Privacy Policy

Conttext Messaging Technology Labs Private Limited (“CONTTEXT”) (“us”, “we”, or “Conttext”, which also includes its affiliates) is the author and publisher of the Internet resource www.Conttext.com (“Website”) on the World Wide Web as well as the software and applications provided by Conttext, including but not limited to the mobile application ‘Conttext’ (together with the Website, referred to as the “Services”).

This privacy policy ("Privacy Policy") explains how we collect, use, share, disclose and protect Personal information about the Users of the Services, including the mobile application called “Therapy”(as defined in the Terms of Use, which may be accessed via the following weblink https://Conttext.com/privacy (the “Terms of Use”)), the End-Users (as defined in the Terms of Use), and the visitors of Website (jointly and severally referred to as “Users” in this Privacy Policy). We created this Privacy Policy to demonstrate our commitment to the protection of privacy and personal information. Theuse of and access to the Services is subject to this Privacy Policy and our Terms of Use. Any capitalized term used but not defined in this Privacy Policy shall have the meaning attributed to it in our Terms of Use.

BY USING THE SERVICES OR BY OTHERWISE GIVING US THEINFORMATION, THE USER WILL BE DEEMED TO HAVE READ, UNDERSTOOD AND AGREED TO THE PRACTICES AND POLICIES OUTLINED IN THIS PRIVACY POLICY AND AGREE TO BE BOUND BY THE PRIVACY POLICY. USERHEREBY CONSENT TO OUR COLLECTION, USE AND SHARING, DISCLOSURE OF USERR INFORMATION AS DESCRIBED IN THIS PRIVACY POLICY. WE RESERVE THE RIGHT TO CHANGE, MODIFY, ADD OR DELETE PORTIONS OF THE TERMS OF THIS PRIVACY POLICY, AT OUR SOLE DISCRETION, AT ANY TIME. IF THE USERDO NOT AGREE WITH THIS PRIVACY POLICY AT ANY TIME, DO NOT USE ANY OF THE SERVICES OR GIVE US ANY OF USERINFORMATION. IF THE USER IS USINGTHE SERVICES ON BEHALF OF SOMEONE ELSE (SUCH AS ACHILD) OR AN ENTITY (SUCH AS ANEMPLOYER), THEN THE USERREPRESENTS THAT THEYARE AUTHORISED BY SUCH INDIVIDUAL OR ENTITY TO (I) ACCEPT THIS PRIVACY 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 PRIVACY POLICY.


1. PRIVACY POLICY

This Privacy Policy is published in compliance with, inter alia:

1. Section 43A of the Information Technology Act, 2000;

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

3. 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 Personal Information (as defined in paragraph 2 below) and Sensitive Personal Data or Information (as defined in paragraph 2 below) relating to an individual;

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

3. How and to whom Conttext will disclose such information.


2. COLLECTION OF PERSONAL INFORMATION


Personal information on the Patient is collected from the Hospital Information Systems (“HIS”),some of the Services require us to know Patient related Medical History which will include all details pertaining to the Patient in all relevant HIS’s across hospitals, where the patient has visited from Medical services.User hereby consents to the data privacy under relevant jurisdictions of use and collection of such information by Conttext. Without prejudice to the generality of the above, information collected by us on the patient may include (but is not limited to) the following:

1.contact data (such as email address and phone number);

2. demographic data (such as gender, date of birth and pin code);

3. data regarding Patient’s usage of the services and history of the appointments made with theUser through the use of Services;

4. insurance data (such as Patient’s insurance carrier and insurance plan);

The information collected by Conttext may constitute ‘personal information’ or ‘sensitive personal data or information’ under the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011. (“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:

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;

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.

Conttext will be free to use, collect and disclose information that is freely available in the public domain without User’sconsent. d


3. PRIVACY STATEMENTS

3.1.1 Accordingly, a condition of each User’s use of and access to the Services is their acceptance of the Terms of Use, which also involves acceptance of the terms of this Privacy Policy. Any User that does not agree with any provisions of the same has the option to discontinue the Services provided by Conttext immediately.

