Privacy Policy
4.1 Who we are and what we collect
In line with the Digital Personal Data Protection Act, 2023 (DPDP Act), the rules made under it, and Section 43A of the Information Technology Act, 2000, Trunion acts as the Data Fiduciary. Trunion does not collect personal information directly through its website. All required information is collected separately through a secure Google Form.
The data collected is limited to information about the Elder and their health conditions, the Client's identity and contact details, immediate family contact details for emergencies, and billing details. Trunion also collects verification data about Caregivers ([Aadhaar Redacted], police verification and court-case checks).
4.2 Consent and purposes
Trunion collects and uses data only with the person's consent, given through the form, and only for these purposes: understanding care needs, matching Caregivers, coordinating medical emergencies, managing billing, and meeting legal duties. If the Elder cannot consent, the Client or the Elder's legal guardian gives consent on their behalf. For any minor, consent is taken from a parent or lawful guardian. Trunion does not sell personal data and does not use an Elder's health information for advertising.
4.3 Data sharing
Data is shared only with the assigned Caregiver and the Care Manager, on a strict need-to-know basis. In a medical emergency involving a threat to life, Trunion's team and Caregivers may share necessary health information with ambulance crews, hospitals and doctors without waiting for further consent. Trunion also uses service providers such as Google (for forms and storage), payment gateways and verification vendors, who process data only on Trunion's instructions. Some of these providers may store data outside India. Data may also be disclosed where the law or a court requires it.
4.4 Caregiver data
Caregiver verification data is used only to verify and place the Caregiver. It is visible only to authorised Trunion staff, is stored securely, and is kept for 3 years after the Caregiver's last placement unless the law requires longer.
4.5 Photos, videos and wellness reports
Trunion takes or shares photos and videos from community gatherings only with consent. Wellness reports are shared only with the Client and the people the Client names.
4.6 Security and data breaches
Trunion uses reasonable security safeguards, including access controls and confidentiality duties for staff. If a personal data breach occurs, Trunion will inform the Data Protection Board of India and the affected persons as the law requires.
4.7 Data retention
Elder and care records are stored securely for 3 years after the service ends. After that, Trunion erases or irreversibly anonymises the data, unless a law or a pending dispute requires it to be kept longer.
4.8 Your rights
You have the right to ask for a summary of your personal data, to have inaccurate data corrected, to have data you no longer need erased, to withdraw consent at any time, and to nominate another person to exercise your rights if you die or become incapable. Withdrawing consent may mean Trunion can no longer provide the services. To use these rights, email hello@trunion.in with "Privacy request" in the subject. Trunion responds within 30 days. You may complain to the Data Protection Board of India if your grievance is not resolved.
4.9 Cookies and changes
The website may use cookies or analytics tools to work properly. Trunion may update this policy by publishing the revised version on its website.
4.10 Grievance Officer
In accordance with the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021 and the DPDP Act, 2023, the Grievance Officer's details are:
- Name: Vijay Naregal
- Email: vijaynaregal@trunion.in
- Address: No 51, 5th Floor, 5th Main, Jayanagar 5th Block, Bengaluru, Karnataka 560041