Privacy Policy 

This Privacy Policy is effective as of September 1, 2024

PLEASE READ THIS PRIVACY POLICY CAREFULLY.

We are committed to protecting your privacy as a user (referred to as "User", "you" or "your") and/or visitor to the Website (“Visitor”, and where contextually relevant, “you” or “your”), and we take our responsibility regarding the security of your Personal Data (defined below) very seriously. We will be clear and transparent about the Personal Data we are collecting and what we will do with that Personal Data.

This privacy notice (the "Privacy Policy") describes the types of Personal Data we process on the VEDIC LAB mobile application (the "VEDIC LAB App") and our website www.vediclab.com (with all related webpages, the “Website”, and collectively with the VEDIC LAB App, the “Platform”). 

Terms capitalized but not defined in this Privacy Policy are defined in the Terms of Service, available here:https://vediclab.com/pages/terms-conditions.

1. Who is responsible for processing your Personal Data?

Swiss EcoNaturals AG (referred to as "VEDIC LAB", "we", "us" or "our") is the "data controller" (i.e., the organisation responsible) for all Personal Data that is collected and processed via the Platform for the purposes of any data privacy laws, principles, and regulations which may apply to Users and/or Visitors (collectively, "Data Privacy Law").

In some situations, some other third parties may be independent controllers of information collected through the Platform but intended for processing by such third parties for the purposes and means determined by them. For example, Ayurvedic Experts (selected by Users seeking the Telehealth Service for Consultations) are independent controllers in respect of data shared with them for the purposes of conducting the Consultations and advising such Users. 

2. What Personal Data do we collect (including by automated means)?

We may ask for and collect Personal Data from Users and/or Visitors (either directly through your use of the Platform or when you communicate with us in any other way, or indirectly through our third party partners or providers) in a number of ways to provide you with the products or services that you request. We may also collect information from you automatically when you visit our Platform. 

"Personal Data" has the meaning given in applicable Data Privacy Law, and includes any information or opinion relating to a natural person which identifies or makes them identifiable, such as name, phone number, other identification number, social media name or ‘handle’, postal address, email address, etc. 

Please refer to Section 3 below for more information on how we use Personal Data collected on the Platform.

2.1 Data Collected by VEDIC LAB

We collect the following categories of Personal Data on the Platform:

• first and last names and email address (this is mandatory information which we require when opening user accounts on the Platform ("User Account")).
• country of residence, billing and shipping address (if these are provided in order to receive deliveries of products purchased from our Platform);
• payment information (e.g., bank account, credit or debit card information, billing address) to process payments for products and services on the Platform;
• Lifestyle activity data provided by Users on the Platform or generated through your use of the VEDIC LAB App (for example, routines completed, duration of routines, etc.); 
• your image, while Users/Visitors avail our AI-based skin analysis (“Skin Analysis Service”) offered by the Platform;
• while Users/Visitors avail our Telehealth Service, the User’s/Visitor’s name, email address and phone number (if provided), along with the “Telehealth Data” which comprises: (i) the Concern in respect of which a Consultation is sought with an Ayurvedic Expert (if provided), (ii) the level of awareness of Ayurveda (if provided), (iii) the User’s/Visitor’s primary diet (if provided), (iv) the User’s/Visitor’s occupation (if provided), (v) information on the User’s/Visitor’s allergies, if any (if provided),and (vi) any message that the User/Visitor wishes to share with the Ayurvedic Expert (if provided), in order to facilitate a Consultation with the relevant Ayurvedic Expert.     

The collection, transmission, storage and processing of the Telehealth Data are carried out for the Company by its appointment service provider processor, through technical integrations on the Company’s Platform. The Company does not receive or store any of the Telehealth Data on its Platform.         

