Privacy Policy

This Privacy Policy explains how Gamira ("Gamira", "we", "us", or "our") collects, uses, stores, shares, processes, and protects information when you use our website, mobile application, AI companion, family dashboard, parent experience, devices, services, and related products (collectively, the "Service").

Gamira is an AI-powered aging-care platform. Because Gamira processes sensitive information — including health, wellness, voice, and emergency information — we encourage you to read this Privacy Policy carefully before using the Service.

By creating a Gamira account or using any part of the Service, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with the practices described here, please do not use the Service.

This policy is intended to provide a comprehensive explanation of our privacy practices. Specific Gamira products or features may provide additional notices that supplement this policy.

Who is responsible for your data

Gamira is operated by Lokesh Bhatt, an individual. The operator's postal address is available on request at bhattlokesh2004@gmail.com. Gamira is not currently a company or other separately registered legal entity. In this Privacy Policy, "Gamira", "we", "us" and "our" mean Lokesh Bhatt as the operator of the Service, who decides why and how your personal data is processed.

Gamira AI is an AI-first companion designed to help aging individuals live more independently while keeping their families connected and informed. Gamira combines voice interaction, health and wellness monitoring, medication reminders, care coordination, emergency assistance, and family connectivity into a unified platform.

Gamira is designed to support dignified aging. The AI companion can converse naturally, provide reminders, answer questions, share wellness information with authorized family members, and help coordinate care.

Gamira is not a medical device, a healthcare provider, a doctor, or a replacement for professional medical care, emergency services, or qualified healthcare professionals.

Gamira is a single application available on Android and iOS, designed to serve both aging parents and their family members through different roles, permissions, and experiences within the same app.

1. Family Administrator Role

The Family Administrator is an authorized family member — commonly the user's son or daughter, but not limited to that relationship — who has primary administrative control over the family account, including settings, permissions, data access, and account-level management. The Family Administrator accesses these controls through their family view within the Gamira app.

2. Parent Role

The Parent role is designed for the aging parent to interact with Gamira and use the care and companion features. The parent can converse with the AI companion, receive reminders, view health and wellness information, and trigger SOS when needed — all within the same Gamira app.

Both roles are part of the same Gamira application but provide different levels of access and control based on the user's role and permissions.

Gamira collects information necessary to provide the Service and information you choose to provide while using our features. Depending on how you use Gamira, this may include:

Account and Profile Information

Name, email address, phone number, profile photo, age or age range, account credentials, preferences, relationship information, and other information you provide when creating or managing your account.

Voice and Conversation Information

Gamira is designed around natural voice interaction. When you use voice features, we may process audio recordings, voice interactions, speech-to-text transcripts, conversation content, conversation history, AI-generated responses, and information derived from those interactions.

Health and Wellness Information

Depending on the features you use, Gamira may process information such as blood pressure, heart rate, oxygen levels, temperature, sleep information, activity levels, steps, wellness information, symptoms, and other health-related information you choose to provide or that is measured through connected devices.

Medication and Care Information

Medication names, schedules, reminder times, refill information, adherence information, care routines, and other details you provide to help manage reminders and care.

Location Information

If you enable location-related features, Gamira may collect or process location information to support emergency assistance, location sharing with trusted family members, safety features, or other features that require location.

Emergency Information

If you use emergency or SOS features, Gamira may process information required to notify your selected emergency contacts or family members, including your identity, location, emergency status, and relevant health or care information configured for emergency situations.

Device and Technical Information

Device type, operating system, app version, IP address, language, approximate region, network information, crash information, technical identifiers, and similar technical data collected automatically.

Usage Information

Information about how you interact with Gamira, including features used, settings, session information, preferences, errors, performance information, and usage patterns.

Payment Information

Paid plans are not on sale yet, so Gamira does not currently collect any payment information. Once they are on sale, the following applies. Paid plans are bought on the Gamira website through Razorpay's checkout. Your card, UPI or bank details are entered with Razorpay, not with Gamira. We receive information about the payment itself, such as the plan, amount, currency, status, date and a payment reference, and keep it as a record of your purchase. Nothing is bought inside the Gamira Android app.

