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Privacy Policy

MEDICAL DIALOGUES

PRIVACY POLICY

**Privacy Policy Including GDPR Compliance for EU Users

This privacy policy applies to the entire contents of the platform “Medical Dialogues” operated by [Meghna A. Singhania] [“Medical Dialogues” which may also be referred to hereon in as “we” or “us” or “our” (as applicable)] including, without limitation, <medicaldialogues.in> or any application or software used to access the platform (“Website” or “Mobile Application”).

Please read the Privacy Policy below carefully before using Medical Dialogues. By using or registering on Medical Dialogues, you accept and agree to the terms of this Privacy Policy. If you do not accept these terms, you will not be allowed to access Medical Dialogues.

The Users are responsible for ensuring that we keep their information current and accurate. The User may update their information by contacting us at [info@medicaldialogues.in], and we will use reasonable efforts to process any change the User makes; provided, however, that requests to delete information are subject to Medical Dialogue’s internal reporting, processing and retention policies and all applicable legal obligations and existing legislations.

We at Medical Dialogues are committed to preserving the privacy of all visitors to our platform ‘Medical Dialogues’. We are committed to ensuring that all services and activities made available via the platform Medical Dialogues will be provided in a safe and secure online environment. By accepting Medical Dialogue’s Privacy Policy and the Terms & Conditions at the time of registration, you expressly consent to our use and disclosure of your personal information in accordance with this Privacy Policy. This Privacy Policy is incorporated into and subject to Medical Dialogue’s Terms & Conditions. This Privacy Policy is effective upon acceptance in registration for new registering users.

Please read the following carefully to understand our views and practices regarding the User Information. The Privacy Policy can be found on our platform at footer of the page named Privacy Policy.

Your Privacy: Our Commitment

At Medical Dialogues, we are extremely proud of our commitment to protect your privacy and recognise that you have a right to know about the information we access or collect about you, how your information is being used by us and what we do to protect your information. Please read the following policy to understand how your personal information shall be treated by Medical Dialogues.

Our commitment towards privacy and protection of User data is based on the principles of lawfulness, transparency, fairness, accuracy, data minimisation, integrity and confidentiality.

What does this Privacy Policy Cover?

This Privacy Policy is part of the Medical Dialogues’ Terms & Conditions and covers the treatment of user information, including personally identifying information, obtained by Medical Dialogues including information obtained when you access the Medical Dialogues’ Site and/or App or any other software provided by Medical Dialogues and any information that you may share through use of the Medical Dialogues Site and/or App.

1.Introduction

1.1 Medical Dialogues (“Medical Dialogues, we, us”) recognizes that people who use Medical Dialogues’ Service (“you” or “Users”) value their privacy. This Privacy Policy details important information regarding the collection, use and disclosure of User information collected on Medical Dialogues’ website located at <www.medicaldialogues.in> and/or the related mobile app (collectively referred to as the “Site“), and any other features, tools, materials, or other services (including co-branded or affiliated services) offered from time to time by Medical Dialogues or its affiliate companies (collectively referred to as the “Service”). Medical Dialogues provides this Privacy Policy to help you make an informed decision about whether to use or continue using the Service.

1.2 This Privacy Policy should be read in conjunction with our Terms & Conditions. By accessing the Site and/or Service, you are consenting to the collection and use of information practices described in this Privacy Policy.

1.3 The User’s use of the Site and/or Service and any information the User may provide through the Site and/or Service remains subject to the terms of this Privacy Policy and our Terms & Conditions, as each may be updated from time to time.

1.4 The User through access of the Site and/or Service and acceptance of this Privacy Policy, hereby warrants and accepts that he/she has given her explicit and unequivocal consent to Medical Dialogues for collection and processing of his/her personal information and that the said collection and processing of his/her personal information is necessary for Medical Dialogues to fulfil their obligations for the provision of services to the said User and the User’s participation on the said platform of Medical Dialogues.

1.5Any questions, comments or complaints that you might have should be emailed to [info@medicaldialogues.in] or forwarded in writing to our address located:[72, Ansari Road, Daryaganj, New Delhi-110002]

2.Categories of Information Processed

2.1“Personal Information”means information that is about any individual, or from which any individual is directly or indirectly identifiable.

