Privacy Policy

WelloPATHY India Private Limited, having its registered office address at 2nd Floor 329, Nandpuri B Chack, Pratap Nagar, Jaipur, Rajasthan - 302029  (which also includes its affiliates) is the author and publisher of the internet website www.wellopathy.com (“Website”) on the world wide web as well as the software and mobile applications provided by WelloPATHY, including but not limited to the mobile application ‘WelloHUM’, and the software and applications of the brand names ‘WelloCLINIC’, ‘WelloLAB’, (together with the Website, referred to as the “WelloPATHY Platform”, or “Platform”).

This Privacy Policy (“Privacy Policy”) applies to the collection, receipt, storage, usage, processing, disclosure, transfer and protection (“Utilization”) of  Personal Information (defined below) of the Users of the Platform or Services(defined hereunder), including the Registered Users, Healthcare Service Providers and Non-Registered Users (as defined in the Terms of Use, which may be accessed via the following web link https://WelloPATHY.com/terms_of_use (the “Terms of Use”)), and the visitors of Website (jointly and severally referred to as “You” “Your”, or “Users” in this Privacy Policy)when you use the WelloPATHY Platform or avail any Services offered through the WelloPATHY Platform, or use mobile applications provided through WelloPATHY Platform(“Application” or Applications”).

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 Platform and the Services offered through the Platform 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.

CONSENT

  1. You acknowledge that this Privacy Policy is a part of the Terms of Use of the WelloPATHY Platform and the other Services, by accessing the WelloPATHY Platform or by otherwise providing Us Your Personal Information Yourself or by making use of the Services provided by the Website or Application, You unconditionally signify Your (i) assent to the Privacy Policy, and (ii) consent to the Utilization of your Personal Information in accordance with the provisions of this Privacy Policy and other related provisions of law.

  2. You acknowledge that You are providing Your Personal Information out of Your free will. If You use the Services on behalf of someone else (including but not limited to, Your child – minor or major or as a legal representative of an individual with mental illness) or an entity (such as Your employer/ Family Members/Relatives), You represent that You are authorized 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 Personal Information as described in this Privacy Policy. Further, You hereby acknowledge that the Utilization of Your Personal Information by WelloPATHY is necessary for the purposes identified hereunder. You hereby consent that the Utilization of any Personal Information in accordance with the provisions of this Privacy Policy shall not cause any wrongful loss to You.

  3. 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 THE CONSENT IS INTIMATED TO US THROUGH THE APPLICATION OR IN WRITING. If You do not provide Us Your Personal Information or if You withdraw the consent to provide Us Your Personal Information 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 WelloPATHY Platform or Services.

  4. WelloPATHY Platform not directed at children and We do not knowingly collect any Personal Information from children. If You are under 18 years of age, then please do not use or access the Service(s) at any time or in any manner. If We learn that a person under 18 years of age has used or accessed the Platform or Service or any personally identifiable information has been collected on the Platform from persons  under 18 years of age, then we will take the appropriate steps to delete this information. Please contact Us at support@wellopathy.com if You are aware that We may have inadvertently collected Personal Information from a child, and We will delete that information as soon as possible.

  5. You may have to give specific consent for sharing of certain sets of data with clear cut expiry time lines.

CHANGES TO THE PRIVACY POLICY:

  1. 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, and. You are requested to review the Privacy Policy from time to time to  keep yourself updated with any changes, modifications made to the terms hereof. There is a tab at the end of the Privacy Policy which indicates when the Privacy Policy was last updated. When We update Our Privacy Policy, we will intimate You of the amendments on Your registered email ID and/or on the WelloPATHY Platform. Alternatively, WelloPATHY may also make Your continued account use or log-in conditional on acceptance of the Agreement and. If You do not agree to the amendments, please do not use the WelloPATHY Platform or Services any further.