We use information collected through Gamira for purposes including:

• Creating and managing your Gamira account.
• Providing the Gamira AI companion and voice interactions.
• Understanding and responding to your requests.
• Personalizing conversations and experiences.
• Remembering preferences and information you choose to save.
• Providing medication, appointment, and daily routine reminders.
• Supporting family and caregiver coordination.
• Providing health and wellness features.
• Providing emergency and SOS functionality.
• Generating reports for sharing with doctors and family.
• Sending notifications and important service messages.
• Improving reliability, performance, and usability.
• Detecting and preventing fraud, misuse, and security threats.
• Providing customer support.
• Maintaining and securing our systems and services.
• Training, developing, evaluating, and improving AI models, subject to applicable law and any legally required consent.
• Complying with applicable legal or security requirements.

Gamira is an AI-first product. Artificial intelligence is central to how Gamira understands conversations, provides responses, detects emergencies, personalizes experiences, and supports care.

Information collected, generated, or processed through Gamira MAY be used for:

• AI model training
• Model development
• Model evaluation
• Testing
• Safety improvement
• Research
• Quality assurance
• Product improvement
• Speech recognition improvement
• Voice system improvement
• Personalization
• Emergency detection improvement

Potentially relevant information used for these purposes may include:

• Voice recordings
• Voice interactions
• Speech-to-text transcripts
• Conversation history
• AI-generated responses
• User feedback
• Health information
• Wellness information
• Medication information
• Care information
• Appointment information
• Emergency information
• Technical information
• Usage information

This Privacy Policy transparently states that collected information may be used for AI training and improvement, subject to applicable law and any legally required consent or other legal requirements. We do not claim that Gamira only uses aggregated or anonymized data for AI training.

AI training does NOT mean public access to user data. Your information is not made publicly accessible through AI training. Access to information used in AI training is restricted and controlled.

Human Review

Where reasonably necessary for AI quality evaluation, safety evaluation, technical troubleshooting, security investigation, abuse prevention, customer support, or model improvement, authorized personnel or authorized service providers may review portions of information. Access is limited to information reasonably necessary for the relevant purpose.

Gamira takes reasonable technical and organizational measures to protect information against unauthorized access, loss, misuse, alteration, disclosure, or destruction. These measures may include:

• Encryption in transit (data encrypted while being transmitted between devices and servers)
• Encryption at rest (data encrypted while stored)
• Secure authentication mechanisms
• Role-based access controls
• Administrative permissions and restrictions
• Access controls and authorization systems
• Audit logging of access and actions
• Security monitoring and alerting
• Infrastructure security
• Backup and recovery controls
• Application security practices
• Network security controls

However, no internet-connected system can guarantee absolute security. No method of transmitting or storing information is completely secure. We cannot promise that Gamira is "100% secure" or that your information will never be compromised despite our efforts.

You can help protect your account by using strong passwords, enabling available security features, keeping your device updated, and only granting device permissions that are necessary for the features you use.

The family administrator role within the Gamira app provides administrative access to the family account. The Family Administrator can:

• View available parent information
• View available health and wellness data
• View medication and care information
• View reports
• Manage available account settings
• Manage doctor appointment functionality
• Initiate SOS
• Initiate account and data deletion

The Family Administrator has primary administrative control over the family account and is responsible for managing permissions, access, and settings appropriately.

The parent experience within the Gamira app is designed for the aging parent. Through their parent view in the app, the parent can:

• Use the AI companion
• View relevant information
• View health and wellness information made available by Gamira
• Receive reminders
• View care-related information
• Book or request doctor appointments where supported
• Trigger SOS

The parent experience within the Gamira app does NOT provide account-level deletion functionality. The parent cannot delete the complete Gamira family account or all associated data from their parent view. Account-level deletion is handled through the family administrator role.

SOS can be triggered by both parent users and family administrator users within the Gamira app.

When an SOS is triggered, the SOS workflow may process:

• Emergency event information
• Available location
• Account information
• Emergency contacts
• Relevant health and care information

Gamira cannot guarantee that SOS will always work. Possible failures include:

• No internet connection
• Mobile network failure
• Device failure
• Battery failure
• Missing or denied permissions (location, notifications, etc.)
• Third-party service failure
• Cloud or service outage
• Software errors
• Incorrect or outdated emergency contact information

Gamira is not a replacement for local emergency services. In a genuine emergency, always contact your local emergency services number directly. SOS is a supplementary tool that may help notify your family or emergency contacts, but it is not a substitute for professional emergency response.

