Privacy Policy

PRIVACY POLICY

At Transcell Biosciences Pvt. Ltd. (hereinafter referred to as “Transcell” , “we” , “our”, “us” in singular, plural, capitalized and uncapitalized forms, including its successors and permitted assigns), protecting your personal data is one of our aspirations.

This privacy policy (“Privacy Policy”), enforceable from the Effective Date of November 15^th, 2025 (Fifteenth Date of November of the year Two Thousand and Twenty Five) governs the Processing of  Digital Personal Data in accordance with the Digital Personal Data Protection Act, 2023 (“DPDPA”) and the Digital Personal Data Protection Rules, 2025 (“DPDPR”). The terms ‘Personal Data’ and ‘Data’ are used interchangeably under this Privacy Policy (except, where any reference to anonymized/de-personalized data is construed, at our discretion). For the purposes of this Privacy Policy, unless otherwise noted, all references to Transcell include Transcell’s website being www.transcell.in (collectively, the “Platform”). By accessing and/or using our website/platform and/or products and/or our services, whether online and/or offline (hereinafter “Services” defined, extendable and modifiable at Transcell’s discretion), you consent to the data practices described in this Privacy Policy. You acknowledge and agree that your access and/or use of Transcell’s website/Platform and/or Services constitutes the consideration received by you to be bound contractually by this Privacy Policy.

For the purpose of this Privacy Policy, the following terms shall have the meanings ascribed to them below:

• “Data Fiduciary” means any person who alone or in conjunction with other persons determines the purpose and means of processing of personal data. For the purpose of this Privacy Policy, Transcell is the Data Fiduciary.
• “Data Principal” means the individual to whom the personal data relates.
• “Data Processor” means any person who processes personal data on behalf of a Data Fiduciary.
• “Personal Data” means any data about an individual who is identifiable by or in relation to such data.
• “Processing” means a wholly or partly automated operation or set of operations performed on digital personal data, including (without limitation) collection, recording, organization, structuring, storage, adaptation, retrieval, use, sharing, disclosure, restriction, erasure, or destruction.
• “You/you” or “Your/your” or “Yourself/yourself” in singular, plural, capitalized and uncapitalized form shall refer to the Data Principal and/or any individual/entity/user accessing and/or using our website and/or products and/or Platform and/or our Services .

APPLICABILITY

This Privacy Policy describes our policies and procedures on the collection, use, storage, and disclosure of your Personal Data and the rights you have with respect to your Personal Data.

CONSENT

• General Consent: You agree to provide your express, explicit, free, specific, informed, unconditional and unambiguous consent for Transcell to collect, process, store, share and purge the Personal Data submitted by you. Transcell updates this Privacy Policy from time to time. Your continued use of the Services and the Platform post the changes shall be deemed to be your acceptance of those changes made in this Privacy Policy.
• Consent by Minor: Transcell does not knowingly collect personally identifiable Personal Data from minors or disabled persons. If you are under the age of 18 (eighteen) or a person with disability, you must seek permission from a parent or guardian to use our Services and/or this Platform. In the event of discovery of incorrect or inadequate Personal Data, Transcell shall have the sole discretion to remove the Personal Data from its system and abstain you from using our Services and/or visiting the Platform without any notice.
• Notice: Before or at the time of requesting your consent, we will provide you with a notice that is clear, plain, and easily comprehensible. This notice will detail: (i) the specific Personal Data to be Processed and the defined purposes for such Processing; (ii) the manner in which you may exercise your rights; and (iii) the manner in which you may make a complaint to the Data Protection Board of India (“DPB”).
• Withdrawal of Consent: You have the right to withdraw your consent at any time with a comparable ease to the process through which consent was given. The consequences of such withdrawal shall be borne by you. Withdrawal will not affect the legality of Processing based on consent before its withdrawal. Upon withdrawal, we will cease and cause our Data Processors to cease Processing your Personal Data, unless such Processing is required or authorized under applicable law.

