Privacy Policy

Hinirog Healthtech Private Limited (“Company” or “NirogStreet” or “We” or “Our” or “Us”) respects an individual's privacy and is committed to protecting the same. This Privacy Policy (“Policy”) describes how we collect, use, disclose and transfer Personal Information (as defined below), through website as well as other software and applications including but not limited to mobile applications provided by NirogStreet under the domain, i.e. www.nirogstreet.com of our Users (hereinafter, collectively referred to as “Customer” or “User” or “You” or “Your”) and ensure its compliance with applicable laws and regulations. Please refer to NirogStreet's Terms of Use, incorporated by reference herein also.

WHY THIS PRIVACY POLICY?

This Privacy Policy is published in compliance with, inter alia: i. Section 43A of the Information Technology Act, 2000:

1. Regulation 4 of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011 (the “SPI Rules”); and
2. Regulation 3(1) of the Information Technology (Intermediaries Guidelines) Rules, 2011.

This Privacy Policy states the following:

1. The type of information collected from the Users, including sensitive personal data or information;
2. The purpose, means and modes of usage of such information; and
3. How and to whom we will disclose such information.

WHAT PERSONAL INFORMATION DO WE COLLECT?

We collect Information through our Website to provide better services and results to our Users. Information is collected by the details provided by User and the data collected by the usage of the services. In general, the user can browse the Website without revealing any Personal Information. Although once Personal Information is provided, the identity of the User is not anonymous anymore. Where possible, we indicate which fields are required and which fields are optional. Our User always has the option of not providing Information by choosing not to use a particular service or feature. Other Information collected includes device information i.e. from which device is the services being used. This shall include the hardware model, operating system, unique identification number associated with the device etc.

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, we may ask you to voluntarily provide us with certain information that personally identifies you or could be used to personally identify you. Without prejudice to the generality of the above, information collected by us from you may include (but is not limited to) the following:

1. Contact data (such as your email address and phone number);
2. Demographic data (such as your gender, your date of birth and your pin code);
3. Data regarding your usage of the services and history of the appointments and other transactions made by or with you through the use of Services;
4. Health or medical data (such as your past medical history and conditions, diagnostic reports, prescriptions and medication history)
5. Insurance data (such as your insurance carrier and insurance plan); and
6. Other information that you voluntarily choose to provide to us (such as information shared by you with us through emails or letters, your work details, your family details)

The information collected from you by NirogStreet 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 with 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:

1. passwords;
2. financial information such as bank accounts, credit and debit card details or other payment instrument details;
3. physical, physiological, and mental health condition;
4. sexual orientation;
5. medical records and history;
6. biometric information;
7. information received by body corporate under lawful contract or otherwise;
8. visitor details as provided at the time of registration or thereafter; and
9. Call data records

Information that is freely available in the public domain or accessible under the Right to Information Act, 2005 or any other law will not be regarded as personal information or sensitive personal data or information.

PURPOSE FOR WHICH THE PERSONAL INFORMATION IS COLLECTED

NirogStreet may use your Personal Information to:

• verify your identity;
• fulfill the Product purchases and transactions;
• communicate with you about your account and activities on the Platform;
• booking and confirming the teleconsultation appointments;
• sign up for our newsletter, if any; respond to a survey or marketing communication;
• allow us to better serve you in responding to your requests;
• to respond to reviews, comments, or other feedback provided to us;
• administer a contest, promotion, survey or other site feature;
• ask for ratings and reviews of the Products;
• follow up with you after correspondence (live chat, email or phone inquiries);
• allow you to log in with a social media account and share activities on your social media pages;
• comply with our legal obligations, policies and procedures, including compliance with relevant industry standards and the enforcement of our terms and conditions;
• help us learn more about your shopping preferences;
• conduct marketing and performance research to assist us in measuring our customer services, benchmarking our performance and to help us improve your shopping experiences and Product offerings;
• send communication related to order updates and offers through e-mail, SMS and social media channels;
• do internal research on our User's demographics, interests, and behavior to better understand and serve you;
• provide you with exclusive offers at the Platform, tailor content, advertisements, and we provide you, and improve the Platform and/or for internal business purposes;
• analyze trends, track User's web page movements, help identify you and your shopping cart for aggregate use;
• prevent, detect, investigate and take action against crimes (including but not limited to fraud and other financial crimes), any other illegal activities, suspected fraud, or violations of Company's terms and conditions in any jurisdiction;
• establish, exercise or defend legal rights in connection with legal proceedings (including any prospective legal proceedings) and seek professional or legal advice in relation to such legal proceedings; and
• comply with any applicable law, regulation, legal process or enforceable governmental request.

