Painalog & Didi’s Dosa LLC Privacy Policy

Effective Date of Current Policy: July 4th, 2024

1. Purpose

At Painalog, our mission is to empower humans to get freedom from pain, and live better. This Privacy Policy explains our practices regarding the collection, use and disclosure of information that we receive through our Services, and how you can opt out of a use or correct or change such information.

2. Scope

This Privacy Policy applies to Personal Information that is Processed by Painalog in the course of our business, including on Painalogs parent company Didi’s Dosa LLC’s websites (each a “Site”), mobile applications by or on behalf of Painalog, the “Services”). All individuals whose responsibilities include the Processing of Personal Information on behalf of Painalog are expected to protect that data by adherence to this Privacy Policy.

“Personal Information” is any information relating to an identified or identifiable natural person under applicable law (“Individual”). “Process” or “Processing” means any operation which is performed upon Personal Information, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction or as otherwise provided under applicable law.

3. TRANSPARENCY/NOTICE—TYPES of Personal Information We Collect and How We Use It

The categories of Personal Information we may collect (directly from you or from third party sources) and our privacy practices depend on the nature of the relationship you have with Painalog and the requirements of applicable law. Some of the ways that Painalog may collect Personal Information include:

• You may provide Personal Information directly to Painalog through interacting with the Services.
• As you navigate the Services, certain passive information may also be collected about your visit, including through cookies and similar technologies as described below.

We endeavor to collect only that information which is relevant for the purposes of Processing. Below are the ways we collect Personal Information and how we use it.

3.1 Types of Personal Information We Collect

Our primary goals in collecting information are to provide and improve our Services, to administer your use of the Services (including your account, if you are an account holder), and to enable you to enjoy and easily navigate our Services. Painalog collects Personal Information regarding its current, prospective, and former clients, customers, users, visitors, and guests, including:

• Information You Provide Directly to Us. When you use the Services or engage in certain activities, such as registering for an account with Painalog, requesting Services or information, or contacting us directly, we may ask you to provide some or all the following types of information:
  • Account Information. If you create an Account, we’ll collect certain Personal Information that can be used to identify you, such as your name, email address, postal address and phone number.
    • When you create an account, we may collect sensitive Personal Information, such as your name and email address.
    • If you create an account using your login credentials from your Facebook or Google account, we’ll be able to access and collect your name, email address, and other Personal Information that the privacy settings on your Facebook or Google account permit us to access.
  • Communications with Us. We may collect Personal Information from you such as email address, phone number or mailing address when you choose to request information about our Services, register for Painalog’s newsletter or a loyalty program that we may offer from time to time, request to receive customer or technical support, or otherwise communicate with us.
  • Automatic Data Collection. We may collect certain information automatically through our Services or other methods of web analysis, such as your Internet protocol (IP) address, cookie identifiers, mobile carrier, mobile advertising identifiers, MAC address, IMEI, Advertiser ID, and other device identifiers that are automatically assigned to your computer or device when you access the Internet, browser type and language, geo-location information, hardware type, operating system, Internet service provider, pages that you visit before and after using the Services, the date and time of your visit, the amount of time you spend on each page, information about the links you click and pages you view within the Services, and other actions taken through use of the Services such as
• Information Submitted Via Services. You agree that Painalog is free to use the content of any communications submitted by you via the Services, including any ideas, inventions, concepts, techniques, or know-how disclosed therein, for any purpose including developing, manufacturing, and/or marketing goods or Services. Painalog will not release your name or otherwise publicize the fact that you submitted materials or other information to us unless: (a) you grant us permission to do so; (b) we first send notice to you that the materials or other information you submit to a particular part of a Service will be published or otherwise used with your name on it; or (c) we are required to do so by law.
• Information from Other Sources. We may receive information about you from other sources, including through third party services and organizations to supplement information provided by you. For example, if you access our Services through a third party application, such as Apple App Store, Google Play App Store, Amazon App Store (together with any similar applications, “App Stores”) we may collect information about you from that third party application that you have made public via your privacy settings. Information we collect through App Stores may include your name, email. This supplemental information allows us to verify information that you have provided to Painalog and to enhance our ability to provide you with information about our business, products, and Services.

