PRIVACY
enGen Global Online Privacy Policy

At enGen Global ("enGen Global")¹, we take the issue of privacy very seriously. We want to assure Users of our company websites, mobile applications, social media tools, consumer portals, and other online or digital resources (collectively "Consumer Platforms") that information which may be collected and/or provided to us is secure and maintained in confidence, consistent with applicable laws, regulations, and corporate standards. "Users" means any individual visiting, using, and/or providing Personal Information via one of our Consumer Platforms. References to "you" or "your" in this online privacy policy mean individual Users. "Personal Information" means any individually identifiable information about a User, including, but not limited to name, date of birth, address, phone number, e-mail address, account number, IP (internet protocol) address, and other sensitive personal data or information such as password, financial information, medical conditions and records, and sexual orientation. Please read through the following pages, which describe the type of information we may collect, how we may use information, and our commitment to maintaining the privacy and security of information.

Please be advised that enGen Global Health does not control data collection, use, or disclosure activities which may occur on platforms owned by a Non-affiliated Third Party²; however, we may receive information from the platform owner about Users who visit our resources located on their platform. For example, enGen Global Health may maintain a Facebook page, but we have no control over how Facebook collects, uses, or discloses information obtained from Users who might visit that page.

I. INFORMATION COLLECTED ONLINE

A. General

How you use a particular enGen Global Health Consumer Platform will determine whether or not we may collect Personal Information from you, and how much we may collect. For many features, we may not require any Personal Information, nor will we ask questions about you. However, for others, we may need to either verify your identity through a login process, or collect sufficient Personal Information to provide the service associated with that feature.

B. Secure messaging and feedback/inquiry forms

enGen Global Health invites Users to contact us using secure messaging or feedback/inquiry forms regarding Consumer Platform accounts, questions or concerns, or enGen Global Health's products or services, where applicable. We may disclose Personal Information to contracted Service Providers³ to allow them to perform a service or function for which they have been engaged. The information provided through secure messages and feedback/inquiry forms may be used by enGen Global Health or its contracted Service Providers to review and respond to Users' communications.

enGen Global Health may establish online communications tools for consumers to contact us regarding certain requests, such as account questions or product or service inquiries. Messages sent by or to consumers who choose to use these online services may be recorded in transaction logs, which may be reviewed to monitor compliance with applicable laws and regulations, as well as the overall effectiveness of the services.

Users can also inquire about products and services offered by a Non-affiliated Third Party or Service Provider by clicking hyperlinks which may be located on our Consumer Platforms. These hyperlinks will then redirect to the Non-affiliated Third Party or Service Provider website. enGen Global Health makes no representations or warranties regarding these websites, their content, or security. Users should review the online privacy policy of the Non-affiliated Third Party or Service Provider for information regarding their data collection, use, and disclosure practices.

C. Use of cookies

A cookie is a piece of information about an internet session that may be created when an individual accesses a website. Cookies can capture information such as your IP address, your internet browser and operating system type, the date and time you visit a website, session information such as page response times, your search history, your saved preferences and password information (if you elect to have a website remember this information), information about the referring URL (uniform resource locator) and the URL clickstream to, through, and from our Consumer Platforms, and other similar details.

enGen Global Health's Consumer Platforms may use cookies to monitor the performance of our resources, to enhance the User experience, and to assess aggregate information about our User base. We may also employ cookies on Non-affiliated Third Party and Service Provider websites to facilitate the delivery of our services and help follow Users’ online activities over time and across online resources to inform more relevant communication with Users.

Most internet browser settings can be modified by individuals to block or disable cookies (“do not track”). If a User decides to block or disable cookies in their internet browser settings, enGen Global’s Consumer Platforms do not respond to these settings, and our use of cookies may not be affected. Users should be aware that blocking or disabling cookies could prevent a particular Consumer Platform or certain features from fully functioning, so Users are encouraged to keep cookies enabled.

D. Non-affiliated Third Party and Service Provider use of cookies

A Non-affiliated Third Party or Service Provider may employ cookies on our Consumer Platforms to facilitate the delivery of their services and help follow Users’ online activities over time and across online resources. Any cookie data shared by enGen Global Health with a Non-Affiliated Third Party or Service Provider is subject to the provisions of this online privacy policy. Users should also review the online privacy policy of the Non-Affiliated Third Party or Service Provider to understand their data collection, use, and disclosure practices.

E. Note about Children’s Online Privacy Protection Act and other laws

Please be advised that enGen Global Health’s Consumer Platforms are intended for general audience Users. Our Consumer Platforms are not directed at children under the age of 13, nor do we make attempts to collect, use, or disclose information from children under the age of 13. enGen Global Health complies with all applicable laws governing advertising and marketing to children, including, but not limited to, The Young Persons (Harmful Publications) Act, 1956, prohibiting marketing to children under the age of 20.

II. USE OF INFORMATION COLLECTED

enGen Global Health does not sell or disclose Personal Information of Users collected through our Consumer Platforms to anyone, unless required under applicable laws.

All information submitted to us may be retained to provide a record of communications and to comply with any applicable legal and/or regulatory requirements, and may also be verified for accuracy.

In addition: enGen Global Health may use Personal Information of Users collected through enGen Global Health’s Consumer Platforms to i) provide relevant health care related information, ii) provide information regarding general health topics, iii) provide updates, news, event notices and announcements, iv) update information we have about Users, and v) monitor the effectiveness of our Consumer Platforms and features. We may also use Personal Information to provide Users with access to information about products, programs, and services offered by enGen Global Health or our subsidiaries and affiliates.