A parent can book or request a doctor appointment through their parent view in the Gamira app where this feature is supported.

The Family Administrator can also book or manage doctor appointments through their family view in the Gamira app.

Doctor appointment features may vary by region, available integrations, and supported healthcare providers. Gamira does not guarantee that any specific doctor, clinic, or appointment slot will be available.

Doctors do NOT receive unrestricted direct access to the Gamira database or Family/Admin Dashboard.

Doctors do not automatically receive a Gamira account simply because the parent has an appointment scheduled.

The parent or Family/Admin Account Holder can choose to send a health or care report to a doctor. The report may contain:

• Health measurements
• Health trends
• Medication information
• Activity information
• Sleep information
• Care information
• Relevant appointment information
• Other selected information

The doctor only receives the information intentionally shared through the supported report-sharing mechanism. Doctors do not have ongoing access to Gamira data unless a user actively shares a new report.

Users may generate reports for the following periods where supported:

• 7 days
• 10 days
• 15 days
• 1 month
• Other supported periods

Reports may be available in the following formats:

• PDF
• CSV

Reports may be shared through:

• Email
• WhatsApp
• Other supported communication methods

After a report is sent through WhatsApp, email, or another external communication platform, the recipient controls their copy of the report. The recipient may download it, store it, forward it, screenshot it, or share it further. Gamira cannot control what the recipient does with the report after it has been shared externally.

Gamira may support sharing reports and information through external communication platforms such as email and WhatsApp.

When you share information through these platforms, the information leaves Gamira's controlled environment and enters the recipient's communication platform. Once shared:

• The recipient controls their copy of the information
• The recipient may download, store, forward, or screenshot the information
• The communication platform may process the information according to its own privacy policy
• Gamira cannot control or delete the recipient's copy
• Gamira cannot control how the communication platform handles the information

You should only share information with recipients you trust, and you should be aware that information shared through external communication platforms is subject to those platforms' own terms and privacy policies.

Gamira uses third-party companies to provide services necessary to operate the platform. These service providers may process information on our behalf. Service providers may include companies that provide:

• Cloud hosting and data storage
• AI processing and machine learning infrastructure
• Speech recognition and natural language processing
• Authentication and identity services
• Payment processing
• Notifications and messaging
• Customer support tools
• Analytics and performance monitoring
• Security and fraud prevention
• Maps and location services
• Communication services (email, WhatsApp integration)

The service providers we currently use include:

This list names our main providers and is not exhaustive; other providers in the categories above may also process information on our behalf.

We take reasonable steps to ensure that service providers processing information on our behalf are subject to appropriate contractual, technical, and organizational safeguards. Service providers are instructed to process information only as necessary to provide the services we request.

We do not sell personal information for money. We may share information in limited circumstances beyond service providers, including:

Business Transfers

If Gamira or substantially all of its assets are involved in a merger, acquisition, financing, restructuring, sale, or similar transaction, information may be transferred as part of that transaction, subject to appropriate protections. This includes transferring the operation of Gamira from Lokesh Bhatt to a company, if one is formed later, with any notice or consent that applicable law requires.

Legal and Security Reasons

We may disclose information when reasonably necessary to protect Gamira, our users, our systems, or others, investigate misuse or fraud, respond to valid legal requests, or comply with applicable legal requirements.

With People You Choose

Information may be shared with family members, caregivers, emergency contacts, doctors, or other people you authorize through Gamira's sharing and report features.

Different types of data may have different retention periods. Examples of data types with potentially different retention periods include:

• Voice recordings
• Transcripts
• Health data
• Account information
• Technical logs
• Security logs
• Reports

Gamira may retain information as reasonably necessary for:

• Service operation
• AI functionality
• AI improvement where permitted
• Security
• Fraud prevention
• Legal obligations
• Dispute resolution
• Business records
• Backups and recovery

When information is no longer reasonably required, we may delete, anonymize, or securely dispose of it, subject to technical, operational, or legal requirements. We do not claim zero data retention.

Letting a paid plan lapse, or moving to a smaller plan, does not by itself delete any of your data.

The family administrator role within the Gamira app provides account-level data deletion functionality. The authorized Family Administrator can initiate deletion of the Gamira account and associated data through the available deletion process.

