PRIVACY POLICY

JITO Chennai — Step Challenge Application

Last updated: 26 June 2026

1. Introduction

This Privacy Policy explains how JITO Chennai ("JITO Chennai", "we", "us", or "our") collects, uses, stores, shares, and protects your personal and sensitive personal data when you use the Step Challenge mobile application (the "App") and its associated web registration form and services (together, the "Service").

By registering for or using the Service, you consent to the collection and use of your information as described in this Policy. If you do not agree, please do not use the Service.

This Policy is published in compliance with the Information Technology Act, 2000 and the rules thereunder, and the Digital Personal Data Protection Act, 2023, as applicable.

2. Who we are

The Service is operated by JITO Chennai.

Registered address: G-135D, 3rd Phase, Spencer Plaza, Anna Road, Chennai, Tamil Nadu – 600002
Point of contact: Mr. Rajesh Shah
Email: chennaichapter@jito.org
Phone: +91-9382117738

JITO Chennai is the data fiduciary responsible for your personal data collected through the Service.

3. Information we collect

3.1 Information you provide

Identity and contact details: your name, mobile number, and email address provided at registration.
Team selection / referral information: the team you select or the referral group you belong to.

3.2 Health and fitness data

Step count data: your daily step counts, read from your device with your explicit permission through Apple HealthKit (on iOS) and Android Health Connect (on Android). We read only the step-count data required to operate the competition. We do not read any other health data.

We use this data solely to track your progress in the competition, rank you on individual and team leaderboards, and award medals when you cross the daily step target.

3.3 Identity verification data (where applicable)

Aadhaar image: Where a participant is not a verified JITO or JBN member and additional eligibility verification is required, we may request that you upload an image of your Aadhaar card for the limited purpose of verifying your eligibility to participate. The handling of this sensitive data is described in Section 7.

3.4 Technical and usage data

Device type, operating system version, and app usage events necessary to operate and secure the Service and to keep your step data synced.

3.5 Payment data

When you pay the registration / participation fee, payment is processed by our third-party payment gateway, Razorpay. We do not collect or store your card, UPI, bank account, or other financial credentials. These are handled directly by Razorpay under its own privacy policy.

4. How we use your information

We use your information to:

register you for the competition and authenticate your login via one-time password (OTP);
read and sync your daily step counts to operate leaderboards and award medals;
assign you to a team and manage team standings;
verify your eligibility to participate;
collect the one-time registration / participation fee;
send you reminders and notifications related to the competition (for example, prompts to open the app so your steps sync before a cut-off);
respond to your queries and provide support;
maintain the security and integrity of the competition, including detecting and acting on suspected manipulation of step data; and
comply with applicable law.

We process your personal data on the basis of the consent you provide when you register and when you grant health-data permission on your device. You may withdraw your consent at any time (see Section 10), though doing so may mean you can no longer participate in the competition.

6. How health-data permissions work

Step data is read from your device's platform health services — Apple HealthKit on iOS and Android Health Connect on Android — only after you grant permission. You may revoke this permission at any time through your device settings. If you revoke permission, the App can no longer record your steps and you may no longer be scored in the competition. We do not access manually entered steps where the platform allows us to exclude them, and the data source is recorded with each entry for integrity purposes.

7. Aadhaar and sensitive data handling

Where an Aadhaar image is collected for eligibility verification of non-JITO / non-JBN participants:

it is collected only with your explicit consent and only for the limited purpose of verifying your eligibility to participate;
it is not used for any other purpose, and is not shared with any third party except as required by law;
it is stored on secured servers located in India with access restricted to authorised personnel; and
it is deleted once eligibility verification is complete or once the competition concludes, whichever is earlier.

We encourage participants to mask any portion of the Aadhaar number not required for verification before uploading. We do not use the Aadhaar number for authentication with any government system.

We do not sell your personal data. We do not share your health or step data with any third party for advertising or marketing.

We share data only:

with Razorpay, our payment gateway, solely to process your registration / participation fee;
with service providers who host or operate the Service on our behalf, under confidentiality obligations and only to the extent necessary;
where required by law, regulation, court order, or governmental authority; and
to protect the rights, safety, or property of JITO Chennai or participants.

Contact details visible to other members through the "member connect" feature (call, WhatsApp, email) are shown only in accordance with your consent and privacy settings, and may be controlled or disabled by you.

9. Data storage, location, and retention

Location: All personal and health data collected through the Service is stored on servers located in India.
Step and competition data: Your step-count data and competition records are retained by JITO Chennai after the competition for record-keeping and audit purposes. You may request deletion as described in Section 10.
Aadhaar images: Deleted on completion of verification or conclusion of the competition, whichever is earlier (see Section 7).
We retain other personal data only for as long as necessary for the purposes set out in this Policy or as required by law.

10. Your rights

Subject to applicable law, you may:

access the personal data we hold about you;
request correction of inaccurate or incomplete data;
withdraw your consent to processing;
request deletion of your personal data; and
raise a grievance regarding the handling of your data.

To exercise any of these rights, contact our grievance contact in Section 12. We will respond within the timelines required by applicable law.

11. Security

We implement reasonable technical and organisational security measures to protect your data, including access controls, server-side computation of all rankings, and restricted access to sensitive data. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.

12. Grievance contact

If you have any questions, concerns, or complaints regarding this Policy or your data, please contact:

Name: Mr. Rajesh Shah
Organisation: JITO Chennai
Address: G-135D, 3rd Phase, Spencer Plaza, Anna Road, Chennai, Tamil Nadu – 600002
Email: chennaichapter@jito.org
Phone: +91-9382117738

13. Children

The Service is intended for users aged 18 and over. We do not knowingly collect data from anyone under 18. If we learn that we have collected data from a person under 18, we will delete it.

14. Medical disclaimer

This App is not a medical device and does not diagnose, treat, cure, or prevent any medical condition. Step counts are provided by your device's operating system and are estimates. Consult a qualified healthcare professional before beginning any physical activity programme.

15. Changes to this Policy

We may update this Policy from time to time. The "Last updated" date at the top reflects the most recent revision. Continued use of the Service after changes take effect constitutes acceptance of the revised Policy.

16. Governing law

This Policy is governed by the laws of India, and any disputes are subject to the exclusive jurisdiction of the courts at Chennai, Tamil Nadu.