Privacy Policy

PRIVACY POLICY

Effective Date: August 06, 2026

Last Updated: August 06, 2026

This Privacy Policy (“Policy”) explains how INTELLIGENCE FIRST PRIVATE LIMITED (“Company”, “we”, “us”, or “our”) collects, uses, stores, shares, discloses, and otherwise processes personal data when you access or use our website, mobile application, software, dashboards, wellness insights, and related services (collectively, the “Platform” or “Services”).

This Policy should be read together with our Terms of Use. By accessing or using the Platform, creating an account, submitting information, or clicking any consent mechanism such as “I Agree,” you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data in accordance with this Policy and applicable law. If you do not agree, you must not use the Platform or Services.

If you use the Platform on behalf of another person or entity, you represent that you are duly authorized to accept this Policy and provide the necessary consents on their behalf.

1. SCOPE AND APPLICABILITY

This Policy is published in compliance with applicable Indian laws, including, where relevant:

This Policy applies to personal data we process in our capacity as a data fiduciary / body corporate, including data relating to:

2. DEFINITIONS

For the purposes of this Policy:

“User, You or Your means any individual or entity who accesses, browses, registers on, or otherwise uses the Platform, including end users and business partners.

“End User” means a natural person who uses the Services, including for booking diagnostic appointments, obtaining reports, purchasing diagnostic packages or diagnostic plans, accessing wellness insights, or availing ancillary diagnostic-related services.

“Personal Data” means any data about an individual who is identifiable by or in relation to such data, and includes “personal information” or “sensitive personal data or information” to the extent recognized under applicable law i.e., the DPDP Act

“Sensitive Personal Data / Health Data” has the meaning assigned under applicable law, including Rule 3 of the IT (Reasonable Security Practices) Rules, 2011 and the DPDP Act. In the context of the Platform, this includes health records, medical history, blood biomarker results, physiological information, passwords, financial information processed in connection with payments, and other data of a sensitive nature.

“Data Principal” shall have the same meaning as provided under the DPDP Act.

“Data Processor” shall have the same meaning as provided under the DPDP Act.

“Diagnostic Partners/Service Providers” includes hospitals/labs, medical practitioners, clinics, diagnostic centres, spas, fitness centres, or similar entities listed on the Platform from whom Users may choose to obtain services.

“Content” All text, graphics, algorithms, reports, dashboards, data outputs, and materials available on the Platform.

“Services” means the diagnostic testing and related services facilitated through the Platform, including diagnostic test booking, sample collection coordination, laboratory testing, report generation, and diagnostic coordination performed or fulfilled through designated Diagnostic Partners or Service Providers outside the application, together with related platform features provided as part of those services, such as report access, dashboards, wellness scores, AI-assisted non-diagnostic insights, educational content, and incidental access to and storage of reports and related medical documents.

“Third Parties” means any person, organization, or application that is not the User or the Company. This includes external vendors such as payment processing partners.

“Platform” refers to the digital infrastructure developed or operated by the Company — including the website, mobile app/interface, or related domain, software systems, analytics engines, dashboards, algorithms — through which Users can access Services.

3. NATURE OF THE PLATFORM

The Platform is a technology-enabled preventive wellness and diagnostic facilitation platform designed to enable users to book diagnostic testing services through independent Diagnostic Partners and to access their diagnostic reports and related non-diagnostic wellness information. The Platform may provide diagnostic test booking and coordination, home sample collection coordination, access to diagnostic reports, biomarker dashboards, wellness summaries, non-diagnostic AI-assisted wellness insights, educational content, and lifestyle awareness information.

The Platform is not a hospital, clinic, emergency service, or diagnostic laboratory. All informational outputs are intended for informational and wellness-support purposes only and do not constitute medical advice. Users are advised to contact a registered medical practitioner before making health related decisions basis the information received through the Platform.

