PRIVACY POLICY

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VRAH Telehealth Services Private Limited (“us”, “we”, or “VRA Health”, which also includes its affiliates) publisher world wide web as well as the software and applications provided by VRA Health, including but not limited to the mobile application VRA Health, and the software and applications of the brand names VRA Health – Doctors Online (together with the Website, referred to as the “Services”).

This privacy policy ("Privacy Policy") explains how we collect, use, share, disclose and protect Personal information about the Users of the Services, including the Practitioners and the visitors of Website (jointly and severally referred to as “you” or “Users” in this Privacy Policy). We created this Privacy Policy to demonstrate our commitment to the protection of your privacy and your personal information. Your use of and access to the Services is subject to this Privacy Policy and our Terms of Use. Any capitalized term used but not defined in this Privacy Policy shall have the meaning attributed to it in our Terms of Use.

BY USING THE SERVICES OR BY OTHERWISE GIVING US YOUR INFORMATION, YOU WILL BE DEEMED TO HAVE READ, UNDERSTOOD AND AGREED TO THE PRACTICES AND POLICIES OUTLINED IN THIS PRIVACY POLICY AND AGREE TO BE BOUND BY THE PRIVACY POLICY. YOU HEREBY CONSENT TO OUR COLLECTION, USE AND SHARING, DISCLOSURE OF YOUR INFORMATION AS DESCRIBED IN THIS PRIVACY POLICY. WE RESERVE THE RIGHT TO CHANGE, MODIFY, ADD OR DELETE PORTIONS OF THE TERMS OF THIS PRIVACY POLICY, AT OUR SOLE DISCRETION, AT ANY TIME. IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY AT ANY TIME, DO NOT USE ANY OF THE SERVICES OR GIVE US ANY OF YOUR INFORMATION. IF YOU USE THE SERVICES ON BEHALF OF SOMEONE ELSE (SUCH AS YOUR CHILD) OR AN ENTITY (SUCH AS YOUR EMPLOYER), YOU REPRESENT THAT YOU ARE AUTHORISED BY SUCH INDIVIDUAL OR ENTITY TO (I) ACCEPT THIS PRIVACY POLICY ON SUCH INDIVIDUAL’S OR ENTITY’S BEHALF, AND (II) CONSENT ON BEHALF OF SUCH INDIVIDUAL OR ENTITY TO OUR COLLECTION, USE AND DISCLOSURE OF SUCH INDIVIDUAL’S OR ENTITY’S INFORMATION AS DESCRIBED IN THIS PRIVACY POLICY.


  • 1. WHY THIS PRIVACY POLICY?

    This Privacy Policy is published in compliance with, inter alia:
     
    • Section 43A of the Information Technology Act, 2000.
    • Regulation 4 of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011 (the “SPI Rules”).
    • Regulation 3(1) of the Information Technology (Intermediaries Guidelines) Rules, 2011.
  • This Privacy Policy states the following:
     
    • The type of information collected from the Users, including Personal Information (as defined in paragraph 2 below) and Sensitive Personal Data or Information (as defined in paragraph 2 below) relating to an individual.
    • The purpose, means and modes of collection, usage, processing, retention, and destruction of such information; and
    • How and to whom VRA Health will disclose such information.
  • 2. COLLECTION OF PERSONAL INFORMATION

    Generally some of the Services require us to know who you are so that we can best meet your needs. When you access the Services, or through any interaction with us via emails, telephone calls or other correspondence, we may ask you to voluntarily provide us with certain information that personally identifies you or could be used to personally identify you. You hereby consent to the collection of such information by VRA Health. Without prejudice to the generality of the above, information collected by us from you may include (but is not limited to) the following:
     
    • contact data (such as your email address and phone number).
    • demographic data (such as your gender, your date of birth and your pin code).
    • data regarding your usage of the services and history of the appointments made by or with you through the use of Services.
    • insurance data (such as your insurance carrier and insurance plan).
    • Medical history and medical treatment details that you voluntarily choose to provide us/to consulting doctor for the consultations and treatment.
    • other information that you voluntarily choose to provide to us (such as information shared by you with us through emails or letters or through the chat and file sharing option of our application.
  • The information collected from you by VRA Health may constitute ‘personal information’ or ‘sensitive personal data or information’ under the SPI Rules.