The legal basis on which we collect your Personal Information:

• Performance of a Contract: some of the Personal Information processed is performed on the basis that it is necessary for the performance of our agreement with you. An example of this would be where we process your Personal Information for delivering the Products ordered by you on our Platform.
• Legitimate Interest: legitimate interests will include where we send you marketing information about our Products, communicate with you in order to serve you better.
• Compliance with a Legal Obligation: for certain types of processing it is necessary in order to allow us to comply with a legal obligation. An example of this would be where we are required to retain business records for fixed periods of time in order to comply with local legal requirements.
• Consent: Finally, in certain limited situations, we rely on your consent in order to process your Personal Information. Where we require your consent in order to collect and process certain Personal Information, we seek your consent at the time of provision, and such processing will only be performed where consent is secured. You can withdraw your consent, as per this Policy where applicable, by sending an email to [email protected].

We may also collect and/or generate anonymized and aggregated information from your use of the Platform. The anonymized or aggregated information is not Personal Information since we are not able to re-identify you using any means available to us from that anonymized or aggregated information. The anonymized and aggregated information is used for a variety of functions, including to help us identify and remediate any bugs, and to improve the performance of our Platform. The Company may use such information in a number of ways, including internal analysis, analytics and research. We may share this information with third parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.

We maintain a social media presence, such as a Facebook, Instagram, LinkedIn and a Twitter feed. You can interact with us through social media, such as by entering our contests, posting content, participating in Olympiads, conducting webinars & seminars, CMEs, sharing material from our Platform, and using our social media plug-ins. When you interact with us using social media, we may receive information such as your user ID, your profile picture, photos you post, and similar information, which is often determined by your privacy settings at the relevant social media sites. We may use the information for the purposes we have described throughout this Policy. Your use of social media sites is primarily governed by the site operators' privacy policies and terms of service, and the information you share with us and with others is largely controlled by the privacy settings you have established at those sites.

Payment Information: You may provide payment information when you use the Platform to buy our Products, including credit cards numbers, billing information using third-party intermediary PCI-DSS compliant service providers. The payment information is provided directly by you, via the Platform, into the PCI/DSS-compliant payment processing service to which the Company subscribes, and the Company does not, itself, process or store the payment information, except as stated herein. Further, these intermediaries are not permitted to store, retain, or use your billing information for any purpose except for payment processing on our behalf.

If you use the Platform, you are responsible for maintaining the confidentiality of your access information and password. You are responsible for restricting access to your computer, mobile device, etc., and you agree to accept responsibility for all activities that occur under your password. We cannot secure any information that you release on you own, that you request us to release or that is released through another third party to whim you have given access.

In case of our customer care support, we may record calls for quality and training purposes.

HOW DO WE COLLECT YOUR PERSONAL INFORMATION?

We communicate with you through a variety of means and channels, including our Platform, email, phone or text messaging on your mobile phone, although we do generally note that our preferred means of communication is email which has the least impact on the environment. Such communications may involve giving to you, as well as receiving information from you. We collect and receive the Personal Information in the following ways:

• When you submit your Personal Information on our Platform: The Company collects and stores the Personal Information that you provide while using our Platform including when you enter your Personal Information into data fields on the Platform as part of a voluntary registration process. We also collect and store your Personal Information through sponsored social media platforms, events, etc. For example, you may submit your name, postal address, e-mail address, and/or other information in order to register, place orders for the Products, booking appointments, receive information about various Products, register for newsletters, receive offers, contact Company's customer care service, or respond to the Company's surveys. To protect your privacy, you should not provide the Company with any information that is not specifically requested or that you do not wish to share. You can choose not to provide certain information, but then you might not be able to use our Platform or certain features of our Platform.
• Automatic collection: We automatically collect and store certain types of information whenever you interact with us. Such information includes information about your use of the Platform, your interaction with content and services available through the Platform. Like many websites, unidentifiable information may be collected using various technologies, such as cookies, Internet tags, and web beacons. Your Internet browser automatically transmits to the Platform some of this unidentifiable information, such as the URL of the Website you just visited and the browser version your computer is operating. Passive information collection technologies can make your use of the Platform easier by allowing the Company to provide better service, customize sites based on consumer preferences, compile statistics, analyze trends, and otherwise administer and improve the Platform. Certain features of the Platform may not work without use of passive information collection technologies. Information collected by these technologies cannot be used to identity you without additional identifiable information. We may also receive/store information about your location and your mobile device, including a unique identifier for your device.
• Other sources: We might receive information about you from other sources, such as updated delivery and address information from third parties which we use to correct our records and deliver your next purchase more easily. Further, we may receive information about you from third parties that feature our Products or promotional offers if you opt-in to receive information from us. You may also book consultation through our platform and allow us to collect the required data to do so. You may also choose to participate in a third-party application or social media sites through which you allow us to collect (or the third party to share) Personal Information about you, including usage information. We may also receive information, such as marketing related or demographic information about you from third parties to enhance our ability to tailor our content and offer you the Products that we believe may be of interest to you. The Company is not responsible for the privacy practices of such third-party websites which it does not own, manage or control.