COLLECTION AND USE OF PERSONAL DATA

To provide you with our Services, we may collect and Process Personal Data (at our discretion) that you voluntarily provide to us. You acknowledge and agree that any Personal Data provided by you shall be true, correct, accurate, and up to date. You may be required to provide certain Personal Data when you elect to use our Services, which may include:

1. Umbilical Cord Blood Stem Cell Banking Services
2. Dental Stem Cell Banking Services and/or
3. TransGen ID

The Personal Data you share with us shall be kept strictly confidential and will be used only for the following specified purposes:

1. providing / administering services and contacting you in such regard;
2. detailed verification of your credentials / profile;
3. enabling your access to use the services, including delivering notifications like confirmations, alerts, updates, and one-time passwords;
4. publishing your feedback regarding our services;
5. responding to your queries, requests, and legitimate claims and resolving any issues;
6. keeping you informed or updating you on various services;
7. sending you information that may be of interest to you;
8. archiving / backing up Personal Data;
9. cooperating with government and regulatory authorities, judicial, quasi-judicial, or regulators in accordance with our legal obligations;
10. notifying you of any violation of any third-party rights, law, agreements, and/or policies;
11. sharing your data with our Data Processors to help perform statistical analysis;
12. conducting research, development and analysis to measure, maintain, protect, develop, expand and improve our business (defined at our discretion), complying with prescribed law.
13. Anonymizing your Personal Data and removing any personal identification/identifier from your data (effectively de-personalizing your original Personal Data); IN COMPLIANCE WITH PRESCRIBED LAW and for the pursuit/advancement/furtherance of the specified purposes for Personal Data collection and use contained in this Privacy Policy (referenced above and subsequently). 
14. monitoring aggregated metrics such as total number of visitors and traffic;
15. sending you marketing communications; and
16. sending you mails or contacting you for customer satisfaction surveys, market research, or promotional activities.

Transcell will take all reasonable measures as prescribed under law to prevent unauthorized access and misuse of your Personal Data. However, Transcell shall not be responsible for any such unauthorized access and misuse of your Personal Data by unauthorized persons despite having taken all such measures.

 SHARING OF YOUR PERSONAL DATA

1. We will not use your Personal Data for any purpose other than the specified purposes for which you have provided consent and for performing anonymized statistical analysis.
2. We may engage Data Processors to process Personal Data on our behalf under a valid contract.
3. We may share your Personal Data in the following instances:
   1. upon serving you a “prior notice”, to our successors or permitted assigns as permitted under law and/or to our subsidiary;
   2. upon taking your express written “prior consent” and on a “need to know” basis, with our business partners in furtherance of providing the services;
   3. upon your request to share Personal Data with identified third parties; and
   4. to any judicial, quasi-judicial, regulatory, statutory, and/or any government agency pursuant to any legal requirement.

Provided however that your consent shall not be required to process, share and/or use (in any manner/through any conduct ascertained by our exclusive discretion) any anonymized data.

DATA TRANSFER

Transcell may, from time to time, expand or reduce its business and this may involve the sale and/or transfer of control of all or part of Transcell. The Personal Data provided shall, where it is relevant to any part of the business so transferred, be transferred along with that and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use the Personal Data for the purposes for which it was originally given to Transcell.

Transcell may also disclose the Personal Data to a prospective purchaser of its business or any part of it. Data may be transferred to or from different jurisdictions and we will take steps to ensure that privacy is protected. 

We may transfer your Personal Data for Processing to countries or territories outside India, except to those countries restricted by the Central Government through notification. Such transfers will be conducted in compliance with the DPDPA, the DPDPR and any other applicable laws that provide for protection or restriction on such transfers.

Public Data It is clarified that any Personal Data that is made publicly available by you or by any other person who is under a legal obligation to make such data publicly available shall not be governed by this Privacy Policy. We shall not be responsible for any unauthorized use or misuse of such data.

DATA RETENTION AND ERASURE

1. We shall retain your Personal Data only for as long as necessary to fulfil the specified purpose for which it was collected. We shall erase your Personal Data upon the withdrawal of your consent or as soon as it is reasonable to assume that the specified purpose is no longer being served, whichever is earlier, unless retention is necessary for compliance with any applicable law.
2. Notwithstanding the above, we shall retain Personal Data, traffic data, and related processing logs for a minimum period of one year for purposes specified under the DPDPR, unless a different period is mandated by law.
3. We are committed to complying with applicable laws to ensure that all measures prescribed by law are taken for storing your Personal Data securely.
4. We have necessary policies and mechanisms in place to ensure that all Personal Data collected is either deleted or anonymized as soon as the specified purpose is fulfilled, unless mandated by law to be retained. Any data destroyed shall be disposed of in a manner that protects your privacy, in accordance with industry-standard practices deemed reasonable and acceptable by us.

YOUR RIGHTS AS A DATA PRINCIPAL

You have the following rights with respect to your Personal Data:

1. Right to Access Information: You have the right to obtain a summary of your Personal Data being Processed by us, the Processing activities undertaken, and the identities of all other Data Fiduciaries and Data Processors with whom your Personal Data has been shared.
2. Right to Correction and Erasure: You have the right to request the correction of inaccurate or misleading Personal Data, the completion of incomplete Personal Data, the updating of your Personal Data, and the erasure of your Personal Data that is no longer necessary for the specified purpose, unless retention is required by law.
3. Right of Grievance Redressal: You have the right to a readily available means of grievance redressal. You must exhaust this mechanism before approaching the DPB.
4. Right to Nominate: You have the right to nominate any other individual who, in the event of your death or incapacity, shall exercise your rights under the DPDPA

YOUR DUTIES AS A DATA PRINCIPAL

You have the following duties:

1. To comply with all applicable laws while exercising your rights.
2. Not to impersonate another person while providing your Personal Data.
3. Not to suppress any material information while providing your Personal Data for any document issued by the State.
4. Not to register a false or frivolous grievance or complaint with us or the DPB.
5. To furnish only verifiably authentic information while exercising your right to correction or erasure.

DATA SECURITY AND BREACH NOTIFICATION

1. Security Safeguards: We secure your Personal Data from unauthorized access, use, or disclosure by implementing reasonable security safeguards, including appropriate technical and organizational measures such as encryption, access controls, and regular audits, to prevent any Personal Data breach.
2. Personal Data Breach Notification: In the event of a Personal Data breach, we shall provide intimation of such breach to the DPB and each affected Data Principal in the form and manner prescribed under the DPDPR.
3. We may collect anonymous data from every visitor to the Platform to monitor traffic and fix bugs, which includes (without limitation) information like web requests, the data sent in response to such requests, Internet Protocol (“IP”) address, browser type, browser language, unique identifiers of the device through the application is accessed (i.e., VPN), information of Wi-Fi connectivity and timestamps. Log file information may be automatically reported by your browser, including (without limitation) web request, IP address, Analytical Code, Geo Stamp, browser type, browser language, referring/exit pages, Universal Resource Locators (“URLs”), platform type, number of clicks, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular page, the date and time of the web request. Such information is not associated with any Personal Data and is only tagged to a unique device identifier.

LIABILITY

Transcell shall in no manner be liable for any violation under this Privacy Policy, if the Personal Data,

1. is already available in public domain; or
2. is submitted by way of any illegal and unlawful means; or
3. is provided by any person who is incompetent under Section 11 of Indian Contract Act, 1872.

TRACKING, COOKIES AND COMMUNICATION

Tracking User Behavior: We may keep track of the websites and pages our users visit within the Platform to determine which services are the most popular. This data is used to deliver customized content and advertising to customers whose behavior indicates interest in a particular subject area.

Use of Cookies: Our Platform may use “cookies” to help personalize your online experience. A cookie is a text file placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. They are uniquely assigned to you and can only be read by a web server in the domain that issued the cookie.

Email Communications: From time to time, we may contact you via email to provide announcements, promotional offers, alerts, confirmations, surveys, and/or other general communication. If you would like to stop receiving marketing or promotional communications via email, you may opt-out by clicking the ‘UNSUBSCRIBE’ button.

EXTERNAL DATA STORAGE SITES

We may store your data on servers provided by third-party hosting vendors (Data Processors) with whom we have contracted.

CHANGES TO THIS PRIVACY POLICY

We reserve the right to change this Privacy Policy at any time. If we make any material changes, we will notify you by email or by posting a notice on our website 30 days prior to the changes taking effect.

Your continued use of the site and/or our Services after such modifications will constitute your:

1. acknowledgment of the modified Privacy Policy
2. agreement to abide and be bound by that Policy

GRIEVANCE REDRESSAL AND DISPUTE RESOLUTION

For any queries about the Processing of your Personal Data or to exercise your rights, or for any grievances related to our Services or the processing of your personal data, you may contact our designated Grievance Redressal Contact Person. We have established an effective mechanism to redress your grievances.

Raising a Complaint: All grievances should be addressed in writing to us at paparao@tran-scell.com. Alternatively, you may call us at +91 8985000888 during business hours (10 a.m. to 4 p.m., Monday through Friday, excluding public holidays). We will respond to your grievance within a reasonable timeframe, not exceeding 90 days from the date of its receipt.

• Name: Mr. Paparao.B [Grievance Redressal Contact Person Name]
• Email: paparao@tran-scell.com

You shall exhaust this mechanism before approaching the Data Protection Board.

Upon the mandatory exhaustion of this grievance redressal mechanism, all disputes arising from these Terms, may be exclusively adjudicated before the Civil Courts at Hyderabad, Telangana, unless otherwise required under applicable international law (with such requirement, ascertained at Transcell’s discretion) (subject to Transcell’s discretionarily qualified exclusive acceptance/rejection of dispute merit in writing, in every case).

ANTI-DISPARAGEMENT COVENANT (INTEGRAL TO/CONSTITUTING A PART OF THIS PRIVACY POLICY)

You agree that you shall not, under any circumstances, either during the use of Transcell’s Services or thereafter, intentionally and maliciously, disparage, criticize or denigrate the talents, skills, products, prospects, abilities, services, integrity, management or character of Transcell, or the senior management of Transcell in a manner that causes, in the sole and absolute discretion of Transcell, material harm to those persons who are engage with Transcell. In furtherance thereto, you shall not indulge in doing the following:

1. writing any unsolicited mails or spamming Transcell imputing or intending to cause annoyance, inconvenience, insult, injury, criminal intimidation, enmity, hatred or ill will, whether during or post the use of Transcell’s Services; and
2. approach press/presses or media (physical and/or digital) and/or post anything on social media in any form or manner that would defame or tarnish the image of Transcell and its agents, affiliates, clients or customers in any manner whatsoever.

You further agree that you will not, directly or indirectly, at any time after the date thereof contact any past, present or prospective investor, lender, customer, supplier, employee, agent or representative of Transcell with the intent, purpose or effect of intentionally and maliciously injuring the reputation of Transcell. You also agree that you shall not encourage another person to undertake such activities on your behalf or permit another through disclosure of information to that party to circumvent the foregoing prohibitions.

Without prejudice to any other rights or remedies of Transcell, you acknowledge and agree that your breach of this Anti-Disparagement covenant (integral to/constituting a part of this Privacy Policy) will cause Transcell grave and irreparable harm, loss, and injury for which damages would not be an adequate remedy for any breach of the provisions of this Anti-Disparagement covenant (integral to/constituting a part of this Privacy Policy) and that, accordingly, Transcell and/or its shareholders/limited liability partners, or any other securities holder of Transcell, shall have the right to an injunction, specific performance or any other equitable remedy for any threatened or actual breach of the provisions of this Anti-Disparagement covenant (integral to/constituting a part of this Privacy Policy) by you. You shall submit to orders and injunctions prayed and waive objections, if any, to such actions or proceedings or relief sought to the extent permitted by applicable Law.

INTELLECTUAL PROPERTY RIGHTS

Transcell’s “Intellectual Property” (“Intellectual Property/IP”) means and includes, without limitation: 

All existing or future patents, patent applications and patent disclosures, together with any reissuance, continuation, continuation-in-part, revision, extension, and re-examination thereof;  any trademark, service mark, logo, trade name, and corporate name, together with any translation, adaptation, derivation, and combination thereof and including any goodwill associated therewith, and any application, registration, and renewal in connection there with trademarks, business processes, domain names, works of authorship, designs, utility models, and any copyrightable work, any copyright, whether registered or unregistered, and any application, registration, and renewal in connection there with copyrights, whether registered or unregistered, which are owned by Transcell or acquired or developed by Transcell in the course of business (ascertained at Our discretion) or developed by you for Transcell and/or for the business (ascertained at Our discretion) of Transcell during the Term of your association/use, including, but not limited to moral rights and any other similar rights in any country, whether negotiable or not and also includes any applications for any of the foregoing and the right to apply for them in any part of the world; and

all processes, inventions (whether patentable or not, and whether or not reduced to practice), any improvements thereto, and any inventions, ideas, programs, codes, software including data and related documentation, databases, programming, codes and schemes, features, application, development work and/or promotion, advertising which in any way contributes/supports, tests, helps the business (as defined at Our discretion) of Transcell whether developed by you or outsourced by Transcell, all other software development tools, supplies, proprietary information, technology, etc., whether owned (or purported to be owned) or controlled or developed or under development, used or licensed (whether as a licensor or licensee) registered or unregistered; algorithms, discoveries, correspondence, trade secrets and confidential information (including any idea, research and development, know-how, formula, compositions, manufacturing and production process and technique, specification, customer and supplier lists, pricing and cost information, and Business and marketing plans and proposals; trade secrets, databases, know-how, creations or improvements upon, additions, or any research effort relating to any of the above, whether registrable or not. 

Transcell’s Intellectual Property additionally includes (without limitation) proprietary technologies (including without limitation, curated human bio samples, vault documentation, text, graphics, annotations, data, and software available through our Services ascertained at our discretion).

Any other content and proprietary right ascertained by Transcell; any copies and tangible embodiments thereof (in whatever form or medium); any license or sub license of an Intellectual Property right, whether exclusive or non-exclusive to Transcell, shall also be part of (without limitation) Transcell’s Intellectual Property.

You SHALL NOT (with reference to Our Intellectual Property) directly and/or indirectly through another/other persons/entity/entities:

• Copy, modify, distribute, reproduce, or create derivative works;
• Reverse engineer or attempt to extract the source code;
• Use our IP for competitive, commercial, or unauthorized purposes;
• Infringe upon our IP (through any manner/conduct deemed infringement at our discretion). 

All rights not expressly granted are reserved by Transcell. By mere virtue of this association and/or engagement and/or use with/of Transcell, you shall not be deemed to hold and/or be entitled to any Intellectual Property rights and/or any documents and/or access rights to any system. Post cessation of use, you are obligated to return of all such material (ascertained at our discretion) and abstain from any unauthorized access/use.

All the Intellectual Property and other ideas, techniques or principles relating to Transcell’s business (ascertained at our discretion) or otherwise, conceived (whether during business hours or not), discovered or made by you through the use of the Transcell’s Services, shall be promptly disclosed to Transcell. 