    “Personal Information” is defined under the SPI Rules to mean any information that relates to a natural person, which, either directly or indirectly, in combination with other information available or likely to be available to a body corporate, is capable of identifying such person.

    The SPI Rules further define “Sensitive Personal Data or Information” of a person to mean personal information about that person relating to:
     
    • passwords.
    • financial information such as bank accounts, credit and debit card details or other payment instrument details.
    • physical, physiological, and mental health condition.
    • sexual orientation.
    • medical records and history.
    • biometric information.
    • information received by body corporate under lawful contract or otherwise.
    • visitor details as provided at the time of registration or thereafter; and
    • call data records.
  • VRA Health will be free to use, collect and disclose information that is freely available in the public domain without your consent.
     
  • 3. PRIVACY STATEMENTS
     
    • 3.1 ALL USERS NOTE:
      This section applies to all users.
       
      • 3.1.1 Accordingly, a condition of each User’s use of and access to the Services is their acceptance of the Terms of Use, which also involves acceptance of the terms of this Privacy Policy. Any User that does not agree with any provisions of the same has the option to discontinue the Services provided by VRA Health immediately.
      • 3.1.2 An indicative list of information that VRA Health may require you to provide to enable your use of the Services is provided in the Schedule annexed to this Privacy Policy.
      • 3.1.3 All the information provided to VRA Health by a User, including Personal Information or any Sensitive Personal Data or Information, is voluntary. You understand that VRA Health may use certain information of yours, which has been designated as Personal Information or ‘Sensitive Personal Data or Information’ under the SPI Rules, (a) for the purpose of providing you the Services, (b) for commercial purposes and in an aggregated or non-personally identifiable form for research, statistical analysis and business intelligence purposes, (c) for sale or transfer of such research, statistical or intelligence data in an aggregated or non-personally identifiable form to third parties and affiliates (d) for communication purpose so as to provide You a better way of booking appointments and for obtaining feedback in relation to the Practitioners and their practice, (e) debugging customer support related issues, (f) for the purpose of contacting you to complete any transaction if you do not complete a transaction after having provided us with your contact information in the course of completing such steps that are designed for completion of the transaction. VRA Health also reserves the right to use information provided by or about the End-User for the following purposes:
        • Publishing such information on the Website.
        • Contacting End-Users for offering new products or services.
        • Contacting End-Users for taking product and Service feedback.
        • Analyzing software usage patterns for improving product design and utility.
        • Analyzing anonymized practice information for commercial use.
        • Processing payment instructions including those through independent third party service providers such as payment gateways, banking and financial institutions, pre-paid instrument and wallet providers for processing of payment transaction or deferral of payment facilities.
      • If you have voluntarily provided your Personal Information to VRA Health for any of the purposes stated above, you hereby consent to such collection and use of such information by VRA Health. However, VRA Health shall not contact You on Your telephone number(s) for any purpose including those mentioned in this sub-section 4.1(iii), if such telephone number is registered with the Do Not Call registry (“DNC Registry”) under the PDPA without your express, clear and un-ambiguous written consent.
         
      • 3.1.4 Collection, use and disclosure of information which has been designated as Personal Information or Sensitive Personal Data or Information’ under the SPI Rules requires your express consent. By affirming your assent to this Privacy Policy, you provide your consent to such use, collection and disclosure as required under applicable law.
      • 3.1.5 VRA Health does not control or endorse the content, messages or information found in any Services and, therefore, VRA Health specifically disclaims any liability with regard to the Services and any actions resulting from your participation in any Services, and you agree that you waive any claims against VRA Health relating to same, and to the extent such waiver may be ineffective, you agree to release any claims against VRA Health relating to the same.
      • 3.1.6 You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information provided as part of account registration. We will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable. If you provide any information that is untrue, inaccurate, out of date or incomplete (or becomes untrue, inaccurate, out of date or incomplete), or VRA Health has reasonable grounds to suspect that the information provided by you is untrue, inaccurate, out of date or incomplete, VRA Health may, at its sole discretion, discontinue the provision of the Services to you. There may be circumstances where VRA Health will not correct, delete or update your Personal Data, including (a) where the Personal Data is opinion data that is kept solely for evaluative purpose; and (b) the Personal Data is in documents related to a prosecution if all proceedings relating to the prosecution have not been completed.
      • 3.1.7. We will retain your information for as long as your account with the Services is active and as needed to provide you the Services. We shall not retain such information for longer than is required for the purposes for which the information may lawfully be used or is otherwise required under any other law for the time being in force. After a period of time, your data may be anonymized and aggregated, and then may be held by us as long as necessary for us to provide our Services effectively, but our use of the anonymized data will be solely for analytic purposes. Please note that your withdrawal of consent, or cancellation of account may result in VRA Health being unable to provide you with its Services or to terminate any existing relationship VRA Health may have with you.

 

  • 3.2 PRACTITIONERS NOTE:
    This section applies to all Practitioners.
     
    • 3.2.1 As part of the registration as well as the application creation and submission process that is available to Practitioners on VRA Health information, including Personal Information or Sensitive Personal Data or Information is collected from the Practitioners.
    • 3.2.2 All the statements in this Privacy Policy apply to all Practitioners, and all Practitioners are therefore required to read and understand the privacy statements set out herein prior to submitting any Personal Information or Sensitive Personal Data or Information to VRA Health, failing which they are required to leave the Services, including the Website immediately.
    • 3.2.3 Practitioners’ personally identifiable information, which they choose to provide to VRA Health, is used to help the Practitioners describe and identify themselves. This information is exclusively owned by VRA Health You will be the owner of your information and you consent to VRA Health collecting, using, processing and/or disclosing this information for the purposes hereinafter stated . VRA Health may use such information for commercial purposes and in an aggregated or non-personally identifiable form for research, statistical analysis and business intelligence purposes, and may sell or otherwise transfer such research, statistical or intelligence data in an aggregated or non-personally identifiable form to third parties and affiliates. VRA Health also reserves the right to use information provided by or about the Practitioner for the following purposes:
      • Publishing such information on the Website.
      • Contacting Practitioners for offering new products or services subject to the telephone number registered with the DNC Registry.
      • Contacting Practitioners for taking product feedback.
      • Analyzing software usage patterns for improving product design and utility.
      • Analyzing anonymized practice information including financial, and inventory information for commercial use.
    • 3.2. VRA Health automatically enables the listing of Practitioners’ information on its Website for every ‘Doctor’ or ‘Clinic’ or ‘Hospital’ added to a Practice using its software. The Practitioner information listed on Website is displayed when End-Users search for doctors on Website, and the Practitioner information listed on Website is used by End-Users to request for doctor appointments. Any personally identifiable information of the Practitioners listed on the Website is not generated by VRA Health and is provided to VRA Health by Practitioners who wish to enlist themselves on the Website, or is collected by VRA Health from the public domain. VRA Health displays such information on its Website on an as-is basis making no representation or warranty on the accuracy or completeness of the information. As such, we strongly encourage Practitioners to check the accuracy and completeness of their information from time to time, and inform us immediately of any discrepancies, changes or updates to such information. VRA Health will, however, take reasonable steps to ensure the accuracy and completeness of this information.
    • 3.2. VRA Health may also display information for Practitioners who have not signed up or registered for the Services, provided that the Practitioners have consented to VRA Health collecting, processing and/or disclosing their information on the Website. Such Practitioners are verified by VRA Health or its associates, and VRA Health makes every effort to capture accurate information for such Practitioners. However, VRA Health does not undertake any liability for any incorrect or incomplete information appearing on the Website for such Practitioners.
  • 3.3 END-USERS NOTE:
    This section applies to all End-Users.
     
    • 3.3.1 As part of the registration/application creation and submission process that is available to End-Users on this Website, certain information, including Personal Information or Sensitive Personal Data or Information is collected from the End-Users.
    • 3.3.2 All the statements in this Privacy Policy apply to all End-Users, and all End-Users are therefore required to read and understand the privacy statements set out herein prior to submitting any Personal Information or Sensitive Personal Data or Information to VRA Health, failing which they are required to leave the VRA Health immediately.
    • 3.3.3 If you have inadvertently submitted any such information to VRA Health prior to reading the privacy statements set out herein, and you do not agree with the manner in which such information is collected, processed, stored, used or disclosed, then you may access, modify and delete such information by using options provided on the Website. Enquire whether VRA Health is in possession of your personal data, and you may also require VRA Health to delete and destroy all such information.
    • 3.3.4 End-Users’ personally identifiable information, which they choose to provide on the Website is used to help the End-Users describe/identify themselves. Other information that does not personally identify the End-Users as an individual, is collected by VRA Health from End-Users (such as, patterns of utilization described above) and is exclusively owned by VRA Health. VRA Health may also use such information in an aggregated or non-personally identifiable form for research, statistical analysis and business intelligence purposes, and may sell or otherwise transfer such research, statistical or intelligence data in an aggregated or non-personally identifiable form to third parties and affiliates. In particular, VRA Health reserves with it the right to use anonymized End-User demographics information and anonymized End-User health information for the following purposes:
      • Analyzing software usage patterns for improving product design and utility.
      • Analyzing such information for research and development of new technologies.
      • Using analysis of such information in other commercial product offerings of VRA Health.
      • Sharing analysis of such information with third parties for commercial use.
    • 3.3.5 VRA Health will communicate with the End-Users through email, phone and notices posted on the Website or through other means available through the service, including text and other forms of messaging. The 