The parent experience within the Gamira app does NOT provide account-level deletion functionality. The parent cannot delete the complete Gamira family account or all associated data from their parent view.

Deletion may not instantly remove information from:

• Backups
• Security logs
• Legally required records
• Systems where temporary retention is necessary

Deletion is handled according to applicable law and Gamira's retention requirements. Some information may need to be retained for security, operational, backup, fraud-prevention, or legal purposes even after account deletion is initiated.

Application-level permissions are different from statutory privacy rights. The features available in the Gamira app interface (such as whether a delete button exists in the parent view) do not define your legal rights.

If applicable law grants an individual a privacy right — such as the right to access, correct, or delete personal information — Gamira will process legally valid requests according to applicable law, even if the parent view does not contain a delete button or a specific feature for exercising that right.

We do not state that parents have absolutely no legal right to delete their personal data. We explain that the absence of a feature in the app interface does not eliminate your statutory privacy rights. You may exercise your legal rights by contacting us as described in the "Privacy Requests and Contact" section.

Gamira uses artificial intelligence to understand conversations, provide responses, personalize interactions, and support care coordination. AI responses are generated using automated systems.

AI can make mistakes. AI responses may occasionally be inaccurate, incomplete, outdated, or inappropriate. Users should not rely solely on an AI response when making important medical, emergency, financial, or safety decisions.

Always verify important information with qualified professionals. AI-generated health information, medication reminders, or care suggestions should be confirmed with a doctor or qualified healthcare provider.

Gamira is not a doctor, nurse, pharmacist, emergency service, medical professional, or healthcare provider. Gamira is not a medical device.

Gamira is not intended to replace professional medical care, diagnosis, treatment, or emergency services. The AI companion, health features, reminders, and reports are supportive tools only.

You should seek professional medical assistance whenever a situation requires medical evaluation, diagnosis, treatment, or emergency care. Do not delay or avoid seeking professional medical help because of information provided by Gamira.

For users in India, Gamira processes personal data in accordance with the Digital Personal Data Protection Act, 2023, and applicable rules and notifications issued thereunder (collectively, the "DPDP Framework").

Under the DPDP Framework, Lokesh Bhatt, as the operator of Gamira, acts as the Data Fiduciary. We provide this Privacy Policy as notice of our data processing practices. We process personal data for lawful and specified purposes, and we seek consent where required by applicable law.

We implement reasonable security safeguards to protect personal data. Data principals have rights under the DPDP Framework, which may include:

• The right to access information about personal data processed
• The right to correction and erasure
• The right to grievance redressal
• The right to nominate another individual to exercise rights in case of death or incapacity

Gamira will comply with applicable requirements under the DPDP Framework. If Gamira is formally designated or required by the Central Government to fulfill additional obligations as a Significant Data Fiduciary, Gamira will fulfill those additional obligations as required. We do not claim that Gamira is currently a registered Significant Data Fiduciary unless and until this is formally true.

Grievances may be raised with our Grievance Officer, whose contact details are in the "Grievance Officer" section below. We will address grievances in accordance with applicable requirements.

Where consent is required under Indian law, Gamira seeks consent for the collection and processing of personal data for specified purposes. Consent is sought in a clear and accessible manner.

You may withdraw consent at any time through available application settings or by contacting us. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.

This Privacy Policy serves as the primary notice of our data processing practices. Additional notices may be provided within specific Gamira features where appropriate.

For certain types of processing — such as processing sensitive personal data or processing data of children — additional consent or safeguards may apply as required by the DPDP Framework.

Under the DPDP Framework, Gamira has responsibilities regarding security incidents and personal data breaches. We maintain an internal process for identifying, investigating, containing, and responding to security incidents.

In the event of a personal data breach, Gamira will investigate the incident promptly and will notify affected data principals and the Data Protection Board of India within the timeframes and in the manner required by applicable law.

We do not promise a universal 72-hour breach notification deadline. Notification timelines are governed by applicable legal requirements, and Gamira will comply with the specific timelines mandated by the DPDP Framework and applicable rules.

For users in the European Union and the European Economic Area ("EU/EEA"), Gamira processes personal data in accordance with the General Data Protection Regulation (GDPR).