RETENTION OF PERSONAL INFORMATION

• We will retain your Personal Information only as long as it is reasonably required or otherwise permitted or required by applicable laws or regulatory requirements. We may also retain your Personal Information so long as it is necessary to fulfill the purposes for which it was collected (including for purposes of meeting any legal, administrative, accounting, or other reporting requirements). Your Personal Information is safeguarded against inappropriate access and disclosure, as per this Policy.
• We also maintain appropriate and adequate administrative, technical and physical safeguards designed to protect your Personal Information against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.

OPTING OUT / WITHDRAWAL OF CONSENT

The Platform provides an option to all the Customers to opt-out of receiving any promotional or marketing communications from us. If you have consented to the collection, use and/or disclosure of your Personal Information as identified in this Policy, you have the right to withdraw this consent at any time by writing to us at [email protected]. Please note that any processing that we have carried out before the withdrawal of your consent remains lawful. Provided that, notwithstanding such request, this information may be retained to comply with our legal obligations, resolve disputes and enforce our agreements.

Updating your Personal Information in relation to your account: You can update or correct your name, and other details by logging into your account and clicking on the "My Profile" page or may call customer care executive.

Receiving promotional emails: You can click on the “unsubscribe” link at the bottom of any promotional email that you receive. Alternatively, you may call customer care executive to discontinue receiving any promotional materials by mail/ e-mail.

Remove content from Customer review: You can remove content that you posted on a public space, such as part of a ratings and review, by e-mailing details to [email protected]. Please note that we will endeavor and try to honor your request to remove information, however, our removal of your information does not completely erase that information from the internet viz. historical copies, or "caches," may remain.

HOW WE STORE YOUR PERSONAL INFORMATION?

We may store Personal Information using our own secure on-site servers or other internally hosted technology. Your Personal Information may also be stored by third parties, via cloud services or other technology, with whom NirogStreet has contracted, to support NirogStreet's business operations.

These third parties do not use or have access to your Personal Information other than for cloud storage and retrieval, and the Company requires such parties to employ at least the same level of security that we use to protect your Personal Information.

CONFIDENTIALITY AND SECURITY

Disclosure may be necessary to provide Users access to our Services, to comply with our legal obligations, to enforce our User Agreement, to prevent, detect, mitigate, and investigate fraudulent or illegal activities related to our Services. Such Personal Information, when shared with third parties, shall be subject to strict confidentiality agreements. We may disclose personal information if required to do so by law or in the good faith belief that such disclosure is reasonably necessary to respond to subpoenas, court orders, or other legal process. We may disclose Personal Information to law enforcement offices, third party rights owners, or others in the good faith belief that such disclosure is reasonably necessary to enforce our Terms or Privacy Policy. We and our affiliates will share / sell some or all of your personal information with another business entity should we (or our assets) plan to merge with, or be acquired by that business entity, or re-organization, amalgamation, restructuring of business. Should such a transaction occur that other business entity (or the new combined entity) will be required to follow this privacy policy with respect to your Personal Information.

In order to secure the information provided to us by our users, we review the processing and storage practices along with the information collected to guard against unauthorized access into the data collected in our systems. Furthermore, user information is protected by subjecting our Employees and Agents who process such information to strict confidentiality agreements, where if they fail to comply with it, such non-compliance shall lead to heavy penalties or legal proceedings, depending upon the gravity of the situation.