2.2“Process”“Processing”or “Processed” means anything that is done with any Personal Information, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

2.3We may Process the following categories of Personal Information about you:

    • Personal details: your name; username or log in details; password; areas or topics of interest; and photograph (if you or another user posts a photo on the Service).
    • Demographic information:gender; age/date of birth; nationality; salutation; job title, company information, education, work experience and other professional information; and language preferences.
    • Contact details: postal address; telephone and/or mobile number; email address; and your public social media handles or profile(s).
    • Consent records: records of any consents you may have given, together with the date and time, means of consent and any related information (e.g., the subject matter of the consent).
    • Location information: location data that describes the precise geographic location of your device (“Precise Location Data”).
    • Employer details: where you interact with us in your capacity as an employee, the contact information of your employer (including name, address, telephone number and email address) to the extent relevant.
    • Views and opinions: any views and opinions that you or other users choose to send to us, or publicly post about us on social media platforms or in the Services, including on forums.

2.4Cookies Information: When you visit the Medical Dialogues Site, we may send one or more cookies – small files – to your computer or another device, which may enable us or others to uniquely identify your browser. A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. This enables the webserver to identify and track the web browser.

Medical Dialogues may use both session cookies and persistent cookies. A persistent cookie remains after you close your browser. Persistent cookies may be used by your browser on subsequent visits to the site. Persistent cookies can be removed by following your web browser help file directions. Session cookies are temporary and typically disappear after you close your browser. You may be able to reset your web browser to refuse all cookies or to indicate when a cookie is being sent. However, some features of the Site or Service may not function properly if the ability to accept cookies is disabled.

We use the session cookies to keep track of you whilst you navigate the Site/Service to prevent frauds and increase website security. We use persistent cookies to enable our Site to recognize you when you visit and keep track of your preferences in relation to your usage of our website.

We may use Google Analytics to analyze the usage of this Site/Service. Google Analytics generates statistical and other information about website use by means of cookies, which are stored on users’ computers. The information generated relating to our Site/Service is used to create reports about the use of the Site/Service. Google will store this information and Google’s privacy policy is available at:http://www.google.com/privacypolicy.html>.

You can manage your preferences relating to the use of cookies on our Site/Service by visiting <www.medicaldialogues.in>. Most browsers allow you to reject all cookies, whilst some browsers allow you to reject just third-party cookies. For example, in Internet Explorer (version 9) you can refuse all cookies by clicking “Tools”> “Internet options”> “Privacy” and selecting “Block All Cookies” using the sliding selector. Blocking all cookies may, however, have a negative impact upon the usability of many websites including our Site/Service.

2.5 Log File Information: When you use our Site/Service, our servers may automatically record certain information that your device sends whenever you visit any website and use certain apps. These server logs may include information such as your web or app request, Internet Protocol (“IP”) address, browser type, browser language, referring/exit pages and URLs, platform type, number of clicks, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, the date and time of your request, the actions you take on a page and one or more cookies that may uniquely identify your browser.

2.6 Clear GIFs Information: When you use our Site/Service, we may employ technology such as “clear GIFs” (a.k.a. Web Beacons) which are used to track the online usage patterns of our users. In addition, we may also use clear GIFs in HTML-based emails sent to our users to track which emails are opened by specific users.

2.7 We also collect other kinds of information from you or other sources, which we refer to as “Other Information” in this Policy, which may include but is not limited to:

    • Device identification (“ID”), which is a distinctive number associated with a smartphone or similar handheld device but is different than a hardware serial number.
    • Advertising ID, which is a unique, user-resettable identification number for advertising associated with a device (e.g., iOS uses the Identifier for Advertising (or “IDFA”) and Android uses Google Advertising ID).
    • Device type, settings and software used.
    • Log files, which may include IP addresses, browser type, ISP referring/exit pages, operating system, date/time stamps and/or clickstream data, including any clicks on customized links.

2.8 Under certain circumstances and depending on applicable law, some of this Other Information may constitute Personal Information. Personal Information together with Other Information is hereinafter referred to as “User Information

2.9 Purposes for which we may process your information: The purposes for which we may Process User Information, subject to applicable law, include:

a) Provision of the Services to You: providing the Services to you from Medical Dialogues or its partners including (i) offering of contests, as well as chat areas, forums and communities, (ii) offering patient assistance tools, (iii) facilitating collaboration between physicians, healthcare professionals and organizations to form connections, learn and collaborate; (iv) verification of the identity of members who have self-identified as a healthcare professional; (v) management of your account, and (vi) customer support and relationship management.

b) Offering and Improving the Services: operating and managing the Services for you; providing personalized content to you; communicating and interacting with you via the Services; identifying issues with the Services and planning improvements to or creating new Services; and notifying you of changes to any of our Services.

c) Verification of Healthcare Professionals: using information supplied to us by you as well as a variety of data we license, we utilize the Verification Details to confirm users’ identity and/or license status. We reserve the right to ask for proof of your certification as a healthcare professional. If our verification process reveals that you are not a fully licensed healthcare professional, your request to participate or continue participation in some of our programs and Services may be denied. While we take steps to verify members we make no guarantee or representation as to the identity or licensed status of any member or user.

d) Facilitation of Continuing Medical Education: provision of medical education credits by Medical Dialogues, including the offering of educational activities and provision of clinical and policy content and related coverage in some parts of the Service that are open only to eligible healthcare professionals.

e) Job Listings: operating and managing the Services to allow you to post your resume online and apply for healthcare positions offered by prospective employers; if we have your geographic location that may be used to help you search for jobs in your area.

f) Surveys: engaging with you for the purposes of obtaining your views on our Services or to understand and report on industry trends.

g) Communications: communicating with you via any means (including via email, telephone, text message, social media, post or in person) regarding content and other information in which you may be interested, subject to ensuring that such communications are provided to you in compliance with applicable law; maintaining and updating your contact information where appropriate; and obtaining your prior, opt-in consent where required.

h) Advertising: provision of advertising based on your interests and interactions with the Services and Channels, including using User Information to serve you advertisements on the Services and Channels, as well as licensing segments of User Information to third parties.

i) Audience Engagement: identification and development of audience engagement, advertising and promotional strategies on various platforms and channels, both within the Service and on Channels.

j) User Engagement and Purchases: tracking purchase traffic and activity across the Service and on Channels, including review of your browsing history (if available); provision of analytics and measurement of cost of traffic against money being made.

k) Commerce Offerings: using cookies to track your browsing history and the amount of money spent at a particular third party merchant’s site to offer coupons and other offers that are relevant to your shopping experience; offering of coupons via SMS messages if a mobile phone number is provided.

l) Lead Generation: business-to-business lead generation in the provision of leads to customers to improve customer’s target marketing campaigns and services through different strategies. This includes generating leads through phone calls and email newsletter marketing to drive you to content, such as white papers and webinars, offered by Medical Dialogues, whereupon your contact information will be shared with our customer.

m) Marketing to Customers: We may market to current and prospective customers and their employees who may or have indicated an interest in doing business with, or have previously conducted business with, Medical Dialogues in order to further generate and promote our business. Such efforts include sending marketing emails or conducting phone calls to drive the purchase of advertising, marketing our lead generation, job boards, and other business services offered by Medical Dialogues.

n) IT Administration: administration of Medical Dialogues’ information technology systems; network and device administration; network and device security; implementing data security and information systems policies; compliance audits in relation to internal policies; identification and mitigation of fraudulent activity; and compliance with legal requirements.

o) Security: electronic security measures (including monitoring of login records and access details) to help mitigate the risk of and provide the ability to identify and rectify a security incident

p) Financial Management: general business and financial management purposes, including: economic, financial and administrative management; planning and reporting; personnel development; sales; accounting; finance; corporate audit; and compliance with legal requirements.

q) Investigations: detecting, investigating and preventing breaches of policy, and criminal offences, in accordance with applicable law.

r) Legal Proceedings: establishing, exercising and defending legal rights.

s) Legal Compliance: Subject to applicable law, we reserve the right to release information concerning any user of Services when we have grounds to believe that the user is in violation of our Terms and Conditions / Terms of Use or other published guidelines or has engaged in (or we have grounds to believe is engaging in) any illegal activity, and to release information in response to court and governmental orders, other requests from government entities, civil subpoenas, discovery requests and otherwise as required by law or regulatory obligations. We also may release information about users when we believe in good faith that such release is in the interest of protecting the rights, property, safety or security of Medical Dialogues, any of our users or the public, or to respond to an emergency.

 3Third Party Sites & The User

3.1 The Medical Dialogues website and/or the App (collectively referred to as “Site”) may include links to other third-party websites or web pages. Such sites or pages are governed by their respective terms & conditions and privacy policies, which are beyond our control. Once you exit the Medical Dialogues Site and enter a third-party site through the Medical Dialogues Site, use of any information you provide shall be governed by the privacy policy and/or terms and conditions of the operator of the particular third-party site you are visiting. Medical Dialogues shall not, under any circumstances, be responsible for any use of the third-party sites by such User.

3.2 Medical Dialogues refuses to acknowledge or represent the accuracy, completeness, reliability or adequacy of the Site’s third-party content. The content, materials, information, services, and products in the Site including text, graphics, and links, are provided “AS IS” and without warranties of any kind, whether expressed or implied. Medical Dialogues is in no way responsible for any content of any linked site or any link contained in a linked site.

3.3 Medical Dialogues disclaims all warranties, expressed and implied with regards to the merchantability and fitness of the Site and/or such third-party sites for a particular purpose. Medical Dialogues also does not guarantee that users shall be able to use the Site and/or such third-party websites without any interruption, which may lead to a loss in continuity.

3.4 Although, Medical Dialogues shall make reasonable efforts to ensure that the Site remains free of viruses or other harmful components, however, Medical Dialogues does not in any way represent or warrant that the Site or the server that makes the Site available shall be free of such harmful components. Use of the services of this Site is at User’s own risk and Medical Dialogues shall not be responsible for any servicing costs, repair or correction of the User’s systems.

3.5 Medical Dialogues does not, in any manner whether express or implied, endorse the advertisements hosted on its Site and the Users responding to such advertisements and/or purchasing any products advertised on Medical Dialogues hereby warrant and accept that they shall do so at their own risk.

3.6 Medical Dialogues reserves all rights to the assets, content, services, information and products and graphics in the Site except any third-party content.

4.Use of Information including Confidential Information by Medical Dialogues

 4.1We may use your personal information to operate and maintain the Site/Service. The information may also be used to provide to you the features and functionality of the Site/Service, including but not limited to the following:

a) administering the Site/Service and enabling its use for the User;

b) providing you with our products, services including their updates;

c) processing and responding to your inquiries or feedback;

d) personalizing your use of the Site/Service,

e) alerting you to new features, special events, products and services, or certain third-party products or services in which we think you will be interested;

f) enforcing the legal terms and conditions that govern your use of the Site/Service;

g) keeping the Medical Dialogues’ Site/Service secure;

h) dealing with customer inputs, complaints and suggestions; and

i) contacting you about your account or profile.

4.2 We may use your information (both personal/private/confidential and non-personal information) to send you marketing and advertising content, including sending you advertising through multiple channels, such as direct mail, email, push notifications and display media. We may send you advertising or content regarding our products and services, or products and services that we market on behalf of another company or any other entity.

 

4.3 We may use your information to communicate with you about:

a)our products and services in which you may be interested provided that you have not requested otherwise;

b)newsletters and information for which you have signed up; and

c)non-marketing or administrative purposes (such as notifying you of major changes to the Site/Service or for customer service purposes).

4.4 We use your information (private/confidential or otherwise) to improve the quality and design of our Site/Service and to create new features, promotions, functionality, and services such as by storing, tracking and analyzing user preferences and trends.

4.5 We also use cookies, clear gifs, log file information, and mobile app information such as device identifiers for purposes such as (a) remembering information so that you will not have to re-enter it during your visit or the next time you visit our Site/Service; (b) providing custom, personalized content and information; (c) monitoring the effectiveness of our marketing campaigns; (d) monitoring aggregate metrics such as total number of visitors, pages viewed, etc. and (e) tracking your entries, submissions, and status in promotions, sweepstakes, and contests. You can learn more about how these technologies are used in the Section below, ‘Third Party Advertising and Analytics’.