All Intellectual Property created, designed or developed by you during/through the use of Transcell’s Services will be regarded as having been made under a contract of service and being a ‘work for hire’ will belong to Transcell absolutely (unless explicitly discounted in writing by Transcell). You irrevocably and perpetually assign, transfer, convey, and deliver to Transcell, all worldwide rights, title, and interest to all the Intellectual Property in all the works developed by you through the use/engagement of Transcell’s Services with Transcell, free and clear of all encumbrances (unless explicitly discounted in writing by Transcell).  Without the express written permission of Transcell, you are not authorised to use, refer, or authorize the use of any of Transcell’s Intellectual Property, logos, marks, trademarks, trade names, etc. for any purpose whatsoever. You acknowledge and agree that the above restrictions are considered reasonable for the legitimate protection of the business and goodwill of Transcell.

If any of the Intellectual Property created, designed or developed by you is not deemed or does not qualify as work made for hire, you hereby assigns, transfers and convey to Transcell all of your right, title and interest in and to such Intellectual Property, including, without limitation, any and all copyrights, patent, trademark, technology and any other know-how, inventions, design rights, mask work rights, exhibition rights, registration rights and other proprietary rights thereto, and any and all renewals thereof (unless explicitly discounted in writing by Transcell). You shall execute and deliver such documents as Transcell may request in order to evidence Transcell’s ownership of the Intellectual Property, and to register or perfect Transcell’s ownership of the Intellectual Property (unless explicitly discounted in writing by Transcell).

Notwithstanding the provisions of section 19(4) of the Copyright Act, 1957, any assignment of Intellectual Property (unless explicitly discounted in writing by Transcell), in so far as it relates to copyrightable material will not lapse nor the rights transferred therein revert to you even if Transcell does not exercise the rights under the assignment within a period of 1 (one) year from the date of assignment. You hereby waive all rights to and shall not raise any objection or claims to the copyright board with respect to the assignment, pursuant to section 19A of the Copyright Act, 1957.

 INDEMNIFICATION AND DAMAGES

You agree to specifically indemnify (to the extent of Transcell’s exclusive discretionary acceptance), defend, and hold harmless Transcell, its directors, employees, and affiliates from any claims, damages, liabilities, or expenses arising from:

• Your use or misuse of Services (directly and/or indirectly through another/other persons/entity/entities);
• Your violation of this Privacy Policy (directly and/or indirectly through another/other persons/entity/entities);
• Regulatory breaches caused by you (directly and/or indirectly through another/other persons/entity/entities);
• Intellectual Property infringement caused by you (directly and/or indirectly through another/other persons/entity/entities);

REMEDIES

Without prejudice to any other rights or remedies of Transcell, you acknowledge and agree that a breach of this Privacy Policy will cause Transcell grave and irreparable harm, loss, and injury for which damages would not be an adequate remedy for any breach of this Privacy Policy and that, accordingly, Transcell and/or its shareholders/limited liability partners, or any other securities holder of Transcell, shall have the right to an injunction, specific performance or any other equitable remedy for any threatened or actual breach of this Privacy Policy. You shall submit to orders and injunctions prayed and waive objections, if any, to such actions or proceedings or relief sought to the extent permitted by applicable Law.

TERMINATION

Transcell may suspend or terminate access to our website and/or Services at any time for violations of this Policy or for operational, legal, or security reasons (ascertain at our discretion).

SEVERABILITY

If any part/clause/parts/clauses of this Privacy Policy is/are held or made invalid by a court and/or (public and/or private) tribunal decision, statute or rule, or otherwise rendered invalid, the remainder of this Privacy Policy shall not be affected thereby, and shall remain valid and enforceable under law. You shall not use Transcell’s/the Company’s website, products/platform, services (including without limitation) digital platforms, and all associated content ascertained at the Company’s exclusive discretion  (“Services” defined, extendable and modifiable at the Company’s discretion) to train, finetune, or evaluate any Artificial Intelligence (“AI”) and Machine Learning (“ML”) Models, without prior express clear and unambiguous written consent obtained from Transcell/the Company.

CONTACT INFORMATION

Transcell welcomes your questions or comments regarding this Privacy Policy at bank@tran-scell.com.