- Section 43A of the Information Technology Act, 2000;
- Regulation 4 of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011 (the “SPI Rules”);
- Regulation 3(1) of the Information Technology (Intermediaries Guidelines) Rules, 2011.
2.COLLECTION OF PERSONAL INFORMATION
Generally some of the Services require us to know who you are so that we can best meet your needs. When you access the Services, or through any interaction with us via emails, telephone calls or other correspondence, we may ask you to voluntarily provide us with certain information that personally identifies you or could be used to personally identify you. You hereby consent to the collection of such information by wetogether. Without prejudice to the generality of the above, information collected by us from you may include (but is not limited to) the following:
- contact data (such as your email address and phone number);
- demographic data (such as your gender, your date of birth and your pin code); data regarding your usage of the services and history of the appointments made by or with you through the use of Services;
- other information that you voluntarily choose to provide to us (such as information shared by you with us through emails or letters.
The information collected from you by wetogether may constitute ‘personal information’ or ‘sensitive personal data or information’ under the SPI Rules.
“Personal Information” is defined under the SPI Rules to mean any information that relates to a natural person, which, either directly or indirectly, in combination with other information available or likely to be available to a body corporate, is capable of identifying such person.
The SPI Rules further define “Sensitive Personal Data or Information” of a person to mean personal information about that person relating to:
- financial information such as bank accounts, credit and debit card details or other payment instrument details;
- physical, physiological and mental health condition;
- sexual orientation;
- medical records and history;
- biometric information;
- information received by body corporate under lawful contract or otherwise;
- visitor details as provided at the time of registration or thereafter; and
- wetogether will be free to use, collect and disclose information that is freely available in the public domain without your consent.
All Health records created either on the website or on the in clinic application are based upon your consent. Such consent is deemed to be given when you visit the website or the clinic. It is the sole responsibility of the clinic to make patients aware that the said establishment uses Q UP software and services. wetogether will not be held liable for the failure of such communication from clinic/practitioner. If you do not want to create your record please inform the clinic or doctor expressly. In the case that you may wish to remove such a record you may contact us on firstname.lastname@example.org Do note your data may still be held after removing personal identifiers mentioned above to facilitate continued services or analysis.
3.1 ALL USERS NOTE:
This section applies to all users.
3.1.3 All the information provided to wetogether by a User, including Personal Information or any Sensitive Personal Data or Information, is voluntary. You understand that wetogether may use certain information of yours, which has been designated as Personal Information or ‘Sensitive Personal Data or Information’ under the SPI Rules, (a) for the purpose of providing you the Services, (b) for commercial purposes and in an aggregated or non-personally identifiable form for research, statistical analysis and business intelligence purposes, (c) for sale or transfer of such research, statistical or intelligence data in an aggregated or non-personally identifiable form to third parties and affiliates (d) for communication purpose so as to provide You a better way of booking appointments and for obtaining feedback in relation to the Practitioners and their practice, (e) debugging customer support related issues. wetogether also reserves the right to use information provided by or about the End-User for the following purposes:
- Publishing such information on the Website.
- Contacting End-Users for offering new products or services.
- Contacting End-Users for taking product and Service feedback.
- Analyzing software usage patterns for improving product design and utility.
- Analyzing anonymized practice information for commercial use.
If you have voluntarily provided your Personal Information to wetogether for any of the purposes stated above, you hereby consent to such collection and use of such information by wetogether. However, wetogether shall not contact You on Your telephone number(s) for any purpose including those mentioned in this sub-section 4.1(iii), if such telephone number is registered with the Do Not Call registry (“DNC Registry”) without your express, clear and un-ambiguous written consent.
3.1.5 wetogether does not control or endorse the content, messages or information found in any Services and, therefore, wetogether specifically disclaims any liability with regard to the Services and any actions resulting from your participation in any Services, and you agree that you waive any claims against wetogether relating to same, and to the extent such waiver may be ineffective, you agree to release any claims against wetogether relating to the same.
3.1.6 You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information provided as part of account registration. If your personal information changes, you may correct, delete inaccuracies, or amend information by making the change on our member information page or by contacting us through email@example.com. We will make good faith efforts to make requested changes in our then active databases as soon as reasonably possible. There may be circumstances where wetogether will not correct, delete or update your Personal Data, including (a) where the Personal Data is opinion data that is kept solely for evaluative purpose; and (b) the Personal Data is in documents related to a prosecution if all proceedings relating to the prosecution have not been completed.