 

4.6 We may anonymize, de-identify, or aggregate your information (private/confidential or otherwise) for any legitimate business purposes, including for reporting and research, or advertising. Such anonymized and/or aggregated data does not personally identify you. Sometimes, this information may be used to target more relevant content or offers to you across different devices – for instance, we may provide you with offers and content on your device, based on your web-based activity.

4.7 We may use the information (private/confidential or otherwise) collected from you to verify User compliances with the Terms and Conditions and/or Privacy Policy governing the use of the Site/Service including monitoring private messages sent through our Site/Service private messaging service. Your privacy settings can be used to limit the publication of your information on the Site/Service. You can adjust your privacy settings by contacting us at [info@medicaldialogues.in].

4.8 We may disclose the information (private/confidential or otherwise) provided to us by the User for any other reason the User provided us with the said information.

 

5 When Medical Dialogues Discloses Information including Confidential Information

5.1 We may disclose the information we collect or receive from you to our subsidiaries, affiliated companies, agents, or other businesses, or service providers who process your information on our behalf in order to provide or operate the Site/Service. For instance, these entities may have access to your information for purposes including (but not limited to) billing and accounting, hosting, marketing, promotional and email services, customer and technical support, and in each case, may use the information to make improvements to the services they provide to us. Our agreements with these service providers limit the kinds of information they can use or process and require them to use reasonable efforts to keep your personal information secure.

5.2 When you choose to share information with social media services about your activities on Medical Dialogues by, for example, connecting your social media account to our Site/Service, then Medical Dialogues may share your personal information and information about your use of the Site/Service with such social media sites. Please make sure to read the terms and privacy statements of such sites prior to connecting to our Site/Service in this way.

5.3 Where you post personal/private/confidential information about yourself through our Site/Service to public areas of our Site/Service, you acknowledge and agree that this personal information will be publicly available.

5.4 Where you have provided your consent, we may share your personal information with selected third parties for their commercial or marketing use in conjunction with your relationship with Medical Dialogues or as part of a specific program or feature.

5.5 In addition, we may disclose to third parties’ various types of your information for targeted online or mobile advertising, as further described in the Section titled “Third Party, Sharing Advertising and Analytics.”

 5.6 We also may share personal information in other situations with your consent.

5.7 Medical Dialogues also reserves the right to disclose personal information that Medical Dialogues believes, in good faith, is appropriate or necessary to enforce our Terms of Use/Terms & Conditions, take precautions against liability or harm, to investigate, prevent and/or respond to third-party claims or allegations, suspected illegal activities, fraud, to respond to court orders or official requests, to comply with State/Central legal regulations, including but not limited to sharing with appropriate tax authorities, to protect the security or integrity of our Site/Service, to report violations of Medical Dialogues’ eligibility rules to third parties or safety of Medical Dialogues, our users or others.

5.8 If you elect to participate in any promotions, surveys, questionnaires, or other events during your usage of Medical Dialogues, the rules or terms and conditions for those events may indicate that your information will be shared with third parties with your consent. You are advised to review the applicable rules and/or terms and conditions for any promotions, surveys, questionnaires or events.

5.9 In the event that Medical Dialogues is involved in a merger, acquisition, sale, bankruptcy, insolvency, reorganization, receivership, assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors’ rights generally, or other change of control, there may be a disclosure of your personal information to another entity related to such event.

5.10 In the event ownership or control of the Medical Dialogues Site/Service is acquired by a new owner, your information may be transferred to the new owner as such a transfer may be necessary for the continued operation of the Medical Dialogues Site/Service. Any changes to this Privacy Policy by the new owner shall be notified on the Medical Dialogues Site.

5.11Information We Disclose to Third Parties

A) We may disclose your User Information to other entities within the Company group, for legitimate business purposes (including operating the Services and providing services to you), in accordance with applicable law. In addition, we may disclose your User Information to:

a) legal and regulatory authorities, upon request, or for the purposes of reporting any actual or suspected breach of applicable law or regulation;

b) outside professional advisors (such as accountants, auditors, or lawyers), subject to binding contractual obligations of confidentiality;

c) third party Processors (such as analytic providers; data centers; etc.), located anywhere in the world, subject to the requirements noted below in this Clause 5.11;

d) any relevant party, law enforcement agency or court, to the extent necessary for the establishment, exercise or defense of legal rights;

