GDPR PRIVACY NOTICE- Pre- Screening Questionnaire

This Privacy Notice provides mandatory information as required under Articles 13 and 14 of the European General Data Protection Regulation (GDPR) regarding the transparency of personal data processing.

PERSONAL DATA

Article 4 of GDPR defines Personal Data and M/s. Nura through pre-screen questionnaire collects the following Personal Data about you (“Data Subject”).

• HEALTH DATA

PURPOSE OF COLLECTING YOUR PERSONAL DATA

M/s. Nura provides a pre-screening questionnaire and as part of the appointment process collects your (“Data Subject”) Personal Data for the purpose of enabling you (“Data Subject”) to proceed with your AI health screening booking

DATA CONTROLLER

M/s. Nura processes your (“Data Subject”) Personal Data as a Data Controller with the meaning as defined under Article 4 of GDPR. However, in these circumstances, M/s. Nura shall be acting under a “Legitimate Interest” to process the Personal Data for the purpose of providing you (“Data Subject”) a comprehensive AI health screening report and as part of the appointment process in relation to your (“Data Subject”) AI health screening booking with M/s. Nura. It is this purpose which forms the “Legal Basis” for the processing of your (“Data Subject”) Personal Data.

DATA PROCESSOR

M/s. Nura processes your (“Data Subject”) Personal Data as a Data Processor also with the meaning as defined under Article 4 of GDPR.

DATA PROTECTION OFFICER

M/s. Nura respects your (“Data Subject”) rights regarding the processing of your (“Data Subject”) Personal Information and provides the details of the Data Protection Officer who can be contacted in case of any concerns and questions regarding how M/s. Nura through pre-screening questionnaire processes your Personal Data or in case you (“Data Subject”) wish to exercise any of the rights provided under GDPR.

DATA PROTECTION OFFICER: MOHAN KUMAR

# C/o. Nura, 376, 100 Feet Rd, Indiranagar, HAL 2nd Stage, Bengaluru, Karnataka- 560038, India

EMAIL ID: dpo@nura.in

DATA PROTECTION PRINCIPLES – AS PER CHAPTER 3 – GDPR

M/s. Nura through pre-screening questionnaire has adopted the following principles to govern the collection and processing of your (“Data Subject”) Personal Data

1. • Your (“Data Subject”) Personal Data shall be processed lawfully, fairly and in a transparent manner
2. • Your (“Data Subject”) Personal Data shall be collected and processed only for the purpose of providing you a comprehensive AI health screening report and as part of the appointment process in relation to your AI health screening booking
3. • Your (“Data Subject”) Personal Data shall be processed only for the purposes as mentioned herein, except where such interests are overridden by the fundamental rights and your (“Data Subject”) freedom which shall always take precedent. However, in the event you (“Data Subject”) have provided any specific consent to such processing, then such consent shall be withdrawn at any time as mentioned in this privacy notice.

• THE RIGHT TO BE INFORMED

M/s. Nura through pre-screening questionnaire as a data controller, shall be obliged to provide
clear and transparent information about your data processing activities.

• THE RIGHT OF ACCESS

You (“Data Subject”) shall have the right to see what data is held about you by M/s. Nura which is specifically obtained from the pre-screening questionnaire (“Data Controller”) (Right to Access). You (“Data Subject”) may request a copy of your (“Data Subject”) Personal Data we (M/s. Nura) hold. Once we (M/s. Nura) have verified your identity, we (M/s. Nura) shall provide access to the Personal Data, we (M/s. Nura) hold about you (“Data Subject”). However, if any requests require any additional time, then we (M/s. Nura) shall inform you regarding the same.

• THE RIGHT TO RECTIFICATION

In the event, you (“Data Subject”) believe that we (M/s. Nura) hold inaccurate or incomplete Personal Information about you (“Data Subject”), you may exercise your right (“Data Subject Right”) to correct or complete or rectify the same. Further, this may be used with the right to restrict processing so as to ensure that incorrect / incomplete information is not processed until the same is rectified or corrected.