4. CATEGORIES OF DATA WE COLLECT

Depending on how you use the Platform, we may collect the following categories of information:

4.1 Identity and Contact Data

4.2 Account and Login Data

4.3 Health and Wellness Data

4.4 Transaction and Payment Data

These include billing information; order history; diagnostic package or diagnostic plan history; renewal history, and where applicable; payment references.

We do not store full card numbers, CVV, or similar highly sensitive payment credentials; such information is typically processed and handled by registered and compliant third-party payment service providers.

4.5 Device, Technical, and Usage Data

4.6 Communications and Support Data

4.7 Third-Party and Provider Data

We may receive personal data relating to you from:

4.8 Publicly Available Data

We may collect or use information lawfully available in the public domain as permitted by applicable law.

5. HOW WE COLLECT DATA

5.1 We may collect information:

Some users may have limited access to certain parts of the Platform without creating an account. However, full access to features and benefits may require registration and submission of personal data.

5.2 We may automatically collect certain information when you access or use the Platform through cookies (through our website), log files, software development kits (SDKs), analytics tools, device identifiers, pixels, tags, and other similar technologies.

Such information may include, without limitation, your device information, browser type, operating system, IP address, app version, device identifiers, pages or screens viewed, features used, access times, referring URLs, crash logs, performance data, location (after taking your permission), and other usage or diagnostic information.

We use such information for lawful and legitimate purposes, including to:

(a) operate, maintain, secure, and improve the Platform;

(b) authenticate users and prevent fraud, misuse, or unauthorized access;

(c) remember user preferences and improve user experience;

(d) monitor platform performance, errors, and technical issues;

(e) conduct analytics and understand usage patterns; and

(f) comply with applicable legal, regulatory, security, and audit requirements.

Where required under applicable law, we shall obtain your consent before using non-essential cookies, location, analytics tools, SDKs, or similar technologies. You may disable or manage cookies through your browser or device settings; however, disabling certain cookies or technologies may affect the functionality, security, or performance of the Platform.

By continuing to use the Platform, and where applicable by providing your consent through the cookie banner, app permissions, or platform settings, you acknowledge the collection and use of such information in accordance with this Privacy Policy.

6. PURPOSES OF PROCESSING

We may process your data for the following purposes:

6.1 To Provide and Operate Services

6.2 To Personalize Your Experience

6.3 To Process Payments

6.4 To Communicate With You

By verifying your contact details and using the Platform, you consent to receive transactional and service-related communications through calls, SMS, email, app notifications, WhatsApp, or similar channels, even if your number is registered on DND / NCPR lists, to the extent permitted by law.

You agree that you may be asked for affirmative action to opt-in (Opt-In) to receive promotional communication from time to time through calls, SMS, WhatsApp or Email. You can opt-out of this at any time by contacting our customer service representative at info@me100.in.

6.5 To Improve and Develop Services

6.6 For Research, Analytics, and Business Intelligence

We may use anonymized, de-identified, or aggregated data for:

6.7 For Legal and Compliance Purposes

7. LAWFUL BASIS AND CONSENT

Where required by law, we rely on one or more of the following grounds:

By using the Platform and voluntarily providing data, you expressly consent to the collection, storage, use, disclosure, and other processing of your personal data and health-related data in accordance with this Policy.

You may withdraw consent at any time by contacting us on info@me100.in, but withdrawal may affect our ability to provide some or all Services.

8. HEALTH DATA CONSENT

Because the Platform may involve health-related and wellness-related information, you expressly acknowledge and consent that we may process data such as:

You represent that you are authorized to provide such information and that it is accurate to the best of your knowledge.

Furthermore, the Platform may facilitate the booking, coordination, and management of diagnostic testing services through independent third-party laboratories (“Diagnostic Partners”).

By using the Platform, you expressly acknowledge and consent that:

9. AI-Enabled Features and Automated Processing

9.1 Certain functionalities of the Platform may incorporate artificial intelligence, machine learning algorithms, statistical methods, or other forms of automated processing to generate wellness scores, summaries, recommendations, and similar informational outputs that are provided in connection with diagnostic services.