3.2 How Painalog Uses Your Information

We Process Personal Information about Individuals for a variety of business purposes, including:

• Fulfill our contract with you and provide you with our Services, such as:
  • Manage Individual information and accounts;
  • Provide access to certain areas, functionalities, and features of Painalog’s Services;
  • Contact you to answer requests for customer support or technical support;
• Analyze and improve our Services pursuant to our legitimate interest, such as:
  • Detect security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
  • Measure interest in Painalog’s Services and short-term, transient use, such as contextual customization of ads;
  • Undertake research for technological development and demonstration;
  • Improve, upgrade or enhance our Services or device;
  • Develop new products and Services;
  • Ensure internal quality control;
  • Verify Individual identity and preventing fraud;
  • Communicate about Individual accounts and activities on Painalog’s Services and systems, and, in Painalog’s discretion, changes to any Painalog policy;
  • Send email to the email address you provide to us to verify your account and for informational and operational purposes, such as account management, customer service, or system maintenance;
  • Debug to identify and repair errors that impair existing intended functionality;
  • Process payment for products or services purchased;
  • Process applications and transactions;
  • Prevent potentially prohibited or illegal activities;
  • Comply with our legal obligations, protecting your vital interest, or as may be required for the public good; and
  • Enforce our Terms.
• Marketing Painalog Products and Services. Painalog may use Personal Information to provide you with materials about offers, products, and Services that may be of interest, including new content or Services. Painalog may provide you with these materials by phone, postal mail, facsimile, or email, as permitted by applicable law. Such uses include:
  • To tailor content, advertisements, and offers;
  • To notify you about offers, products, and services that may be of interest to you;
  • To provide Services to you and our sponsors;
  • To audit interactions, transactions and other compliance activities;
  • For other purposes disclosed at the time that Individuals provide Personal Information; or
  • Otherwise with your consent.
• Research and Development. Painalog may use Personal Information to create de-identified information that we may use alone or in the aggregate with information obtained from other sources, in order to help us to optimally deliver our existing products and Services or develop new products and Services. From time to time, Painalog may perform research (online and offline) via surveys. 
• Direct Mail, Email and Outbound Telemarketing. Individuals who provide us with Personal Information, or whose Personal Information we obtain from Third Parties, may receive periodic emails, newsletters, mailings, or phone calls from us with information on Painalog’s or our business partners’ products and services or upcoming special offers/events we believe may be of interest. We offer the option to decline these communications at no cost to the Individual by following the instructions in Section 6 below.
• Services via Mobile Devices. Painalog may provide Services that are specifically designed to be compatible and used on mobile devices. Painalog will collect certain information that your mobile device sends when you use such Services, like a device identifier, user settings, location information, mobile carrier, and the operating system of your device. Mobile versions of Painalog’s Services may require that users log in with an account. In such cases, information about use of mobile versions of the Services may be associated with accounts. In addition, Painalog may enable Individuals to download an application, widget, or other tool that can be used on mobile or other computing devices. Some of these tools may store information on mobile or other devices. These tools may transmit Personal Information to Painalog to enable Individuals to access accounts and to enable Painalog to track use of these tools. Some of these tools may enable users to email reports and other information from the tool. Painalog may use information transmitted to Painalog to enhance these tools, to develop new tools, for quality improvement and as otherwise described in this Privacy Policy or in other notices Painalog provides.
• De-Identified and Aggregated Information Use. Painalog may use Personal Information and other information about you to create de-identified and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access Painalog’s Services, or other analyses we create. De-identified and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Services. De-identified or aggregated information is not Personal Information, and Painalog may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes. We may share this information within Painalog and with Third Parties for our or their purposes in a de-identified or aggregated form that is designed to prevent anyone from identifying you.
• Other Uses. Painalog may use Personal Information for which we have a legitimate interest, such as direct marketing, individual or market research, anti-fraud protection, or any other purpose disclosed to you at the time you provide Personal Information or with your consent.

