The following Privacy Policy governs the online information collection practices of Plum Benefits Pvt Ltd (“Plum Benefits Pvt Ltd,” “we,” “us,” “our”). It outlines the types of information that we gather about you while you are using our website https://www.plumhq.com/ and the ways in which we use this information.

Plum Benefits Pvt Ltd is a web-based SaaS model which helps users who have created Plum accounts (“User(s)”) to share their content, such as information, files, and folders (“Content”) and analyze their pre-existing customers, prospective customers and third parties (“Viewer(s)”) on the basis of the content viewed by them. The viewers are the non-registered users of the web-services and product offerings (“Service(s)”) provided by Plum Benefits Pvt Ltd. We process your data in accordance with the applicable laws and regulations following industry best practices.

PURPOSE AND SCOPE

The Privacy Policy applies primarily to information that we collect online; however, it may apply to some of the data that you provide to us offline and/or through other means, as well (for example, via telephone or through the mail).

The Privacy Policy documents and describes the manner in which our organization collects information from all our users/viewers of our services. While providing our services on behalf of our registered users, we collect information related to viewers. The use of information collected on behalf of our users is governed primarily by our contract for the engagement with them and the privacy policies governing their organization. We are not accountable for the privacy policies and practices undertaken by our users or any other third parties.

HOW WE COLLECT DATA ABOUT YOU

We may collect different data from or about you depending on how you use the sites.

Data provided by registered users:

Account creation and login

When you create an account or login into your account, we collect personal information such as first name, last name, email address, and password.

Data provided by non-registered users:

Access pre-existing user’s content

When you request to view a pre-existing user’s content, the user may ask for personal information such as email address in order to open a Plum link. Plum Benefits Pvt Ltd collects and stores this personal information on behalf of its users.

When you provide this personal information, you do so in accordance with that user’s privacy practices and policies. Plum Benefits Pvt Ltd is not responsible for the privacy practices of its users and only processes this information in accordance with the applicable agreement it has with each user. For any issues pertaining to the processing of such personal information, please contact the user directly.

Data collected through automated means:

System data

Technical data about your computer or device, like device type, operating system, and IP address. This data helps us improve the delivery of our web pages and to measure traffic on the site.

The collection of data will also depend on the individual settings of your device and software. It is recommended to refer to the policies of your device manufacturer or software provider to learn about information they might share with us.

User Generated Data:

Account Creation, log in, and Usage as a viewer

We collect information and material (user-generated content) provided to us voluntarily by our users or the viewers to publish and process on our platform.

The user-generated content is inclusive of text, photos & videos associated with the accounts/ emails used to create an account with Plum Benefits Pvt Ltd or to access links as viewers.

Data Collected from Third Parties:

Integration of Third Parties such as Google Drive, OneDrive, Dropbox, Box

When you connect your existing cloud storage such as Google Drive, we access your account on your behalf to get information about your files & folders. When you choose to create a Google Drive file link in Plum, we download the selected file(s) from your Google Drive and store it in our own storage for reliability purposes.

Data collected during transactions:

Transactional Data

On the basis of types of services requested, Plum also collects information such as:

• type of service that has been requested
• order details for such a request
• payment & transaction information (such as merchant’s name, payment method, and chargeable amount for the service)
• date and time the service was provided
• For the purpose of promotion codes, name of the person associated with such a code will also be collected

Some information is collected through the use of cookies, web beacons, and tracking technologies. Please refer to the Cookie Policy for more details on the type of cookies being used.

Health and Fitness Data

If you choose to participate in step-based fitness challenges or similar wellness features made available through the Plum app, Plum may, with your permission, access and process limited health and fitness data from your device or from supported health and fitness platforms such as Android Health Connect.

Data we access

• Step count – the number of steps recorded by your device or connected fitness source.
• Walking or running distance – the distance recorded in connection with your walking, running or step activity.
• Active calories burned – energy expended during physical activity.
• Total calories burned – an estimate of overall calories burned, only where this is needed as a fallback or supporting metric for the step challenge feature.