By accessing or using such features, you acknowledge and agree that:

9.2 Non-Reliance on AI-Generated Outputs

You expressly acknowledge and agree that any outputs, insights, scores, recommendations, summaries, or other information generated by the Platform, including through artificial intelligence or automated systems (“AI Outputs”), are provided solely for general informational and wellness-support purposes.

You agree that:

You further acknowledge that any decisions or actions taken based on AI Outputs are undertaken at your sole discretion and risk.

To the fullest extent permitted under applicable law, the Company disclaims all liability arising from:

10. DATA ANONYMIZATION, AGGREGATION, AND AI TRAINING RIGHTS

We may transform personal data into anonymized, de-identified, or aggregated datasets that do not directly or indirectly identify you, to the extent reasonably practicable.

Such anonymized or aggregated data may be used for:

We do not sell Health Data to advertisers, data brokers, or third-party marketing networks, and we do not use Health Data for targeted advertising or behavioural advertising.

The Company exclusively owns all rights, title, and interest in such anonymized, de-identified, or aggregated datasets, and in all models, analyses, outputs, and derivative works created from or using such data, provided that such data does not identify you.

All such datasets, AI systems, models, outputs, reports, and derived works form part of the Company’s intellectual property. Except for the limited right to use the Platform as expressly permitted under the Terms of Use, you shall have no ownership or proprietary rights in or to the same.

11. DATA SHARING AND DISCLOSURE

We do not sell your personal data. We may share anonymised or aggregated data that does not identify you, as described in this Policy.

11.1 With Diagnostic and Healthcare-Related Partners

We may share relevant personal and health data with laboratories, healthcare providers, sample collection partners, logistics providers, and related service partners in order to facilitate the Services. This also includes sharing your address and precise location with sample collection partners to enable phlebotomist dispatch to your selected location.

11.2 With Service Providers and Vendors

We may engage vendors for:

These parties are contractually required to process data only for authorized purposes and to provide protection for your data that is at least equivalent to that described in this Policy.

11.3 With Artificial Intelligence and Cloud Infrastructure Providers

To generate wellness insights, summaries, dashboards, and scores in connection with diagnostic services, we process your health, biomarker and report data using third-party artificial intelligence and cloud infrastructure providers. These providers act as our processors, handle the data solely on our documented instructions to deliver the Services, and are contractually restricted from using it for their own purposes. This processing may occur on servers located outside India, subject to the safeguards described in Clause 11.8. We obtain your consent to this processing before generating AI-based outputs.

11.4 With Payment Partners

Financial and billing data may be shared with banks, financial institutions, payment processors, gateways, wallet providers, or other relevant entities to complete authorized transactions.

11.5 Business Transfers

Your data may be disclosed or transferred in connection with:

Any successor entity may continue to use the data in a manner consistent with this Policy and applicable law.

11.6 Legal and Regulatory Disclosure

We may disclose personal data where required by law or where necessary to:

11.7 Research and Commercial Use of Non-Identifiable Data

We may share anonymized, de-identified, or aggregated data with research institutions, partners, investors, or strategic collaborators, provided such data does not identify you.

We do not use or disclose your health or biomarker data, or any data derived from it, for advertising purposes.

11.8 Cross Border Data Transfer

Your personal data may be transferred to, stored in, or processed in jurisdictions outside India by our service providers. Such transfers shall be made in compliance with applicable restrictions under the DPDP Act and any rules notified thereunder. We shall ensure that appropriate contractual and technical safeguards are in place to protect your data in accordance with applicable law.

12. ACCOUNT MANAGEMENT, CORRECTION, AND DELETION

You are responsible for ensuring that the personal data and other information provided by you on the Platform is accurate, current, complete, and not misleading.