• THE RIGHT TO ERASURE (“RIGHT TO BE FORGOTTEN”)

You shall have the right to inform us (M/s. Nura) to delete or erase any of the Personal Data we (M/s. Nura through the pre-screening questionnaire) hold about you (“Data Subject”). In the event of such intimation, we (M/s. Nura) shall take all reasonable steps to ensure such deletion or erasure. Further, where no overriding legal basis or legitimate reason continues to exist for processing your (“Data Subject”) Personal Data, you (“Data Subject”) shall inform us to delete your Personal Data.

• THE RIGHT TO RESTRICT PROCESSING

You (“Data Subject”) shall have the right to inform us (M/s. Nura) to stop processing your Personal Data. However, in case of the following, you (“Data Subject”) may exercise the right to restrict processing

1. Accuracy of your Personal Data is contested
2.  Processing of your Personal Data is unlawful
3.  We (M/s. Nura) no longer require your Personal Data for processing
4.  The Right to object has been exercised and processing is restricted, pending a decision on the
   status of the processing

• THE RIGHT TO DATA PORTABILITY

You (“Data Subject”) may request your Personal Data be transferred to another controller or processor, which is to be provided in a commonly used and machine-readable format. This right shall be available in case the original processing was based on your (“Data Subject”) consent, the processing is by automated means and if such processing is based on the fulfilment of a contractual obligation as provided for under GDPR

• THE RIGHT TO OBJECT

You (“Data Subject”) shall have the right to object to the processing of your Personal Data by us (M/s. Nura)

• The processing is for the purpose of direct marketing
• The processing involves any automated decision making and profiling
•  The processing is for any other purpose other than for the purpose as outlined in this Privacy Notice

RETETION PERIOD

We (M/s. Nura) shall retain your Personal Data till such time we have addressed the basis for the pre- screening questionnaire

SHARING YOUR (“Data Subject”) PERSONAL DATA

M/s. Nura shall disclose your (“Data Subject”) Personal Data where required to do so by law, if subject to court order or subpoena or other legal proceeding or if M/s. Nura reasonably believes that such disclosure is necessary to

1. • Comply with the law
2. • Comply with the requests of law enforcement
3. • Enforce legal policies mentioned in pre-screening questionnaire
4. • Protect the security or integrity of M/s. Nura
5. • Exercise or protect the rights of M/s. Nura

HOW WE PROTECT YOUR (“Data Subject”) PERSONAL DATA

M/s. Nura has in place appropriate physical, electronic, technical, operational and managerial procedures and measures to protect your (“Data Subject”) Personal Data against loss, misuse and unauthorised access. M/s. Nura shall ensure that your Personal Data is encrypted using Secure Socket Layer (SSL) and is stored with industry-standard encryption.

Although M/s. Nura endeavours to safeguard your (“Data Subject”) Personal Data, transmissions made by means of Internet cannot be made absolutely secure M/s. Nura shall hold no liability for any acts, attacks, inadvertent disclosure beyond its control.

DATA PORTABILITY – CHAPTER 3 – GDPR

You (“Data Subject”) shall have the right to ask for any data provided by you to M/s. Nura through the pre-screening questionnaire (“Data Controller”) which may be provided in a structured, commonly used and machine-readable format. Further, you (“Data Subject”) shall have the right to have the data, which M/s. Nura holds about you (“Data Subject”) through the pre-screening questionnaire

DATA BREACH NOTIFICATION

M/s. Nura (“Data Controller”), shall notify you (“Data Subjects”) in case of becoming aware of data breach within 72 hours upon such awareness regarding such data breach under GDPR. Further, such data breach notification shall be sent via email to the email id registered or mentioned by you (“Data Subject”) at the time

PRIVACY BY DESIGN

M/s. Nura through pre-screening questionnaire shall implement appropriate technical and organisational measures in an effective manner to meet the requirement of GDPR as also protecting your (“Data Subject”) rights. M/s. Nura through pre-screening questionnaire shall hold and process the Personal Data absolutely necessary for completion of our obligations (data minimisation), as well as limiting the access to personal data to those needing to act out of processing

CONSENT – As per Article 6 and 9 of GDPR

Your (“Data Subject”) consent to this Privacy Notice is collected in accordance with Article 6 and 9 of GPDR.

OPT OUT / WITHDRAW CONSENT

In the event, you (“Data Subject”) intend to withdraw your consent provided to M/s. Nura through pre-screening questionnaire then you shall contact our Data Protection Officer and send an email (mentioned in this privacy notice) informing the same.