Voyager Health Private Limited, on behalf of itself and its affiliates/group companies under the brand "MedVault" (“MedVault”) is the author and publisher of the Internet resource www.medvault.in (“Website”) on the World Wide Web as well as the software and applications provided by MedVault, including but not limited to the mobile application ‘MedVault’.
This privacy policy ("Privacy
Policy") explains how we collect, use, share, disclose and
protect Personal information about the Users of our Services as listed on
our Website, including the Practitioners (as defined in the Terms of Use,
which may be accessed via the following web link https://medvault.in/privacy and or under privacy in
the settings tab of our Mobile Application (the “Terms of Use”)), the
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:
i.Section 43A of the Information Technology Act, 2000;
ii.Regulation 4 of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011 (the “SPI Rules”);
iii.Regulation 3(1) of the Information Technology (Intermediaries Guidelines) Rules, 2011.
This Privacy Policy states the following:
iv.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;
v.The purpose, means and modes of collection, usage, processing, retention and destruction of such information; and
vi.How and to whom MedVault 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 website, 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 MedVault. 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 our services as listed on our Website and history of the appointments made by or with you through the use of our Services as listed on our Website;
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 MedVault 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:
vi.Passwords;
vii.Financial information such as bank accounts, credit and debit card details or other payment instrument details;
viii.Physical, physiological and mental health condition;
ix.Sexual orientation;
x.Medical records and history;
xi.Biometric information;
xii.Information received by body corporate under lawful contract or otherwise;
xiii.Visitor details as provided at the time of registration or thereafter; and
xiv.Call data records.
MedVault will be free to use, collect and disclose information that is freely available in the public domain without your consent.
•3.PRIVACY STATEMENTS
o3.1ALL USERS NOTE:
This section applies to all users.
!3.1.1Accordingly, a condition of each User’s use of and access to our Services as listed on our Website 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 our Services as listed on our Website provided by MedVault immediately.
!3.1.2An indicative list of information that MedVault may require you to provide to enable your use of our Services as listed on our Website is provided in the Schedule annexed to this Privacy Policy.
!3.1.3All
the information provided to MedVault by a User, including Personal
Information or any Sensitive Personal Data or Information, is voluntary. You
understand that MedVault 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
i.Publishing such information on the Website.
ii.Contacting
iii.Contacting
iv.Analysing software usage patterns for improving product design and utility.
v.Analysing anonymized practice information for commercial use.
vi.Processing payment instructions including those through independent third party service providers such as payment gateways, banking and financial
institutions,
If you have voluntarily provided your Personal Information to
MedVault for any of the purposes stated above, you hereby consent to such
collection and use of such information by MedVault. However, MedVault shall
not contact You on Your telephone number(s) for any purpose including those
mentioned in this
!3.1.4Collection, 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.
!3.1.5MedVault does not control or endorse the content, messages or information found in any Services as listed on our Website and, therefore, MedVault specifically disclaims any liability with regard to the Services as listed on our Website and any actions resulting from your participation in any of the Services as listed on our Website, and you agree that you waive any claims against MedVault relating to same, and to the extent such waiver may be ineffective, you agree to release any claims against MedVault relating to the same.
!3.1.6You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information provided as part of account registration. If your personal information changes, you may correct, delete inaccuracies, or amend information by making the change on our member information page or by contacting us through support@medvault.in. 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 MedVault has reasonable grounds to suspect that the information provided by you is untrue, inaccurate, out of date or incomplete, MedVault may, at its sole discretion, discontinue the provision of the Services as listed on our Website to you. There may be circumstances where MedVault 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.
!3.1.7If you wish to cancel your account or request that we no longer use
your information to provide you Services, contact us through support@medvault.in. We will retain your information for as long as your account with our Services as listed on our Website is active and as needed to provide you our Services as listed on our Website. 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 as listed on our Website 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 MedVault being unable to provide you with its Services as listed on our Website or to terminate any existing relationship MedVault may have with you.
!3.1.8If
you wish to
!3.1.9MedVault may require the User to pay with a
credit card, wire transfer, debit card or cheque for Services for which
subscription amount(s) is/are payable. MedVault 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
!3.1.10Due
to the communications standards on the Internet, when a User or the
!3.1.11The Website uses temporary cookies to store certain (that is not sensitive personal data or information) that is used by MedVault and its service providers for the technical administration of the Website, research and development, and for User administration. In the course of serving advertisements or optimizing services to its Users, MedVault may allow authorized third parties to place or recognize a unique cookie on the User’s browser. The cookies however, do not store any Personal Information of the User. You may adjust your Internet browser to disable cookies. If cookies are disabled you may still use the Website, but the Website may be limited in the use of some of the features.
