Hospitto Prime LLP (“Hospitto”,“we”, or “us”, which also includes its affiliates) is the author andpublisher of the internet resource www.hospitto.com (“Website”) on the world wide web as well as the applications and software provided by Hospitto, including but not limited to the mobile application ‘Hospitto’, and the application and software of the brand names ‘Hospitto.com’, ‘Hospitto prime ’, (together with the Website, referred to as the “Services”).
a. Section 43A of the Information Technology Act, 2000;
b. Regulation 4 of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011 (the “SPI Rules”);
c. Regulation 3(1) of the Information Technology (Intermediaries Guidelines) Rules, 2011.
d. The type of information collected from the Users, including Personal Information (as defined in paragraph 2 below) and Sensitive Personal Data or Information (as defined in paragraph 2 below) relating to an individual;
e. The purpose, means and modes of collection, usage, processing, retention and destruction of such information; and
f. How and to whom Hospitto will disclose such information.
2. COLLECTION OF PERSONAL INFORMATION
Generally, some of the Services require us to know who you are so that we can meet your needs to the fullest. 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 Hospitto. Without prejudice to the generality of the above information collected by us from you may include (but is not limited to) the following:
a. contact data (such as your phone number and email address);
b. demographic data (such as your gender, your pin code and date of birth);
c. data regarding your usage of the services and history of the appointments made by or with you through the use of Services;
d. insurance data (such as your insurance plan and insurance carrier);
e. Other information that you voluntarily choose to provide us (such as information shared by you with us through emails or letters.
The information collected from you by Hospitto 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:
f. medical records and history;
g. financial information such as bank accounts, credit and debit card details or other payment instrument details;
h. physical, physiological and mental health condition;
i. sexual orientation;
j. call data records;
l. biometric information;
m. information received by body corporate under lawful contract or otherwise; and
n. visitor details as provided at the time of registration or thereafter;
You understand and agree that Hospitto is free to use, collect and disclose information that is freely available in the public domain without your consent.
3. PRIVACY STATEMENTS
3.1 ALL USERS NOTE:
This section applies to all users.
3.1.3 All the information provided to Hospitto by a User, including any Sensitive Personal Data or information or Personal Information is voluntary. You understand that Hospitto 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 sale or transfer of such research, statistical or intelligence data in an aggregated or non-personally identifiable form to third parties and affiliates (c) for commercial purposes and in an non-personally identifiable or aggregated form for statistical analysis, research and business intelligence purposes, (d) for communication purpose so as to furnish an improved way of appointments booking and obtaining feedback in relation to the Practitioners and their medical practice, (e) debugging customer support related issues.Hospitto also reserves the right to use information provided by or about the End-User for the following purposes:
I. Publishing such information on the Website.
II. Contacting End-Users for offering new products or services.
III. Analysing software usage patterns for improving product design and utility.
IV. Contacting End-Users for taking product and Service feedback.
V. Analysinganonymized practice information for commercial use.
If you have voluntarily provided your Personal Information to Hospitto for any of the purposes stated above, you hereby consent to such collection and use of such information by Hospitto. However, Hospitto 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”) under the PDPA without your clear, express and unambiguous written consent.
3.1.5 Hospitto does not control or endorse the content, messages or information found in any Services
and, therefore, Hospitto 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 Hospitto relating to same, and to the extent such waiver may be ineffective, you agree to release any claims against Hospitto relating to the same.
3.1.6You are solely responsible for maintaining the accuracy of the information you submit to us, such as
contact information provided as part of account registration. If there is any change in the personal information previously submitted by you then, you mayamend, correct or delete the inaccuracies in the information by making the change on our member information page or by contacting us through firstname.lastname@example.org.Hospitto will makegenuine efforts to make the requested changes in our active databases as soon as it is reasonably practicable. If you provide any information that is inaccurate, untrue, out of date or incomplete (or becomes inaccurate, untrue, out of date or incomplete), or Hospitto has reasonable grounds to suspect that the information provided by you is inaccurate, untrue, out of date or incomplete, then Hospitto may, at its sole discretion, discontinue the provision of the Services to you. There may be circumstances where Hospitto will not update, correct or delete 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.
