PRIVACY POLICY
Connect 2 Clinic Private Limited ("connect2clinic", "Company", "We", "Our" or "Us") is the owner of www.connect2clinic.com and the connect2clinic mobile application (the URLs and mobile application together referred to as "Websites" and individually a "Website"). The terms 'You' or 'Your' refer to You as the User (whether You are a Registered User or Unregistered User or an HCP) of the Website or of the services offered by the Website ("Service").
connect2clinic is committed to Your privacy. This privacy policy ("Privacy Policy") applies to the collection, use, storage, processing, disclosure and transfer of Your Information (defined below) when You use the Website and/or the Services. Please read and understand this Privacy Policy carefully. Your use or access of the Services shall constitute your agreement to this Privacy Policy. If you do not agree with our policies and our practices as described herein, do not use the Services offered by the Company.
1. WHY THIS PRIVACY POLICY?
This Privacy Policy states the following:
- i. The type of information collected from the Users, including Personal Information (as defined in paragraph 4 below) and Sensitive Personal Data or Information (as defined in paragraph 4 below) relating to an individual;
- ii. The purpose, means and modes of collection, usage, processing, retention and destruction of such information; and
- iii. How and to whom connect2clinic will disclose such information.
2. CONSENT
- 2.1. By clicking on the "I accept' button at the end of page containing the Terms of Use or by providing us Your Personal Information or by making use of the features provided by the Website, 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 Company 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.
- 2.2. You acknowledge that You are providing Your Personal Information out of Your free will. You have the option not to provide us the Personal Information sought to be collected. You will also have an option to withdraw Your consent at any point, provided such withdrawal of consent is intimated to us in writing at hello@connect2clinic.com. If You do not provide us Your Personal Information or if You withdraw the consent at any point in time, We shall have the option not to fulfill the purposes for which the said Personal Information was sought and we may restrict You from using the Website.
3. CHANGES TO THE PRIVACY POLICY
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3.1. We may update this Privacy Policy at any time, with or without an advance notice. We will indicate as and when required when the Privacy Policy was last updated on the Website.
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3.2. When We update Our Privacy Policy, the next time You visit the Website, the Website will provide a message which will intimate You of the amendments to the Privacy Policy. You will be required to provide Your consent to the amendments before You proceed. If You do not agree to the amendments, please do not use the Website any further.
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3.3. You acknowledge and agree that it is your responsibility to review this privacy policy periodically and become aware of the modifications. Your continued use of the Website following the posting of changes to this policy will be deemed as your acceptance to those changes.
4. WHAT PERSONAL INFORMATION IS COLLECTED FROM YOU?
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 connect2clinic. Without prejudice to the generality of the above, information collected by us from you may include (but is not limited to) the following:
- i. contact data (such as your email address and phone number);
- ii. demographic data (such as your gender, your date of birth and your pin code);
- iii. data regarding your usage of the services and history of the appointments made by or with you through the use of Services;
- iv. insurance data (such as your insurance carrier and insurance plan);
- v. other information that you voluntarily choose to provide to us (such as information shared by you with us through emails or letters.
The information collected from you by connect2clinic 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.
We will be free to use, collect and disclose information that is freely available in the public domain without your consent.
5. HOW WE COLLECT INFORMATION?
The methods by which We collect Your Information include but are not limited to the following:
- i. When You register on Our Website,
- ii. When You create a profile on Our Website or as part of Services
- iii. When You provide Your Information to us,
- iv. When You use the features on Our Website and/or when You use Services,
- v. When You access Website or Services,
- vi. By use of cookies (discussed below).
We will be free to use, collect and disclose information that is freely available in the public domain without your consent.
6. HOW THE INFORMATION COLLECTED IS USED?
We collect Your Information for various purposes, including the following:
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In order to enable You to use the Website and utilize the Services. For instance, You may provide Your health related information on the Website in order to consult privately with an HCP, or You may provide Your financial information in order to process a payment which You need to make on the Website.
- to respond to Your inquiries;
- to provide You with information about products and services available on the Website;
- to personalize Your experience on the Website;
- to help You address Your problems incurred on the Website including addressing any technical problems;
- for proper administering of the Website;
- to conduct internal reviews and data analysis for the Website (e.g., to determine the number of visitors to specific pages within the Website);
- to improve the services, content and advertising on the Website;
- to protect the integrity of the Website; and
- to respond to judicial process and provide information to law enforcement agencies or in connection with an investigation on matters related to public safety, as permitted by law.
- to conduct analytical studies on various aspects including user behaviour, user preferences etc
- to make disclosures as may be required under applicable law.
- to use information provided by or about the User for the following purposes:
- Publishing such information on the Website.
- Contacting Users for offering new products or services.
- Contacting Users for taking product and Service feedback.
- Analyzing software usage patterns for improving product design and utility.
- Analyzing anonymized practice information for commercial use.
- For any other purpose with your consent.
