PRIVACY POLICY

 

 

This Privacy Policy (“Policy”) describes the policies and procedures on the collection, use, disclosure and protection of your information when you use our website located at www.orangehealth.in, or the [Orange Health] mobile application (collectively, “Application”) that are the proprietary materials of [Orchard Healthcare Private Limited] an Indian company having its registered office at 4th Floor, No 22, Salarpuria Towers - I, Hosur Road Koramangala, Bangalore 560095 (hereinafter referred as “Orange Health” or “Company” or “Us” or “We”).

 

The terms “you” and “your” refer to the user of the Application. The term “Services” refers to any services offered by Orange Health including by allowing access of the Application to you or the services that are enables through your use of the Application.

 

Please read this Policy before using the Application or submitting any personal information to Orange Health. This Policy is a part of and incorporated within, and is to be read along with, the Terms of Use published at www.orangehealth.in/terms. Any capitalized term use but not defined shall have the same meaning as ascribed to it in the Terms of Use.
 

 

1. YOUR CONSENT

 

By using the Application and/or the Services, you agree and consent to the collection, transfer, use, storage, disclosure and sharing of your information as described and collected by us in accordance with this Policy.  If you do not agree with the Policy, please do not access the Application or use any of the Services.

 

If you use the Application and/or the Services on behalf of someone else (such as your child) or an entity (such as your employer), you represent that you are authorised by such individual or entity to (i) accept this 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 information as described in this Policy.
 

 

2. STRUCTURE AND BASIS

 

a) This Policy is published in compliance with, inter alia:

 

i. Section 43A of the Information Technology Act, 2000 (“IT Act”);
 

ii. Regulation 4 of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011 (the “Privacy Rules”);
 

iii. Regulation 3(1) of the Information Technology (Intermediaries Guidelines) Rules, 2011.
 

 

b) This Privacy Policy states the following:

 

i. The type of information collected from the Users, including Personal Information and Sensitive Personal Data or Information (as defined in the Privacy Rules) relating to a User;


ii. The purpose, means and modes of collection, usage, processing, retention and destruction of such information; and


iii. How and to whom Orange Health will disclose such information.
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3. INFORMATION WE COLLECT FROM YOU

 

We will collect and process the following information about you:

 

a) Information you give us - This includes information submitted when you:

 

i. Create or update your Orange Health user account, which may include your name, gender, address (including pin code), date of birth, email id, phone number, photograph, national identification proof, login name and password; if you are an End User , we will also collect information about your medical history (drug allergies, chronic conditions), health habits, health indicators (BMI, weight, height), diagnostics reports, prescriptions, or any pictures/ photos/ files or other content shared by you. If you are a RMP, we will collect information that include your practice details and specialty, years of experience, proofs of educational / technical qualifications, proofs of certifications and affiliations, registration details with the National Medical Council, State Medical Council or such similar authorities/bodies. or

ii. Use our Services, we may collect and store information about you to process your requests and automatically complete forms for future transactions, including (but not limited to) your phone number, address, email, RMPs consulted in the past, diagnostic reports, billing information and credit or payment card information.

iii. Correspond with Orange Health for customer support;

iv. Enable features that require Orange Health's access to any content (e.g.- photo gallery, contact details etc.) stored in or any feature or functionality (e.g. – camera, calendar, location etc.) of the device that you use to access the Application;

v. Report problems for troubleshooting.

 

b) Information we collect about you – We will automatically collect and analyse the following demographic and other information each time that you use the Application:

 

i. Communications: When you communicate with us (via email, text, phone, through the Application or otherwise), we may maintain a record of your communication;

ii. Location information: Depending on the Services that you use, and your app settings or device permissions, we may collect your real time information, or approximate location information as determined through data such as GPS, IP address;

iii. Transaction Information: We collect transaction details related to your use of our Services, the Users (i.e. End User or RMP) that you interact with  by use of our Application, and information about your activity on the Services, including the full Uniform Resource Locators (URL), the type of Services you requested or provided, comments, domain names, search results selected, number of clicks, information and pages viewed and searched for, the order of those pages, length of your visit to our Services, the date and time you used the Services, amount charged, methods used to browse away from the page and any phone number used to call our customer service number and other related transaction details;

 

iv. Record stored on the Application: Any diagnostic report, prescriptions or such other record or file that is rendered through the Application and/or is uploaded on to the Application by you.


 

4. COOKIES

 

The Application uses temporary cookies to store certain (that is not sensitive personal data or information) that is used by Orange Health and its service providers for the technical administration of the Application, research and development, and for User administration. In the course of serving advertisements or optimizing services (such as recording User preferences) to its Users, Orange Health may allow authorized third parties to place or recognize a unique cookie on the User’s browser. The cookies, however, do not store any personal information of the User. You may adjust your internet browser to disable cookies. If cookies are disabled you may still use the Website, but the Website may be limited in the use of some of the features.
 

 

5. USES OF YOUR INFORMATION

 

a) We use the information we collect for following purposes:

 

i. To provide the Services that you choose to receive through or by use of the Application and to fulfil any obligations inuring upon us therefrom;

ii. To communicate with you in relation to your use of the Services, including to provide customer support services, to send reminders etc.

iii. To provide, personalize, maintain and improve the features and functionalities of the Application and the Services;

iv. To administer and enhance the security of our Application and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;

v. To provide you with information about Services we consider similar to those that you are already using, or have enquired about, or may interest you. If you are a registered user, we will contact you by electronic means (e-mail or SMS or whatsapp or telephone) with information about these services;

vi. To generate and review reports and data about, and to conduct research on, our user base and Service usage patterns;

vii. To allow you to participate in interactive features of our Services, including receiving any feedback; or

viii. To use the information on an aggregated basis (which would be de-identified if it is Personal Information or Sensitive Personal Data or Information) for research, statistical analysis or business intelligence purposes whether for internal operations or other commercial purpose.

