Privacy Notice for Independent Healy World Members (IHWM) – India 

Protecting your personal data is a high priority for us. We process your data in accordance with Indian privacy laws, including the Digital Personal Data Protection Act, 2023 along with the Information Technology Act, 2000, and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011. This privacy notice explains which personal data is processed by DHC Medical Services Pvt. Ltd. (“Healy,” “we,” “us”) as part of your membership as an Independent Healy World Member (IHWM).

Note: Please read this Privacy Notice along with the Privacy Policy and any other document issued by Healy in this regard, carefully before providing your consent. Together, these documents form an integrated part of our terms and govern the collection, use, and protection of your personal data. By consenting, you agree that these documents are applicable to you in full. 

1. Definitions:

Data Fiduciary  

The responsible entity for processing your personal data is: 

DHC Medical Services Pvt Ltd
B (Block), Building No. 38, First Floor, Shivalik, New Delhi – 110017
Email: contact.apac@healy.world 

DHC Medical Services Pvt. Ltd. coordinates data protection compliance to provide transparent information to our members. You may exercise your rights or raise any grievance with the designated Authorized Person, who serves as your main contact: 

Authorized Person
Email: dpo@healy.world 

Personal Data: refers to your data through which you can be identified or pertains to you. Personal Data includes but shall not be limited to your complete name, gender, date of birth, contact details, address, identity proof, bank account etc. For the purpose and usage of this policy, your “personal data” shall include the digital personal data.

Processing: this refers to any operation or set of operations, conducted wholly or partially by automated means, that involves handling digital personal data. This includes, but is not limited to, gathering, recording, organizing, structuring, storing, adapting, retrieving, utilizing, aligning, combining, indexing, sharing, transmitting, disseminating, limiting, erasing, or otherwise making data accessible or deleting it. 

2. Purposes and Legal Basis for Data Processing

We process your personal data in the context of your IHWM membership for the following purposes: 

2.1. Collecting Personal Data at Membership Initiation 

To set up an IHWM membership, we collect the following personal data: 

• First and last name
• Date of birth
• Gender
• Business information (if applicable)
• Address
• Mobile phone number
• Email address
• PAN number, Aadhaar number, or other identification number (if required)
• Bank account details for payment processing

This data processing is necessary to establish, manage, and conclude the business relationship in compliance with our contractual obligations and applicable Indian laws. 

Important Notice: Our services are intended only for individuals aged 18 and older. Healy does not process personal data of minors.

2.2. Collecting Personal Data During Membership 

Throughout your membership, we process your personal data for the following purposes: 

• Membership management
• Order processing and delivery
• Distribution of promotional and informational material (if you have consented)
• Conducting trainings, webinars, and events
• Payment processing and tax compliance
• Compliance with legal and regulatory requirements 

These processes are conducted in compliance with our contractual agreements with members and relevant Indian regulations.

2.3. iPayout 

For commission payments, we use the payment service provider iPayout. As an IHWM member, you enter into a separate agreement with iPayout, which acts as an independent data controller. Healy transmits only the data necessary for payment processing to iPayout, which includes: 

• Your full name
• Account details (iPayout account)
• PAN, Aadhaar, or other identification data (if required) 

Additionally, Healy processes specific data related to iPayout for identity verification and fraud prevention.

2.4. Use of Healy BackOffice 

Our BackOffice, provided by Jenkon, is used for managing IHWM memberships. Data processed includes: 

• Email address
• Password
• Sales and performance data
• Transaction data 

This processing is essential to grant you access to the BackOffice and manage your IHWM activities. Jenkon processes your data solely on behalf of Healy and in compliance with all applicable data protection laws. More information can be found at Jenkon Privacy Policy.

2.5. Use of ZOHO for Accounting 

Healy uses ZOHO for accounting and managing financial obligations, including invoicing and payment processing. We process personal data such as: 

• Name
• Contact information
• Payment details
• Transaction data 

ZOHO acts as a data processor and processes your data solely according to our instructions, ensuring appropriate data protection standards. For more details, visit ZOHO Privacy Policy.

2.6. Data Sharing for Network and Referral Purposes 

To support your business as an Independent Healy World Member, certain personal data is shared within the IHWM network for referral and genealogy purposes. This may include: 

• Your name
• Contact details
• Sales and performance statistics 

This processing fosters collaboration and business growth within the IHWM network. In addition, your first and last name, as well as your company name, are displayed in the online store when a customer enters your referral code. This allows for purchase tracking and commission calculation.

Your data shall be processed by Healy only for the purposes described in the preceding paragraphs.

3. CONSENT: 

By using/accessing our website and/or application, providing us with your personal data, or engaging with our services, you consent to the collection, use, processing, storage, and disclosure of your personal data in accordance with the terms of this notice. You reserve the right to withdraw your consent by writing to the Authorized Person. Once you choose to withdraw your consent, your personal data shall no longer be processed or retained by us, unless the same is to be utilized for permissible ground(s) under the applicable law.

Data Transfer Outside India 

Personal data may be transferred outside of India when using third-party providers such as iPayout, Jenkon, or ZOHO, which may be located outside India. For such transfers, we ensure that adequate safeguards are in place to protect your data, including standard contractual clauses, and take steps to ensure compliance with applicable Indian regulations on data transfer.

4. Security Measures

Healy protects your data through technical and organizational measures against unauthorized access, loss, and destruction. Our website is secured with SSL encryption to protect data during transmission, and our security measures are continuously updated to reflect the latest technology.

5. Recipients of Your Personal Data

Your personal data is only shared with third parties when necessary to fulfill contractual obligations or based on our legitimate interest. Third-party recipients may include hosting providers, payment processors, and logistics partners. Contracts with these third-party processors ensure that they maintain the required data protection standards.

6. Data Retention Period

Your personal data is stored as long as necessary to fulfill the purposes outlined or as required by legal retention periods in India. After this time, data is either deleted or anonymized.

7. Your Rights as a Data Subject

You have the following rights concerning your personal data: 

• Right to Access: Request a summary of your personal data, processing activities processed by us and the identity of other Data Processor(s) apart from the aforementioned, if applicable.
• Right to Rectification/Updating: Request correction or update of inaccurate or incomplete data.
• Right to Deletion: Request deletion of your data if no legal retention obligations apply.
• Right to Restrict Processing: Request restriction of your data processing.
• Right to Data Portability: Request transfer of your personal data in a structured, machine-readable format.
• Right to Object: Object to the processing of your data, particularly for direct marketing purposes
• Right to Withdraw Consent: Withdraw your consent to data processing at any time.
• Right to nominate: an individual of your own choice, to act on your behalf in the event of a death or an incapacity. For the purposes of this notice, “incapacity” means the inability to exercise your rights as a Data Subject due to unsoundness of mind or bodily infirmity.

9. Changes to This Privacy Notice

We reserve the right to modify this privacy notice as needed. Any changes will be posted on our website and in the BackOffice. 

Disclaimer: Healy will not be responsible for any incorrect, misleading, or fraudulent information that you may provide, nor will it be liable if you misrepresent yourself as another individual. In such cases, you agree to indemnify and hold Healy harmless from any claims, losses, damages, or liabilities arising due to the provision of incorrect information or misrepresentation on your part.

Effective Date:  April, 2025