We may store Personal Information using our own secure on-site servers or other internally hosted technology. Your Personal Information may also be stored by third parties, via cloud services or other technology, with whom NirogStreet has contracted, to support NirogStreet's business operations. These third parties do not use or have access to your Personal Information other than for cloud storage and retrieval, and the Company requires such parties to employ at least the same level of security that we use to protect your Personal Information. Such information may also be converted to physical form from time to time. We take necessary precautions to protect the Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification with security safeguards appropriate to the sensitivity of the Personal Information, regardless of the format in which it is held. We use various methods to safeguard Personal Information. They include:

• Physical measures: locked filing cabinets, restriction of access to offices, and alarm systems.
• Technical tools: passwords and encryption, using generally industry best practices.
• Organizational controls: confidentiality agreements, limiting access on a need-to-know basis, staff training and security clearances.

Online security is also a priority. NirogStreet makes all User information accessible to its employees only on a need-to-know basis. We incorporate security measures such as encryption and authentication tools to protect your Personal Information from unauthorized use. Firewalls are utilized to protect our servers and network from unauthorized users accessing and tampering with files and other information that we store.

It is important for you to protect against unauthorized access to your password, your computer and your mobile phone or device. Be sure to log off from the Website when finished. NirogStreet 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 NirogStreet by sending an email at [email protected]. You shall be liable to indemnify NirogStreet, its employees and Partners due to any loss suffered by them due to such unauthorized use of your account and password.

Further, we attempt to keep your Personal Information up-to-date, accurate in the best possible manner as it may be necessary for the purpose for which it was collected. We value the importance you attach to your Personal Information given to us and therefore we have: (i) taken all reasonable measures and precautions to keep such information safe and secure and to prevent any unauthorized access to or misuse of the same; and (ii) enable you to review and edit the same.

We use regular Malware Scanning. We implement a variety of security measures when a User enters, submits, or accesses their information to maintain the safety of your Personal Information.

However, we shall not be liable to any Users for any loss, damage (whether direct, indirect, consequential or incidental) or harm caused to the Users due to the unauthorized access or misuse of the Personal Information by any third party.

DO WE USE “COOKIES”?

We may track your preferences and activities on the Platform. “Cookies” are small data files transferred to your computer's hard drive by a website, while using a web browser (if you allow). They keep a record of your activities on the Platform making your subsequent visits to the site more efficient. The Cookies may store a variety of information, including, the number of times that you access the Platform, registration information and the number of times that you view a particular page or other item on the Platform. The use of cookies is a common practice adopted by most major sites to better serve their clients. Most browsers are designed to accept cookies, but they can be easily modified to block cookies.

By continuing the use of the Platform, you are agreeing to our use of cookies. If you do not agree to our use of cookie, you can block them in your browser setting, but you may lose some functionality on the Platform.

We use cookies to:

• understand and save User's preferences for future visits.
• keep track of advertisements.
• compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future. We may also use trusted third-party services that track this information on our behalf.

You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser settings. You may look at your browser's help menu to learn the correct way to modify your cookies.

If you turn cookies off, some features will be disabled. It won't affect the User's experience that makes your site experience more efficient and may not function properly.

However, you will still be able to place orders.

CUSTOMER COMMENTS AND CONTENT

If you post any comments or content on our Platform, you should be aware that any information you choose to provide there may be read, collected, or used by the third parties. We are not responsible for the information you choose to submit, and we cannot guarantee that third parties have not made copies of or will not use such information in any way.

LINKS TO THIRD PARTY ADVERTISEMENTS OR SITES

We may display links to web sites that are owned or operated by third parties on our Platform. Please understand that these websites are independent from the Company, and the Company has no control over the content on that website, even if the Company provides information or Products to the owner of that website. The Company is not making any representations, endorsements, or accepting any responsibility for the content or the use of such website. Further, we are not responsible or liable for any damage or loss related to the use of any third-party website. You should always read the terms and conditions and the privacy policy of a third-party website before accessing or using it.

THIRD PARTY ANALYTICS

We use third-party analytics services to evaluate your use of the Platform, compile reports on activity, collect demographic data, analyze performance metrics, and collect and evaluate other information relating to the Platform and mobile and internet usage. These third parties use cookies and other technologies to help analyze and provide us the information and, in some cases, connect such information with other data held by our, or third party, environments. You consent to the processing of information about you by these analytics providers in the manner and for the purposes set out in this Policy.

At present, we work with the following analytic partners:

• Google: Google's advertising requirements can be summed up by Google's Advertising Principles. They are put in place to provide a positive experience for Users. We use Google AdSense Advertising on our Platform. Google, as a third-party vendor, uses cookies to serve ads on our Platform. Google's use of the DART cookie enables it to serve ads to our Users based on previous visits to our Platform and other sites on the Internet. The Users may opt-out of the use of the DART cookie by visiting the Google Ad and Content Network privacy policy. We have implemented the following:
  
  
  1. Remarketing with Google AdSense
  2. Google Display Network Impression Reporting
  3. Demographics and Interests Reporting
  4. DoubleClick Platform Integration
  5. Google Event Tracking
• We, along with third-party vendors such as Google use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to compile data regarding the User interactions with ad impressions and other ad service functions as they relate to our Platform.
• The Users can set preferences for how Google advertises to you using the Google Ad Settings page. Alternatively, you can opt out by visiting the Network Advertising Initiative Opt-Out page or by using the Google Analytics Opt-Out Browser Add-on.
• MoEngage: MoEngage tool is used for running various marketing campaigns and optimizing them so as to enhance User acquisition and retention. It is used for running marketing campaigns by helping in deciding the target audience and doing various campaign performance analysis.

CHILDREN AND MINOR'S POLICY

The app is accessible to users aged 13 and above. Users under 18 must obtain parental or guardian consent access certain features and functionalities of the app, particularly those involving personal data collection, in-app purchases, or interactions with other users.

• Data Collection and Privacy: We will collect only the data necessary to provide core services to all users, with additional restrictions on data collection from users aged 13-17. Sensitive data, such as location information, biometric data, or financial information, will not be collected from users aged 13-17 without explicit parental consent.

Data collected from users aged 13-17 will not be used for targeted advertising or profiling. All data collected will be used solely for providing the app's services and enhancing user experience. We will not share data collected from minors with third parties without parental consent, except where required by law.

Data related to users aged 13-17 will be retained only as long as necessary for the purposes for which it was collected and will be securely deleted upon account termination or parental request.

• Content and Interaction Guidelines: Content and interactions within the app are moderated to ensure appropriateness for all users, especially minors. Users can report inappropriate content or behaviour, and tools are provided to block or limit interactions. The app employs industry-standard security measures, including encryption and two-factor authentication, to protect user accounts and data. Special protections are in place for accounts belonging to minors.

It is advised that the parents and guardians 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.

This policy complies with Indian laws and it will be regularly reviewed and updated. Users will be notified of significant changes, and continued use of the app implies acceptance of the updated terms. We adhere to industry standards and best practices to protect user data from unauthorized access or breaches.

DISPOSAL OF PERSONAL INFORMATION

We will only use your Personal Information for those purposes and will make sure that your privacy is protected. We shall take reasonable steps to delete or permanently de-identify Personal Information that is no longer needed.

POLICY REVIEW AND CHANGES

Please note that we review and may make changes to this Policy from time to time. When changes are made, the Policy link will include a notation “Revised (date).” indicating that you should review the new terms, which will be effective immediately upon posting on this page, with an updated effective date. By accessing the Platform after any changes have been made, you signify your agreement on a prospective basis to the modified Policy and any changes contained therein.

PRIVACY CONCERNS

If you are concerned about the handling of your Personal Information, or if you have any grievance with respect to our use of your information, you may communicate such grievance to the Data Protection Officer:

The Grievance Officer is identified above pursuant to the provisions of applicable laws including but not limited to the Information Technology Act, 2000 and the Consumer Protection Act, 2019, and the rules enacted under those laws.

CONSENT

By accessing and/or using our platform and providing the information as explained in this policy at any time, you consent to our collection and use of the information you disclose on the platform . If you do not agree with this privacy policy at any time, do not use any of the services or give us any of your information. If you use the services on behalf of someone else (such as your child) or an entity, you represent that you are authorised by such individual or entity to accept this privacy policy on such individual's or entity's behalf.

You agree and consent to receive all communications related to our services on the mobile number provided by you to NirogStreet, even if such mobile number is registered under DND/NCPR list under the Telecom Commercial Communications Customer Preference Regulations, 2018 (“TRAI Regulations”). Notwithstanding your registration with the National Do Not Call Registry (In Fully or Partly blocked category under National Customer Preference Register set up under the Telecom Regulatory Authority of India), you hereby express your interest and accord informed consent to receive communications (including commercial communications) in relation to NirogStreet's services. You further confirm that no communication to you from the NirogStreet or on behalf of the NirogStreet shall be construed as Unsolicited Commercial Communication under Regulation 2(bw) of the TRAI Regulations and you have specifically opted to receive communications in this regard on the mobile number provided by you.