MEDISENSE PRIVACY POLICY

Medisense is committed to providing you notice about how Medisense, our affiliates and third-party service providers (together, “we”, or “us”, or “our”) handle your information. Medisense and all our affiliates that provide Services through our Platform (defined below) care about the confidentiality and security of your information. Reference to "you" and “users” in this Policy refers to the customers availing the services provided by Medisense (“Services”). Any Personal Information (as defined below) and/or Personal Data (as defined below) collected from you will be used by us in accordance with and as described in this Privacy Policy (“Privacy Policy”).

The Policy sets out: (a) the types of information that we may collect from you when you access or use our Services through the online medium and (b) our practices for collecting, using, maintaining, protecting and disclosing that information. By using or accessing our Services and providing Personal Information and/or Personal Data, you agree to the terms and conditions of this Privacy Policy.

You are responsible for ensuring the accuracy of the Personal Data you submit to Medisense. Inaccurate information may affect your ability to use the Platform, the information you receive when using the Platform, and our ability to contact you. For example, your email address and mobile number should be kept current because that is one of the primary manners in which we communicate with you.

You also expressly consent to our use and disclosure of your Personal Information and/or Personal Data in any manner as described in this Policy and further signify your agreement to this Policy and the Terms & Conditions (being incorporated by reference herein). If you do not agree with the terms and conditions of this Policy, please do not proceed further, browse, or register for any of our Services or provide us with any information. To adjust your email and data preferences or opt out of further communications, please email us at medical@medisense.health

1. DEFINITIONS

“Affiliates” shall mean Medisense or any other entity that, directly or indirectly, through one or more intermediaries, controls, is controlled by, or is under common control with, Medisense.

“Company” or “Companies” shall mean any corporation(s), limited liability company or companies, partnership(s) or other similar entities.

“Health Passport” means an electronic record allotted to each individual User while he/she registers on the Platforms with a User Account. This Health Passport shall contain all important health information of the User which is subject to modification or alteration at the sole discretion of the User.

“Non-personal Identification Information” shall mean any non-personal information collected from the Users pursuant to their interaction on the Platform, including but not limited to the browser name, the type of computer and technical information about Users means of connection to the Platform such as the operating system, the Internet service providers utilized and other similar information.

“Personal Identification Information/ Personal Data” shall mean any information that identifies or can be used to identify, contact or locate the person, when the Users use the Platform, register, conclude a transaction, respond to a survey, fill out a form, and anything else in connection with other activities, services, features or resources we make available on the Platform. Users may be asked for personal information including, but not limited to name, email address, phone number and residential address, as well as information about personal health issues and insurance submitted through our Services, disclosed by the Users in relation to the services provided by us. Medisense will collect Personal Identification Information from Users only if they voluntarily submit such information to us. Users can always refuse to supply Personal Identification Information, except that it may prevent them from services provided by us. For the purposes of this Policy, Personal Identification Information and Non-personal Identification Information shall together be referred to as "Personal Information".

“Platform/(s)” shall mean the Medisense mobile application and the Medisense Website collectively through which the Services are provided by Medisense to the Users.

“Privacy Policy” shall mean this Privacy Policy.

“Services” shall mean the services in terms of health teleconsultation as well as telemedicine services by Medisense and/or its Affiliates.

"Third Party" shall mean any person or entity other than you or us which may include payment facilitators and other such entities which are not associated with us or any of our affiliates.

“Terms and Conditions” shall mean the Terms and Conditions for Medisense.

“Users” or “You” shall mean users, visitors, customers, prospective customers who avail or will avail the services provided by Medisense.

“Website” means the platform on which we provide our customers the access to our Services that is available via www.medisense.me www.medisense.health www.medisensehealth.com www.medisense.ai

2. SCOPE AND NATURE OF POLICY

This Privacy Policy covers Personal Information and/or Personal Data collected from and about you – individuals who are Users, customers and prospective customers of our business. This Privacy Policy includes examples of the types of information we may collect and the kinds of companies to which we may disclose information. These examples are illustrative and should not be considered a complete inventory of our information collection or sharing practices. Accordingly, the words “include” and “including” mean inclusion without limitation.