You may request correction, completion, or updating of your personal data by using the available account settings on the Platform or by contacting us at info@me100.in. Our data retention practices are further described in Clause 14 of this Privacy Policy.

You may delete your account and associated personal data directly within the Me100 app (Profile, then Personal Information, then Delete Account). You may also request account and data deletion without reinstalling the app by visiting https://www.me100.in/account-deletion. Following a verified deletion request, we will delete your personal data except where retention is required under applicable law, as described in Clause 14.

We shall process lawful and verifiable requests in accordance with applicable law and within a reasonable period, subject to technical feasibility, verification requirements, and any legal, regulatory, contractual, tax, audit, fraud prevention, dispute resolution, medical record, compliance, or other lawful retention obligations.

We may decline, defer, or limit any request for correction, updating, or deletion where retention or continued processing of such data is permitted or required under applicable law, or where such data is necessary for legal claims, regulatory compliance, fraud prevention, security, audit, dispute resolution, enforcement of our terms, or protection of our legitimate rights and interests.

In case of account closure or deletion request:

(a) certain personal data may continue to be retained for lawful purposes, including legal, regulatory, tax, audit, fraud prevention, dispute resolution, security, and compliance purposes;

(b) anonymised, aggregated, or de-identified data that does not identify you may continue to be used for analytics, research, product improvement, statistical, business, and service development purposes;

(c) withdrawal of consent, deletion of personal data, or closure of your account may limit, suspend, or terminate your ability to access or use certain Services, including historical reports, health records, analysis, insights, recommendations, or other Platform features.

13. USER RIGHTS UNDER THE DPDP ACT

Subject to applicable law, you may have the right to access a summary of your personal data being processed, request correction, completion, or updating of inaccurate data, request erasure of personal data, where legally permissible, withdraw consent, grievance redressal, nominate another person to exercise rights on your behalf in case of death or incapacity, when such framework becomes applicable.

We may need to verify your identity before acting on such requests.

14. DATA RETENTION

14.1 General Principle

We retain Personal Data only for as long as is reasonably necessary to fulfil the specific purpose for which it was collected or processed, in accordance with applicable law, including the DPDP Act and any rules notified thereunder.

14.2 Purposes of Retention

Personal data may be retained for one or more of the following purposes:

14.3 Retention Periods

We typically apply the following retention periods to categories of personal data:

Report access and related medical document storage are provided as incidental platform features connected with diagnostic services and are subject to the retention periods set out in this Clause.

Where a specific retention period is mandated by any applicable law, rule, regulation, or order of a competent authority, the longer of the prescribed period or the period stated above shall apply.

14.4 Review and Deletion

We shall periodically review retained personal data to determine whether its continued retention is necessary for the purposes stated in Clause 14.2. Where personal data is no longer required for any such purpose and no legal obligation mandates its continued retention, we shall:

within a reasonable timeframe, and in any event no later than 90 days following the determination that such data is no longer required.

14.5 Rights of the Data Principal

15. SECURITY AND CONFIDENTIALITY

We implement reasonable and industry-aligned managerial, technical, operational, and physical safeguards designed to protect personal data against unauthorized access, misuse, disclosure, alteration, destruction, or accidental loss.

These safeguards may include encryption in transit and at rest, role-based access controls, secure infrastructure and servers, monitoring, logging, and incident response systems, confidentiality obligations for employees and processors, and security reviews and vulnerability management.

Access to personal data is restricted on a need-to-know basis.

While the Company implements robust security practices in line with industry standards, you acknowledge and agree that no digital platform, system, or network can be guaranteed to be completely secure or immune from cyber risks. It is hereby clarified that the Company shall not be liable for losses arising from security incidents to the extent that such incidents are caused by circumstances beyond its reasonable control, provided the Company has implemented and maintained reasonable security safeguards in accordance with applicable law.

