We collect personal information from you in order to provide the Services, including to match you with the right Consultants. “Consultants” means anyone who provides, seeks to provide, or has provided Holistic Advice through a registered a Consultant Account. “Users” means anyone who visits the website or who otherwise accesses or uses the Services seeking Holistic Advice, including those that have registered a User Account.

Information you provide us

We collect personal information you provide to us. This includes:

• Information you provide when you contact us;

• The information required to create an account, such as your username, email, gender and location;

• Your preferences and selected Consultants;

• How long your chats with Consultants last, to inform your payment obligations; and

• Your feedback on the quality of the Services and your discussions with Consultants.

Recordings

We record video, audio and chat discussions you have with Consultants. We will use this information to assess or respond to a complaint or dispute, or for audit purposes to ensure compliance with our User Terms of Service, our Consultant Terms of Service and this Policy. Information from recordings may be also used for data analysis to improve and develop our Services. Recordings are stored for 120 days. During this period, you can download your recordings. After 120 days, all recordings are de-identified (this means we modify the video to remove associated personal information) and will no longer be downloadable.

Location

We use your IP address to identify your rough or approximate location (e.g. your municipality). We use this information try to match you with a more local Consultant who may be better placed to provide more valuable Holistic Advice to you.

Demographic and usage information

We may collect certain demographic and usage information though Google Analytics and Facebook Pixel (described in more detail below). This information may include the previous website you were on and your “likes” and biographical information on Facebook.

Device data

We collect information about the device you use to access the Services, such as the model and whether it is a mobile device. We use this information to optimize the matching and chat functions on the Services, as well to understand more about our Users.

Payment

Stripe is our payment processing partner. For information on how Stripe uses your information to process payments, please review Stripe’s privacy policy.

We may collect personal information when you contact us, when you use our website or when you engage with us over social media. We collect and use this information so that we can:

• Communicate with you and keep you updated on Asaino;
• To identify and authenticate you;
• To provide you with information that you request from us, and to receive feedback from you;
• Enable you to participate in promotions and surveys;
• To understand how you use our products, content and services, for data analytics, statistical analysis, internal business purposes, and product development purposes;
• To manage our business and day-to-day business and operational needs; and
• Comply with any legal requirements or defend our legal rights.

Job applications

If you submit a job application to us, we will use the information relating to that application (such as your employment history) to assess your suitability to any of our job postings. We may also collect information from third parties about you, such as references you list, for the same purpose.

Under privacy laws, Consultants are solely accountable and liable for any collection, use, or disclosure of your personal information that they engage in. That said, we still require all Consultants to meet certain minimum privacy standards, which include the following:

• Consultants are only allowed to use your personal information to provide the Holistic Advice you request.
• While Consultants are permitted to request more information to understand your situation, they are not allowed to request anything that is not required to provide Holistic Advice.
• Consultants are prohibited from contacting you outside of Asaino’s website. If a Consultant contacts you outside of Asaino’s website, contact us immediately.
• Consultants are required to keep your personal information strictly confidential. They can only disclose your information when required to by law.
• Consultants are prohibited from recording or copying discussions with you (including screen-shotting). However, we do not prohibit other forms of collecting your personal information, such as note-taking.
• Consultants must be able to explain their privacy and data protection policies and practices to you in a transparent and timely fashion upon your request.

It’s important to protect your privacy when communicating with a Consultant. Remember:

• When you select a new Consultant using our Services, we will only share your username and your selected Holistic Advice topic with them.
• While we try to match you with a local Consultant, sometimes the Consultant will be located in a different jurisdiction. This means that different laws may apply to them, including when authorities can lawfully access your information.
• Never give your personal information to Consultants unless absolutely necessary to receive the Holistic Advice.
• Never share your password or payment information with anyone.
• Never share information about you that you do not feel comfortable providing. This includes the format of your discussion with the Consultant. While video chat is the default, you are always free to switch to audio-only or our chat function.

Cookies

We use cookies on this website. Cookies are essentially small packages of data stored on your internet browser that tell us about your browsing behaviour. We use that information to monitor usage of our website and improve it. We may also use this information to improve our marketing.

For more information on cookies and how to manage them, check the support pages for your browser, such as Firefox, Safari, Chromeor Internet Explorer.

Google Analytics

We use Google Analytics (including Google Analytics for Firebase) to better understand your use of our website. Google Analytics collects information on user behaviour on our website, which includes how many times a user visits our website, what pages they visit, and where they were referred from. Google uses the data collected through cookies to track and examine the use of the website, to prepare reports on its activities, and share them with other Google services. Advertising identifiers for mobile devices (such as Android and iOS Advertising Identifiers) are also collected. Google may use the data collected on the websites to contextualize and personalize the ads of its own advertising network.

Google will not associate your IP address with any other data held by Google. To learn more about Google Analytics, click here. You can deactivate the Google Analytics function with a browser add-on, which you can download here. To do this you must install that browser add-on. This will prevent the analysis information from being sent to Google.