PERSONAL INFORMATION COLLECTED: In order to provide Services to You, we might require You to voluntarily provide Us certain information that personally identifies You. You hereby consent to the collection of such information by WelloPATHY. The information that We may collect from You, about You, may include but are not limited to, the following:

  1. Patient/Caregiver/Doctor/Health Care Professional Name,

  2. Photo-ID ,

  3. Photograph,

  4. Additional information for electronic Know Your Customer (eKYC) process

  5. Additional information for Know Your Customer (KYC) process

  6. Doctor/Healthcare Professional credentials (including but not limited to registration details with relevant authorities),

  7. Birth date/age,

  8. Blood group,

  9. Gender,

  10. Address (including country and pin/postal code),

  11. Location information, including Your GPS location,

  12. Mobile number and Phone number

  13. Email address,

  14. Physical, physiological and mental health condition, provided by You and/or Your Healthcare Service provider or accessible from Your medical records,

  15. Data from your wearables (such as Apple Watch, Fitbit etc.)  and 3rd party apps on your device (such as Google Fit, Apple Health etc), 

  16. Personal medical records and history,

  17. Valid financial information at time of purchase of product/Services and/or online payment,

  18. WelloPATHY Platform Login ID and password,

  19. User details as provided at the time of registration or thereafter,

  20. Records of interaction with WelloPATHY representatives,

  21. Your usage details such as time, frequency, duration and pattern of use, features used and the amount of storage used,

  22. Master and transaction health records and other data stored in Your user account,

  23. Internet Protocol address, browser type, browser language, referring URL, files accessed, errors generated, time zone, operating system and other visitor details collected in Our log files, the pages of WelloPATHY Platform that You visit, the time and date of Your visit, the time spent on those pages and other statistics ("Log Data"),

  24. User’s tracking Information such as, but not limited to the device ID, Google Advertising ID and Android ID,

  25. Any other information that is willingly shared by You. Collectively referred to as “Personal Information”).

HOW WE COLLECT PERSONAL INFORMATION: The methods by which We collect Your Personal Information include but are not limited to the following:

  1. When You register on the WelloPATHY Platform,

  2. When You provide Your Personal Information to Us,

  3. During the course of Services provided to You by Us,

  4. When You use the features on the WelloPATHY Platform,

  5. Through Your device, once You have granted permissions to Our Application (discussed below),

  6. Through wearables, once you have granted permissions to Us to access Wearables data, or You provide Us the data in a structured file format e.g. csv etc..

  7. Through 3rd party apps like Google Fit, Apple Health, Fitbit etc. once you have granted permissions to Us to access those apps data or You provide Us the data in a structured file format e.g. csv etc.

  8. Through HSPs pursuant to consultation in-person, or on the WelloPATHY Platform,

  9. By the use of cookies (also discussed below),

  10. We collect information that Your browser/Application sends whenever You visit WelloPATHY Platform, such as, the Log Data. In addition, We may use third party services that collect, monitor and analyze this. This information is kept completely secure.

USE OF PERSONAL INFORMATION: YOUR PERSONAL INFORMATION MAY BE USED FOR VARIOUS PURPOSES INCLUDING BUT NOT LIMITED TO THE FOLLOWING:

  1. To provide effective Services;

  2. To debug customer support related issues;

  3. To operate and improve the WelloPATHY Platform;

  4. TO PERFORM ACADEMIC/STUDIES, CLINICAL OR OTHER RESEARCH AND ANALYSIS FOR OUR UNDERSTANDING, INFORMATION, ANALYSIS, SERVICES AND TECHNOLOGIES IN ORDER TO PROVIDE ALL USERS IMPROVED QUALITY OF CARE; AND ENSURING THAT THE CONTENT AND ADVERTISING DISPLAYED ARE CUSTOMIZED TO YOUR INTERESTS AND PREFERENCES;

  5. To contact You via phone, SMS, email or third-party communication services such as WhatsApp etc. for appointments, technical issues, payment reminders, obtaining feedback and other security announcements;

  6. To send promotional and marketing emails from Us or any of Our channel partners via SMS, email, snail mail or third-party communication services such as WhatsApp, Facebook etc.;

  7. To advertise products and Services of WelloPATHY and third parties;

  8. To transfer information about You, if We are acquired by or merged with another company;

  9. To share with Our business partners and/or HSPs  for provision of specific services You have ordered so as to enable them to provide effective Services to You;

  10. To administer or otherwise carry out Our obligations in relation to any Agreement You have with Us;

  11. To build Your profile on the WelloPATHY Platform;

  12. To respond to subpoenas, court orders, or legal process, or to establish or exercise Our legal rights or defend against legal claims; 

  13. To investigate, prevent, or take action regarding illegal activities, suspected fraud, violations of Our Terms of Use, breach of Our agreement with You or as otherwise required by law;