(above uses collectively referred to as "Purpose(s)")
7. DISCLOSURE OF YOUR INFORMATION
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction. We may disclose Personal Information or Information that we collect or you provide as described in this privacy policy:
- To our subsidiaries and affiliates.
- To contractors, service providers, and other third parties we use to support our business, provide services to you and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
- To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the Company about our Website users is among the assets transferred.
- To third parties to market their products or services to you if you have consented to these disclosures. We contractually require these third parties to keep personal information confidential and use it only for the purposes for which we disclose it to them.
- To fulfill the Purpose for which you provide it.
- For any other purpose disclosed by us when you provide the information.
- With your consent.
We may also disclose your Personal Information:
- To comply with any court order, law, or legal process, including responding to any government or regulatory request.
- To enforce or apply our terms of use and other agreements, including for billing and collection purposes.
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others.
8. HOW WE PROTECT YOUR INFORMATION?
- 8.1. The security of Your Personal Information is important to us. We have adopted reasonable security practices and procedure to ensure that the Personal Information (protected health information) collected is secure. You agree that such measures are secured and adequate. We restrict access to Your Personal Information only on a need to know basis to Us and Our affiliates' employees, agents, third party service providers, partners, and agencies who need to know such Personal Information in relation to the Purposes as specified above in this Privacy Policy and provided that such entities agree to abide by this Privacy Policy and confidentiality obligations.
- 8.2 Your Personal Information is maintained by Company 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. Company 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 Company’s business.
- No administrator at Company 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. Company does not undertake any liability for any unauthorised use of your account and password. If you suspect any unauthorized use of your account, you must immediately notify Us to by sending an email to hello@connect2clinic.com or grievances@connect2clinic.com. You shall be liable to indemnify Company due to any loss suffered by it due to such unauthorized use of your account and password.
- 8.4 Notwithstanding the above, We are 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, Company 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 Company 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.
9. COOKIES
We may store temporary or permanent 'cookies' on Your computer. A cookie is a small piece of data that is sent to Your browser from a web server and stored on Your computer's hard drive. A cookie cannot read data off Your hard disk or read cookie files created by other sites. Once You close Your browser, the cookie simply terminates. For instance, by setting a cookie on Your browser, You would not have to log in a password more than once, thereby saving time while on the Websites. You can choose whether to accept cookies by changing the settings of Your browser. You can reset Your browser to refuse all cookies or allow Your browser to show You when a cookie is being sent. If You reject the cookies on the websites, You may still be able to use the Websites, but it shall be limited to certain minimal functionality. The only drawback to this is that You may be limited only to some areas of the Websites or limited to certain functions of the Websites. Some of Our business partners may use cookies on the Websites. Please note that We have no access to or control over such cookies. connect2clinic and Our business partners may use cookies to better personalize the content, banners, and promotions that You see on the Websites.
10. LINKS
The Websites may contain links to other third party sites. The third party sites are not under the control of connect2clinic. Please note that connect2clinic is not responsible for the privacy practices of such third party sites. connect2clinicencourages You to be aware when You leave the Websites and to read the privacy policies of each and every third party site that collects personal information. If You decide to access any of the third-party sites linked to the Websites, You do this entirely at Your own risk. Any links to any partner of the Websites is the responsibility of the linking party. This Privacy Policy applies to Services that are owned and operated by Us. We does not exercise control over the sites displayed as search results or links from within its Services. These other sites may place their own cookies or other files on the Users’ computer, collect data or solicit personal information from the Users, for which We are not responsible or liable. Accordingly, connect2clinic does not make any representations concerning the privacy practices or policies of such third parties or terms of use of such websites, nor does We guarantee the accuracy, integrity, or quality of the information, data, text, software, sound, photographs, graphics, videos, messages or other materials available on such websites. The inclusion or exclusion does not imply any endorsement by Us of the website, the website's provider, or the information on the website. If you decide to visit a third party website linked to the Website, you do this entirely at your own risk. connect2clinic encourages the User to read the privacy policies of that website
11. CORRECTING INACCURACIES OR UPDATING PERSONAL INFORMATION
If Your Personal Information changes, or if You need to update or correct Your Personal Information or have any grievance with respect to the processing or use of Your Personal Information, for any reason, You may send updates and corrections to us at hello@connect2clinic.com and We will take all reasonable efforts to incorporate the changes within a reasonable period of time. If Your Personal Information is stored as part of Your profile on the Website, You can update Your profile on the profile pages of the Websites.
12. CHILDREN'S AND MINOR'S PRIVACY
The Website are not meant to be used by or intended for minors. The Company strongly advises the parents or guardians to supervise the use of the Website by their minor children. Any use of the Website and provision of Personal Information, Usage Information or other information to us by any minor is deemed to have been provided under due supervision and consent by such parents or guardians. Where the patient is a minor, after confirming the age, Services would be allowed only if the minor is consulting along-with an adult whose identity needs to be ascertained.