3.1.2 All the information provided to Conttext by a User (Provider or Practitioner), including Personal Information or any Sensitive Personal Data or Information, is voluntary. User understand that Conttext may use certain information of User’s, which has been designated as Personal Information or ‘Sensitive Personal Data or Information’ under the SPI Rules, (a) for the purpose of providing theUser 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 a better way of organizing, communicating, coordinating and collaborating for better care provision (e) debugging customer support related issues.. Conttext also reserves the right to use information provided by or about the End-User for the following purposes:

1. Publishing such information on the Website.

2. Contacting User for offering new products or services..

3. Contacting Userfor taking product and Service feedback.

4. Analyzing software usage patterns for improving product design and utility.

5. Analyzing anonymized practice information for commercial use.

3.1.4 Collection, use and disclosure of information which has been designated as Personal Information or Sensitive Personal Data or Information’ under the SPI Rules requires User express consent. By affirming User assent to this Privacy Policy, User provide User consent to such use, collection and disclosure as required under applicable law.

3.1.5 Conttext does not control or endorse the content, messages or information found in any Services and, therefore, Conttext specifically disclaims any liability with regard to the Services and any actions resulting from User participation in any Services, and the User agrees that the User waive any claims against Conttext relating to same, and to the extent such waiver may be ineffective, User agree to release any claims against Conttext relating to the same.

3.1.6 Users are responsible for maintaining the accuracy of the information the User submit to us, such as User contact information provided as part of account registration. If User’s information changes, User may correct, delete inaccuracies, or amend information by making the change on our member information page or by contacting us through privacy@Conttext.com. We will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable. If User provides any information that is untrue, inaccurate, out of date or incomplete (or becomes untrue, inaccurate, out of date or incomplete), or Conttext has reasonable grounds to suspect that the information provided by User is untrue, inaccurate, out of date or incomplete, Conttext may, at its sole discretion, discontinue the provision of the Services to User. There may be circumstances where Conttext will not correct, delete or update User 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 User wish to cancel Useraccount or request that we no longer use User information to provide User Services, contact us through support@Conttext.com. We will retain User information for as long as User account with the Services is active and as needed to provide User 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, User 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 User withdrawal of consent, or cancellation of account may result in Conttext being unable to provide User with its Services or to terminate any existing relationship Conttext may have with User.

3.1.8 If User 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 support@Conttext.com .

3.1.9 Conttext may require the User to pay with a credit card, wire transfer, debit card or cheque for Services for which subscription amount(s) is payable. Conttext 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 use and disclosure of such credit card number and information to third parties as necessary to complete such billing operation. Verification of credit information, however, is accomplished solely by the User through the 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, Conttext provides User an option not to save User payment details. User is advised, however, that internet technology is not full proof safe and User should exercise discretion on using the same.

3.1.10 Due to the communications stands on the Internet, when a User or the End-User or anyone who visits the Website, Conttext automatically receives the URL of the site from which anyone visits. Conttext 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 Conttext 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, Conttext 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.

3.1.11The Website uses temporary cookies to store certain (that is not sensitive personal data or information) that is used by Conttext 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, Conttext 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. User may adjust User internet browser to disable cookies. If cookies are disabled,User may still use the Website, but the Website may be limited in the use of some of the features

3.1.12 This Privacy Policy applies to Services that are owned and operated by Conttext. Conttext does not exercise control over the sites displayed as search results or links from within its Services. These other sites may place their own cookies or other files on the Users’ computer, collect data or solicit personal information from the Users, for which Conttext is not responsible or liable. Accordingly, Conttext does not make any representations concerning the privacy practices or policies of such third parties or terms of use of such websites, nor does Conttext guarantee the accuracy, integrity, or quality of the information, data, text, software, sound, photographs, graphics, videos, messages or other materials available on such websites. The inclusion or exclusion does not imply any endorsement by Conttext of the website, the website's provider, or the information on the website. If User decide to visit a third party website linked to the Website, User do this entirely at User own risk. Conttext encourages the User to read the privacy policies of that website.

3.1.13 The Website and /or the “Therapy” App may enable User to communicate with other Users or to post information to be accessed by others, whereupon other Users may collect such data. Such Users, including any moderators or administrators, representatives or agents, and their opinions or statements do not necessarily reflect those of Conttext, and they are not authorized to bind Conttext to any contract. Conttext hereby expressly disclaims any liability for any reliance or misuse of such information that is made available by Users or visitors in such a manner.

3.1.14 Conttext does not collect information about the visitors of the Website from other sources, such as public records or bodies, or private organisations, save and except for the purposes of registration of the Users (the collection, use, storage and disclosure of which each End User must agree to under the Terms of Use in order for Conttext to effectively render the Services).