• Information which Users/Visitors voluntarily provide to the Company in order to receive their free basic ayurvedic assessment reports based on a questionnaire provided on the Website/App (the “Free Ayurvedic Quiz”);
• information which Users voluntarily choose to post or share in the Expert Center;
• information that Users choose to share with us as feedback or surveys for example, when completing workout reviews, giving feedback to us about your experience in the Platform, completing member surveys, etc. 
• information about purchases of products and services through the Platform (whether these products or services are provided by us or our third party partners);
• prior Assessment Reports of Users or Visitors, shared with us to forward to the relevant Ayurvedic Experts when seeking new Consultations;
• information about your use of the Platform, such as which content our Users consume the most or Website pages visited by Visitors;
• communications with us or directed to us via letters, emails, chat services, calls, and social media (including communications seeking customer care);
• where Users/Visitors have chosen to share their activities on/through the Platform with others through social media platforms, their necessary social network information (including username/handle specific to that social media platform) in order to facilitate such sharing;
• when Users have sent a referral link to a friend, colleague, or family member or been referred to VEDIC LAB by a friend, we may be able to identify the identity of the person who referred you or who you referred;
• when Users have elected to sign up and log into the Platform using a third-party account you created (e.g. through Facebook or Apple), information you have agreed to make available to us (e.g. name, email address, profile information, preferences); and
• location of Users and Visitors based on the IP address of their computer or device, which we use to customise your experience on the Platform (e.g. language settings, time/date). 

2.2 Data Collected from Third Parties

We collect the following kinds of data from third parties: 

• payment information to process your payments where payments are made using a third party processor;
• completed Telehealth Service Assessment Reports pertaining to Users/Visitors, from Ayurvedic Experts, for the purpose of forwarding such reports to the relevant Users/Visitors. We do not process these reports for any other purposes than to transmit them to you; 
• enhanced or “beautified” versions of images uploaded by Users who seek the Skin Analysis Service, from our external AI provider; and
• where Users/Visitors choose to share your activities on/through the Platform with others through social media platforms as publicly available information, including any information you share in a public social media post where you tag, use a hashtag, link, or otherwise direct the post to our attention.

2.3 Automatic Data Collection and Cookies

We also automatically collect certain information about interactions of Users and Visitors with the Website ("Usage Data"). To do this, we may use cookies, pixels, web beacons, software developer kits, third-party libraries and similar technologies (collectively termed "Cookies" in this Privacy Policy). Usage Data includes information about how Users/Visitors access and use our Website and your account, including device information, browser information, information about your network connection, your IP address and other information regarding your interaction with the Website.

We use the following kinds of Cookies, in the scenarios described below: 

• Necessary Cookies: to enable the basic features of our Website. These cannot be disabled.
• Functional Cookies: to power and improve our Website and our services (including to remember your actions and preferences). 
• Analytics Cookies: to run analytics and better understand interactions with our services to administer, improve and optimize them. 
• Performance Cookies: to understand and analyze the key performance indices of the Website, to deliver a better user experience for visitors.
• Advertisement Cookies: to permit third parties (such as Google and Meta) and services providers to use Cookies on our Website to better tailor the services, products and advertising on our Website and other websites including the websites of those third parties. 

For specific information about the Cookies that we use related to powering our store with Shopify, see https://www.shopify.com/legal/cookies. 

We use cookies administered by Google Analytics to analyse the number of Website visitors and their source, uniqueness of visitors to our Website, interactions with our Website, and pages visited by Visitors. To learn more about how Google uses information from our Site based on our use of Google Analytics, please visit https://policies.google.com/technologies/partner-sites. 

Our Cookie banner/Cookie footer allows you to make choices on accepting or not accepting the above Cookies. You can also choose to set your browser to remove or reject Cookies through your browser controls, and specifically for Google Analytics, by installing the Google Analytics Opt-Out Browser Add-On from https://tools.google.com/dlpage/gaoptout.  

Please keep in mind that removing or blocking Cookies can negatively impact your user experience and may cause some of our Platform services, including certain features and general functionality, to work incorrectly or no longer be available.

3. Why and how do we use your Personal Data, and on What Basis

Your Personal Data may be used for the following purposes:

3.1 Provide features of the Platform and the products and services you request:

We use the Personal Data you give us to provide the Platform and the products and services you request, including:

• to create and set up your User Account;
• to deliver to you the products you purchase on our Website;
• to provide you the Skin Analysis Service assessment report with an enhanced or “beautified” version of your image, should you seek this service;
• to provide the basic assessment report based on the Free Ayurvedic Quiz available on our Website/App, should you seek this service;
• to provide you the Telehealth Service, should you seek this service;
• if Users use the Platform to track your activities, we will collect and store this information so that you can review it on the Platform and track your progress on the ‘Routine’ screen of the App. We may also use this information to calculate further information about your activity so that this can be provided to you as part of the functionality of the Platform;
• if Users choose to post in the Expert Center, the information that you share will be public information that can be accessed by anyone whether or not they are a part of the VEDIC LAB community. As the information posted to the Expert Center is public information, it will also be indexed and accessible via third party internet search engines, websites and apps. For further information about how content posted in the Expert Center is publicly available, please refer to our Expert Center Guidelines Addendum appended to the Terms of Use;
• if Users choose to save your enhanced image from the Skin Analysis Service, we will process your image to display this enhanced image to you and store it to display to you from time to time. We do not process your image for any other purpose; 
• to improve the products, services and content available on the Platform;
• to improve and tailor your experience on the Platform so that you have a seamless experience using it (such as automated setting of date and time, language, etc.); and
• to offer Users and Visitors personalized recommendations based on your previous interactions with the Platform.

3.2 Communicate information about our products and services and for other promotional purposes:

With your consent, or as otherwise permitted by applicable Data Privacy Law, we will use Users’ (and, where they avail the Telehealth Service, the Skin Analysis Service or the Free Ayurvedic Quiz through the Platform, Visitors’) Personal Data to provide information and recommendations that we believe is of interest to you, prior to, during, and after your interactions with us, including marketing communications and news concerning our products, services, events and other promotions. You can opt-out at any time after you have given your consent to such communications. In providing tailored promotional materials to you, VEDIC LAB may use the personal information collected through your use of the Platform, such as the user preferences you set and profile data you submit, as well as activity data generated through your use of the Platform.

3.3 Customer service communications:

We use Users’ data to manage our relationship with you as our customer and to improve our services and enhance your experience with us (e.g. to respond to your inquiries when you reach out to us). From time to time, we may also conduct customer surveys to gauge satisfaction with our Platform and the services and products that we provide. Where services (such as the Telehealth Service or Skin Analysis Service) are availed by Visitors, their personal data will be processed in similar manner in order to provide customer support.

3.4 Administrative or legal purposes:

We use Personal Data of Visitors and/or Users to improve our business, including for statistical and marketing analysis, systems testing and to diagnose technical and service problems, maintenance and development of our Platform, or in order to deal with a dispute or claim. We may also perform data analysis based on the data we collect from you for statistical and marketing analysis purposes – for example, we may use information about how Users of our Platform search for and find specific activities to better understand the best ways to organise and present the content that we offer.

3.5 Security, health, administrative, crime prevention/detection and legal purposes:

We may use Personal Data from Users and/or Visitors to verify your information and identity, and to protect against, identify and prevent fraud and other unlawful activities. We may use your Personal Data to detect, investigate or take action regarding possible fraudulent, illegal or malicious activity. We may also share your Personal Data with government authorities or enforcement bodies for compliance with legal requirements, or as otherwise required or permitted by applicable Data Privacy Law.

3.6 Other purposes:

We may also use your Personal Data in other ways, and where we do so, we will provide specific notice at the time of collection and obtain your consent unless otherwise permitted by applicable Data Privacy Law.

3.7 Bases for Processing 

We will only process your personal data where we have a legal basis to do so, which will depend on the reasons for which we have collected and need to use your personal data. 

Our bases for the data processing we undertake are as follows:

Where we receive your Personal Data as part of providing our services to you based on a contract, we require such Personal Data to be able to carry out the contract. Without that necessary Personal Data, we will not be able to provide our services to you.

Personal details including about your health are considered “sensitive” Personal Data under applicable Data Privacy Law. We will process any such data only if you have given your explicit consent, or if the sensitive Personal Data has been manifestly made public by you (e.g., by posting information about your health status in the VEDIC LAB Expert Center), or otherwise in compliance with applicable Data Privacy Law.

As described more fully below, you may always contact us at the details in Section 11 with any questions or requests about your Personal Data.

4. How do we protect and manage your Personal Data (including international transfers and retention periods)?

4.1 Encryption and security

We follow strict security procedures in the storage and disclosure of our Users’ and Visitors’ Personal Data, which are designed to protect it against misuse, unauthorised access, modification or disclosure and accidental loss, destruction or damage. The data you provide to us is protected using SSL (Secure Socket Layer) technology. SSL is the industry standard method of encrypting Personal Data and credit card details so that they can be securely transferred over the internet.