3.1.7 If you wish to cancel your account or request that we no longer use your information to provide you Services, contact us through firstname.lastname@example.org We will retain your information for as long as your account with the Services is active and as needed to provide you the Services. We shall not retain such information for longer than is required for the purposes for which the information may lawfully be used or is otherwise required under any other law for the time being in force. After a period of time, your data may be anonymized and aggregated, and then may be held by us as long as necessary for us to provide our Services effectively, but our use of the anonymized data will be solely for analytic purposes. Please note that your withdrawal of consent, or cancellation of account may result in wetogether being unable to provide you with its Services or to terminate any existing relationship wetogether may have with you.
3.1.8 If you wish to opt-out of receiving non-essential communications such as promotional and marketing-related information regarding the Services, please send us an email at email@example.com.
3.1.9 Due to the communications standards on the Internet, when a User or the End-User or anyone who visits the Website, wetogether automatically receives the URL of the site from which anyone visits. wetogether also receives the Internet Protocol (IP) address of each User’s computer (or the proxy server a User used to access the World Wide Web), User’s computer operating system and type of web browser the User is using, email patterns, as well as the name of User’s ISP. This information is used to analyze overall trends to help wetogether improve its Service. The linkage between User’s IP address and User’s personally identifiable information is not shared with or disclosed to third parties. Notwithstanding the above, wetogether may share and/or disclose some of the aggregate findings (not the specific data) in anonymized form (i.e., non-personally identifiable) with advertisers, sponsors, investors, strategic partners, and others in order to help grow its business.
3.1.10 The Website uses temporary cookies to store certain (that is not sensitive personal data or information) that is used by wetogether and its service providers for the technical administration of the Website, research and development, and for User administration. In the course of serving advertisements or optimizing services to its Users, wetogether 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.
3.1.11 A User may have limited access to the Website without creating an account on the Website. Users can make appointments with the doctors by providing their name and phone number through Mobile Application.
3.1.15 wetogether has implemented best market practices and security policies, rules and technical measures to protect the personal data that it has under its control from unauthorised access, improper use or disclosure, unauthorised modification and unlawful destruction or accidental loss. However, for any data loss or theft due to unauthorized access to the User’s electronic devices through which the User avails the Services, wetogether shall not be held liable for any loss whatsoever incurred by the User.
3.1.16 wetogether implements reasonable security practices and procedures and has a comprehensive documented information security programme and information security policies that contain managerial, technical, operational and physical security control measures that are commensurate with respect to the information being collected and the nature of wetogether’s business.
3.2 PRACTITIONERS NOTE
This section applies to all Practitioners.
3.2.1 As part of the registration as well as the application creation and submission process that is available to Practitioners on wetogether, certain information, including Personal Information or Sensitive Personal Data or Information is collected from the Practitioners.
3.2.3 Practitioners’ personally identifiable information, which they choose to provide to wetogether, is used to help the Practitioners describe and identify themselves. This information is exclusively owned by wetogether. You will be the owner of your information and you consent to wetogether collecting, using, processing and/or disclosing this information for the purposes hereinafter stated . wetogether may use such information for commercial purposes and in an aggregated or non-personally identifiable form for research, statistical analysis and business intelligence purposes. wetogether also reserves the right to use information provided by or about the Practitioner for the following purposes:
- Publishing such information on the Website.
- Contacting Practitioners for offering new products or services.
- Contacting Practitioners for taking product feedback.
- Analyzing software usage patterns for improving product design and utility.
- Analyzing anonymized practice information including financial, and inventory information for commercial use.
3.2.4 wetogether automatically enables the listing of Practitioners’ information on its Website for every ‘Doctor’ or ‘Clinic’ added to a Practice using its software. The Practitioner information listed on Website is displayed when End-Users search for doctors on Website, and the Practitioner information listed on Website is used by End-Users to request for doctor appointments. Any personally identifiable information of the Practitioners listed on the Website is not generated by wetogether and is provided to wetogether by Practitioners who wish to enlist themselves on the Website, or is collected by wetogether from the public domain. wetogether displays such information on its Website on an as-is basis making no representation or warranty on the accuracy or completeness of the information. As such, we strongly encourage Practitioners to check the accuracy and completeness of their information from time to time, and inform us immediately for any discrepancies, changes or updates to such information. wetogether will, however, take reasonable steps to ensure the accuracy and completeness of this information.
3.2.5 wetogether may also display information for Practitioners who have not signed up or registered for the Services, provided that the Practitioners have consented to wetogether collecting, processing and/or disclosing their information on the Website. Such Practitioners are verified by wetogether or its associates, and wetogether makes every effort to capture accurate information for such Practitioners. However, wetogether does not undertake any liability for any incorrect or incomplete information appearing on the Website for such Practitioners.
3.3 END-USERS NOTE
This section applies to all End-Users.
3.3.1 As part of the registration/application creation and submission process that is available to End-Users on this Website, certain information, including Personal Information or Sensitive Personal Data or Information is collected from the End-Users.
3.3.3 If you have inadvertently submitted any such information to wetogether prior to reading the privacy statements set out herein, and you do not agree with the manner in which such information is collected, processed, stored, used or disclosed, then you may access, modify and delete such information by using options provided on the Website. In addition, you can, by sending an email to firstname.lastname@example.org, inquire whether wetogether is in possession of your personal data, and you may also require wetogether to delete and destroy all such information.
3.3.4 End-Users’ personally identifiable information, which they choose to provide on the Website is used to help the End-Users describe/identify themselves. Other information that does not personally identify the End-Users as an individual, is collected by wetogether from End-Users (such as, patterns of utilization described above) and is exclusively owned by wetogether. wetogether may also use such information in an aggregated or non-personally identifiable form for research, statistical analysis and business intelligence purposes. In particular, wetogether reserves with it the right to use anonymized End-User demographics information and anonymized End-User health information for the following purposes:
- Analyzing software usage patterns for improving product design and utility.
- Analyzing such information for research and development of new technologies.
- Using analysis of such information in other commercial product offerings of wetogether.
- Sharing analysis of such information with third parties for commercial use.
3.3.5 wetogether will communicate with the End-Users through email, phone and notices posted on the Website or through other means available through the service, including text and other forms of messaging. The End-Users can change their e-mail and contact preferences at any time by logging into their "Account" at www.qupapp.comand changing the account settings.
3.3.6 wetogether may keep records of electronic communications and telephone calls received and made for making appointments or other purposes for the purpose of administration of Services, customer support, research and development and for better listing of Practitioners.
3.3.7 All wetogether employees and data processors, who have access to, and are associated with the processing of sensitive personal data or information, are obliged to respect the confidentiality of every End-Users’ Personal Information or Sensitive Personal Data and Information. Q UP has put in place procedures and technologies as per good industry practices and in accordance with the applicable laws, to maintain security of all personal data from the point of collection to the point of destruction. Any third-party data processor to which wetogether transfers Personal Data shall have to agree to comply with those procedures and policies, or put in place adequate measures on their own.
3.4 CASUAL VISITORS NOTE
3.4.1 No sensitive personal data or information is automatically collected by wetogether from any casual visitors of this website, who are merely perusing the Website.
3.4.3 If you, as a casual visitor, have inadvertently browsed any other page of this Website prior to reading the privacy statements set out herein, and you do not agree with the manner in which such information is obtained, collected, processed, stored, used, disclosed or retained, merely quitting this browser application should ordinarily clear all temporary cookies installed by wetogether. All visitors, however, are encouraged to use the “clear cookies” functionality of their browsers to ensure such clearing / deletion, as wetogether cannot guarantee, predict or provide for the behaviour of the equipment of all the visitors of the Website.
4.CONFIDENTIALITY AND SECURITY
4.1 Your Personal Information is maintained by wetogether in electronic form on its equipment, and on the equipment of its employees. Such information may also be converted to physical form from time to time. wetogether takes all necessary precautions to protect your personal 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 wetogether’s business.
4.2 Your Personal Information is maintained by wetogether in electronic form on its equipment, and on the equipment of its employees. Such information may also be converted to physical form from time to time. wetogether takes all necessary precautions to protect your personal 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 wetogether’s business.
4.3 wetogether makes all User information accessible to its employees, agents or partners and third parties only on a need-to-know basis, and binds only its employees to strict confidentiality obligations.