3. THE INFORMATION WE COLLECT

3.1 In Relation to The Services

1. For the purposes of enrolling the Services provided by us, Users will be required to disclose information including personal contact details. We collect Personal Data that you provide to us when you register for an account, update personal information on the Platform(s), complete a survey, sign-up for email updates, send us email messages. We may use the Personal Data that you provide to respond to your questions, provide you the specific Services you select, send you updates about various new and updated Services, send you email messages about the Platform maintenance or updates, user experience monitoring and improvement, and related business purposes and to carry out market research operations for our Services. We use this information and share it as needed with our affiliates solely for their performance of contracted Services for us. We never sell the information that we collect.
2. We may collect different data from or about you depending on how you use the Services. The information we collect directly from you are
   1. Name
   2. E-mail address
   3. Phone number
   4. Postal address
   5. Credit card and billing details, including billing address (for future transactions made by you)
   6. Information about your transactions with us, our affiliates or others
   7. Health information about personal health issues and health insurance policy details.
3. If you submit any personal information that is not your own, you represent and warrant that you have the authority to do so and to permit us to use that information in accordance with this Privacy Policy. If you contact us with a question, comment, or complaint, we may collect your name and contact information (such as your email address or mailing address) in order for us to respond to your request. We may also keep a record of the correspondence in order to assist you in the future.
4. If you sign up to receive marketing communications from us, we will collect your name and email address in order to email you regarding products and services that you have indicated are of interest to you. You may also be added to our marketing list when you create an account with us.
5. We also collect some data automatically, such as information about your device and what parts of our Services you spend time using only to achieve efficiency in providing services to you. We use tools such as cookies, web beacons, and similar technologies to gather the information listed above. Some of these tools offer you the ability to opt out of data collection. We use this information to help improve the contents of the Platform and the Services and to compile aggregate statistics about individuals using our Platform and the Services for internal, market research purposes. We may install cookies that collect the domain name of the user, your internet service provider, your operating system, and the date and time of access. A cookie is a small piece of information, which is sent to your browser and stored on your computer or other device. Cookies do not damage your device. You can set your browser to notify you when you receive a cookie. This will enable you to decide if you want to accept it or not. If you do not accept cookies, you may not be able to use all functionality of your browser software or this Platform. We may obtain the services of outside parties to assist us in collecting and processing information collected through cookies. We may also request location access, access to camera, gallery, sms, physical activities to provide you better and personalised user experience. These accesses are needed to show you nearby and global service providers, auto detect of OTP (One time password), ease of use when updating health records or documents related to personal and professional identification, to enable you to join video or audio-based consultations.
6. We may also use internet tags (also known as action tags, web beacons, single-pixel GIFs, clear GIFs, invisible GIFs, and 1-by-1 GIFs) and cookies through the Services and may deploy these tags/cookies through a third-party advertising partner or a web analytical service partner which may be located and store the respective information (including your IP address) in a foreign country. These tags/cookies may be placed both on online advertisements that bring users to the Services. We use this technology to measure the Users’ responses to the Platform and the Services and the effectiveness of our advertising campaigns (including how many times a page is opened and what information is consulted) as well as to evaluate your use of the Services. The third-party partner or the web analytical service partner may be able to collect data about visitors to the Site and other sites because of these internet tags/cookies, may compose reports regarding the Platform’s activity for us and may provide further services which are related to the use of the Platform and the internet. They may provide such information to other parties, if there is a legal requirement that they do so, or if they hire the other parties to process information on their behalf.
7. We may be able to determine from an IP address a user’s Internet Service Provider, the geographic location of their point of connectivity, operating system(s) you use, the date and time you used the Platform, and information about the type of device you use to connect to the Services. Medisense uses IP addresses to calculate usage levels of the Platform, help diagnose problems with our servers, administer our Platform, and monitor regions from which you navigate to our Platform. Location data may be used to route your traffic to the nearest regional server to reduce latency and improve your experience.
8. We do not collect, or store financial account numbers or identifications issued by a governmental entity, employer or other authority. In case you choose to make a payment on our website, you will be redirected to a payment gateway provided by a third party, offering different types of payment options and thereby collecting your financial information for the purpose of making a payment.
9. Your name, email address, and other identifiable profile information is editable through the profile settings in your account. If you would like to access, correct, amend, remove, obtain a copy, or limit the use of any Personal Data about you that has been collected and stored by us, please notify us by emailing at medical@medisense.health so that we may respond to your request. For your protection, we may need to verify your identity before fulfilling your request to access, correct, amend, remove, obtain a copy, or limit the use of your Personal Data. We will use the mobile number and email address from your request to identify the Personal Data that we have collected and stored. We will respond to your request at our earliest convenience and in compliance with the applicable law.
10. We may need to retain certain information for recordkeeping compliance, to complete transactions that you began prior to requesting such access, change or deletion, or in the event that you have an active account using our software and/or the Services. In general, we will retain your Personal Data for the period necessary to fulfil the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.
11. By actively opting into emails from us, you agree that your information may undergo processing including updating your record to reflect your affirmative request to receive emails and tracking within those emails such as when you open them and when you click on links. We use that data to determine which content resonates with you to personalize your experience with Medisense and for other marketing purposes, such as determining your interest in our Services. If you do not want to have your data processed in this manner, you can opt out of emails from Medisense or you can abstain from opting into communications. You may contact our customer care support by or emailing us at medical@medisense.health