3.1.7If you wish to cancel your account or request that we no longer use your information to provide
youServices, contact us email@example.com. We will retain your information for as long as your account with the Services is active and as needed to provide you the Services. Hospitto shall not withhold 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 the use of this anonymized data will be solely for the analytic purposes. Please note that your withdrawal of consent or cancellation of account may result in Hospitto being unable to provide you with its Services or to terminate any existing relationship Hospitto may have with you.
3.1.8If you wish to opt-out of receiving non-essential communications such asmarket-related and
Promotional information regarding the Services, please send us an email at firstname.lastname@example.org.
3.1.9Hospitto may require the User to pay with a credit card, wire transfer, debit card or cheque for
theServices for which subscription amount(s) is/are payable. Hospitto will collect such User’s credit card number and/or other financial institution information such as bank account numbers and will use that information for the billing and payment processes, including but not limited to the disclosure and use of such credit card number and information to third parties as necessary to complete such billing operation. However,the verification of such credit information is accomplished solely by the user through the secure authentication process. User’s credit-card/debit card details are transacted upon secure sites of approved payment gateways which are digitally under encryption, thereby providing the highest possible degree of care as per current technology. However, Hospitto provides you an option not to save your payment details. The user is advised, however, that internet technology is not full proof safe and User should exercise discretion on using the same.
3.1.10Due to the communications standards on the Internet, when a User or the End-User or anyone
who visits the Website, Hospitto automatically receives the URL of the site from which anyone visits. Hospitto 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 Hospitto 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, Hospitto may share and/or disclose some of the aggregate findings (not the specific data) in ananonymized form (i.e., non-personally identifiable) with advertisers, sponsors, investors, strategic partners, and others in order to help grow its business.
3.1.11The Website uses temporary cookies to store certain information (that is not sensitive personal
data or information) which is used by Hospitto 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, Hospitto may allow authorized third parties to place or recognize a unique cookie on the User’s browser. Thesecookies however, do not store any kind of 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 to the use of some of the features.
3.1.12A User may have limited access to the Website without creating an account on the Website.
However, unregistered Users can make appointments with the doctors by providing their name and respective phone number. In order to have access to all the features and benefits on our Website, a User must create an account on our Website. To create an account, a User needs to provide the following information, which the User recognizes and expressly acknowledges as his Personal Information allowing others, including Hospitto, to identify the User: name, User ID, email address, country, ZIP/postal code, age, phone number, password chosen by the User and valid financial account information. The additional information requested on the registration page, including the ability to receive promotional offers from Hospitto, is optional. Hospitto may, in future, include other optional requests for information from the User to help Hospitto to customize the Website to deliver personalized information to the User.
3.1.14TheHospitto’s website may enable its User to communicate with other Users or to post the
information to be accessed by other users, whereupon the other Users may collect such data. Such Users, including any administrators or moderators, are not the authorized Hospitto representatives or agents, and their statements or opinions do not necessarily reflect those of Hospitto, and they are not authorized to bind Hospitto to any contract. Hospitto hereby expressly disclaims any liability for any reliance or misuse of such information that is made available by visitors or Users in such a manner.
3.1.15Hospitto does not collect information about the visitors of the Website from other sources, such
3.1.16Hospitto maintains a strict "No-Spam" policy, which means that Hospitto does not intend to rent,
sale or otherwise give your e-mail address to a third party without your consent.
3.1.17Hospitto has implemented the best international market practices and security policies, rules and
technical measures to protect the personal data which it has under its control from unauthorized access, improper disclosure or use, unlawful destruction or unauthorized modification or accidental loss. However, for any theft or data loss due to unauthorized access to the User’s electronic devices through which the User avails the Services, Hospitto shall not be held liable for any loss whatsoever incurred by the User.
3.1.18Hospitto implements reasonable security practices and procedures and has a comprehensive
documented information security policies and information security programme that contain managerial,operational, technical and physical security control measures that are commensurate with respect to the information being collected and the nature of Hospitto’s business.
3.1.19Hospitto takes your right to privacy very seriously and other than as specifically stated in this
This section is applicable to all the Practitioners.
3.2.1 As part of the registration as well as the application creation and submission process that is available to Practitioners on Hospitto, certain information, including Personal Information or Sensitive Personal Data or Information is collected from the Practitioners.
therefore required to read and understand the privacy statements set out herein prior to submitting any Personal Information or Sensitive Personal Data or Information to Hospitto, failing which they are required to leave the Services, including the Website immediately.