3.3 Cookies, Pixel Tags/Web Beacons, Analytics Information, and Interest-Based Advertising

We, as well as Third Parties that provide content, advertising, or other functionality on our Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Services. We use Technologies that are essentially small data files placed on your computer, tablet, mobile phone, or other devices (referred to collectively as a “device”) that allow us to record certain pieces of information whenever you visit or interact with our sites, services, applications, messaging, and tools, and to recognize you across devices.

• Cookies. Cookies are small text files placed in visitors’ computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Site may not work properly.
• Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on the Site that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.
• Social Media Buttons or Widgets: Our Website includes social media features such as the Facebook “Like” button and LinkedIn (that might include widgets such as the share this button or other interactive mini-programs). These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. These social media features are either hosted by a Third Party or hosted directly on our Website. Your interactions with these features are governed by the privacy policy of the company providing it.
• Analytics. We may also use Google Analytics to collect information regarding visitor behavior and visitor demographics on some of our Services, and to develop website content. For more information about Google Analytics, please visit google.com/policies/privacy/partners/. You can opt out of Google’s collection and Processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout. For more information about Segment, please visit https://segment.com or contact us as provided below. To opt out of Mouseflow, please visit https://mouseflow.com/opt-out/.

Our uses of such Technologies fall into the following general categories:

• Operationally Necessary. We may use cookies, web beacons, or other similar technologies that are necessary to the operation of our sites, services, applications, and tools. This includes technologies that allow you access to our sites, services, applications, and tools; that are required to identify irregular site behavior, prevent fraudulent activity and improve security; or that allow you to make use of our functions such as shopping-carts, saved search, or similar functions;
• Performance Related. We may use cookies, web beacons, or other similar technologies to assess the performance of our websites, applications, services, and tools, including as part of our analytic practices to help us understand how our visitors use our websites, determine if you have interacted with our messaging, determine whether you have viewed an item or link, or to improve our website content, applications, services, or tools;
• Functionality Related. We may use cookies, web beacons, or other similar technologies that allow us to offer you enhanced functionality when accessing or using our sites, services, applications, or tools. This may include identifying you when you sign into our sites or keeping track of your specified preferences, interests, or past items viewed so that we may enhance the presentation of content on our sites;
• Advertising or Targeting Related. We may use first-party or third-party cookies and web beacons to deliver content, including ads relevant to your interests, on our sites or on third party sites. This includes using technologies to understand the usefulness to you of the advertisements and content that has been delivered to you, such as whether you have clicked on an advertisement.

If you would like to opt out of the Technologies we employ on our sites, services, applications, or tools, you may do so by blocking, deleting, or disabling them as your browser or device permits.

3.4 Cross-Device Tracking

Your browsing activity may be tracked across different websites and different devices or apps. For example, we may attempt to match your browsing activity on your mobile device with your browsing activity on your laptop. To do this our technology partners may share data, such as your browsing patterns, geo-location and device identifiers, and will match the information of the browser and devices that appear to be used by the same person.

3.5 THIRD-PARTY WEBSITES, SOCIAL MEDIA PLATFORMS, AND SOFTWARE DEVELOPMENT KITS

The Site may contain links to other websites and other websites may reference or link to our Site or other Services. These other domains and websites are not controlled by us, and Painalog does not endorse or make any representations about Third-Party websites or social media platforms. We encourage our users to read the privacy policies of each and every website and application with which they interact. We do not endorse, Screen or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.

We use third party software development kits (“SDKs”) or Application Programming Interfaces (“APIs”), as part of the functionality of our Services. APIs and SDKs may allow third parties including analytics and advertising partners to collect your Personal Information to provide analytics services and content that is more relevant to you.

3.6 Third-Party Payment Processing

When you make purchases through the Services, we Process your payments through a third-party application, including App Stores. The third-party application may collect certain financial information from you to Process a payment on behalf of Painalog, including your name, email address, address and other billing information.

4. Onward Transfer—Painalog May Disclose Your Information

4.1 Information We Share

We may share your information as described in this Privacy Policy and with the categories of third parties listed below. For a list of the categories of Personal Information we have disclosed about consumers for a business purpose in the past 12 months, please contact us as set forth below.

