Privacy Policy

Information We Collect

1. Personal Information refers to any information about a natural person who can be identified from that information, either by itself or when it is combined with other information. 

2. Information you provide to us: We will only require you to provide such personal information that is necessary for us to provide you with a Service at your request. We may also collect certain information automatically, details of which are provided below:

Personal Information Categories: 

• Demography information, such as your full name, date of birth, age, gender;
• Contact information, such as your e-mail address and telephone number/s;
• Information provided by you or within your account (messages to our support team);
• Health Information, which may include information in relation to your chronic health conditions, genetic details, known illnesses; 
• Records pertaining to your health, medical conditions, which could be in the form of scans, prescriptions, diagnostic reports, and such other readable formats; 
• Audio-visual recordings that may be created when you undergo teleconsultations with the RMPs; 
• You may further provide us with details regarding the following identifiers, to enable us to offer you curated Services: 

- Healthcare Proxy;
- Health Insurance Details;
- Conditions and symptoms;
- Medications;
- Allergies and Intolerances;
- Surgeries and Procedures;
- Reproductive Health Details;
- Lifestyle and Nutrition;
- Preventive Screenings;
- Immunizations;
- Genetic Information; 
- Body Vitals – blood pressure, breathing rate, temperature, oxygen saturation level, respiratory rate, pulse; 

• In case where you add details of your family members, dependents, minors, such categories of information which are also applicable to you, may be collected; 
• Payment information (we do not retain this information, this is managed by our payment service provider exclusively); and, 
• Additional information relevant to your use of our Platform, such as your marketing preferences, survey responses and feedback, if any. 

3. Information we collect automatically. We collect information using cookies and other similar technologies to help distinguish you from other users of our Website. We do this to give you a better, personalized experience, and to minimize your efforts with respect to your interactions with us. 
When you visit our website, we may collect the following information:
a. Pages you access, view and which links you follow;
b. Your IP address and general location; 
c. Details of your devices for using our Website, including URL and time stamps; any passwords that you use;
d. Your preferences or details of your selections with respect to our RMPs, service offerings.
We may further use tracking technologies to assess the performance of the Platform, including as part of our analytic practices or otherwise to improve the content, products or services offered through the Website. 

4. Information We Collect from Third Parties: We may work with a limited number of third parties (including mobile network providers, collection agencies, analytics providers like Google Analytics) to provide the Services and may receive information about you from such third parties. You understand and agree that third party websites may have their own policies which are different from that of the Platform. You note that such interactions, to that limited extent, will be governed by the policies of such third parties. Please note that we do not own or operate such third-party sites, and we have not reviewed, and do not review, all the material, including goods or services, made available through third-party sites. We urge you to review such policies before you continue your interactions with such third-party sites and services. 

5. We do not collect any further information from you, if not specifically mentioned hereinabove. 

Why We Collect Your Information?

6. We take your right to privacy seriously, and so we have attempted to identify and enumerate the specific use cases as below: 

• To create your profile and register your account with us and allow you to continue on our Platform as a registered user;  
• To communicate with our RMPs;
• To provide and process service requests initiated by you;
• To provide curated Services;
• To provide you our Services, respond to your queries, complaints, address your concerns and facilitate transactions; 
• To comply with legal obligations; 
• To comply with any compliances required by the law enforcement agencies, governmental authorities; 
• We may also use your information to conduct any surveys and feedback conversations.

7. Sharing your information with third parties
We will never display, rent, or sell your personal information to others.
We may share your data with selected third parties. We may share your information with companies which provide IT solutions; enable financial transactions; business analytics; cloud services; contact management systems; customer relationship solutions; marketing affiliates; and, such other vendors, and, service providers who work alongside us to provide you our Services and make available the Platform to you.  
There are certain other exceptional circumstances in which we may disclose your information to third parties. This would be where we believe that the disclosure is:
a. Required by the law, or in order to comply with judicial proceedings, court orders or legal or regulatory proceedings; 
b. Necessary to protect the safety of our employees, our property or the public; 
c. Necessary for the prevention or detection of crime, including exchanging information with other companies or organizations for the purposes of fraud protection;
d. As part of a merger, business, or asset sale, in the event that this happens we will share your information with the prospective seller or buyer involved.