Accordingly, to the fullest extent permitted under applicable law:

You further agree to promptly notify the Company of any suspected or actual security incident, unauthorized access, or breach involving your account or data.

Nothing in this clause shall limit any obligations imposed on the Company under applicable law with respect to reasonable security practices or breach notification requirements.

16. DATA BREACH RESPONSE

If we become aware of a personal data breach, we will take reasonable steps to contain and investigate the incident, assess the nature and severity of the breach, mitigate risks where feasible, and notify affected individuals and/or regulators where required by applicable law.

Where feasible and legally required, breach notifications may include a description of the incident, categories of data affected, mitigation measures, and contact details for further information.

17. THIRD-PARTY WEBSITES AND SERVICES

The Platform may contain links or integrations to third-party websites, applications, or services that are not owned or controlled by the Company. The Company does not exercise any control over, and shall not be responsible for, the content, security, or privacy practices of such third-party platforms.

Any access to or use of such third-party services is undertaken at your sole discretion and risk and shall be governed by the respective terms and privacy policies of those third parties.

18. COMMUNICATION RECORDS, SURVEYS, AND FEEDBACK

We may keep records of support emails, chats, telephone calls, appointment-related communications, survey responses, complaints and service feedback.

Such records may be used for service administration, quality assurance, training, analytics, customer support, fraud detection, and product improvement.

Do note that participation in surveys or contests is optional unless specifically required for a particular service flow.

19. CHILDREN’S PRIVACY

The Platform is intended only for users 18 and older, we do not knowingly collect personal data from minors, and if we learn that data from a person under 18 has been collected, we will take steps to delete such data and disable the relevant account, with parents/guardians invited to contact info@me100.in.

Parents and guardians are encouraged to monitor minors’ online activities.

20. NO-SPAM COMMITMENT

We maintain a no-spam approach and do not intend to sell or rent your personal data to unrelated third parties for their independent marketing without lawful basis or consent.

21. POLICY CHANGES

The Company reserves the right to update or modify this Policy from time to time. Any revised version will be made available on the Platform with an updated effective date.

You are encouraged to review this Policy periodically to stay informed of any changes. Your continued use of the Platform after such updates become effective shall constitute your acceptance of the revised Policy. Your continued use after non-material amendments shall constitute acceptance.

If you do not agree with any modifications, you must discontinue use of the Platform and may request closure of your account.

In case the Company is notified as or becomes a Significant Data Fiduciary under the DPDP Act it shall comply with additional obligations including conducting Data Protection Impact Assessments, appointing a Data Protection Officer and independent data auditor, and undertaking periodic audits, in accordance with the rules notified thereunder.

22. CONTACT, GRIEVANCE, AND DATA PROTECTION OFFICER

For questions, concerns, or grievances, you may contact:

INTELLIGENCE FIRST PRIVATE LIMITED

A-37 Mayapuri Industrial Area

Phase-II, New Delhi – 110064

India

Privacy / Support Email: info@me100.in

Grievance Officer: Mr. Arsalan Mubasshir

We will endeavour to acknowledge and address your concerns within the timelines required under applicable law.

23. CONSENT TO THIS POLICY

You acknowledge that this Privacy Policy forms an integral part of the Terms of Use of the Platform, and that your access to or use of the Platform signifies your acceptance of this Policy and your consent to the collection, use, disclosure, processing, storage, and retention of your personal data in the manner described herein.

In the event of any conflict between this Privacy Policy and the Terms of Use regarding the processing or protection of personal data, the provisions of this Privacy Policy shall prevail to the extent of such conflict, unless the Terms of Use provide a higher standard of protection

This Privacy Policy, including its interpretation, validity, enforcement, breach, or termination, shall be subject to and resolved in accordance with the governing law, dispute resolution mechanism, and jurisdiction provisions that are set forth in the Terms of Use, which are hereby incorporated by reference. This includes any grievance, claim, dispute, or controversy that arises out of or relates to this Privacy Policy.