We collect or access this data only when you choose to enable the step tracking and grant the required permissions through your device, the Plum app and/or Android Health Connect. You can choose not to grant these permissions, but this may limit your ability to participate in or use the related feature.

How we access this data

We access this data through the Android Health Connect platform and Apple Health, a secure on-device health data store provided by Google and Apple. Health Connect aggregates data from various sources (Google Fit, Samsung Health, fitness wearables, etc.) and provides unified access with user consent.

Legal basis for processing

• We collect or access your health and fitness data only when you choose to enable the step tracking and wellness feature and grant the required permissions through your device, the Plum app and/or Android Health Connect.
• You can withdraw these permissions at any time through the available permission settings. If you withdraw permission, Plum will stop collecting or syncing new health and fitness data for this feature, but you may not be able to use some or all parts of the step tracking and wellness feature.

THE TYPES OF INFORMATION WE COLLECT AND STORE

We may collect personal and sensitive personal information about you and store this information in connection with the provision and fulfillment of our services to you. Personal information may include:

• First name and last name
• Email address
• Location
• IP Address

Where you choose to use the step tracking and wellness feature, we may also collect and store the following health and fitness data, which we treat as sensitive personal information:

• Step count
• Walking or running distance
• Active calories burned
• Total calories burned

HOW WE USE YOUR PERSONAL INFORMATION

The above personal information may be used for the following purposes:

• To provide you with information about our offerings and/or our periodic newsletters;
• To respond to your requests;
• For creation or development of business intelligence or data analytics in relation to the offerings provided by us (for this purpose we may share the personal information with certain software or tools available online);
• To manage our relationship with you;
• For internal record keeping;
• To provide you with authorization to login and use your user account;
• To verify your identity;
• To maintain correct and up-to-date information about you;
• To identify you as a contracting party;
• To improve our website;
• To enable automated handling of the subscriptions;
• To otherwise be able to provide the services to you and
• To comply with our legal or statutory obligations.

Health and fitness data

We use the health and fitness data described above only to provide and support the step tracking and wellness feature you choose to use, including for:

• Step challenge participation: enabling you to participate in step tracking, wellness activities, step-based challenges or similar features that you choose to join.
• Progress tracking: displaying your daily, weekly, and overall step progress for the activity you join within the Plum app.
• Team leaderboards: aggregating team step totals for competitive rankings.
• Personal motivation: showing distance walked and estimated calories burned to help you stay active.
• Goal setting: allowing you to set and track daily step goals.

We use this data only to provide and support the step tracking and wellness feature you choose to use, including syncing your progress, troubleshooting, security, user support, feature-related reminders or nudges that you can manage or turn off, and competition-related reports for your employer or organisation, where applicable. We do not use this data for marketing.

What we do not do with this data

We do not:

• Sell your health or fitness data.
• Use your health or fitness data for advertising, targeted marketing or profiling for unrelated services.
• Share your health or fitness data with advertisers or data brokers.
• Use your health or fitness data for credit, insurance, claims, employment or other decisions that may affect you.
• Transfer health data outside the Plum ecosystem.
• Use your identifiable health or fitness data for research, analytics or commercial purposes, unless permitted by applicable law and, where required, with your consent.

WHO HAS ACCESS TO YOUR DATA WITHIN OUR ORGANIZATION?

Within our organization, access to your data is limited to those who require access to provide you with the products and services you purchase from us, to contact you, and to respond to your inquiries, including refund requests. Those staff members may be on teams, such as marketing, events, development, executive, and customer support. Employees only have access to relevant data to their team on a ‘need to know’ basis.

WHO DO WE SHARE YOUR DATA WITH OUTSIDE OUR ORGANIZATION, AND WHY?

Processors

We may use service providers & third parties for operating and improving the sites, to assisting with certain functions, such as payment processing, email transmission, conducting surveys or contests, data hosting, managing our ads, third-party solutions for marketing and analytics, and some aspects of our technical and customer support. We take measures to ensure that these service providers access, process, and store information about you only for the purposes we authorize, through the execution of Data Processing Agreements or Addenda.