3.1.15 Conttext maintains a strict "No-Spam" policy, which means that Conttext does not intend to sell, rent or otherwise give User e-mail address to a third party without User consent.

3.1.16 Conttext has implemented best international 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, Conttext shall not be held liable for any loss whatsoever incurred by the User.

3.1.17 Conttext 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 Conttext’s business.

3.1.18 Conttext takes User right to privacy very seriously and other than as specifically stated in this Privacy Policy, will only disclose User Personal Information in the event it is required to do so by law, rule, regulation, law enforcement agency, governmental official, legal authority or similar requirements or when Conttext, in its sole discretion, deems it necessary in order to protect its rights or the rights of others, to prevent harm to persons or property, to fight fraud and credit risk, or to enforce or apply the Terms of Use.


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 Conttext, certain information, including Personal Information or Sensitive Personal Data or Information is collected from the Practitioners.

3.2.2 All the statements in this Privacy Policy apply to all Practitioners, and all Practitioners are 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 Conttext, failing which they are required to leave the Services, including the Website immediately.

3.2.3 Practitioners’ personally identifiable information, which they choose to provide to Conttext, is used to help the Practitioners describe and identify themselves. This information is exclusively owned by Conttext User will be the owner of User information and User consent to Conttext collecting, using, processing and/or disclosing this information for the purposes hereinafter stated. Conttext may use such information for commercial purposes and in an aggregated or non-personally identifiable form for research, statistical analysis and business intelligence purposes, and may sell or otherwise transfer such research, statistical or intelligence data in an aggregated or non-personally identifiable form to third parties and affiliates. Conttext 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 offering new products or services subject to the telephone number registered with the DNC Registry.

3. Contacting Practitioners for taking product feedback.

4. Analyzing software usage patterns for improving product design and utility.

5. Analyzing anonymized practice information including financial, and inventory information for commercial use.

3.3 END-USER / PROVIDERS [HOSPITALS]NOTE: This section applies to all End-Users / Providers.

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.

3.3.2 All the statements in this Privacy Policy apply to all End-Users, and all End-Users are 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 Conttext, failing which they are required to leave the Conttext immediately.

3.3.3 If User have inadvertently submitted any such information to Conttext prior to reading the privacy statements set out herein, and the User do not agree with the manner in which such information is collected, processed, stored, used or disclosed, then User may access, modify and delete such information by using options provided on the Website. In addition, User can, by sending an email to privacy@Conttext.com, inquire whether Conttext is in possession of User personal data, and User may also require Conttext 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 Conttext from End-Users (such as, patterns of utilization described above) and is exclusively owned by Conttext. Conttext may also use such information in an aggregated or non-personally identifiable form for research, statistical analysis and business intelligence purposes, and may sell or otherwise transfer such research, statistical or intelligence data in an aggregated or non-personally identifiable form to third parties and affiliates. In particular, Conttext reserves with it the right to use anonymized End-User demographics information and anonymized End-User health information for the following purposes:

1. Analyzing software usage patterns for improving product design and utility.

2. Analyzing such information for research and development of new technologies.

3. Using analysis of such information in other commercial product offerings of Conttext.

4. Sharing analysis of such information with third parties for commercial use.

3.3.5 Conttext 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.Conttext.com and changing the account settings.

3.3.6 At times, Conttext conducts a User survey 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, Conttext may offer contests to qualifying End-Users in which we ask for contact and demographic information such as name, email address and mailing address. The demographic information that Conttext collects in the registration process and through surveys is used to help Conttext improve its Services to meet the needs and preferences of End-Users.

3.3.7 All Conttext 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. Conttext 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 Conttext transfers Personal Data shall have to agree to comply with those procedures and policies, or put in place adequate measures on their own.

3.3.8 Conttext may also disclose or transfer End-Users’ personal and other information provided by a User, to a third party as part of reorganization or a sale of the assets of a Conttext corporation division or company. Any third party to which Conttext transfers or sells its assets to will have the right to continue to use the personal and other information that End-Users provide to us, in accordance with the Terms of Use

3.3.9 To the extent necessary to provide End-Users with the Services, Conttext may provide their Personal Information to third party contractors who work on behalf of or with Conttext to provide End-Users with such Services, to help Conttext communicate with End-Users or to maintain the Website. Generally these contractors do not have any independent right to share this information, however certain contractors who provide services on the Website, including the providers of online communications services, 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, User consent to us disclosing User Personal Information to contractors, solely for the intended purposes only.