3.2 Information We Collect from Third Party Sources

In some cases, we collect user information from third parties. We also may collect information about you that we may receive from business partners, marketers, analysts and other sources to, enable us to verify and update information contained in our records and better customize the Services for you. If required, we may also collect information from credit reporting agencies to determine your creditworthiness, credit score and credit usage, in compliance with and to the extent permitted by applicable laws. Some third parties may provide us information about you (such as the sites where you have been shown ads or demographic information) from offline and online sources that we may use to provide you more relevant and useful advertising.

3.3 Legal Bases for Processing Under law of Relevant Country

Without prejudice or clash with any of the provisions of the Law regarding protecting the privacy of Personal Data, we process your Personal Data, as set out in Section 3 below, under the following legal bases:

1. Data / Information collected either from you or through a third party
2. Our processing is necessary to perform our obligations under a contract with you or to perform steps requested by you prior to entering into a contract with you (e.g., to verify the information you have provided to us and provide the Services to you).
3. Our processing is necessary for our legitimate interests, including to protect the security of our Services; to protect the health and safety of others; to establish, protect and defend our legal rights and interests; to prevent fraud and verify identity and authorization of Users; to personalize User experiences and content; to understand and analyze usage trends; and to improve the Services.
4. Legal Compliance: Where our processing is required to comply with applicable law (for example, to maintain your payment transaction history for tax reporting purposes).

In addition, we may process information to the extent necessary to protect the health, safety or vital interests of any person and to establish, protect and defend our legal rights.

3.4 Data Retention Practice

Our privacy policy document outlines our data retention practices to ensure that we are transparent and accountable in handling user data. If a user decides to delete their account, we want to inform them that all data entered by them during registration will be deleted immediately from our platform. However, any consultations or transactions made by the user will be retained for a period of 3 years for compliance purposes. This retention period is necessary to comply with legal and regulatory requirements, resolve any disputes or claims, and to maintain an accurate record of transactions. By choosing to delete their account, users acknowledge and agree to our data retention practices.

4. USE, PROCESSING AND DISCLOSURE OF YOUR INFORMATION

We use and disclose the information we collect, in the following ways:

4.1. Providing Support and Services:

1. We generally use the information we collect from and about you to provide and operate the Services, respond to User requests, for customer service and support, to send marketing communications based on your consent (which you may withdraw at any time), to help us personalize user experiences and to improve the Services. We may share information with healthcare providers who provide Services to you, and they share information with us, for purposes related to treatment, payment and healthcare operations, and otherwise as agreed or authorized by you. We employ third parties to perform functions on our behalf. Examples include technical assistance, analyzing data, and providing marketing assistance. They have access to anonymized and non-anonymized personal information needed to perform their functions but may not use this information for other purposes. Access to this information will permit them to provide services more efficiently and effectively to you and to us. For example, your IP address may be used to estimate your location and personalize your experience with the Services; we may share information such as IP address, user name, email address, and cookie and web beacon information with third parties in order to tailor services and enable us advertise to our various market segments; your IP address and email address and the page you are viewing may be shared with a third party that operates the “chat” feature for our Services; and aggregate data about IP addresses, pages loaded, time to load pages and errors encountered may be used by third-party performance monitoring and improvement products.
2. We collect information for our legitimate reasons, including (without limitation to):
   1. Operate our Website and provide our Services to you
   2. Enable our affiliates and third parties to provide customized Services to you
   3. Run, grow and develop our business
   4. Store training and personnel records for use by you or our affiliates
   5. Sending you administrative messages and information, including, messages from our affiliates, notifications about changes to our Services; and updates to our agreements
   6. Sending you information, such as by email or text messages, about the Services chosen by you, new services, new features, promotions, newsletters, and other available Services (which you can opt out of at any time)
   7. Facilitate the Services’ technical functioning, including troubleshooting and resolving issues, securing the Services and preventing fraud and abuse
   8. Carry out research and statistical analysis
   9. Carry out marketing and business development
   10. For internal administrative and auditing purposes
   11. Improve our Services and develop new products, services, and features.
3. If we rely on our legitimate interests for using your Personal Information, we will undertake a balancing test to ensure that our legitimate interests are not outweighed by your interests or fundamental rights and freedoms which require protection of the Personal Information.
4. If we rely on your consent for us to use your Personal Information in a particular way, but you later change your mind, you may withdraw your consent by visiting your profile page and clicking the box to remove consent and we will stop doing so. If you withdraw your consent, this may impact the ability for us to provide some of our Services to you.