4.4 Part of the functionality of wetogether is assisting the doctors to maintain and organise such information. wetogether may, therefore, retain and submit all such records to the appropriate authorities, or to doctors who request access to such information.
4.5 Part of the functionality of the wetogether is assisting the patients to access information relating to them. wetogether may, therefore, retain and submit all such records to the relevant patients, or to their doctors.
4.6 Notwithstanding the above, wetogether is not responsible for the confidentiality, security or distribution of your Personal Information by our partners and third parties outside the scope of our agreement with such partners and third parties. Further, wetogether 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 wetogether 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.
6.CHILDREN'S AND MINOR'S PRIVACY
wetogether strongly encourages parents and guardians to supervise the online activities of their minor children and consider using parental control tools available from online services and software manufacturers to help provide a child-friendly online environment. These tools also can prevent minors from disclosing their name, address, and other personally identifiable information online without parental permission. Although the wetogether Website and Services are not intended for use by minors, wetogether respects the privacy of minors who may inadvertently use the internet or the mobile application.
7. CONSENT TO THIS POLICY
8. ADDRESS FOR PRIVACY QUESTIONS
Name:Mrs. Santoshi Sawant,
Phone: 7387728809 (Ask to be connected to Mrs. Santoshi Sawant)
Indicative List of Information by Nature of Service
- End-Users registering for an account on ‘wetogether’ mobile application: You can create an account by giving us information regarding your [name, mobile number], and such other information as requested on the End-User registration page. This is to enable us to provide you with the facility to use the account to book your appointments and store other health related information.
- Practitioner availing of the free listing service on the Website or ‘wetogether’ mobile application by registering for an account: As a Practitioner, you may be required to provide us with information regarding your [name, mobile number, email address], and such other information as requested. wetogether may send email and/or SMS confirmations or other communications to End-Users in connection with their bookings, appointments or other interactions with you, if such interactions have been facilitated by wetogether.
10.TRAFFIC DATA COLLECTED
We automatically track and collect the following categories of information when you visit our Site: (1) IP addresses; (2) domain servers; (3) types of devices accessing the Site; (4) types of web browsers used to access the Site; (5) referring source which may have sent you to the Site; and (6) other information associated with the interaction of your browser and the Site (collectively "Traffic Data”).
11.INTERACTIVE AND INSTALLED TOOLS
We also collect other information, some of which may be Personal Information that you voluntarily provide to us when you choose to use some of the our interactive tools and services ("Interactive Tools"), such as searching for Providers and searching for available appointments with them. We also collect information you provide voluntarily in free-form text boxes on the Site and through responses to surveys, questionnaires and the like. Some of the free Interactive Tools on our Site ask you for health-related Personal Information. You may elect to use certain Services available through the Site that require you to download and install software on your computer ("Installed Tools"). The Installed Tools may collect and transmit information from your computer system solely relating to use of the Installed Tools and for the purpose of providing you the relevant Services, for example, by informing wetogether when a user is logged on and available to receive update or alert notices.
We may use third party website analytics services in connection with the Site. These website analytics services do not collect Personal Information that you do not voluntarily enter into the Site. These services do not track your browsing habits across websites which do not use their services. We are using the information collected from these services to find usability problems to make the Site easier to use. The recordings will never identify you or your account.
We store all Traffic Data and review postings indefinitely, even after "deletion," and may archive such information elsewhere. We store all Personal Information until you request that we modify or delete it, in which case we may still wind up retaining some of that information.
14.Q UP'S USE OF YOUR INFORMATION
We may use your Personal Information to recommend certain resources or medical providers. We may use your Contact Data to send you information about wetogether or our products or Services, to contact you when necessary, including to remind you of upcoming or follow-up appointments, and in conjunction with your use of certain Interactive Tools. We may use your Demographic Data, your Traffic Data, your Insurance Data or your Medical Data to customize and tailor your experience on the Site, in emails and in other communications, displaying content that we think you might be interested in and according to your preferences. You agree that wetogether may use Personal Information to allow your doctors to make appointments with other doctors on your behalf through the Services. We may also use your de-identified Personal Information to run (or authorize third parties to run) statistical research on individual or aggregate health or medical trends. Such research would only use your Personal Information in an anonymous manner that cannot be tied directly back to you.
15.SHARING OF INFORMATION
16. LINKS TO OTHER WEBSITES