  14. TO AGGREGATE PERSONAL INFORMATION FOR RESEARCH FOR ACADEMIC/STUDIES, CLINICAL OR OTHER RESEARCH, , STATISTICAL ANALYSIS AND BUSINESS INTELLIGENCE PURPOSES, AND TO SELL OR OTHERWISE TRANSFER SUCH RESEARCH, STATISTICAL OR INTELLIGENCE DATA IN AN AGGREGATED AND/OR NON-PERSONALLY IDENTIFIABLE FORM TO THIRD PARTIES AND AFFILIATES WITH A PURPOSE OF PROVIDING SERVICES TO THE USERS OR FOR THE ADVANCEMENT OF SCIENTIFIC KNOWLEDGE ABOUT HEALTH AND DISEASE.

  15. To share with Your family members/caregivers/HSP’s/Doctors if you provide your consent during your use of the WelloPATHY Platform. 

  16. To share with your family members/caregivers/HSPs/Doctors in case of medical emergencies, subject to the applicable laws.

  17. Analysing data, tracking trends, building algorithms, creating databases for rating  systems, recommendations engines, etc

  18. For Services that require HSP authorized personnel to visit Your premises, We use the location data of (i) HSP personnel  to track their trips to Your location and keep You updated about their real time location status (ii)  You, from your mobile devices through GPS, as to enable HSP's personnel reach Your  location accurately and also to enhance Your use of our Platform, including to improve pick-up locations, enable safety features, and prevent and detect fraud. (Collectively referred to as “Purpose(s)”)

SHARING AND TRANSFERRING OF PERSONAL INFORMATION:

  1. You authorize Us to exchange, transfer, share, part with all or any of Your Personal Information, across borders and from Your country to any other countries across the world with Our affiliates / agents / third party service providers / partners / banks and financial institutions for the Purposes specified under this Policy or as may be required by applicable law.

  2. You hereby consent and authorize Us to publish feedback obtained by You on the WelloPATHY Platform. User’s financial information 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, User is advised to exercise discretion while saving the payment details.

  3. You acknowledge that some countries where We may transfer Your Personal Information may not have data protection laws which are as stringent as the laws of Your own country. You acknowledge that it is adequate that when WelloPATHY transfers Your Personal Information to any other entity within or outside Your country of residence, WelloPATHY will place contractual obligations on the transferee which will oblige the transferee to adhere to the provisions of this Privacy Policy. You acknowledge that WelloPATHY may be obligated to by law to disclose or transfer your Personal Information with Courts and Government agencies in certain instances such as for verification of identity, or for prevention, detection, investigation, prosecution, and punishment for offences, or in compliance with laws such as intimation of diagnosis of an epidemic disease. You hereby consent to disclosure or transfer of Your Personal Information in these instances.

  4. Notwithstanding the above, We are not responsible for the confidentiality, security or distribution of Your Personal Information by third-parties outside the scope of Our Agreement with such third-parties. Further, We 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 Us including but not limited to, acts of government, computer hacking, unauthorized 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. We may share Your Personal Information with Our other corporate and/or associate entities and affiliates to (i) help detect and prevent identity theft, fraud and other potentially illegal acts and cyber security incidents, and (ii) help and detect co-related/related or multiple accounts to prevent abuse of Our Services.

  6. We may share / transfer Personal Information about You, with Our parent, affiliates, subsidiaries, and joint ventures that are committed to serving Your online needs and related services, throughout the world.  Our parent, affiliates, subsidiaries, and joint ventures follow privacy practices no less protective of all users than our practices described in this document, to the extent allowed by applicable law. We, Our parent, affiliates, subsidiaries, joint ventures, or any combination of such, will share some or all of Your Personal Information with another business entity should we plan to, merge with, or be acquired by that business entity.

PERMISSIONS: Once You download and install Our Applications, You may be prompted to grant certain permissions to allow the Application to perform certain actions on Your device. These actions include permission to:

  1. read/write/modify/delete data in relation to the Application on Your device’s storage;

  2. view/access information relating to networks/access networks, including permission to send and receive data through such networks/access networks;

  3. determine Your approximate location from sources like, but not limited to, mobile towers and connected Wi-Fi networks;

  4. determine Your exact location from sources such as, but not limited to, GPS;

  5. view/access device information, including but not limited to the model number, IMEI number, operating system information and phone number of Your device;

  6. access device information including device identification number required to send notification/push notifications.