8. How long do we keep your personal information?
We will only store your personal information for as long as we need it for the purposes for which it was collected, and where necessary. This may vary with the nature of the personal information so collected. Where we provide you with any Service, such as where you register, we will retain any information you provide to us at least for as long as we continue to provide that Service to you. We retain your information till the period that is required for the purposes of us meeting your requests on our Platform, and in compliance with the applicable laws, statutory requirements. 

9. How do we protect your personal information?
a. We use and employ reasonable technical, organizational, logical, physical, administrative measures to protect your personal information against any unauthorized access, modification, or use;  
b. We employ necessary anonymization techniques to ensure that your personal identity is never visible to our systems, or our teams, without proper authorization and only on a need-to-know basis.
c. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk. 

10. What rights do you have in respect of your personal information? 
You have a number of rights in relation to the information we hold about you. In order to action these rights, you are encouraged to write to: privacymatters@fluentinhealth.com.
These rights include:
a. The right to access the information we hold about you, and to obtain details of processing;
b. The right to withdraw your consent to our continued processing of the information, at any point of time, subject only to any legitimate reason for continued processing in certain circumstances; 
c. The right to rectify your account information and preferences available with us;
d. The right to erasure any personal data that we process, in certain circumstances, to the extent permissible in law, and feasible.

11. Overseas Transfer 
Your information may be transferred to and stored in locations outside of the territory of India. We will do this only when the destination jurisdiction has an adequate and appropriate level of protection and where the transfer is lawful. 
When we transfer your Personal Information from your Home Country (country, state and city in which you are present) to the Alternate Country (another country, state and city), we will comply with our legal and regulatory obligations in relation to your Personal Information, including having a lawful basis for transferring Personal Information and putting appropriate safeguards in place to ensure an adequate level of protection for the Personal Information. We will also ensure that the recipient in Alternate Country is obliged to protect your Personal Information at a standard of protection comparable to the protection under applicable laws.
Our lawful basis for such transfer will be either on the basis of consent or one of the safeguards permissible by laws.

12. Cookies and Analytics.
We and our third-party service providers that publish advertisement on our Platform, will set or access cookies on your web or mobile browser to distinguish you from other users of the Services. Third-party service providers will use cookies in accordance with their own privacy policies and cannot access cookies used by us. This helps us to provide you with a good experience when you use the Services and allows us to improve the Services. 
We may use the Web Beacons in order to develop and analyze use of the Service. Beacons are used to calculate the total number of users and to identify registered users using saved our cookies. 

13. Personal Data of Children 
As a parent or legal guardian, You must have attained the age of majority to be able to use and access our Services. 
In the event that such Personal Information of minor is disclosed to us, you hereby consent to the processing of the minor’s Personal Information and accept and agree to be bound by this Privacy Policy and take responsibility for his or her actions.

14. Personal Data of Other Individuals 
In some situations, you may provide Personal Information of other individuals (family, friends, likewise) to us. If you provide us with such Personal Information, you represent and warrant that you have obtained their consent for their Personal Information to be collected, used, and disclosed as set out in this Privacy Policy.

15. Changes to our Privacy Policy
We make periodical changes to the privacy policy with or without notice. The new terms would be displayed on the webpage and by using or continuing to use the Services you agree to the periodical changes made to the Privacy Policy and it would also be presumed that you are aware of any modifications thus made. Please check back frequently to see any updates or changes to our privacy policy.
This version was last updated on Oct 1, 2023 and archived versions can be obtained by contacting us.

16. Contact Us
If you have any questions about your privacy or our use of your personal data, please contact our Data Protection Officer at dpo@fluentinhealth.com.