 

  • 4. CONFIDENTIALITY AND SECURITY
     
    • 4.1 Your Personal Information is maintained by VRA Health in electronic form on its equipment, and on the equipment of its employees. Such information may also be converted to physical form from time to time. VRA Health takes all necessary precautions to protect your personal information both online and off-line and implements reasonable security practices and measures including certain managerial, technical, operational and physical security control measures that are commensurate with respect to the information being collected and the nature of VRA Health’s business.
    • 4.2 No administrator at VRA Health will have knowledge of your password. It is important for you to protect against unauthorized access to your password, your computer, and your mobile phone. Be sure to log off from the Website when finished. VRA Health does not undertake any liability for any unauthorised use of your account and password. You shall be liable to indemnify VRA Health due to any loss suffered by it due to such unauthorized use of your account and password.
    • 4.3 VRA Health makes all User information accessible to its employees, agents, or partners and third parties only on a need-to-know basis and binds only its employees to strict confidentiality obligations.
    • 4.4 Part of the functionality of VRA Health is assisting the doctors to maintain and organise such information. VRA Health may, therefore, retain and submit all such records to the appropriate authorities, or to doctors who request access to such information.
    • 4.5 Part of the functionality of the VRA Health is assisting the patients to access information relating to them. VRA Health may, therefore, retain and submit all such records to the relevant patients, or to their doctors.
    • 4.6 Notwithstanding the above, VRA Health is not responsible for the confidentiality, security, or distribution of your Personal Information by our partners and third parties outside the scope of our agreement with such partners and third parties. Further, VRA Health shall not be responsible for any breach of security or for any actions of any third parties or events that are beyond the reasonable control of VRA Health including but not limited to, acts of government, computer hacking, unauthorised access to computer data and storage device, computer crashes, breach of security and encryption, poor quality of Internet service or telephone service of the User etc.
  • 5. CHANGE TO PRIVACY POLICY

    VRA Health may update this Privacy Policy at any time, with or without advance notice. In the event there are significant changes in the way VRA Health treats User’s personally identifiable information, or in the Privacy Policy itself, VRA Health will display a notice on the Website or send Users an email, as provided for above, so that you may review the changed terms prior to continuing to use the Services. As always, if you object to any of the changes to our terms, and you no longer wish to use the Services.

    If a User uses the Services or accesses the Website after a notice of changes has been sent to such User or published on the Website, such User hereby provides his/her/its consent to the changed terms.
     
  • 6. CHILDREN'S AND MINOR'S PRIVACY

    VRA Health strongly encourages parents and guardians to supervise the online activities of their minor children and consider using parental control tools available from online services and software manufacturers to help provide a child-friendly online environment. These tools also can prevent minors from disclosing their name, address, and other personally identifiable information online without parental permission. Although the VRA Health Website and Services are not intended for use by minors without the supervision of parents/guardians, VRA Health respects the privacy of minors who may inadvertently use the internet or the mobile application.
     
  • 7. CONSENT TO THIS POLICY

    You acknowledge that this Privacy Policy is a part of the Terms of Use of the Website and the other Services, and you unconditionally agree that becoming a User of the Website and its Services signifies your (i) assent to this Privacy Policy, and (ii) consent to VRA Health using, collecting, processing and/or disclosing your Personal Information in the manner and for the purposes set out in this Privacy Policy. Your visit to the Website and use of the Services is subject to this Privacy Policy and the Terms of Use.