Under the GDPR, users have the following rights, subject to applicable conditions:

• Right of access to your personal data
• Right to rectification of inaccurate personal data
• Right to erasure ("right to be forgotten")
• Right to restriction of processing
• Right to data portability
• Right to object to processing
• Right to withdraw consent where consent was given
• Rights related to automated decision-making and profiling

Health data is considered a special category of personal data under Article 9 of the GDPR and receives additional protection. Gamira processes health data only where an appropriate legal basis applies, such as explicit consent or other permitted grounds.

To exercise your GDPR rights, please contact us as described in the "Privacy Requests and Contact" section. We will respond to valid requests in accordance with applicable legal requirements.

Lokesh Bhatt, as the operator of Gamira, is the data controller for personal data processed through the Service, unless otherwise specified.

We do not claim that all European data physically remains in Europe. Information collected through Gamira may be processed or stored in countries outside the EU/EEA, including India and the United States, where our service providers and infrastructure are located.

When personal data is transferred outside the EU/EEA, appropriate legal mechanisms are used to ensure the transfer complies with the GDPR. These mechanisms may include:

• Standard Contractual Clauses (SCCs) approved by the European Commission
• Adequacy decisions by the European Commission for specific countries
• Other appropriate safeguards recognized under the GDPR
• Explicit consent to the transfer where applicable

If you have questions about the specific safeguards used for international transfers, please contact us.

For users in the United States, Gamira processes personal data in accordance with applicable federal and state privacy laws. The United States does not have a single comprehensive federal privacy law. Instead, privacy is regulated through a combination of sector-specific laws, state laws, and consumer protection regulations.

Gamira provides this Privacy Policy as notice of its data processing practices. Users in the United States may have additional rights under state privacy laws, as described in the "United States — State Privacy Laws" section.

The Health Insurance Portability and Accountability Act (HIPAA) applies to "covered entities" (such as healthcare providers and health plans) and their "business associates." HIPAA applicability depends on whether Gamira is operating as a covered entity or business associate in a relevant relationship.

We do NOT claim that Gamira is "HIPAA certified." We do NOT automatically claim that Gamira is "HIPAA compliant." HIPAA does not have a formal certification process, and HIPAA compliance depends on the specific legal relationship and context.

If Gamira operates as a business associate of a covered entity in a specific arrangement, appropriate Business Associate Agreements (BAAs) and HIPAA safeguards may apply to that arrangement. Users should consult with their healthcare provider or legal advisor to understand whether HIPAA applies to their specific use of Gamira.

Even where HIPAA does not apply, consumer health apps may have obligations under Federal Trade Commission requirements and state privacy laws, as described in the following sections.

The Federal Trade Commission Act ("FTC Act") prohibits unfair or deceptive acts or practices. Under the FTC Act, the Federal Trade Commission can take action against companies that make misleading privacy or security claims or that fail to protect consumer data.

Gamira is subject to the FTC Act. This means we must accurately represent our privacy and security practices, and we must take reasonable measures to protect consumer data. The statements in this Privacy Policy are intended to accurately reflect our practices.

Consumer health apps that are not covered by HIPAA may still have obligations under the FTC Act, including the FTC Health Breach Notification Rule.

The FTC Health Breach Notification Rule requires certain entities not covered by HIPAA — including vendors of personal health records and related entities — to notify consumers, the FTC, and in some cases the media, in the event of a breach of identifiable health information.

If Gamira is subject to the FTC Health Breach Notification Rule in a specific context, Gamira will provide required notifications in the event of a qualifying breach, in accordance with applicable legal requirements.

We do not promise a universal 72-hour breach notification deadline. Notification timelines are governed by the specific legal requirements that apply to each situation.

Various U.S. state privacy laws may provide additional rights depending on the user's state of residence and whether the law applies. Examples include the California Consumer Privacy Act (CCPA), the California Privacy Rights Act (CPRA), the Virginia Consumer Data Protection Act (VCDPA), the Colorado Privacy Act (CPA), the Connecticut Data Privacy Act (CTDPA), and other state laws.

Depending on your state and the applicability of the law, you may have rights such as:

• The right to know what personal information is collected
• The right to access personal information
• The right to correct personal information
• The right to delete personal information
• The right to opt out of the sale or sharing of personal information
• The right to limit the use of sensitive personal information
• The right to non-discrimination for exercising privacy rights

Gamira does not sell personal information for money. To exercise your state privacy rights, please contact us as described in the "Privacy Requests and Contact" section.

