Privacy Policy

1.Who We Are (Data Fiduciary)

For the purposes of the DPDP Act, Ketto Online Ventures Private Limited is the Data Fiduciary that determines the purpose and means of processing your personal data through the App. You can reach us, including our Grievance Officer, using the details at the end of this Policy.

2.The Data We Collect

We collect only the data needed to operate the App and deliver its features. The categories below map to what the App actually does.

2.1 Data you provide during onboarding

• Identity and contact: your name, gender, and phone number (in international format, defaulting to +91 for India).
• Medication details: your medication status (already on, just starting, or considering), medication type, dose, and frequency.
• Journey and injection data: your self-reported journey stage, last injection date, and injection site.
• Body measurements: your height, weight, and goal weight.
• Health context: health conditions you select (such as PCOS, diabetes, or hypertension) and GLP-1 side effects you have experienced.
• Goals and preferences: your stated goals and your decision, coaching, and logging style preferences.

2.2 Data you generate while using the App

• Dose and injection logs: recorded doses, injection sites used, and dose history.
• Meal and nutrition logs: meals added manually, by voice, by photo, or by barcode scan, and the resulting nutritional estimates.
• Lifestyle logs: water, activity, sleep, weight, and symptom entries, and your daily lifestyle score.
• Medical hub records: secondary medications and blood-work or lab results you choose to record.
• Moments: personal reflections you write in the Moments feature.

2.3 Data from connected services (with your permission)

• Health platform data: where you enable it, we read steps, weight, sleep, and activity data from Apple Health, Google Fit, or Health Connect. We read this data to power App features and do not write back to those platforms.
• Voice and image input: audio from voice meal logging and images from photo meal logging or barcode scanning, processed to identify food and estimate nutrition.

2.4 Data collected automatically

• Device and usage data: device type, operating system, app version, and in-app interaction data, used to operate, secure, and improve the App.
• Notification status: whether you have granted, denied, or deferred notification permissions.

3.How We Use Your Data

We use your personal data for the following purposes:

• to set up and personalise your experience during onboarding and thereafter;
• to provide core features, including dose reminders, injection-site rotation, the estimated medication-level curve, meal and lifestyle logging, and the lifestyle score;
• to generate insights, adaptation trends, and stage-appropriate personalisation cards;
• to process voice, photo, and barcode inputs for meal logging and nutrition estimation;
• to sync and display data from health platforms you have connected;
• to enable the coach and doctor connection feature when you choose to use it;
• to send you notifications and reminders you have opted into;
• to maintain the security, integrity, and performance of the App; and
• to comply with legal obligations and enforce our Terms.

We process your data on the basis of the consent you provide during onboarding and through in-app permissions, and, where applicable, for other lawful purposes permitted under the DPDP Act. You may withdraw your consent at any time, as described in Section 7.

4.Consent

We rely on your consent to process your personal data, including your health-related data, for the purposes described in this Policy. During onboarding and at relevant points in the App, we present clear requests for consent, for example before syncing health-platform data or enabling notifications. Your consent must be free, specific, informed, unconditional, and unambiguous, given through a clear affirmative action. You may decline optional permissions and still use the core features that do not depend on them.

You can withdraw your consent at any time, and doing so is as easy as giving it. Withdrawing consent does not affect the lawfulness of processing carried out before withdrawal, and may mean that certain features can no longer be provided to you. See Section 7 for how to exercise this right.

5.How We Share Your Data

We share data only in the limited circumstances below:

• Processors and service providers: trusted parties who process data on our behalf and under our instructions to deliver App features, such as cloud hosting, nutrition databases (including Open Food Facts), and AI processing providers for voice and photo features.
• Health platforms: Apple Health, Google Fit, or Health Connect, only to the extent needed to sync the data you have authorised.
• Support connection: when you use the coach or doctor connection feature, the information needed to route your call or message to the relevant support contact.
• Legal and safety: where required by law, regulation, legal process, or governmental request, or to protect the rights, safety, and property of Ketto, our users, or others.
• Business transfers: in connection with a merger, acquisition, restructuring, or sale of assets, subject to the protections described in this Policy.

6.Data Retention

We retain your personal data for as long as your account is active and as needed to provide the App’s features to you. If you delete your account, we will delete or irreversibly anonymise your personal data within a reasonable period, except where we are required to retain certain data to comply with legal obligations, resolve disputes, or enforce our agreements.

7.Your Rights Under the DPDP Act

Subject to the DPDP Act, you have the following rights in respect of your personal data:

• Access: to obtain a summary of the personal data we process about you and how it is processed.
• Correction and erasure: to correct or update inaccurate or incomplete data, and to request deletion of your data where it is no longer required.
• Withdraw consent: to withdraw any consent you have given, at any time and as easily as you gave it, without affecting processing carried out before withdrawal.
• Grievance redressal: to have your concerns addressed by our Grievance Officer.
• Nomination: to nominate another individual to exercise your rights in the event of your death or incapacity.

You can exercise several of these rights directly in the App, for example by editing your profile, managing permissions, or deleting your account. For anything else, contact us using the details in Section 12.

8.How We Protect Your Data

We apply reasonable technical and organisational safeguards to protect your personal data against unauthorised access, disclosure, alteration, and destruction. These include encryption of data in transit, access controls, and secure storage practices. No system is completely secure, and while we work to protect your data, we cannot guarantee absolute security.

9.Children’s Privacy

The App is intended only for individuals aged eighteen (18) and above. We do not knowingly collect personal data from children. If we learn that we have collected data from a child without appropriate consent, we will take steps to delete it promptly.

10.Storage and Processing Location

Your personal data is primarily stored and processed in India. Where limited processing takes place outside India through our service providers, we take steps to ensure that such processing is consistent with applicable Indian law and that your data continues to receive an adequate level of protection.

11.Changes to This Policy

We may update this Privacy Policy from time to time. Where changes are material, we will provide reasonable notice through the App or by other appropriate means and update the “Last updated” date above. We encourage you to review this Policy periodically.

12.Grievance Officer and Contact

If you have any questions, concerns, or complaints about this Privacy Policy or how we handle your personal data, you may contact our Grievance Officer: