Privacy Policy

The website ‘fluenthealth.com’, the app ‘Fluent Health’ (each individually and collectively referred to as “Platform(s)”) are owned and operated by Be Fluent LLP (“We”, “our”, “us”, “Fluent Health” “Be Fluent”). We respect your privacy and are committed to protecting your personal information. This privacy policy (“Policy”), sets out Be Fluent’s policies and practices on collection, use, disclosure, storage, security and management of personal information obtained when an individual (“User”) accesses or visits our Platform and/or are provided with our services, whether via our Platform or otherwise, either directly or indirectly, including through any mode, such as through third party applications including e-mails, WhatsApp, etc. (“Services”) and also applies to Personal Information which we obtain through any individual and process other than through the Platform (for example, including but not limited to personal information about our employees, customers, end-users, vendors and service providers or any other individual having any association with us in the course of our business activities).  

This has to be read in conjunction with our Terms of Use and the capitalised terms used but not defined herein shall have the meanings as ascribed under the Terms of Use.

This Privacy Policy hereinafter deals with the following aspects:

• Information we collect 
• De-identified / Anonymized Information
• Why we collect your information 
• Sharing your information with third parties
• How long do we keep your personal information
• How do we protect your personal information
• What rights do you have in respect of your personal information
• What are your duties
• Overseas transfer
• Cookies and Analytics
• Personal data of children
• Personal data of other individuals
• Privacy outside the Platform
• Changes to our Privacy Policy
• Contact Us
• Grievance Officer
• Governing Law

Personal information refers to any data or information that relates to a natural individual / person, which, either directly or indirectly, itself or in combination with other information is capable of identifying such individual / person (“Personal Information”). It does not include information that has been made anonymous, aggregated or has been stripped off of any and all Personal Information, so that it can no longer be used to identify a natural individual / person, whether alone or in combination with other information. (“De-identified Information”). 

We will only require you to provide us with such Personal Information that is necessary for us to provide you with our Services at your request. In the event that you voluntarily provide us with any Personal Information and for which you have not indicated that you do not consent to the use of such Personal Information, we may process such Personal Information in connection with providing you with our Services. We may also collect certain information automatically, details of which are provided further below.

Personal Information categories that we process: 

• Demography information, such as your full name, date of birth, age, sex assigned at birth, gender;

• Contact information, such as your e-mail address, mobile number/s and telephone number/s;

• Account credentials, including username, password, biometrics and other forms of account authentication credentials;

• Information provided by you or within your account including messages, instructions or other forms of communication exchanged with our support team and/or systems, including bots and automated systems;  

• Health Information, which may include information in relation to your chronic health conditions, genetic details, known illnesses; 

• Records pertaining to your health (physical, physiological or mental), medical conditions, medical history, 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 registered medical practitioners (“RMP”); 

• 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 provide information / documents / details of other individuals (whether members of your family or otherwise), such categories of information which are also applicable to you, may also be collected of theirs from you; 

  • 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.

We collect information using cookies and other similar technologies to help distinguish you from other Users of our Platform. 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 Platform, we may collect the following information:

1. Online activity data (including activity on the Platform) such as pages you access, view and which links you follow;

2. Your IP address and general location; 

3. Details of your devices for using our Platform, including URL and time stamps; your searches on the Platform;

4. Your preferences or details of your selections with respect to our Service offerings.  

We may further use tracking technologies to assess the usage and performance of the Platform or parts thereof, including as part of our analytic practices or otherwise to improve the content, products or services offered through the Platform. 

We may work with third parties (including mobile network providers, collection agencies and analytics providers) 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. 

We may anonymize and de-identify personal information, in an irreversible manner, collected through your usage and/or access of our Platform, Services, information provided to us in surveys or feedbacks or data collected via any other third-party. Therefore, our usage, storage, processing, security, data management and disclosure of such De-identified Information is not restricted to this Policy, and it may be used and disclosed to others in furtherance of our business activities and for research purposes including but not limited to biomedical health and clinical research. It is clarified that all such De-identified Information shall be solely and exclusively owned by Be Fluent and may be used by Be Fluent in any manner as it may deem appropriate. No direct or indirect financial or non-financial benefits of any nature will be provided to you for any potential use of the said de-identified and anonymized information. Be Fluent shall during the process of creation, disclosure and/or transmission of the said De-identified Information comply with all the relevant obligations stipulated under the applicable laws.

We do not collect any further Personal Information from you, if not specifically mentioned hereinabove.

We take your right to privacy seriously, and only collect your data for specified purposes. We have therefore, identified and enumerated the specific use cases where your information may be processed for one or more of the following purposes: 

• To create your profile and register your account with us and allow you to continue on our Platform as a registered User;  

• To provide and process service requests initiated by you;

• To provide curated Services;

• To communicate with you with regards to your queries, requests, or grievances etc;

• To provide you our Services, respond to your queries, complaints, address your concerns and facilitate transactions; 

• To comply with legal and / or contractual obligations; 

• To comply with any compliances required by the law enforcement agencies, governmental authorities; 

• For the purpose of processing and/or responding to your application and related inquiries in connection with potential employment opportunities at Be Fluent;

• For the purpose of matters in connection with your employment, where you have joined us as an employee.  

• We may also use your information to conduct any surveys and feedback conversations. The information obtained through our surveys and feedback conversation may be used by us in an aggregated, non-personally identifiable format for research purposes and in furtherance of our business interests; 

• We may use the Personal Information and/or the De-identified Information obtained from you for the purpose of analysing and improving features and functionalities of our Platform and/or Services;

• We may share the De-identified Information obtained from you, with the third parties, who may further utilise the said information for biomedical and clinical research;

• We may use your De-identified Information for research and analysis purposes, including but not limited to designing and developing solutions or applications for Machine Learning, Algorithm Learning, Large Language Models or Artificial Intelligence and in furtherance of our lawful business activities. 

• In furtherance of the Services provided through our Platform, we may refer, interpret, extract and/or collect data from the health information / records provided by you. However, we do not guarantee the accuracy of the information that is so referred, interpreted, extracted and/or collected from such records. It is the responsibility of the User to verify and ensure that the information referred, interpreted, extracted and/or collected from such records is accurate and up to date.

• We may utilise artificial intelligence and machine learning technologies to automatically generate a summary / summaries of the information and/or documents, including Personal Information, that you upload / provide.

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 us with IT solutions; enable financial transactions; document extraction; analytics; cloud services; email infrastructure and delivery service solution; communication system solution providers; service providers who provide Personal Information removal and redaction services; contact management systems; customer relationship solutions; marketing affiliates; product analytics tools to track user behaviour and improve user experience; our affiliates or group entities, where required for administrative / operational purposes or offering additional services to you; and, such other vendors, and service providers who work alongside us to provide you our Services and make available the Platform to you. We may, on your instructions, share your information with such other persons, including RMPs as indicated by you. We try to ensure that these third-party service providers agree to process and use information in compliance with our Policy or in a similar, industry-standard manner, and have same level of data protection as adhered by Be Fluent. 

We may share certain De-identified Information (such as anonymous User usage data, referring/exit pages and URLs, platform types, number of clicks, etc.) with third parties to demonstrate the usage patterns for Be Fluent’s advertisements, content, functionality promotions. If you do not want us to use your information for us to market to you, and/or to pass on to third parties for marketing purposes, please contact us through communication channel available, as listed under the Section titled “Contact Us” below.

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:

1. Required by the law, or in order to comply with judicial proceedings, court orders or legal or regulatory proceedings; 

2. Necessary to protect the safety of our employees, our property or the public; 

3. Necessary for the prevention or detection of crime, including exchanging information with other companies or organizations for the purposes of fraud protection;

4. Necessary to enforce this Policy or our Terms of Use;

5. 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;

6. Necessary in the event of our bankruptcy, reorganization, insolvency, receivership or an assignment for the benefit of creditors.

Unless mandated under law or for providing our Services in accordance with this Policy, we do not share your information in any manner which may identify you.

We will only store your personal information for as long as we need it for the specified 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 Personal Information till the period that is required for the purposes of us meeting your requests on our Platform or for providing our Services to you. We may retain certain data as necessary:

• For legitimate business purposes, including but not limited to auditing, accounts related; 

• If required by applicable laws; 

• To prevent fraud or future abuse; or 

• For the purpose of any contract (which may extend beyond the termination of our relationship with you).

• For detection of unauthorized access, its investigation, remediation to prevent recurrence and continued processing in such case.

All personal information retained by us is treated in accordance with this Policy. In case you request that your personal data be removed from our databases, you are requested to reach out at the contact information set out below. 

However, it may not be possible to completely delete all your personal information due to technological and legal constraints. We will take such steps as are reasonable to securely destroy the information or to ensure that the information pertaining to you is de-identified and/or anonymized as necessary. Please note that any request for deletion will not extend to any De-identified Information as the same does not contain any of your Personal Information. 

The third parties processing your information on our behalf, will be promptly notified of the withdrawal of consent and asked to erase your information as mandated under the laws of India.  

Despite our best efforts towards protecting your privacy we cannot guarantee in case any of the third-party entities with whom we share your Personal Information with and in accordance with this Policy, completely delete or erase your data upon requested by Be Fluent or by you. 

We take the security of your Personal Information very seriously. We use and employ reasonable technical, organizational, logical, physical, administrative measures to protect your personal information against any unauthorized access, modification, or use.  Be Fluent is currently implementing the International Standard IS/ISO/IEC 27001 2025, ISO 13485 and SOC 2 Type 2  to demonstrate our commitment towards maintaining and implementing requisite Privacy and Information Security policies and procedures.

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.

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 Platform or otherwise transmitted to us; any transmission is at your own risk.

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 the contact information set out below. These rights include:

1. The right to access the personal information in our control or custody, and to obtain details of processing;

2. The right to withdraw your consent to our continued processing of the personal information, at any point of time, subject only to any legitimate reason for continued processing in certain circumstances; 

3. The right to correct, rectify your account information and preferences available with us;

4. The right to erasure of any personal information that we process, in certain circumstances, to the extent permissible in law, and feasible. However, the right shall not extend to erasure of any non-personal data or De-identified Information. Further, in the instance where You request for deletion of whole or part of your personal information, any Personal information shared with a third party will be ceased to be processed within a reasonable time, provided that We and / or the third parties are not required to process such information under the law;

5. The right to nominate a person who shall become responsible for managing, handling your personal information, in the event of your death or incapacity, that is available with us by providing us such information as may be required by us;

6. The right to seek grievance redressal against us, in furtherance of your use of the Platform and/or Services.

Please note that we will require certain personal information from you such as your name, contact details, personal information given to us, and other reasonable identifiers to identify You for the purpose of enabling You to exercise Your rights. 

You have the duty to:

1. Comply with the provisions of the applicable laws;

2. Not impersonate another person, not suppress any material information;

3. Not to register a false or frivolous grievance;

4. Furnish only such information as is complete, accurate, consistent and verifiable. 

In case you withdraw your consent or request for erasure of whole or any part of your Personal Information, our Services in full or in part, may become inaccessible to you. We will not be able to offer our full Services where consent is withdrawn or Personal Information is erased on your request, and we shall convey to you, at that particular time of request about such a concern that you should be aware of. 

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 adopts data security measures that meet or exceed the standards practiced by Be Fluent and where the transfer is lawful and not prohibited by the Government as a restricted or prohibited destination for transfer of information. 

When we transfer your Personal Information to a location outside of the territory of India, 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 such location outsider of the territory of India is obliged to protect your Personal Information at a standard of protection comparable to the protection under the applicable laws of India.

Our lawful basis for such transfer will be either on the basis of consent or one of the safeguards permissible by laws. 

We and our third-party service providers that publish advertisement(s) 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 also allows us to improve the Services. In case you would prefer not to receive cookies, you can alter your browser’s configuration to refuse cookies.

We may use the Web Beacons in order to develop and analyse use of the Service. Web Beacons (sometimes referred to as “clear gifs”) collect only limited information that includes a cookie number, time and date of a page view, and a description of the page on which the Web Beacon resides. These Web Beacons do not carry any personally identifiable information and are only used to track usage of the Website and activities associated with the Website. 