Gamira is primarily designed for adults and aging parents. It is not intended to be directed toward children, and we do not knowingly collect personal information from children for independent use.

If you believe that a child has provided personal information to us without appropriate authorization, please contact us so that we can review and take appropriate action.

Our website and services may use cookies, analytics technologies, local storage, pixels, or similar technologies for the following purposes:

• Essential cookies (required for the website to function)
• Authentication and session functionality
• Security (including fraud prevention and account protection)
• Preferences (remembering your settings and choices)
• Analytics (understanding how the website is used)
• Performance monitoring
• Error detection and debugging

Marketing and non-essential tracking technologies are subject to consent where required by applicable law. You may be able to manage certain browser or device settings to control cookies and similar technologies.

Some technologies may be provided by third-party service providers and may be subject to their own privacy policies.

When you share reports or information through external communication platforms such as WhatsApp or email, the data is transmitted through those platforms and is subject to their own terms, privacy policies, and security practices.

Once information is sent through an external communication platform:

• The recipient controls their copy of the information
• The recipient may download, store, forward, or screenshot the information
• The communication platform may process, store, or retain the information according to its own policies
• Gamira cannot control, access, or delete the recipient's copy
• Gamira cannot control how the communication platform handles the information

You are responsible for ensuring that you share information only with appropriate recipients and through appropriate channels.

Gamira may be used by people in different countries and regions. Depending on how our services are operated, information may be processed or stored in locations different from where you live, including India, the United States, and other countries where our service providers and infrastructure are located.

By using Gamira, you understand that information may be processed through the systems and service providers required to operate the service, which may be located in different countries.

We take reasonable steps to ensure that international processing is subject to appropriate safeguards, as described in the relevant regional sections of this Privacy Policy.

Gamira maintains an internal process for identifying, investigating, containing, and responding to security incidents. Gamira will investigate suspected incidents promptly and will notify users, regulators, authorities, or other relevant parties within the timeframes and manner required by applicable law. Where appropriate, Gamira may notify affected individuals earlier than the legally required deadline.

We do not promise a universal 72-hour breach notification deadline. Different laws may impose different notification timelines, and Gamira will comply with the specific timelines mandated by each applicable legal requirement.

Our security incident response process may include:

• Detection and identification of potential incidents
• Investigation and assessment of scope and impact
• Containment and mitigation measures
• Notification to affected parties as required by law
• Remediation and post-incident review
• Documentation and improvement of security measures

We may update this Privacy Policy from time to time as Gamira, technology, features, legal requirements, or our privacy practices change.

When we make changes, we may update the "Last Updated" date at the top of this policy. If changes are significant, we may provide additional notice through the Gamira website, application, or other appropriate communication channels.

We encourage you to review this Privacy Policy periodically to stay informed about how we collect, use, and protect your information.

If you have questions about this Privacy Policy, your information, or Gamira's privacy practices — or if you wish to exercise your privacy rights — you can contact us.

To submit a privacy request (such as access, correction, deletion, or objection), please email us with sufficient information to identify your account. We will respond to valid requests in accordance with applicable legal requirements.

For grievances under the DPDP Framework, you can also contact our Grievance Officer directly, as described in the next section.

In accordance with the Digital Personal Data Protection Act, 2023 and the rules made under it, you may contact our Grievance Officer with any complaint or question about how your personal data is processed, or to exercise your rights as a data principal.

We will acknowledge and respond to your grievance within the period required by applicable law.

If you are not satisfied with our response, you may approach the Data Protection Board of India, as provided under the Digital Personal Data Protection Act, 2023.

The following summary highlights key aspects of how Gamira handles your information. This summary does not replace the full Privacy Policy above. Please read the complete policy for full details.

By using Gamira, you trust us with information that can be important to you and your family. We are committed to handling that information responsibly and building Gamira with privacy, security, transparency, and user control in mind.

This Privacy Policy is intended to be transparent and comprehensive. If any part of this policy is unclear, please contact us for clarification.

Gamira is built with care for dignified aging. We will continue to work to earn the trust you place in us.