Facebook Pixel

We use Facebook Pixel cookies to better understand your use of our website. Facebook Pixel collects information on user behaviour on our website, which includes how many times a user visits our website, what pages they visit, and where they were referred from. Facebook uses the data collected through cookies to track and examine the use of the website, to prepare reports on its activities, and share them with other Facebook services. Advertising identifiers for mobile devices (such as Android and iOS Advertising Identifiers) are also collected. Facebook may provide us with information associated with your Facebook account, such as your likes, location and age (Facebook may provide us with additional information if you use Facebook to create an account with us). Facebook may use the data collected on the websites to contextualize and personalize the ads of its own advertising network. For more information on how to limit the data Facebook Pixel shares and uses about you, click here. You can read more about how Facebook Pixel works from Facebook’s Data Policy (see “Information from partners”).

We may also de-identify, aggregate or anonymize information to identify trends, manage our business, develop statistical information, understand how we are performing, or develop relevant products, services or offers. Such information may also be shared with: (a) our affiliates and business partners to understand and improve our Services’ performance and to develop better apps in the future; and (b) third parties for other analytical purposes. At no time will such information personally identify, or be used to identify, any individual.

We do not sell or lease your personal information to third parties.

We may share your information for three main reasons: (a) with our affiliates and service consultants; (b) for legal reasons; and (c) for business reasons.

(a) Affiliates and service consultants

We may also share your information with other organizations (such as service consultants) that assist us in providing the Services or other services. For example, we store our information on servers provided to us by Amazon Web Services and Google Firebase. When we share information with service consultants, we require them to commit to protecting your personal information in line Asaino standards, and limit use and disclosure of the information for the specific purposes for which we supplied it.

We may share your personal information with an affiliate who has referred you to us through an affiliate or promotional link in order to confirm the success of their referral.

(b) Legal reasons

In rare circumstances, we may share your information about you if we reasonably believe that it is needed to:

• Comply with any valid legal process, governmental request, or applicable law, rule, or regulation;

• Investigate, remedy, or enforce potential User Terms of Service or Consultant Terms of Service violations;

• Protect the rights, property, and safety of us, our Users, Consultants, or others; or

• Detect and resolve any fraud or security concerns.

(c) Business reasons

We may share personal information with business partners where it is relevant to a business transaction, such as the sale of Asaino to another company, as part of a corporate re-organization or to pursue a partnership or investment opportunity.

We only collect information by lawful means. As part of using our Services or interacting with us, we may collect and process some details about you. When we do so, we will collect, use or share your personal information with your consent for the purposes identified or as otherwise permitted or required by law. In compliance with our privacy obligations, we may obtain your permission based on implied consent (including through this privacy policy) or through other means (such as express consent). However, in some situations, the law allows us to collect, use or disclose personal information without your consent.

You can withdraw your consent to the collection, use or disclosure of your information at any time. However, in some cases withdrawing consent will mean that we can no longer provide you with certain services or perform certain tasks where the information is required to do so.

You may withdraw your consent to the collection, use or disclosure of your personal information at any time by contacting the Privacy Officer (see ‘Contact information’ below) and, subject to any legal constraints, we will comply with your request.

Some of our service consultants and business partners may be based in different countries. This means your information may be accessible to law enforcement authorities outside of your jurisdiction, in accordance with the laws of that jurisdiction.

We protect your information by limiting access to it on a strict “need-to-know” basis, and we implement reasonable physical, organizational and technological safeguards as appropriate.

We only keep your information as long as it is operationally or legally necessary. After that, we will either destroy or de-identify the information.

When requested in writing, we will inform you of the existence, use, and disclosure of your personal information that we maintain.

To access your personal information, submit a written a request that identifies yourself, the information you want to review and how we can contact you (see ‘Contact information’ below for how to contact us). We may not be able to provide you with all the information you request, depending on the circumstances, and there may be a charge for copies of your personal information.

You can also access previous recordings of your discussions with Consultants directly through your account.

We will make reasonable efforts to keep your information accurate and up-to-date. If a change or correction is required, let us know right away. We’ll make any appropriate updates needed. You can review your personal information by reviewing your account information and preferences, reviewing the correspondence we send to you, or by requesting access to your personal information, as described above.

Because of the rapidly changing state of technology, we cannot make any guarantees that our systems will be able to honour Do-Not-Track requests sent by your browser.

If you are a California resident, you can make certain requests regarding your personal information. We will fulfill each of these requests to the extent required by law.

• You can ask us what personal information we have about you, including a list of categories of your personal information that we have sold and a list of categories of your personal information that we have shared with another company for a business purpose.

• You can ask us to delete your personal information.

• You can ask that we stop selling your personal information.

In order to exercise these rights, contact our Privacy Officer using the contact information outlined below.

If you have any questions or concerns about this privacy policy or about Asaino’s handling of your personal information, please contact the Asaino Privacy Officer in writing at

Mailing address: 405, Town Square, New Airport Road, Viman Nagar Pune, India

Email: services@asaino.com

Please note that we may need to confirm your identity or request additional details in order to process your request.

We may modify this notice from time to time and will post the most current version online.

Last updated: June 4, 2021