3.2.3The personally identifiable information of the Practitioner, which they choose to provide to
Hospitto, is used to help the Practitioners identify and describe themselves. This information is exclusively owned by Hospitto You will be the owner of your information and you consent to Hospittofor collecting, processing,using and/or disclosing this information for the purposes hereinafter stated. Hospitto may use such information for commercial purposes and in an aggregated or non-personally identifiable form for statistical analysis,research and business intelligence purposes, transfer or otherwise sale suchstatistical, research or intelligence data in a non-personally identifiable form or aggregatedform to the third parties and affiliates. Hospitto also reserves the right to use information provided by or about the Practitioner for the following purposes:
(1) Publishing such information on the Website.
(2) Contacting Practitioners for taking product feedback.
(3) Contacting Practitioners for offering new products or services subject to the telephone number registered with the DNC Registry.
(4) Analyzinganonymized practice information including financial, and inventory information for commercial use.
(5) Analyzing software usage patterns for improving product design and utility.
3.2.4Hospitto automatically enables the listing of Practitioners’ information on its Website for every
‘Doctor’ or ‘Clinic’ added to a Practice using its software. This information listed on Website is displayed when the End-Users search for doctors on the Website, and the Practitioner’s information listed on Website is used by End-Users to request for doctor’s appointment. Any personally identifiable information of the Practitioners listed on the Website is not generated by Hospitto and is provided to Hospitto by Practitioners who wish to enlist themselves on the Website, or is collected by Hospitto from the public domain. Hospitto displays such information on its Website on an as it is basis making nowarranty or representation on the completeness or accuracy of the information. As such, we strongly recommend Practitioners to check thecompleteness and accuracy of their information from time to time and inform us immediately of any discrepancies, changes or updates to such information. Hospitto will, however, take reasonable steps to ensure the accuracy and completeness of this information.
3.2.5Hospitto may also display information for Practitioners who have not signed up or registered for the
services, provided that the Practitioners have consented to Hospitto for collecting, processing and/or disclosing their information on the Website. Such Practitioners are verified by Hospitto or its associates, and Hospitto puts in the best efforts to capture accurate information for such Practitioners. However, Hospitto does not undertake any liability for anyincomplete or incorrect information of such practitioners appearing on the Website.
This section applies to everyEnd-user.
3.3.1As part of the application/registration creation and submission process that is available to End-user
on this Website, certain information, including Personal Information or Sensitive Personal Data or Information is collected from the End-Users.
required tounderstand and read the privacy statements set out herein prior to submitting any Personal Information or Information to Hospittoor Sensitive Personal Data, failing at which they are required to leave the Hospitto immediately.
3.3.3If you have inadvertently submitted any of such information to Hospitto prior to reading theprivacy
Statements set out herein, and you do not agree with the manner in which such information is collected, stored, processed, disclosed or used, then you may access,delete and modify such information by using the options provided on the Website. In addition, you can, by sending an email to email@example.com, inquire whether Hospitto is in possession of your personal data, and you may also require Hospitto to destroy and delete all such information.
3.3.4Theend-Users’ personally identifiable information, which they choose to provide on the Website is
used to help the End-Users identify/describe themselves. The other informationcollected by Hospitto from End-Users (such as, patterns of utilization described above) that does not personally identify the End-Users as an individual is exclusively owned by Hospitto. Hospitto may also use such information in an aggregated or non-personally identifiable form for statistical analysis,research and business intelligence purposes, and may sell or otherwise transfer such statistical,research or intelligence data in an aggregated or non-personally identifiable form toaffiliates or third parties. In particular, Hospitto reserves with it the right to use anonymized End-User health information and anonymized End-User demographics information for the following purposes:
(1) Simply analyzing such information for research and development of new technologies.
(2) Analysing software usage patterns for improving product design and utility.
(3) Sharing analysis of such information with third parties for commercial use.
(4) Using analysis of such information in other commercial product offerings of Hospitto.
3.3.5Hospitto will communicate with the End-Users through phone, email 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.hospitto.com and changing the account settings.
3.3.6At times, Hospittomay conduct User surveys to collect information about End-Users' preferences.
These surveys are optional and if End-Users choose to respond, their responses will be kept anonymous. Similarly, Hospitto may offer contests to the qualifying End-Users in which we ask for contact and demographic information such as name,mailing address and email address. The demographic information that Hospitto collects in the registration process and through surveys is used to help Hospitto improve its Services to meet the needs and preferences of the End-Users.
3.3.7Hospitto may keep records of electronic communications and telephone calls received andmade
forfixing appointments or other purposes for the purpose of administration of Services, customer support, research and development and for abetter listing of the medical Practitioners.
3.3.8All Hospittodata processors and employees, who have access to, and are associated with the
processing of sensitive personal information or dataare obliged to respect the confidentiality of every End-Users’ Personal Information or Sensitive Personal Data and Information. Hospitto has put in place procedures and technologies as per good industry practices and in accordance with the applicable laws, to maintain thesecurity of all personal data from the point of collection to the point of destruction. Any third-party data processor to which Hospitto transfers Personal Data shall have to agree to comply with thosepolicies and procedures, or put in place adequate measures on their own.
3.3.9Hospitto may also disclose or transfer End-Users’ personal and other information provided by a
3.3.10To the extent necessary to provide End-Users with the Services, Hospitto may provide their
Personal Information to third party contractors who work on behalf of or with Hospitto to provide End-Users with such Services, to help Hospitto communicate with End-Users or to maintain the Website. Generally these contractors do not have any independent right to share this information;however, the contractors who provide the services on this Website, including the online communication services providers, may use and disclose the personal information collected in connection with the provision of these Services in accordance with their own privacy policies. In such circumstances, you consent to us disclosing your Personal Information to contractors, solely for the intended purposes only.
3.4CASUAL VISITORS NOTE
3.4.1Hospitto does not automatically collect any sensitive personal data or information from any casual
visitors of this website, who are merely perusing the Website.
andit is required by all the casual visitors to completely read and understand the privacy statements set out herein, failing which they are required to leave this Website immediately.
3.4.3If 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, stored, used,processed, disclosed or retained, merely quitting this browser application should ordinarily clear all temporary cookies installed by Hospitto. However, all the site visitors are advised to use the “clear cookies” functionality of their respective browsers to ensure such clearing/deletion, as Hospitto cannot guarantee,provide or predict the behavior of the equipment of all the visitors of the Website.
3.4.4You are not a casual visitor and if you have willingly submitted any personal data or information to
4. CONFIDENTIALITY AND SECURITY
4.1 Your Personal Information is maintained by Hospitto 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. Hospitto takes all necessary precautions to protect your personal information bothoff-line and online and implements reasonable measures and security practices including certain managerial,operational, technical and physical security control measures that are commensurate with respect to the information being collected and the nature of Hospitto’s business.
4.2 No administrator at Hospitto will have the knowledge of your password. It is important for you to protect against unauthorized access to your password,your mobile phone and your computer. Be sure to log off from the Website when finished. Hospitto does not undertake any liability for any unauthorized use of your account and password. If you suspect any unauthorized use of your account, you must immediately notify Hospitto by sending an email to firstname.lastname@example.org You shall be liable to indemnify Hospitto due to any loss suffered by it due to such unauthorized use of your account and password.
4.3 Hospitto makes all User information accessible to its employees, partners or agents 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 Hospitto is assisting the doctors to maintain and organize such information. Hospitto may, therefore, submit and retain all such records to the appropriate authorities, or to doctors who request access to such information.
4.5 Part of the functionality of Hospitto is assisting the patients to access the information relating to them. Hospitto may, therefore, retain and submit all such records to the relevant patients, or to their respective doctors.
4.6 Notwithstanding the above, Hospitto is not responsible for thesecurity, confidentiality or distribution of your personal information by third parties and our partners outside the scope of our agreement with such third parties and partner. Further, Hospitto 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 Hospitto whichis including but not limited to, acts of the government,unauthorised access to computer data,computer hacking, and storage device, computer crashes, breach of security and encryption, poor quality of telephone service or Internet service of the User etc.
If a User uses the Services or accesses the Website after a notice of changes has been sent to such User or published on the Website, such User hereby provides his/her/its consent to the changed terms.
6. CHILDREN'S AND MINOR'S PRIVACY
Hospitto 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. Such tools can also prevent the minors from disclosing their personal information including their name, mailing address, and any other personally identifiable information online without parental permission. Although the Hospitto Website and Services are not intended for use by minors, Hospitto 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