
• Data from Integrated Health Apps and devices: If you connect your Apple Watch or Apple Health, Morpheus Training, or similar applications with our Services, we may access certain health metrics (e.g., heart rate, HRV, step count, activity data, sleep). This data is only accessed with your explicit consent and is used solely to enhance our wellness recommendations and progress tracking.
• Your Contributions: Information and content you provide, including content, communications and other information you provide when you use our Products and Services, including when you sign up for an account, create or share content, and message or communicate with others.

Some information – such as IP address and/or browser and device characteristics – is collected automatically when you visit our Website or access our Services or Apps.

2. How Do We Use Your Information?

• To create and manage user accounts
• To deliver and personalize our Services
• For marketing and promotional communication as well as Testimonials on our website(s) and other social media channels (with consent)
• To fulfill and manage orders (including third-party delivery)
• For analytics, improvement, and development of Services
• To track progress and personalize health reports
• For compliance with legal requirements
• For risk monitoring, fraud detection, and platform optimization

3. Legal Basis for Processing

• Consent
• Legitimate interest
• Contractual necessity
• Legal obligations

4. Consent and Withdrawal

By using our Services, you provide explicit consent for the collection, use, and processing of your personal and health-related data. You may withdraw consent at any time by emailing us at ankur@thepivothealth.com. Upon withdrawal, we may no longer be able to offer our Services to you. We will retain necessary data for up to 180 days after withdrawal for legal or transactional requirements.

5. Sharing of Information

We may share your data with:

• Third-party vendors and service providers (e.g., payment processors, delivery partners, analytics tools, marketing platforms, healthcare apps and devices)
• Cloud storage providers such as Amazon Web Services (AWS) and Google Workspace
• Legal authorities, if required by law or regulation
• In case of mergers or acquisitions, with the acquiring entity (with continued privacy safeguards)

We do not sell or rent your data to third parties for marketing purposes without consent.

6. International Data Transfers

Your data may be transferred to and processed in countries outside your own, including India, the EU, and others via third-party tools. We take appropriate safeguards to ensure data protection.

7. Data Storage and Security

Your data is stored on Amazon Web Services (AWS) and Google Workspace. To protect your personal information, we take reasonable precautions and follow practices to make sure it is not inappropriately lost, misused, accessed, disclosed, altered or destroyed.

However, no method of transmission or storage is 100% secure. Users are encouraged to safeguard passwords and log out after use.

8. User Rights

Users have the right to:

• Access, rectify, or delete their data
• Withdraw consent at any time
• Object to processing
• Request data portability
• Lodge a complaint with data protection authorities

To exercise these rights, contact us at ankur@thepivothealth.com. Correction of personal information or retrieval of access credentials can also be requested via this email.

9. Minors' Data

Our Services are intended for individuals aged 18 or older. If we become aware of any data collected from minors without guardian consent, we will promptly delete it. Guardians may contact the Grievance Officer to request deletion.

10. Cookies and Tracking Technologies

We use cookies, pixels, and analytics tools (e.g., Google Analytics, Facebook Pixel) to personalize experiences and analyze usage. You may manage cookie settings in your browser. Some services may be impacted if cookies are disabled.

11. Device and Metadata Usage

We collect metadata such as device ID, browser version, app activity, and feature usage. This data is used for analytics, fraud detection, and service optimization.

12. Advertising and Remarketing

We may use third-party platforms to deliver targeted advertisements based on your interaction with our Services. These may include pixels or tracking technologies. Users can opt out via industry-standard opt-out tools.

13. Aggregated and Anonymized Data

We may use anonymized and aggregated data for research, analytics, or product development purposes. This data cannot identify any individual user.

14. Notifications and Compliance

We may send periodic notifications about updates to this policy or important service information. Users will be informed annually of their rights and our right to suspend access for non-compliance with this policy or Terms of Use.

15. Updates to this Policy

We may update this privacy policy periodically. The updated version will carry a revision date. If material changes are made, users will be notified via email or a website notice.

16. Governing Law and Jurisdiction

This policy is governed by the laws of India. Any disputes shall be subject to the exclusive jurisdiction of the courts in Delhi.

17. Contact Information

If you would like to: access, correct, amend or delete any personal information we have about you, register a complaint, or simply want more information contact our Grievance Officer at ankur@thepivothealth.com.