 

b) We may combine the information that we receive from third parties with the information you give to us and information we collect about you for the purposes set out above.  Further, we may anonymize and/or de-identify information collected from you through the Services or via other means, including via the use of third-party web analytic tools. As a result, our use and disclosure of aggregated and/or de-identified information is not restricted by this Policy, and it may be used and disclosed to others without limitation.


6. DISCLOSURE AND DISTRIBUTION OF YOUR INFORMATION

 

We may share your information that we collect for following purposes:

 

a) With Service Providers: We may share your information with our vendors, consultants, marketing partners, research firms and other service providers or business partners, to the extent it is necessary to (i) render Services to you (ii) enable the features and functionalities of the Application. Illustratively, if you are a End User your Personal Information and Sensitive Personal Data and Information will be shared with our business partners for providing diagnostic services or with the RMPs to provide consultation to you or with a Pharmacy to deliver the medicines ordered through the Application. We may also share your information with a third party vendor to carry out any of the purposes for which such information was collected that are illustrated in clause 5(a) of this Policy.

b) For Compliance with Laws: We may share this information with governmental agencies or other agencies assisting us, when we are:

 

i. Obligated under the applicable laws or in good faith to respond to directions from legal/statutory authorities including police officials, courts etc.; or


ii. Responding to claims that an advertisement, posting or other content violates the intellectual property rights of a third party;


iii. Under a duty to disclose or share your personal data in order to enforce our Terms of Use and other agreements, policies or to protect the rights, property, or safety of the Company, our customers, or others, or in the event of a claim or dispute relating to your use of our Services. This includes exchanging information with other companies and organizations for the purposes of fraud detection and credit risk reduction.

 

c) For Internal Use: We may share your information with any present or future member of our “Group” (as defined below)or affiliates for our internal business purposes The term “Group” means, with respect to any person, any entity that is controlled by such person, or any entity that controls such person, or any entity that is under common control with such person, whether directly or indirectly, or, in the case of a natural person, any Relative (as such term is defined in the Companies Act, 1956 and Companies Act, 2013 to the extent applicable) of such person.
 

 

7. DATA SECURITY PRECAUTIONS

 

a) Your Personal Information and Sensitive Personal Data and Information is maintained by Orange Health in electronic form on equipment and digital resources owned or controlled by it. This information may be converted to physical form as and when deemed necessary for any business purpose. Orange Health takes all reasonable precautions to protect your Personal Information and Sensitive Personal Data and Information both online and off-line, and implements reasonable security practices and measures including certain managerial, technical, operational and physical security control measures that are commensurate with respect to the information being collected and the nature of Orange Health’s business.

b) Orange Health does not have access nor is aware of the passwords enabled by the Users to access their accounts maintained with Orange Health, whether in their capacity of an End User, RMP or any other category of User.

c) Orange Health makes all User information accessible to its employees, agents, vendors and third parties only on a need-to-know basis and binds them with confidentiality obligations.

d) Notwithstanding the above, Orange Health is not responsible for the confidentiality, security or distribution of your Personal Information or Sensitive Personal Data and Information by our service provider, vendors and third parties outside the scope of our agreement with such service provider, vendors and third parties. Further, Orange Health 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 Orange Health including but not limited to, acts of government, computer hacking, unauthorised access to computer data and storage device, computer crashes, breach of security and encryption, poor quality of Internet service or telephone service of the User etc.
 

 

8. LINKS TO OTHER WEBSITES

 

The Application may contain links to other websites. Any personal information about you collected when you browse such websites is not governed by this Policy. Orange Health shall not be responsible for and has no control over the practices and content of any website accessed using the links contained on the Application. This Policy shall not apply to any information you may disclose to any of our service providers/service personnel which we do not require you to disclose to us or any of our service providers under this Policy.

 

 

9. POLICY CHANGES

 

We may occasionally update this Policy and such changes will be posted on this page. If we make any significant changes to this Policy we will endeavour to provide you with reasonable notice of such changes, such as via prominent notice on the Application or to your email address on record and where required by applicable law, we will obtain your consent. To the extent permitted under the applicable law, your continued use of our Services after we publish or send a notice about our changes to this Policy shall constitute your consent to the updated Policy.


10. GRIEVANCE OFFICER AND APPLICATION SECURITY

 

If you have any queries relating to the processing or usage of information provided by you in connection with this Policy, please email us at (hello)_at_(orangehealth_dot_in) or write to our Grievance Officer at the following address: Orchard Healthcare Pvt Ltd, Floor 4, Salarpuria Towers 1, 29 Hosur Road, Koramangala, Bangalore 560029

 

 

Further, please note that the Application stores your data with the cloud platform of [Amazon Web Services] provided by [Amazon Web Services, Inc.,] which may store this data on their servers located outside of India. [Amazon Web Services] has security measures in place to protect the loss, misuse and alteration of the information, details of which are available at [https://aws.amazon.com/]. The privacy policy adopted by Amazon Web Services are detailed in [https://aws.amazon.com/privacy.] In the event you have questions or concerns about the security measures adopted by Amazon Web Services, you can contact their data protection / privacy team / legal team or designated the grievance officer at these organisations, whose contact details are available in its privacy policy, or can also write to our Grievance Officer at the address provided above.