• We Use Vendors and Service Providers. We may share any information we receive with vendors and service providers. The types of service providers (processors) to whom we entrust Personal Information include service providers for: (i) provision of IT and related services; (ii) provision of information and services you have requested; (iii) payment processing; (iv) customer service activities; and (v) in connection with the provision of the Site. Painalog has executed appropriate contracts with the service providers that prohibit them from using or sharing Personal Information except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements.
• Business Partners. Painalog may share Personal Information with our business partners for our and our business partners’ internal business purposes or to provide you with a product or service that you have requested. Painalog may also provide Personal Information to business partners with whom we may jointly offer products or services, or whose products or services we believe may be of interest to you. In such cases, our business partner’s name will appear, along with Painalog. Painalog requires our affiliates and business partners to agree in writing to maintain the confidentiality and security of Personal Information they maintain on our behalf and not to use it for any purpose other than the purpose for which Painalog provided them.
• Marketing – Interest-Based Advertising and Third Party Marketing. Through our Services, Painalog may allow Third-Party advertising partners to set tracking tools (e.g., cookies) to collect information regarding your activities (e.g., your IP address, page(s) visited, time of day). We may also share such de-identified information as well as selected Personal Information (such as demographic information and past purchase history) we have collected with Third-Party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit non-Painalog related websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising.” We may allow access to other data collected by the Site to facilitate transmittal of information that may be useful, relevant, valuable or otherwise of interest to you. If you prefer that we do not share your Personal Information with Third-Party advertising partners, you may opt out of such sharing at no cost by following the instructions in Section 6 below.
• Disclosures to Protect Us or Others (e.g., as Required by Law and Similar Disclosures). We may access, preserve, and disclose your Personal Information, other Account information, and content if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) respond to your requests; (iii) protect yours’, ours’ or others’ rights, property, or safety; (iv) to enforce Painalog policies or contracts; (v) to collect amounts owed to Painalog; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) if we, in good faith, believe that disclosure is otherwise necessary or advisable. In addition, from time to time, server logs may be reviewed for security purposes – e.g., to detect unauthorized activity on the Services. In such cases, server log data containing IP addresses may be shared with law enforcement bodies in order that they may identify users in connection with their investigation of the unauthorized activities.
• Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction as permitted by law and/or contract. In such event, Painalog will endeavor to direct the transferee to use Personal Information in a manner that is consistent with the Privacy Policy in effect at the time such Personal Information was collected.

4.2 INTERNATIONAL Data Transfers

You agree that all Personal Information collected via or by Painalog may be transferred, Processed, and stored anywhere in the world, including but not limited to, the United States, the European Union, in the cloud, on our servers, on the servers of our affiliates or the servers of our service providers. Your Personal Information may be accessible to law enforcement or other authorities pursuant to a lawful request. By providing information to Painalog, you explicitly consent to the storage of your Personal Information in these locations.

5. Your Privacy Choices

5.1 General

You have the right to object to and opt out of certain uses and disclosures of your Personal Information. Where you have consented to Painalog’s Processing of your Personal Information or Sensitive Personal Information, you may withdraw that consent at any time and opt out of further Processing by contacting painalog.app@gmail.com. Even if you opt out, we may still collect and use non-Personal Information regarding your activities on our Sites and/or information from the advertisements on Third-Party websites for non-interest based advertising purposes, such as to determine the effectiveness of the advertisements.

5.2 Email and Telephone Communications

If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. We will process your request within a reasonable time after receipt. Note that you will continue to receive transaction-related emails regarding products or services you have requested. We may also send you certain non-promotional communications regarding Painalog and our Services and you will not be able to opt out of those communications (e.g., communications regarding updates to our Terms or this Privacy Policy).

5.3 Mobile devices

Painalog may occasionally send you push notifications through our mobile applications with notices that may be of interest to you. You may at any time opt out from receiving these types of communications by changing the settings on your mobile device. Painalog may also collect location-based information if you use our mobile applications. You may opt out of this collection by changing the settings on your mobile device.