USE OF COOKIES:

  1. Cookies are files with small amount of data, which may include an anonymous unique identifier. Cookies are sent to You on the WelloPATHY Platform and/or Application.

  2. We may store temporary or permanent ‘cookies’ on Your computer/device to store certain data (that is not Sensitive Personal Data or Information). You can erase or choose to block these cookies from Your computer. You can configure Your computer’s browser to alert You when We attempt to send You a cookie with an option to accept or refuse the cookie. If You have turned cookies off, You may be prevented from using certain features of the WelloPATHY Platform.

  3. We do not control the use of Cookies by third parties. 

SECURITY:

  1. The security of Your Personal Information is important to Us. We have adopted reasonable security practices and procedures including role-based access, secure communication, password protection, encryption, etc. to ensure that the Personal Information collected is secure. You agree that such measures are secured and adequate. We restrict access to Your Personal Information to Our 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 Policy, provided that such entities agree to abide by this Privacy Policy. 

  2. While We will endeavor to take all reasonable and appropriate steps to keep secure any information which We hold about You and prevent unauthorized access, You acknowledge that the internet is not 100% secure and that We cannot guarantee absolute security of Your Personal Information. Further, if You are Secondary User, You hereby acknowledge and agree that Your Personal Information may be freely accessible by the Primary User and other Secondary Users and that WelloPATHY will not be able to restrict, control or monitor access by Primary User or other Secondary Users to your Personal Information. We will not be liable in any way in relation to any breach of security or unintended loss or disclosure of information caused in relation to Your Personal Information.

THIRD PARTY LINKS

During Your interactions with Us, it may happen that We provide/include links and hyperlinks of third-party websites not owned or managed by Us (“Third-party Websites”). It may also happen that You or other Users may include links and hyperlinks of Third-party Websites. The listing of such Third-Party Websites (by You, other Users or by Us) does not imply endorsement of such Third-party Websites by WelloPATHY. Such Third-party Websites are governed by their own terms and conditions and when You access such Third-party Websites, You will be governed by the terms of such Third-party Websites. You must use Your own discretion while accessing or using Third-party Websites. We do not make any representations regarding the availability and performance of any of the Third-party Websites. We are not responsible for the content, terms of use, privacy policies and practices of such Third-party Websites. We do not bear any liability arising out of Your use of Third-party Websites.

ACCESS

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, or request that We no longer use Your Personal Information to provide You Services, or opt-out of receiving communications such as promotional and marketing-related information regarding the Services, for any reason, You may send Us an email at support@wellopathy.com and We will take all reasonable efforts to incorporate the changes within a reasonable period of time.

COMPLIANCE WITH LAWS

You are not allowed to use the services of the Website or Application if any of the terms of this Privacy Policy are not in accordance with the applicable laws of Your country.

TERM OF STORAGE OF PERSONAL INFORMATION:

  1. WelloPATHY may keep records of communications, including phone calls received and made for making enquiries, orders, feedback or other purposes for rendering services effectively and efficiently. WelloPATHY will be the exclusive owner of such data and records. However, all records are regarded as confidential. Therefore, will not be divulged to any third party, unless required by law. The data will be shared only after following the internal procedures of verification of such request and maintaining the same for future reference/audit.

  2. WelloPATHY shall store Your Personal Information at least for a period of three years from the last date of use of the Services, Website or Application or for such period as may be required by law.

  3.  If You share Your personal profile and/or medical history/records or any other information with a doctor or other HSPs via the WelloPATHY Platform, and then chooses to delete the information, the Doctor/HSP may still choose to store the information for their records. Similarly, if a Doctor/HSP chooses to remove any prescription, reports or any other information, shared with patient/end-consumer via WelloPATHY Platform, the patient/end-consumer may choose to store the information. Under no circumstances can WelloPATHY be held liable for any one party’s right or preference to store the other party’s information once any information or medical record is exchanged between the two parties.

GRIEVANCE OFFICER

We have appointed a grievance officer, whose details are set out below, 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 support@wellopathy.com and Our officer will attempt to resolve Your issues in a timely manner.

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