If you receive e-mail updates, news, announcements and/or special notices from enGen Global Health websites, enGen Global Health uses the name, demographic, e-mail and other contact information you supply to provide those updates, news, announcements and notices through its own facilities or those of a contracted service supplier. You may remove yourself from these mailings at any time by following the removal instructions included in all such messages. Your e-mail address and other contact information will be used only for enGen Global Health-related mailings and will not be given, sold or rented to any other party for any other use without your prior approval.

Personal Information may also be anonymized by enGen Global Health (i.e. stripped of individual identifiers), aggregated with other data, and used for general research, classification, marketing, or other purposes without permission.

III. ACCESS TO INFORMATION COLLECTED ONLINE

A. Employees

Certain enGen Global Health employees may be provided with Personal Information of Users in order to respond to their needs, assist with customer service and related account issues, and provide requested information regarding specific products or services. Certain employees may also be provided with Personal Information of Users in order to monitor the effectiveness of our Consumer Platforms and features. enGen Global Health employees are required, by written confidentiality statements, corporate policies, and applicable laws or regulations, to maintain the confidentiality of Personal Information, and to use strict standards of care in handling information. Employees who do not conform to these confidentiality requirements are subject to disciplinary sanctions, up to and including dismissal.

B. enGen Global Health’s subsidiaries and affiliates

enGen Global Health may disclose Personal Information of Users collected through its Consumer Platforms to its subsidiaries and affiliates as necessary to carry out its business operations. It may also disclose Personal Information to contracted Service Providers that are contracted by enGen Global Health to provide certain services or perform certain functions on its behalf.

Personal Information collected through Consumer Platforms by subsidiaries and affiliates may also be disclosed to enGen Global Health as necessary to carry out their business operations. All Personal Information may be disclosed in order to respond to a User’s needs, and/or to provide information about products or services offered by or through enGen Global Health, its subsidiaries and affiliates, or contracted Service Providers. Personal Information is treated with the same strict standards of confidentiality that enGen Global Health applies to other types of confidential information. enGen Global Health's subsidiaries and affiliates are subject to corporate policies regarding privacy and confidentiality, and enGen Global Health's contracted Service Providers and business associates are legally bound by contract to follow the same, or no less restrictive, standards of confidentiality as followed by enGen Global Health.

C. Third parties

Other than as set forth herein, enGen Global Health does not transmit any Personal Information collected through its Consumer Platforms to any third party without the permission of the User. However, Personal Information may be transmitted if there is a specific need to complete a transaction requested by the User or if necessary for providing a service or benefit to the User.

D. Consumer Platform communication services

enGen Global Health has access to communications sent by or to Users who choose to utilize any Consumer Platform communication features. enGen Global Health will not release the content of specific communications to any third party without the User’s consent, other than as set forth above, or unless permitted or required under applicable law or regulation.

IV. COMPLIANCE ASSURANCE

A. Security

enGen Global Health uses commercially reasonable information security practices and technologies, which have been certified and approved by the Government of India and are in congruence to applicable laws and regulations, to protect the information we maintain, and to help ensure compliance with the security and privacy standards described in this online privacy policy. For Users who choose to communicate with enGen Global Health using their personal e-mail account, please be aware that there is always some risk in sending information over the internet. Although we make reasonable efforts to protect your information from unauthorized access, use, disclosure, or alteration, you should be aware there is always some risk in transmitting information over the internet, such as the potential for interception or misuse of your information before we receive it.

B. Account access

Consistent with the requirements set forth under applicable laws, enGen Global Health grants access to Personal Information only to those employees, subsidiaries and affiliates, and contracted Service Providers as necessary to provide appropriate products and services, or as Users authorize. All such employees, subsidiaries and affiliates, and contracted Service Providers are subject to confidentiality statements, privacy policies, and/or other contractual obligations at least, or no less restrictive, as the standards followed by enGen Global Health.

C. Internal compliance with privacy and security programs

enGen Global Health maintains internal privacy and security programs to help ensure compliance with this online privacy policy, and to maintain the privacy and security of Personal Information. These programs include oversight by a Chief Privacy Officer and a Chief Information Security Officer who oversee the maintenance of the privacy and security programs, as well as the enforcement of privacy and security practices. Additionally, our privacy and security programs include on-going employee training, on-going maintenance and updating of security systems and internal processes, and monitoring customer feedback and complaint resolution processes.

D. Questions and concerns

If you have questions about this online privacy policy, or concerns regarding your Personal Information, please send us your question by emailing us or calling + 91 (44) 6651 1000 (not toll free).

V. CHANGES TO ONLINE PRIVACY POLICY

enGen Global Health reserves the right to change, modify, or update this online privacy policy at any time and for any reason. enGen Global Health will promptly post changes, modifications, and updates to its Consumer Platforms accordingly. Continued use of our Consumer Platforms constitutes your acceptance of the terms of our online privacy policy.

2016 enGen Global Health

Notes

¹enGen Global Health includes any wholly and majority-owned subsidiaries and affiliates. References to “us”, “we”, and “our” in this online privacy policy mean enGen Global Health.
²Non-affiliated Third Party refers to an entity that offers a tool, service, product, or forum that enGen Global Health may utilize, but there is no contractual relationship between enGen Global and the entity (e.g., Facebook, LinkedIn, Google Analytics).
³Service Providers means any vendor that has been contracted by enGen Global Health to provide a service or perform a function on behalf, or for the benefit, of enGen Global Health, including but not limited to technical support, system or account administration, or data analytics.