13. PRIVACY STATEMENTS
This section applies to all Users:
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We do not control or endorse the content, messages or information found in any Services and, therefore, We 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 the Company relating to same, and to the extent such waiver may be ineffective, you agree to release any claims against the Company to relating to the same.
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If you wish to deactivate or discontinue your account or request that we no longer use your information to provide you Services, contact us through hello@connect2clinic.com,grievances@connect2clinic.com. 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 / deactivation / discontinuation of account may result in the Company being unable to provide you with its Services or to terminate any existing relationship, the Company may have with you.
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If you wish to opt-out of receiving non-essential communications such as promotional and marketing-related information regarding the Services, please send us an email at hello@connect2clinic.com,grievances@connect2clinic.com.
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We may require the You to pay with a credit card, wire transfer, debit card or cheque for Services for which fees amount(s) is/are payable. We will collect such User’s credit card number and/or other financial institution information such as bank account numbers and will use that information for the billing and payment processes, including but not limited to the use and disclosure of such credit card number and information to third parties as necessary to complete such billing operation. Verification of credit information, however, is accomplished solely by the User through the authentication process. User’s credit-card/debit card details are transacted upon secure sites of approved payment gateways which are digitally under encryption, thereby providing the highest possible degree of care as per current technology. However, We provides you an option not to save your payment details. User is advised, however, that internet technology is not full proof safe and User should exercise discretion on using the same.
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Due to the communications standards on the Internet, when a User or anyone who visits the Website, We automatically receives the URL of the site from which anyone visits. We also receives the Internet Protocol (IP) address of each User’s computer (or the proxy server a User used to access the World Wide Web), User’s computer operating system and type of web browser the User is using, email patterns, as well as the name of User’s ISP. This information is used to analyze overall trends to help Us improve its Service. The linkage between User’s IP address and User’s personally identifiable information is not shared with or disclosed to third parties. Notwithstanding the above, We may share and/or disclose some of the aggregate findings (not the specific data) in anonymized form (i.e., non-personally identifiable) with advertisers, sponsors, investors, strategic partners, and others in order to help grow its business.
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You may have limited access to the Website without creating an account on the Website. In order to have access to all the features and benefits on our Website, a User must first create an account on our Website. To create an account, a User is required to provide the following information, which such User recognizes and expressly acknowledges is Personal Information allowing others, including Us, to identify the User: name, User ID, email address, country, ZIP/postal code, age, phone number, password chosen by the User and valid financial account information. Other information requested on the registration page, including the ability to receive promotional offers from the Company, is optional. We may, in future, include other optional requests for information from the User to help Us to customize the Website to deliver personalized information to the User.
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The Website may enable You to communicate with other Users or to post information to be accessed by others, whereupon other Users may collect such data. Such Users, including any moderators or administrators, are not authorized Company’s representatives or agents, and their opinions or statements do not necessarily reflect those of Company, and they are not authorized to bind Company to any contract. Company hereby expressly disclaims any liability for any reliance or misuse of such information that is made available by Users or visitors in such a manner.
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We do not collect information about the visitors of the Website from other sources, such as public records or bodies, or private organisations, save and except for the purposes of registration of the Users (the collection, use, storage and disclosure of which each User must agree to under the Terms of Use in order for Company to effectively render the Services).
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We maintain a strict "No-Spam" policy, which means that Company does not intend to sell, rent or otherwise give your e-mail address to a third party without your consent.
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We have implemented best market practices and security policies, rules and technical measures to protect the personal data that it has under its control from unauthorized access, improper use or disclosure, unauthorized modification and unlawful destruction or accidental loss. However, for any data loss or theft due to unauthorized access to the User’s electronic devices through which the User avails the Services, Company shall not be held liable for any loss whatsoever incurred by the User.
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We have implemented reasonable security practices and procedures and have a comprehensive documented information security programme and information security policies that contain managerial, technical, operational and physical security control measures that are commensurate with respect to the information being collected and the nature of Company’s business.
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We take your right to privacy very seriously and other than as specifically stated in this Privacy Policy, will only disclose your Personal Information in the event it is required to do so by law, rule, regulation, law enforcement agency, governmental official, legal authority or similar requirements or when Company, in its sole discretion, deems it necessary in order to protect its rights or the rights of others, to prevent harm to persons or property, to fight fraud and credit risk, or to enforce or apply the Terms of Use
14. COMPLIANCE
As per the Telemedicine Practice Guidelines under “Indian Medical Council (Professional Conduct, Etiquette and Ethics) (Amendment) Regulations, 2020, in the event non-compliance is noted, the connect2clinic shall be required to report the same to Board of Governors, in supersession to Medical Council of India who may take appropriate action.
15. GRIEVANCE OFFICER
We have appointed a Grievance Officer to address any concerns or grievances that You may have regarding the processing of Your Personal Information. If You have any such grievances, please write to Our Grievance Officer at grievances@connect2clinic.com and Our officer will attempt to resolve Your issues in a timely manner.