5.5 “Do Not Track”

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

5.6 Cookies and Interest-Based Advertising

As noted above, you may stop or restrict the placement of cookies on your computer or remove them from your browser by adjusting your web browser preferences. Please note that cookie-based opt-outs are not effective on mobile applications. However, on many mobile devices, application users may opt out of certain mobile ads via their device settings. The online advertising industry also provides websites from which you may opt out of receiving targeted ads from our data partners and our other advertising partners that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, or http://www.youronlinechoices.eu/, and www.aboutads.info/choices/. To separately make choices for mobile apps on a mobile device, you can download DAA’s AppChoices application from your device’s app store. Alternatively, for some devices you may use your device’s platform controls in your settings to exercise choice.

To be clear, whether you are using our opt-out or an online industry opt-out, these cookie-based opt-outs must be performed on each device and browser that you wish to have opted-out. For example, if you have opted-out on your computer browser, that opt-out will not be effective on your mobile device. You must separately opt out on each device. Advertisements on Third-Party websites that contain the AdChoices link and that link to this Privacy Policy may have been directed to you based on anonymous, non-Personal Information collected by advertising partners over time and across websites. These advertisements provide a mechanism to opt out of the advertising partners’ use of this information for interest-based advertising purposes.

6. Your Privacy Rights

In accordance with applicable law, you may have the right to:

• Access Personal Data about you consistent with legal requirements. In addition, you may have the right in some cases to receive or have your electronic Personal Data transferred to another party.
• Request correction of your Personal Information where it is inaccurate or incomplete.  In some cases, we may provide self-service tools that enable you to update your Personal Information or we may refer you to the controller of your Personal Information who is able to make the correction.
• Request deletion of your Personal Information, subject to certain exceptions prescribed by law.
• Request restriction of or object to Processing of your Personal Information, including the right to opt in or opt out of the sale of your Personal Data to third parties, if applicable, where such requests are permitted by law.

If you would like to exercise any of these rights, contact us as set forth below. We will process such requests in accordance with applicable laws. To protect your privacy, we will take steps to verify your identity before fulfilling your request.

7. Data Retention

Painalog retains the Personal Information we receive as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

8. Security of Your Information

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us. We do not accept liability for unintentional disclosure.

By using the Site or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Site. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Site or sending an e-mail to you. You may have a legal right to receive this notice in writing.

9. International Users

By using the Site, Painalog will transfer data to the United States and globally. By choosing to visit the Site, utilize the Services or otherwise provide information to us, you agree that any dispute over privacy or the terms contained in this Privacy Policy will be governed by the laws of Vermont, United States and the adjudication of any disputes arising in connection with Painalog or the Site will be in accordance with the Terms.

If you are visiting from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your information to the United States and to Processing of your data globally. By providing your Personal Information, you consent to any transfer and Processing in accordance with this Policy.

10. Children’s Privacy

The Services are not directed to children under 18 years of age, and Painalog does not knowingly collect Personally Identifiable Information from children under 18 years of age. If you learn that your child has provided us with Personal Information without your consent, you may alert us at painalog.app@gmail.com. If we learn that we have collected any Personal Information from children under 18 years old, we will promptly take steps to delete such information and terminate the child’s Account.

11. Redress/Compliance and Accountability

If you have any questions about our privacy practices, this Privacy Policy, or, if you are located in the European Economic Area or UK, how to lodge a complaint with the appropriate authority, please contact Painalog by email at painalog.app@gmail.com. We will address your concerns and attempt to resolve any privacy issues in a timely manner.

12. Changes To Our Privacy Policy and Practices

We may revise this Privacy Policy from time to time at our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use the Services after the new Privacy Policy takes effect.

13. Contact Us

If you have any questions about our privacy practices or this privacy policy, or if you wish to submit a request to exercise your rights, please contact us at: painalog.app@gmail.com or by mail at:

Didi’s Dosa LLC

Attention: Painalog Privacy

83 Elmwood Ave, Barre VT 05641

We are headquartered in the United States.