Privacy Policy

We at Sai Life Limited (“Sai”), are committed to protecting your privacy. We have prepared this Privacy Policy (“Policy”) to describe to you our practices regarding the personal data we collect from you.

This 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.

Please read our Privacy Policy carefully to get a clear understanding of how Sai collects, uses, protects or otherwise handles Personal Data. If you do not agree to any part of this Policy, then we cannot provide any Service to you.

By submitting or providing to us your personal information, you consent to the use of that information as set out in this Policy. We process personal data based on your consent, given no later than at the commencement of the processing. We process personal data only when there is a legal basis for doing so or you have granted us your consent in this regard.

You acknowledge, consent and agree that Sai may collect, process, and use the information that you provide to us and that such information shall only be used by us or third parties acting under our direction, pursuant to confidentiality agreements.

Although we may attempt to notify you when changes are made to this Policy, you are responsible for periodically reviewing any changes which may be made to the Policy. We may, in our sole discretion, modify or revise the Policy at any time, and you agree to be bound by such modifications or revisions.

1. Overview of the Policy:

The right to privacy is a fundamental right and is necessary to protect personal data as an essential facet of informational privacy. Our aim is to ensure that the right data is used by a person in the right role and only in the right context, so that internal and external customers and other stakeholders can trust us for their business. This Policy is a legal document that we use to disclose the way we gather, use and manage the personal information of our customers and clients.

 

2. Definitions:

• Act: means the Information Technology Act, 2000 (21 of 2000).
• Personal Data: means data which relate to a living individual who can be identified – (a) from those data, or (b) from those data and other information which is in the possession of, or is likely to come into the possession of, the data controller, and includes any expression of opinion about the individual and any indication of the intentions of the data controller or any other person in respect of the individual.
• Processing of Personal Data: means any operation or series of operations carried out on Personal Data or sets of Personal Data, whether automated or not. These operations include collection, recording, organization, structuring, storage, adaptation, alteration, retrieval, consultation, use, and disclosure by transmission, dissemination, or any other means of making the data available, alignment or combination of data, restriction, erasure, or destruction.
• Sensitive personal data or information: means such personal information which consists of information relating to:

1. 1. password;
   2. financial information such as Bank account or credit card or debit card or other payment instrument details;
   3. physical, physiological and mental health condition;
   4. sexual orientation;
   5. medical records and history;
   6. Biometric information;
   7. any detail relating to the above clauses as provided to Sai for providing service; and
   8. 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 these rules.

• Website: shall mean our Website https://sailife.com/ and the features and functionality thereof (“Services”).

3. Scope of the Policy: The Privacy Policy applies to all geographies where we operate. This policy applies to the Processing of Personal Data collected by Sai, directly or indirectly, from all individuals including, but not limited to Sai’s Website, Sai’s current, past or prospective job applicants, employees, clients, consumers, suppliers or vendors, contractors or subcontractors, shareholders or any third parties. In this Policy, “you” and “your” means any covered individual. “We”, “us”, “our” and “Sai” means Sai Life Sciences Limited.

4. Our Assurance: Sai is committed to safeguarding Personal Data by respecting individual autonomy, clearly defining the appropriate use and flow of such data, and fostering trust between individuals and data processors. Sai ensures that individuals’ rights are protected, appropriate organizational and technical measures are implemented, and clear standards are followed for data sharing. Sai maintains accountability for all processing activities, provides remedies for unauthorized or harmful processing, protects Personal Data throughout its lifecycle, and ensures that all processing is carried out in a transparent manner.

5. Personal Data Collection:

1. 1. During the course of our relationship, Sai may collect and process Personal Data, which may include basic identification and contact details (including email correspondence), and any other information as required for legitimate business or legal purposes.
   2. Sai shall not knowingly collect or process Personal Data of children below the age of 13 without obtaining verifiable parental consent. Sai shall not engage in tracking, behavioural monitoring, or targeted advertising directed at children.
   3. During your use of the Website, Sai may automatically collect certain information, including device details (such as device type, operating system, and unique identifiers), approximate location information (such as city, state, or country based on IP address), and data collected through cookies and similar tracking technologies. Sai may also use web beacons or similar tools to monitor usage and interactions with the Website. Additionally, Sai may collect and store information in log files, including IP address, browser type, internet service provider, referring and exit pages, operating system, date and time stamps, and usage patterns, and may link such information with Personal Data where necessary to enhance and improve its services.

6. Purposes for Data Collection:

1. • Accepted Purposes: Sai may use Personal Data to facilitate access to and use of its website(s), mobile application(s), and digital platforms; deliver information and services; handle queries, requests, orders, or applications; perform and manage contractual commitments; enhance and develop its offerings and user experience; communicate with users and obtain feedback; identify and resolve service or operational issues; comply with legal, regulatory, tax, pharmacovigilance, transparency, and disclosure requirements; address government or authority requests; handle medical, safety, and quality-related matters; detect and prevent fraud or unlawful activities; and respond to emergencies involving risk to life or health. Sai will limit the collection of Personal Data to what is necessary for these purposes.
   • At our sole discretion, for any reason or no reason at all, we reserve the right to remove any data/information or messages, if we believe that such action is necessary:

• • • • to conform to the law, comply with legal process served on us, or investigate, prevent, or take action regarding suspected or actual illegal activities;
      • to enforce this policy, to take precautions against liability, to investigate and defend ourselves against any third-party claims or allegations, to assist government enforcement agencies, or to protect the security or integrity of Sai; or
      • to exercise or protect the rights, property, or personal safety of Sai, or others entities associated with us.
  • Third Party Service Providers: We employ service providers to support the operation of the Sai. Information shared for this purpose may include device and online identifiers, ISP details, session ID or log data, internet, browser, and network activity, as well as location data. We authorize our service providers to handle your personal information only if we are confident they are implementing appropriate measures to safeguard it.