4. CONFIDENTIALITY AND SECURITY

4.1 User Information is maintained by Conttext 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. Conttext takes all necessary precautions to protect User 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 Conttext’s business.

4.2 No administrator at Conttext will have knowledge of User password. It is important for User to protect against unauthorized access to User password, User computer and UserCommunication devices [like mobilephone, tablets and User terminals]. Be sure to log off from the Website when finished. Conttext does not undertake any liability for any unauthorised use of User account and password. If Usersuspects any unauthorized use of User account, User must immediately notify Conttext by sending an email to support@Conttext.com , User shall be liable to indemnify Conttext due to any loss suffered by it due to such unauthorized use of User account and password.

4.3 Conttext 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 “Therapy” App / Conttext is assisting the doctors to maintain and organise such information. Conttext 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 “Therapy” App / Conttext is assisting the patients to access information relating to them. Conttext may, therefore, retain and submit all such records to the relevant patients, or to their doctors.

4.6 Notwithstanding the above, Conttext is not responsible for the confidentiality, security or distribution of Use Personal Information by our partners and third parties outside the scope of our agreement with such partners and third parties. Further, Conttext 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 Conttext 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.


5. CHANGE TO PRIVACY POLICY


Conttext may update this Privacy Policy at any time, with or without advance notice. In the event there are significant changes in the way Conttext treats User’s personally identifiable information, or in the Privacy Policy itself, Conttext will display a notice on the Website or send Users an email, as provided for above, so that User may review the changed terms prior to continuing to use the Services. As always, if User object to any of the changes to our terms, and User no longer wish to use the Services, User may contact support@Conttext.com to deactivate Useraccount. Unless stated otherwise, Conttext’s current Privacy Policy applies to all information that Conttext has about User and User account. 
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 their consent to the changed terms.


6. CONSENT TO THIS POLICY

User acknowledge that this Privacy Policy is a part of the Terms of Use of the Website and the other Services, and User unconditionally agree that becoming a User of the Website and its Services signifies User (i) assent to this Privacy Policy, and (ii) consent to Conttext using, collecting, processing and/or disclosing User Information in the manner and for the purposes set out in this Privacy Policy. User visit to the Website and use of the Services is subject to this Privacy Policy and the Terms of Use.


7. ADDRESS FOR PRIVACY QUESTIONS

Should User have questions about this Privacy Policy or Conttext's information collection, use and disclosure practices, User may contact, the Data Protection Officer appointed by Conttext in accordance with the provisions of PDPA. We will use reasonable efforts to respond promptly to any requests, questions or concerns, which User may have regarding our use of User information. If User have any grievance with respect to our use of User information, User may communicate such grievance to the Data Protection Officer:

Mrs. Vinutha Murthy
Conttext Messaging Technology Labs Private Limited,
Regus,
Ground Floor, Tower D, RMZ Infinity
Old Madras Road, Bangalore
India 560 016
privacy@conttext.com

Indicative List of Information by Nature of Service

1. The Provider’s Admin End-Users registers accounts using the Therapy Admin Panel for the Useraccounts, which include other Admins and End Users. User can create an account by giving information by linking their HIS to Conttext.This is to enable us to provide User with the facility to exchange information regarding Userday-to-day activities with the provider through the medium of Therapy Mobile Applications. 
Against every Practitioner (Doctors or Nurses) listed in Therapy, the Hospitals (Herein “Providers”) Privacy policy and terms of Use shall govern the use of such confidential data and the same shall be only accessible to Authorized person of the Providers.

2. The Provider will be able to create group of Practitioners using the Therapy Admin console and the Practitioners will be able to collaborate using the mobile application “Therapy”. The same is also possible with other End Users (like Patients) whereby the Provider shall create Groups/Communities, which shall be used for sharing of information of interest to the groups.Practioners will be listed under unique identity code (as per the nature of use):
 Practitioner may be required to provide us with information regarding their [name, mobile number, email address], and such other information as requested on the Practitioner registration page to create an account. Conttext may send Chat, Messages, Email and/or SMS confirmations or other communications to End-Users in connection with Practitioners operations or its services to Patients and other End Users like Information sharing.