!3.1.12A User may have limited access to the Website without creating an account on the Website. Unregistered Users can make appointments with the doctors by providing their name and phone number. 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 MedVault, 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 MedVault, is optional. MedVault may, in future, include other optional requests for information from the User to help MedVault to customize the Website to deliver personalized information to the User.
!3.1.13This Privacy Policy applies to Services that are owned and operated by MedVault. MedVault does not exercise control over the sites displayed as search results or links from within its Services as listed on our Website. 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 MedVault is not responsible or liable. Accordingly, MedVault does not make any representations concerning the privacy practices or policies of such third parties or terms of use of such websites, nor does MedVault 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 MedVault 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. MedVault encourages the User to read the privacy policies of that website.
!3.1.14The Website may enable User 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 MedVault representatives or agents, and their opinions or statements do not necessarily reflect those of MedVault, and they are not authorized to bind MedVault to any contract. MedVault 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.
!3.1.15MedVault does 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 End User must agree to under the Terms of Use in order for MedVault to effectively render its Services as listed on our Website).
!3.1.16MedVault maintains a strict
!3.1.17MedVault has implemented best international market practices and security policies, rules and technical measures to protect the personal data that it has under its control from unauthorised access, improper use or disclosure, unauthorised 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 as listed
on our Website, MedVault shall not be held liable for any loss whatsoever incurred by the User.
!3.1.18MedVault implements reasonable security practices and procedures and has 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 MedVault’s business.
!3.1.19MedVault takes 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 MedVault, 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.
o3.2PRACTITIONERS NOTE:
This section applies to all Practitioners.
!3.2.1As part of the registration as well as the application creation and submission process that is available to Practitioners on MedVault, certain information, including Personal Information or Sensitive Personal Data or Information is collected from the Practitioners.
!3.2.2All 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 MedVault, failing which they are required to leave the Services, including the Website immediately.
!3.2.3Practitioners’ personally identifiable
information, which they choose to provide to MedVault, is used to help the
Practitioners describe and identify themselves. This information is
exclusively owned by MedVault You will be the owner of your information and
you consent to MedVault collecting, using, processing and/or disclosing this
information for the purposes hereinafter stated. MedVault may use such
information for commercial purposes and in an aggregated or
i.Publishing such information on the Website.
ii.Contacting Practitioners for offering new products or services subject to the telephone number registered with the DNC Registry.
iii.Contacting Practitioners for taking product feedback.
iv.Analysing software usage patterns for improving product design and utility.
v.Analysing anonymized practice information including financial, and inventory information for commercial use.
!3.2.4MedVault automatically enables the listing of
Practitioners’ information on its Website for every ‘Doctor’ or ‘Clinic’
added to a Practice using its software. The Practitioner information listed
on Website is displayed when
!3.2.5MedVault may also display information for Practitioners who have not signed up or registered for the Services, provided that the Practitioners have consented to MedVault collecting, processing and/or disclosing their information on the Website. Such Practitioners are verified by MedVault or its associates, and MedVault makes every effort to capture accurate
information for such Practitioners. However, MedVault does not undertake any liability for any incorrect or incomplete information appearing on the Website for such Practitioners.
o
This section applies to all
!3.3.1As
part of the registration/application creation and submission process that is
available to
!3.3.2All
the statements in this Privacy Policy apply to all
!3.3.3If you have inadvertently submitted any such information to MedVault 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. In addition, you can, by sending an email to privacy@medvault.in, inquire whether MedVault is in possession of your personal data, and you may also require MedVault to delete and destroy all such information.
!
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
i.Analysing software usage patterns for improving product design and utility.
ii.Analysing such information for research and development of new technologies.
iii.Using analysis of such information in other commercial product offerings of MedVault.
iv.Sharing analysis of such information with third parties for commercial use.
!3.3.5MedVault will communicate with the
!3.3.6At
times, MedVault conducts a User survey to collect information about
!3.3.7MedVault may keep records of electronic communications and telephone calls received and made for making appointments or other purposes for the purpose of administration of Services, customer support, research and development and for better listing of Practitioners.
!3.3.8All
MedVault employees and data processors, who have access to, and are
associated with the processing of sensitive personal data or information,
are obliged to respect the confidentiality of every
!3.3.9MedVault may also disclose or transfer
!3.3.10To
the extent necessary to provide
to contractors, solely for the intended purposes only.
o3.4CASUAL VISITORS NOTE:
!3.4.1No sensitive personal data or information is automatically collected by MedVault from any casual visitors of this website, who are merely perusing the Website.