4.2. Verification

1. To verify the identity of Users, applicants and others with whom we interact; and
2. To confirm authorization of Users that access and use the Services.

4.3. Affiliates and Subsidiaries:

Amongst our affiliated and subsidiary companies in furtherance of the purposes set out in this Policy; their use of your information is subject to this Privacy Policy.

4.4. Third-Party Service Providers:

We use a variety of third-party service providers that perform functions on our behalf, such as public relations, legal services, billing and payment processing, content management tools, analytics, fraud and abuse prevention, data analysis, marketing and advertising services (including retargeted advertising), email and hosting services, and customer services and support etc. We share the information (you provide us with) with third parties for the purposes of carrying out the Services in a fashion customized according to your needs and preferences. These service providers may access your personal information and are required to use it solely as we direct, to provide our requested service. We require such third parties to

1. Abide by this Privacy Policy and applicable law
2. Handle personal information in a professional and confidential manner and adopt adequate security while using such information and
3. Use personal information only as needed to fulfil the relevant purposes.

4.5. Legal Compliance and Protection of Rights:

We may also use or disclose information if required to do so by law or in the good-faith belief that such action is necessary to

1. confirm to applicable law or comply with legal process served on us or the Services
2. establish, protect and defend our rights or property, the Services or our Users, including to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms & Conditions, other agreements or policies, or as evidence in litigation in which we are involved
3. act under emergency circumstances to protect the personal safety of us, our affiliates, agents, or Users of the Services or the public which includes exchanging information with other companies and organizations for fraud protection and
4. to fully cooperate with law enforcement agencies in identifying those who use our services for illegal activities and may, in our sole discretion, disclose personal information or other information to satisfy any law, regulation or government request.

4.6. Aggregate/Anonymous Information:

We may share aggregate/anonymous information about use of the Services with third parties for research, marketing, analytics and other purposes, provided such information does not identify a particular individual. The sharing of such data is unrestricted.

4.7. Business Transfers:

As we continue to develop our business, we may seek to buy, merge, or partner with other companies. In such transactions, (including in contemplation of such transactions) user information may be among the transferred assets. If a portion or all of our assets are sold or transferred to a third party, customer information would likely be one of the transferred business assets. If such transfer is subject to additional mandatory restrictions under applicable laws, we will comply with such restrictions.

4.8. Marketing and Promotions

We may use the information you provide us with to send you information, news, updates and offers about us or our Services (subject to your consent where required by applicable law).

4.9. Personalize Service and Ads

We may use the information you provide us with for the following purposes:

1. To personalize content and experiences on our Services, including providing you reports, recommendations, and feedback based on your preferences.
2. To better target ads so that Users receive ads that are relevant to them.

To request more information about the companies to whom we have disclosed your information, please contact us as set out in the “Contact Information” section.

5. ADVERTISING

In order to have more relevant advertising on our Services and to manage our advertising that third parties may engage in, and to measure and improve our ads and marketing efforts, we may work with advertising companies, ad exchanges, channel partners, measurement services and ad networks.

These companies may employ various tools and advances to measure advertising effectiveness. They may also use this technology to serve specialized or relevant advertising content. Any information that these third parties collect is completely anonymous and does not contain any personal contact information.

6. HOW WE PROTECT YOUR INFORMATION

All the personal and non-personal information you provide us with will be secured and safely stored on both our paper and digital records. We shall exercise utmost care and caution with respect to maintaining the confidentiality of all of your information. We use various technical and management practices to help protect the confidentiality, security and integrity of data stored on our system. We shall use strict security procedures, data protection tools and anti-virus/hacking technology to prevent data loss or unauthorised access. We use account information in a password-protected environment as a security measure to protect your data. We use administrative, physical, and technical safeguards to protect data. We maintain a high level of data protection via safeguards such as data backup, audit controls, access controls, and data encryption. We use industry standard SSL/TLS encryption to enhance security of electronic data transmissions. We urge you to take precautionary measures in maintaining the integrity of your data. Please be responsible for making sure no one can see or access your account and log-in/password information. If you use our Services through a potentially non-secure internet connection, such use is at your own risk. We are not responsible for your handling, sharing, re-sharing and/or distribution of your Personal Data. Moreover, if you forward your Personal Data electronically to another person on or off the Services, we are not responsible for any harm or other consequences from third party use or re-sharing of your information.