4.2 International transfers of your Personal Data

VEDIC LAB operates its business in the EEA. The Personal Data that VEDIC LAB collects from Users and Visitors will be stored and processed in the EEA. It might also be shared with third party data recipients (e.g., e-commerce and logistics providers, customer support providers, customer relationship management tool providers, appointment facilitation software providers, third party staffing/resource providers, payment service providers, and Ayurvedic Experts) that are not located in the EU, EEA or the UK. Therefore, the Personal Data that Users and Visitors provide to VEDIC LAB may be transferred internationally to countries other than the country in which you initially provided your data.

While countries outside the EU, EEA and the UK do not always have strong data privacy laws, we take measures to protect your Personal Data as described in this Privacy Policy and in compliance with applicable Data Privacy Law. We also require all third party data recipients (including our service providers) to process your information in a secure manner and in accordance with applicable Data Privacy Law. If you have further questions about this, please contact us at the details in Section 11 below.

4.3 Retention of Personal Data

We will not retain Users’/Visitors’ data for longer than is necessary to fulfil the purposes for which it is being processed. To determine the appropriate retention period, we consider the amount, nature and sensitivity of the personal data, the purposes for which we process it, and whether we can achieve those purposes through other means.

We also consider the periods for which we might need to retain personal data in order to meet our legal obligations, or to deal with complaints and queries, and to protect our legal rights in the event of a claim being made.

In general, this means that we will likely keep your Personal Data for as long as your User Account is open. Following closure of your User Account, however, we may still retain a limited portion of your Personal Data so that we can maintain a continuous relationship with you if and when we are in contact with you again, and to comply with our internal processes and any legal obligations.

When we no longer need your personal data, we will securely delete or destroy it. 

Information that Users have shared in the Expert Center will remain public even after you have closed your VEDIC LAB account. Where you choose to delete content that you have posted to the Expert Center, VEDIC LAB will delete such content from its Platform and associated data servers, etc. However, the information may not be deleted from third party websites, apps or internet search engine indexes instantly as removal of the content depends on third party policies; please assess the necessity to, and pursue courses of action against such third parties to delete such content, at your discretion.

User images shared with us for availing the Skin Analysis Service are retained and processed by our external AI service provider only for as long as necessary to perform the AI-based analysis and create the enhanced or “beautified” image for display, and then deleted by the external AI service provider. 

VEDIC LAB retains the enhanced versions of User images for those Users who choose to retain and view their enhanced images (based on the reports of the Skin Analysis Service) and periodically displays these to users. Such images, along with other User data, are retained for as long as the User Account remains open. 

Users can exercise their right to seek deletion of their data (including their images) as set out in Section 6 below. 

1. Who do we share your Personal Data with?

We may share your Personal Data with the following entities/persons for the purposes described in this Privacy Policy:

1. other companies and entities within the VEDIC LAB / Swiss EcoNaturals AG group. Currently these other entities are also located within the EEA;
2. our trusted third party partners who offer products and services on or through our Platform, including our Ayurvedic Experts with whom Users/Visitors seek Consultations through our Telehealth Service. If Users/Visitors choose to purchase products or services offered on our Platform by third parties, you may be a customer of both VEDIC LAB and these third parties, and we and our partners may collect and share information about you, such as your contact details and your billing information. We are not responsible for third parties’ use of your personal data where such use is permitted for their own purposes. You should consult their privacy policies for further information;
3. third party social media platforms in various circumstances, including where:
4. Users/Visitors are able to access third party social media services through our Platform or before coming to our Platform;
5. you connect your User Account to your social media account, in which case we will receive from the social media platform the Personal Data you choose to share, based on the preferences and settings on your social media account. We will use this information in order to improve and personalize your use of our Platform; and
6. we use social media plugins on our Platform (e.g. a “share” or “like” button), and your use of these plug-ins, may result in the disclosure of certain of your information to the social media platform in question, and possibly presented on your social media profile, to be shared with others in your network – however, we will only share your Personal Data with these social media platforms if you have provided your express consent for us to do so.
7. Third party vendors and service providers - other companies, contractors or agents that assist us in providing services to you, including our online e-commerce platform that allows us to sell and deliver our products and services to you (Shopify), to fulfill and deliver your orders, we work with third-party logistics providers (DHL, Swiss Post or UPS depending on customer location), handle the support ticketing service providers, appointment facilitation service providers, legal service providers, marketing service providers, administration service providers, third party software service provider for the Expert Forum service, and resource management agencies associated with them, customer services and information technology support
8. Our external Skin Analysis Service provider that processes User images (including to enhance or “beautify” them) and provides the analysis report in this respect. Our external Skin Analysis Service provider retains and processes User images in the EU region. The report and the enhanced images are transmitted back to VEDIC LAB, and the external service provider then deletes all User images. Our external Skin Analysis Service provider retains only a completely anonymized version of the report, and does not retain any User data or images;
9. payment processors which facilitate Users’/Visitors’ payments to us, and for anti-fraud screening, which may need information about your method of payment to process payment or ensure the security of your payment transaction. Before entering your personal details we suggest that you read and become familiar with the privacy policy for any such third-party provider; 
10. government authorities, law enforcement bodies and regulators for compliance with legal requirements, or where otherwise required by applicable Data Privacy Law; 
11. our legal and other professional advisers in order to enforce our legal rights in relation to our contract with Users/Visitors; and
12. in connection with a business transaction such as a merger, takeover, restructuring or reorganization, in order to facilitate such a transaction. 