!3.4.2Nevertheless, certain provisions of this Privacy Policy are applicable to even such casual visitors, and such casual visitors are also required to read and understand the privacy statements set out herein, failing which they are required to leave this Website immediately.
!3.4.3If you, as a casual visitor, have inadvertently browsed any other page of this Website prior to reading the privacy statements set out herein, and you do not agree with the manner in which such information is obtained, collected, processed, stored, used, disclosed or retained, merely quitting this browser application should ordinarily clear all temporary cookies installed by MedVault. All visitors, however, are encouraged to use the “clear cookies” functionality of their browsers to ensure such clearing / deletion, as MedVault cannot guarantee, predict or provide for the behaviour of the equipment of all the visitors of the Website.
!3.4.4You are not a casual visitor if you have willingly submitted any personal data or information to MedVault through any means, including email, post or through the registration process on the Website. All such visitors will be deemed to be, and will be treated as, Users for the purposes of this Privacy Policy, and in which case, all the statements in this Privacy Policy apply to such persons.
•4.CONFIDENTIALITY AND SECURITY
o4.1Your
Personal Information is maintained by MedVault 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. MedVault takes all
necessary precautions to protect your personal information both online and
o4.2No administrator at MedVault 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. MedVault 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 MedVault by sending an email to support@medvault.in. You shall be liable to indemnify MedVault due to any loss suffered by it due to such unauthorized use of your account and password.
o4.3MedVault makes all User information accessible to
its employees, agents or partners and third parties only on a
employees to strict confidentiality obligations.
o4.4Part of the functionality of MedVault is assisting the doctors to maintain and organise such information. MedVault may, therefore, retain and submit all such records to the appropriate authorities, or to doctors who request access
to such information.
o4.5Part of the functionality of the MedVault is assisting the patients to access
information relating to them. MedVault may, therefore, retain and submit all such records to the relevant patients, or to their doctors.
o 4.6Notwithstanding the above, MedVault 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, MedVault 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 MedVault 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
MedVault may update this Privacy Policy at any time, with or without advance notice. In the event there are significant changes in the way MedVault treats User’s personally identifiable information, or in the Privacy Policy itself, MedVault 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, you may contact support@medvault.in to deactivate your account. Unless stated otherwise, MedVault’s current Privacy Policy applies to all information that MedVault has about you and your account.
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
MedVault 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
are not intended for use by minors, MedVault 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 MedVault 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.
•8.ADDRESS FOR PRIVACY QUESTIONS
Should you have questions about this Privacy Policy or MedVault's information collection, use and disclosure practices, you may contact, the Data Protection Officer appointed by MedVault in accordance with the provisions of PDPA. We will use reasonable efforts to respond promptly to any requests, questions or concerns, which you may have regarding our use of your personal information. If you have any grievance with respect to our use of your information, you may communicate such grievance to the Data Protection Officer:
Mr Arjun
Unit #117, Ground Floor, Shree Complex, St Johns Road, Sivan Chetty Gardens,
Phone:9741858222
Email: privacy@medvault.in
SCHEDULE
Indicative List of Information by Nature of Service
•
Website or ‘MedVault’ mobile application:
You can create an account by giving us information regarding
your [name, mobile number, email address], and such other information as
requested on the
•
You can use the Website without registering for an account, but to book an appointment, you may be asked certain information (including your [mobile number], and such other information as requested when you choose to use the Services without registration) to confirm the appointment.
•3.Practitioner availing of the free listing service on the Website or
‘MedVault’ mobile application by registering for an account:
As a Practitioner, you may be required to provide us with information regarding your [name, mobile number, email address], and such other
information as requested on the Practitioner registration page to create an account.
MedVault may send email and/or SMS confirmations or other communications to
•4.Practitioner availing of the free listing service on the Website or ‘MedVault’ mobile application without registering for an account:
As a Practitioner, you may avail of the listing service without registering for an account by providing information regarding your [name, mobile number, email address], and such other information as requested by any of MedVault’s employees or agents who contact you in person or by telephone. In such event, MedVault will maintain this information if and until you choose to register for an account, for which MedVault may contact you from time to time. MedVault will, after such information is collected from you, send you a confirmation email confirming the information provided and the fact that you will be listed on the Website or Mobile Application. In the event you do not wish to be so listed on the Website or Mobile Application, please inform MedVault immediately at support@medvault.in
•
You may be required to create an account and may be required to provide MedVault with information such as your name, mobile number, email address, and such other information as requested by MedVault on the MedVault Consult registration page in order to complete your registration.