Authorities

We may access, preserve, and disclose information about you to third parties, including the content of messages if we believe disclosure is in accordance with or required by applicable law, regulation, legal process, or audits. We may also disclose information about you if we believe that your actions are inconsistent with our Terms of Service or related guidelines and policies, or if necessary to protect the rights, property, or safety of, or prevent fraud or abuse of, the Company or others.

Transfer of business

If we (or our assets) are acquired, or if we go out of business, enter bankruptcy or go through some other change of control, personal information could be one of the assets transferred to or acquired by a third party.

Health and fitness data

We do not sell your health or fitness data, and we do not share it with advertisers or data brokers. Where applicable, we may share competition-related reports with your employer or organisation in connection with step-based challenges you choose to join.

International transfers

Your health and fitness data may be processed or stored in India or other countries where Plum or its authorised service providers operate, in accordance with applicable law. Where required, Plum will use appropriate contractual, technical and security safeguards for such processing or transfers.

WHY AND FOR HOW LONG DO WE STORE THE INFORMATION WE COLLECT FROM YOU?

We retain certain information collected from you while you are a member on the site, and in certain cases where you have deleted your account, for the following reasons:

• So that you can use our sites;
• To ensure that we do not communicate with you if you have asked us not to;
• To provide you with a refund, if entitled;
• To better understand the traffic to our sites so that we can provide all members with the best possible experience;
• To detect and prevent abuse of our sites, illegal activities and breaches of our Terms of Service; and
• To comply with applicable legal, tax or accounting requirements.

We retain user data for as long as necessary for the purposes described above. This means that we retain different categories of data for different periods of time depending on the type of data, the category of user to whom the data relates, and the purposes for which we collected the data.

Health and fitness data

• On-device: Health and fitness data may remain available on your device and in Android Health Connect depending on your device and app settings.
• App cache: The Plum app may temporarily store limited step data on your device to support the feature, including offline viewing, syncing and app performance.
• Plum systems: Plum may store limited step tracking and wellness data on its systems where needed to provide the feature, including challenge participation records, team leaderboard calculations, troubleshooting, security and support, and progress synchronization across devices.
• Retention period: We retain identifiable step tracking and wellness data only for as long as needed to provide the feature, meet legal or security requirements, resolve disputes, and maintain necessary records. After that, we delete, de-identify or aggregate the data in accordance with our retention practices.
• Account deletion: If you delete your Plum account or request deletion of applicable step tracking and wellness data, we will process the request in accordance with applicable law, verification requirements and Plum’s retention practices. This may include deleting, de-identifying or anonymising the data so that it is no longer reasonably identifiable to you.

SECURITY

We implement a variety of administrative, managerial, and technical security measures to help protect your personal information. Our Company has various internal control standards which relate specifically to the handling of personal information. These include certain controls to help safeguard the information we collect online. Our employees are trained to understand and comply with these controls, and we communicate our Privacy Policy practices and guidelines to our employees. However, while we strive to protect your personal information, you must also take steps to protect your information. We urge you to take every precaution to protect your personal information while you are on the Internet.

Health and fitness data

• We use appropriate technical and organisational safeguards designed to protect health and fitness data, including encryption in transit where applicable.
• Where health and fitness data is stored by Plum, we apply appropriate security measures designed to protect it from unauthorised access, disclosure, alteration or loss.
• Access is restricted to essential personnel who need it to provide, secure or support the feature.
• We may conduct security reviews, assessments or testing based on risk, system criticality and our internal security practices.
• We handle health and fitness data in accordance with applicable Indian privacy, data protection and information security laws.

YOUR RIGHTS UNDER THE GDPR

You have certain rights if you are within the EU. This includes

• Right to access. This right allows you to obtain a copy of your personal data, as well as other supplementary information.
• Right to restrict processing. You have the right to restrict the processing of your personal data in certain circumstances.
• Right to rectification. You have the right to have any incomplete or inaccurate information we hold about you corrected.
• Right to object to processing. The right to object allows you to stop or prevent us from processing your personal data. This right exists where we are relying on a legitimate interest as the legal basis for processing your personal Data. You also have the right to object where we are processing your personal data for direct marketing purposes.
• Right to erasure. You have the right to ask us to delete or remove personal data when the personal data is no longer necessary for the purpose which you originally collected or processed.
• Right to Data Portability. You have the right to receive the personal data which you have provided with us, in a way that is accessible and machine-readable.