7. Data Processing by Sai: We are committed to complying with any applicable legislation relating to Personal Data and we shall ensure that Personal Data is collected and processed in accordance with applicable data protection law in India.

• • Lawfulness, fairness and transparency: Sai shall process Personal Data in a lawful, fair, and transparent manner in accordance with applicable data protection laws. Sai shall ensure that Personal Data is collected and used only where a valid legal basis exists, and that such processing does not result in unjustified, unexpected, or misleading impact on individuals. Sai shall be open, clear, and accurate about its data practices, and shall provide individuals with appropriate, accessible, and timely information regarding the collection, use, storage, and sharing of their Personal Data, including the purposes of processing and their rights in relation to such data.
  • Legitimate Purpose, Limitation and data minimization: We collect your Personal Data for specific, explicit, and legitimate purposes and do not further process it in a manner that is inconsistent with those purposes. We collect only the necessary amount of data required for a particular purpose.
  • Data accuracy and storage limitation: Sai ensures that the Personal Data processed is accurate and, when necessary, kept up to date. Additionally, we will retain Personal Data only for as long as required to fulfill the purposes for which it was collected. This includes meeting legal, accounting, or reporting obligations, as well as asserting or defending against legal claims until the relevant retention period ends or until the claims are resolved. Once the applicable retention period has expired, we will securely dispose of your personal data in accordance with relevant laws and regulations.
  • Confidentiality, Security and Availability: We maintain Confidentiality, Security and Availability of the data we collect or gather. We maintain Confidentiality of data by ensuring that data exchanged is not accessible to unauthorized users. We make sure the Integrity of the data by ensuring that a system and its data has not suffered unauthorized modification; And the Availability guarantees that data, systems and applications are available to users when they need them.
  • Limited Access to the Personal Data: Only individuals who have a legitimate need-to-know or require access for their specific job roles will be granted access to Personal Data. We will not share Personal Data with any external individuals or entities, except for the Accepted Purposes, or with the explicit consent person who’s Data is to be shared, or when there is a legitimate interest or legal requirement to do so, provided that it is allowed by applicable law. In such cases, the disclosure of Personal Data will be limited strictly to what is necessary and reasonable to fulfil the Accepted Purposes.
  • Protection of Your Personal Data: Sai implements appropriate administrative, physical, and technical safeguards to protect Personal Data from unauthorized access, use, or disclosure. While commercially reasonable measures are in place to secure information, no system can be guaranteed to be completely secure, and any transmission is at the user’s risk. Sai may notify individuals in the event of a data breach where required. Sai may also retain or disclose Personal Data where necessary to comply with applicable laws, respond to lawful requests, address security or fraud concerns, or protect its rights, property, or the safety of individuals, without limiting any legal rights or remedies available to users.
  • Deletion of Your Personal Data: You may request deletion of your personal data by us, and we will use commercially reasonable efforts to honor your request, but please note that we may be required to keep such information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). When we delete any information, it will be deleted from the active database, but may remain in our archives. We may also retain your information for fraud prevention or similar purposes.

8. Your Rights:

• • You have the right to request a copy of the Personal Data that we have about you. Additionally, if you find any inaccuracies in your Personal Data, you can request for it to be corrected, or if your data is incomplete, you can ask for it to be completed appropriately.
  • You have the right to be forgotten which grants you the authority to request the erasure of your Personal Data under various circumstances, including when the data is no longer necessary for its original purpose, when you withdraw your consent, when you object to the processing of your data, when your Personal Data has been unlawfully processed, when there is a legal obligation to erase your data, or when erasure is necessary to comply with applicable laws.
  • You also have a right to access information we hold about you. We are happy to provide you with details of your Personal Information that we hold or process. To protect your personal information, we follow set storage and disclosure procedures, which mean that we will require proof of identity from you prior to disclosing such information. You can exercise this right at any time by contacting us on the details mentioned in the Policy.

9. Breach of this Policy: Non-compliance with the Policy and relevant laws can have severe consequences and may subject both Sai and you to damages, criminal fines, and penalties. Sai considers any failure to adhere to this Policy as a grave matter and may result in the initiation of appropriate disciplinary and legal actions.

10. Data Protection Officer: If you have any questions, discrepancies, or grievances regarding the processing of your Personal Data, you can contact the Data Protection Officer (DPO) at contact@sailife.com. The DPO will promptly address your concerns within the period prescribed by law. If you have any queries about the content, interpretation, or implications of the Policy, you may also reach out to the DPO.

However, Sai retains the right to reject any request that might compromise the security and confidentiality of others’ Personal Data or those requests that are impractical or not made in good faith. This is in accordance with the circumstances outlined in the law, allowing Sai to refuse such requests.