7. SECURITY

We strive to ensure the security, integrity and privacy of your Personal Information and Personal Data and to protect it against unauthorized access or unauthorized alteration, disclosure or destruction. We implement appropriate physical, electronic and managerial procedures to safeguard and help prevent unauthorized access and for the purposes of maintaining data security. Our payment gateway partners are compliant with the payment card industry standard (PCI standard) and also use SSL secured communication channels, encryption, passwords and physical security measures in order to protect the Personal Information and Personal Data of Users.

However, we cannot guarantee absolute security as no method of protection and transmission of data is completely secure. We are also not responsible for any breach of security or for any actions of any Third Parties that receive your Personal Information. Notwithstanding anything contained in this Policy or elsewhere, we shall not be held responsible for any loss, damage or misuse of your Personal Information or Personal Data, if such loss, damage or misuse is attributable to any event that is beyond our reasonable control.

8. RETENTION OF YOUR INFORMATION

We retain your information for as long as required to satisfy the purpose for which it is collected and used (for example, for the time necessary for us to provide you with customer service, answer queries or resolve technical problems), unless a longer period is necessary for our legal obligations or to establish, protect, or defend legal claims.

9. CHANGES TO THE PRIVACY POLICY

We reserve the right to amend this Privacy Policy at any time to reflect changes in the law, our data collection and use practices, the features of our Services, or advances in technology. If we make a material change to the Privacy Policy, you will be provided with appropriate notice in accordance with legal requirements. By continuing to use the Services, you are confirming that you have read and understood the latest version of this Privacy Policy.

10. YOUR CHOICES

If you would like to update your preferences on the types of communications you receive from us, or opt out of marketing communications from us, you may do so at any time Please note that we may continue to send non-promotional communications such as important notices, payment confirmations and transaction-related emails and other information about your use of the Services. If you would like to opt-out of marketing, you may also do so by emailing us your request at medical@medisense.health

11. RIGHTS OF ACCESS OF DATA SUBJECT

Subject to applicable law and as explained in this section, you may have certain rights with respect to the information we collect and process about you.

11.1 Access, Correction, Deletion and Objection Rights: You may have the right to access, request correction and deletion of, and object to our use of your information. To exercise your rights, please contact us as set forth in the “Contact Information” section below. You may also access and modify much of the information that you have submitted either by telephone or email. In addition, we may retain certain information about you as required by law or as permitted by law for legitimate business purposes. For example, if you request that we delete your information, but we believe that you have violated our Terms of Use, we may retain information about you in order to attempt to resolve the issue before deleting it

11.2. Complaints:

If applicable, you may make a complaint to the privacy regulator or supervisory authority where you are based. Alternatively, you may seek a remedy through local courts if you believe your rights have been breached.

You are entitled to the following rights under the applicable law:

1. To obtain access to and/or a copy of certain information we hold about you
2. To obtain, in certain circumstances, a copy of certain information we have of yours in a structured, commonly used and machine-readable format, and to ask us to transfer this to a third party of your choice
3. To request that we update your information we hold that is out of date
4. To request that we delete certain information we hold about you
5. To request that we restrict the way we process and disclose certain of your information
6. To revoke your consent for the processing of your information, to the extent our processing of your information is not based on another legal basis; and
7. To object to certain processing of your information as follows
   1. Right to object to direct marketing: you may object to our processing of your information for direct-marketing purposes (including any direct marketing processing based on profiling).
   2. Right to object to processing (including profiling) based on legitimate interest grounds. In addition, where we are relying upon our legitimate interests to process information, you may object to that processing. If you object, we must stop that processing unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms, or we need to process the information for the establishment, exercise or defense of legal claims. We will consider each case on an individual basis.

12. CONTACT INFORMATION

You may exercise your rights or make a request regarding your information held by us, request further information about your legal rights under applicable law, or submit a complaint about our privacy practices by contacting us at any time, using the contact details set forth below.

We will consider all requests and provide our response within the time period stated by applicable law. Please note, however, that certain information may be exempt from such requests in some circumstances, if we need to keep processing your information to provide services to you or to comply with a legal obligation. Moreover, you will not be permitted to examine the information of any other person or entity. We also may request you provide us with information necessary to confirm your identity before responding to your request.

If you have any questions about this Privacy Policy or would like to exercise your rights regarding your information that we hold or would like to raise a complaint with us related to your information, you should contact us as at medical@medisense.health