To exercise your rights, you can contact us at [email protected]

YOUR RIGHTS UNDER THE CCPA

Users who are California residents have certain rights under the California Consumer Privacy Act (CCPA). Included in these rights are

• Right to know. You have the right to request to know more about the categories and specific pieces of personal information that we have collected about you and access a copy of your personal information.
• Right to deletion. You have the right to request the deletion of personal information that we have collected about you.
• Right to non-discrimination. If you choose to exercise any of your rights under CCPA, we will treat you like all other users. In other words, there is no penalty for exercising your rights under CCPA.
• Right to opt out. You have the right to opt out of the sale of your personal information. We do not sell personal information. However, the service providers we partner with (for example, our advertising partners) may use technology on the service that “sells” personal information as defined by the CCPA. If you wish to opt out of the use of your personal information for interest-based advertising purposes and these potential sales as defined under CCPA law, you may do so by following the instructions below. Please note that any opt-out is specific to the browser you use. You may need to opt-out on every browser that you use.

To exercise any of these rights under CCPA, please email [email protected]. To know more about your rights and how to exercise them visit our Data Subject Request Policy.

YOUR CONTROLS OVER HEALTH AND FITNESS DATA

In addition to the rights described above, you have the following controls over the health and fitness data used for the step tracking and wellness feature:

• Revoke access: You can manage or revoke Plum’s access to your health and fitness data through the permission settings available in your device settings for the Plum app.
• Data correction: You can correct your health or fitness data through the app or device from which the data was originally generated.
• Data export: You can export your health data directly from Health Connect.
• Deletion requests: Contact [email protected] to request deletion of health data from Plum servers.

OUR POLICY CONCERNING CHILDREN & THEIR DATA

Our Sites are not directed to children under the age of sixteen, and we do not knowingly collect personally identifiable information from children or distribute such information to third parties. We screen users who wish to provide personal information in order to prevent children from providing such information. If we become aware that we have inadvertently received personally identifiable information from a child, we will delete such information from our records. If we change our practices in the future, we will obtain prior, verifiable parental consent before collecting any personally identifiable information from children.

Health and fitness data

The step tracking and wellness feature is intended only for individuals who are 18 years of age or older. Plum does not knowingly collect health or fitness data from children through this feature. If Plum becomes aware that health or fitness data has been collected from a child through this feature, Plum will take appropriate steps in accordance with applicable law, which may include deleting the data, de-identifying it, disabling access to the feature, or taking other appropriate remedial action. If you believe a child has provided health or fitness data through the Plum app, please contact us at [email protected].

LINKS TO OTHER WEBSITES

Our sites may contain links to other websites that are not operated by us. If you click on a third-party link, you will be directed to that third-party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

Third parties are under no obligation to comply with this Privacy Policy with respect to personal data that you provide directly to those third parties or that those third parties collect for themselves. We do not control the third-party sites that may be accessible through our services. Thus, this Privacy Policy does not apply to information you provide to third-party sites or gathered by the third parties that operate them.

CHANGES TO THIS POLICY

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. If we make any material change/s to the Policy, we will notify you via email, through a notification posted on the Services, or as required by applicable law. You can see when the Policy was last updated by checking the date at the bottom of this page. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective from when they are posted on this page.

Where we update the section relating to the health and wellness data, we will, where required, provide appropriate notice of material changes and seek fresh consent if the change involves collecting a new category of health or fitness data, using the data for a new purpose, or materially changing how the data is processed.

CONTACT US

If you have any questions about this Privacy Policy, you can contact us at [email protected]

CONTACT DETAILS OF OUR DATA PROTECTION OFFICER

Sankaralingam T

Data Protection Officer

Plum Benefits Pvt Ltd

6th Floor, TOWER-B, Primeco Union City, Main Rd, Sadara Mangala Industrial Area, Thigalarapalya, Whitefield, Bengaluru, Karnataka 560048

E-mail : [email protected]

Last Updated: 11th June 2026