6. Your Rights and Choices

6.1 Under certain circumstances, by applicable Data Privacy Law Users and Visitors may have the right to:

1. Request information about whether we hold personal information about you, and, if so, what that information is and why we are holding/using it;
   
2. Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it;
3. Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you, corrected;
4. Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see (e) below);
5. Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes;
6. Object to automated decision-making including profiling, that is not to be subject of any automated decision-making by us using your personal information or profiling of you;
7. Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it;
8. Request transfer of your personal information in an electronic and structured form to you or to another party (commonly known as a right to “data portability”). This enables you to take your data from us in an electronically useable format and to be able to transfer your data to another party in an electronically useable format; and
9. Withdraw consent. In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes to which you originally agreed, unless we have another proper and legitimate basis for doing so.

6.2 If you wish to exercise your rights related to your Personal Data (including the rights set out above), please contact the VEDIC LAB team using the details in Section 11.

6.3 While you will generally not be required to pay a fee to access your Personal Data or to exercise any of your other statutory rights, we may charge a reasonable fee if your request for access is clearly completely unfounded or excessive or decline to comply with such requests where permitted by applicable Data Privacy Law.

6.4 We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it and to prevent unauthorised modification of your personal information.

6.6 You also have the right to lodge a complaint about our processing of your Personal Data with the body regulating data protection in the country or state / province in which you live.

7.The Expert Center

Where you choose to post information in the Expert Center, the information that you share will be public information which can be viewed by anyone (whether or not they are a part of our community). Information posted in the Expert Center will be indexed to third party internet search engines (such as Google), websites and apps.

8. Links to other websites

Our Platform may provide links to other, external websites for the convenience and information of our Visitors and Users. These websites operate independently from us. If you visit any such website, you are subject to that website’s own privacy policies. We strongly suggest you review those external websites’ privacy policies. To the extent any linked websites are not owned or controlled by us, we are not responsible for their content, any use of the websites, or the privacy practices of the websites.

9. Children

Users must be of legal age in their respective countries and not under 18 years old, in order to create accounts on, and use, the Platform. If we identify any User that appears to be below the age of 18 years, we will reach out to that User to verify their age and/or delete their account if they are found to be below 18 years of age.

10. Updates to this Privacy Policy

VEDIC LAB may revise and update this Privacy Policy at any time in its sole discretion by posting an updated Privacy Policy on the Platform. All such changes to the Privacy Policy are effective immediately when posted to the Platform and apply to all access to and use of the Platform thereafter.

11. How to contact us

We welcome questions and comments about this Privacy Policy and our privacy practices. If we receive a complaint from you about how we have handled your Personal Data, we will investigate and determine what action we should take to resolve the complaint. We will contact you within a reasonable time and may request more information to assist us with our investigation. We aim to resolve all complaints in a timely manner. If you wish to provide feedback or if you have questions or concerns or wish to exercise your rights related to your Personal Data, please contact the VEDIC LAB team at the following email address: care@vediclab.com.