Privacy Policy

Healthiespan Technologies Private Limited (“us”, “we”, or “Healthiespan”, which also includes its affiliates) is the author and publisher of the internet resource www.healthiespan.com (“Website”) on the world wide web as well as the software and applications provided by Healthiespan, including but not limited to the mobile application ‘Healthiespan’, and the software and applications of the brand names ‘Healthiespan iOS Apps’, ‘Healthiespan Android Apps’, ‘Healthiespan Agent Portal’ and ‘Healthiespan Customer Portal’ (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, the End-Users, and the visitors of the 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.

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 and Sensitive Personal Data or Information relating to an individual;
• The purpose, means and modes of collection, usage, processing, retention and destruction of such information; and
• How and to whom Healthiespan 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 Healthiespan. Information collected 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);
• 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 Healthiespan 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 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.

Healthiespan 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

1. 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 Healthiespan immediately.
2. An indicative list of information that Healthiespan may require you to provide to enable your use of the Services is provided in the Schedule at the end of this Privacy Policy.
3. All the information provided to Healthiespan by a User, including Personal Information or any Sensitive Personal Data or Information, is voluntary. Healthiespan may use such information (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 purposes so as to provide you a better way of booking appointments and obtaining feedback in relation to the Practitioners and their practice, (e) debugging customer support related issues. Healthiespan 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; analysing software usage patterns for improving product design and utility; analysing anonymized practice information for commercial use.
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.
5. Healthiespan does not control or endorse the content, messages or information found in any Services and, therefore, Healthiespan 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 Healthiespan relating to same.
6. You are responsible for maintaining the accuracy of the information you submit to us. 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@healthiespan.com. We will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable.
7. If you wish to cancel your account or request that we no longer use your information to provide you Services, contact us through support@healthiespan.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.
8. 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 support@healthiespan.com.
9. Healthiespan may require the User to pay with a credit card, wire transfer, debit card or cheque for Services for which subscription amounts are payable. Healthiespan 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. 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, Healthiespan provides you an option not to save your payment details.
10. When a User or the End-User or anyone visits the Website, Healthiespan automatically receives the URL of the site from which anyone visits. Healthiespan 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 analyse overall trends to help Healthiespan 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.
11. The Website uses temporary cookies to store certain information (that is not sensitive personal data or information) that is used by Healthiespan and its service providers for the technical administration of the Website, research and development, and for User administration. The cookies 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.
12. A User may have limited access to the Website without creating an account. 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, providing the following information: name, User ID, email address, country, ZIP/postal code, age, phone number, password chosen by the User and valid financial account information.
13. This Privacy Policy applies to Services that are owned and operated by Healthiespan. Healthiespan does not exercise control over the sites displayed as search results or links from within its Services. If you decide to visit a third party website linked to the Website, you do this entirely at your own risk. Healthiespan encourages the User to read the privacy policies of that website.
14. Healthiespan maintains a strict “No-Spam” policy, which means that Healthiespan does not intend to sell, rent or otherwise give your e-mail address to a third party without your consent.
15. Healthiespan 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, Healthiespan shall not be held liable for any loss whatsoever incurred by the User.
16. Healthiespan 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 Healthiespan's business.
17. Healthiespan 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 Healthiespan, 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.

3.2 End-Users

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.
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 Healthiespan.
3. If you have inadvertently submitted any such information to Healthiespan 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 support@healthiespan.com, inquire whether Healthiespan is in possession of your personal data, and you may also require Healthiespan to delete and destroy all such information.
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 Healthiespan from End-Users and is exclusively owned by Healthiespan. Healthiespan 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.
5. Healthiespan 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.
6. At times, Healthiespan conducts a User survey to collect information about End-Users' preferences. These surveys are optional and if End-Users choose to respond, their responses will be kept anonymous.
7. Healthiespan 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.
8. All Healthiespan 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 End-Users' Personal Information or Sensitive Personal Data and Information. Healthiespan has put in place procedures and technologies as per good industry practices and in accordance with the applicable laws, to maintain security of all personal data from the point of collection to the point of destruction.
9. Healthiespan may also disclose or transfer End-Users' personal and other information provided by a User, to a third party as part of reorganization or a sale of the assets of a Healthiespan corporation division or company. Any third party to which Healthiespan transfers or sells its assets to will have the right to continue to use the personal and other information that End-Users provide to us, in accordance with the Terms of Use.
10. To the extent necessary to provide End-Users with the Services, Healthiespan may provide their Personal Information to third party contractors who work on behalf of or with Healthiespan to provide End-Users with such Services, to help Healthiespan communicate with End-Users or to maintain the Website. Generally these contractors do not have any independent right to share this information.

3.3 Casual Visitors

1. No sensitive personal data or information is automatically collected by Healthiespan from any casual visitors of this website, who are merely perusing the Website.
2. Nevertheless, 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. If 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 Healthiespan.
4. You are not a casual visitor if you have willingly submitted any personal data or information to Healthiespan 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.

4. Confidentiality and Security

1. Your Personal Information is maintained by Healthiespan 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. Healthiespan 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 Healthiespan's business.
2. No administrator at Healthiespan 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. Healthiespan 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 Healthiespan by sending an email to support@healthiespan.com. You shall be liable to indemnify Healthiespan due to any loss suffered by it due to such unauthorized use of your account and password.
3. Healthiespan 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. Part of the functionality of Healthiespan is assisting the doctors to maintain and organise such information. Healthiespan may, therefore, retain and submit all such records to the appropriate authorities, or to doctors who request access to such information.
5. Part of the functionality of the Healthiespan is assisting the patients to access information relating to them. Healthiespan may, therefore, retain and submit all such records to the relevant patients, or to their doctors.
6. Notwithstanding the above, Healthiespan 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, Healthiespan 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 Healthiespan 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. Changes to Privacy Policy

Healthiespan may update this Privacy Policy at any time, with or without advance notice. In the event there are significant changes in the way Healthiespan treats User's personally identifiable information, or in the Privacy Policy itself, Healthiespan will display a notice on the Website or send Users an email, 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@healthiespan.comto deactivate your account. Unless stated otherwise, Healthiespan's current Privacy Policy applies to all information that Healthiespan 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

Healthiespan 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 Healthiespan Website and Services are not intended for use by minors, Healthiespan 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 Healthiespan 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.

Schedule: Indicative List of Information by Nature of Service