The Platform / Services are not intended or designed to attract children under the age of 18 (eighteen) or a minor to access or use the same. By accessing our Platform / Services, you declare and confirm that you are 18 (eighteen) years of age or older or are either a parent or legal guardian of a minor. You also affirm that you are competent to enter into the terms, conditions, obligations, affirmations, representations, and warranties set forth in this Policy, and to abide by and comply with this Policy. In the event that any Personal Information of a minor is disclosed to us, by you either as a parent or the legal guardian, you hereby consent to the processing of the minor’s Personal Information and accept and agree to be bound by this Policy and take responsibility for his or her actions.

In the event you have reason to believe that an individual is under the age of 18 (eighteen) or a minor accessing our Services without the consent of their parent or guardian, please contact us at the contact information provided under the Section titled “Contact Us” below and we will seek to revoke access and delete any information associated with the minor as quickly as possible.

In some situations, you may provide Personal Information of other individuals (family, kids grandparents, friends, likewise) to us. If you provide us with such Personal Information, you attest, declare, represent and warrant to us that you are fully and duly legally authorized to share and have obtained their express consent for their Personal Information to be collected, used, and disclosed as set out in this Policy. In the event where information / documents of other individuals is stored on the Platform in your account as contemplated in the foregoing, access to the same will be made available only to you as their duly authorized representative.

In case any information / documents of minors is uploaded / shared, you additionally attest, declare, represent and warrant to us that you are the parent and/or the legal guardian of such minor. Upon a minor reaching the age of majority, the said minor has the right and option to revoke the earlier parental / guardian consent and/or request for deletion of their information / documents that was shared by you by reaching out to us at the contact information provided below.

The Platform may contain various links to other websites, including links to various third-party service providers websites. Be Fluent is not and cannot be responsible for the privacy practices or the content of any of these other websites. We may share aggregate, non-personally identifiable or De-identified Information with other websites for research, analytics or other purposes that are in furtherance of our business activities. Please check with those websites in order to determine their privacy policies and your rights under them. 

We make periodical changes to the Policy. The new terms would be displayed on the webpage and will be notified to you. By using or continuing to use the Services post such notification of change you agree to the changes made to the Policy and it would also be deemed that you are aware of the changes thus made. Please check back frequently to see any updates or changes to our Policy.

This version was last updated on August 25, 2026 and archived versions can be obtained by contacting us.

1. If you find any discrepancies or have any queries or grievances in relation to the collection, processing, storage, use, disclosure and transfer of your Personal Information under this Policy, please contact the following and we will resolve the issues raised by you within 30 (thirty) days from receiving them:

• Name: Winifred Fernandes

• Role: Grievance Officer

• Email: grievanceofficer@fluentinhealth.com

• Address: 2nd Floor, 21/A Film Center, Janta Nagar, Tardeo 400036

The details of the Grievance Officer may be changed by us from time to time by updating this Policy. 

2. When submitting the grievance, please provide your complete contact details, including name, address, telephone number, mobile number and e-mail address. If we do not receive an e-mail address, we will respond by postal mail.

3. Please ensure that your grievance contains complete details in relation to your complaint or query to enable us to effectively and expeditiously address the same. Please sufficiently describe the nature of your grievance along with providing supporting documents evidencing the grievance raised. 

4. If, at any time it is found that the grievance raised was malicious or the person raising the grievance has made the same knowing it to be false or the person raising the grievance has produced any forged or misleading document, then the same could result in civil and/or criminal liability against such person.

This Policy is governed by the laws of India. Subject to the arbitration provision below, you agree that the courts at Mumbai, India shall have exclusive jurisdiction over all matters relating to or arising out of this Policy.

Any dispute, controversy or claim arising out of or relating to this Policy shall be referred to and finally resolved by arbitration to be conducted in accordance with the provisions of the Arbitration and Conciliation Act, 1996. The arbitration proceedings shall be conducted by a sole arbitrator to be appointed by mutually by the concerned disputing parties. The seat, place and venue of the arbitration shall be Mumbai only. The arbitration proceedings shall be conducted in the English language only.

Version 2.0 Updated Aug 25, 2026