e) any relevant third-party provider, where our Services use third party advertising, plugins or content. If you choose to interact with any such advertising, plugins or content, information about your activities on the Services and Channels to provide you targeted advertising based upon your interests may be shared with the relevant third-party provider. If you click or tap on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria;

f) any sponsors of contests, competitions, sweepstakes, and prize draw, or content offerings, the registration data for such events is to be used by us as part of User Information and may be shared with the sponsor and others, subject to this Privacy Policy and the sponsor’s privacy policy. For contests, competitions, sweepstakes, and prize draws, please read the official rules or terms and conditions carefully before you submit your information; and

g) to third parties whose practices are not covered by this Privacy Policy (e.g., third party providers of goods and services, marketing and advertising companies and agencies, content publishers and retailers). Under applicable law, we may share Other Information with other parties who already possess your Personal Information in order to enhance their records about you or enhance their ability to provide products and services.

B) For some of our Services, we may make some information, such as the name of our users, their mailing address, phone number, email address and in certain circumstances their employer’s name, company size and other industry data available on a rental or other basis (e.g., sale) to third party providers of goods and services, for example, when such information is provided in connection with certain content available on our websites. Depending on where you reside, when you register for certain Services, we may share the Personal Information you provide with certain advertisers and sponsors.

C) Some of the Services may include websites that Medical Dialogues operates on behalf of third parties (“Licensors”). Where applicable, we may share some or all of your Personal Information with the Licensor; however, this privacy policy does not cover the user of your Personal Information by a Licensor. The privacy practices of Medical Dialogues’ Licensors may differ from this policy and we encourage you to contact those third parties directly if you have questions regarding their use of your Personal Information. When you use a co-branded service (a service operated with a partner of Medical Dialogues) or register or otherwise provide information on a co-branded site, where applicable, we may pass the collected information back to that partner, which may include third party service providers whose services are embedded into and/or appear within the Services.

D) With respect to surveys, in the event that responses are publicly disclosed, users will be notified at the time they take the survey. Otherwise we will disclose only aggregate information regarding its users’ responses in surveys to other participants in the survey. Where surveys allow users to submit written comments, and where Medical Dialogues advises users of the possibility of such disclosure at the time, they take the survey, Medical Dialogues reserves the right to disclose any information provided by users, provided that no User Information identifying a specific user is disclosed.

E) Medical Dialogues and some of our advertisers may use third party advertising service companies to serve advertisements and perform related services when you interact with the Services. Often, these third-party advertising companies employ cookies and other technologies to measure the effectiveness of website, app and email advertisements and to create a record of interaction with our content that they use in conjunction with their advertising which appears on other sites or applications, or for reporting website traffic, app use, statistics, advertisement data and/or other activities on the Services. We also engage third party providers to assist with the segmentation of this data.

F) We may also sell or transfer Online Data to certain third parties such as advertisers who will use this data to serve ads that they believe are relevant to your interests, and who agree to maintain the confidentiality of this information. Some of these third parties may combine the Online Data with their own data about you to form a more detailed picture.

G) We may engage third party providers to assist with the collection, storage and segmentation of Online Data and the providers are required to maintain the confidentiality of this information. These third-party providers may collect User Information from our Services for their own purposes, such as to monitor fraud around the web.

H) We may also engage third parties for the purpose of recognizing our users and delivering interest-based content and advertisements to them. We may share your User Information with our partners such as your name, postal address, email, or another identifier. Our partners may also: (i) collect information directly from your device, such as your IP address, device ID, advertising ID, and information about your browser or operating system; (ii) combine User Information about you received from Medical Dialogues with information about you from other sites or services; and (iii) place or recognize a unique cookie on your browser.

I) If we engage a third-party processor to process your User Information, the Processor will be subject to binding contractual obligations to: (i) only process the User Information in accordance with our prior written instructions; and (ii) use measures to protect the confidentiality and security of the User Information; together with any additional requirements under applicable law.

J) The Services contain links to other sites or partners whose information practices may be different from ours. You should consult the privacy policy of these third parties to learn how your privacy is protected.

6.Lawful Basis for Processing User Information

6.1 In processing your User Information in connection with the purposes set out in this Privacy Policy, we may rely on one or more of the following legal bases, depending on the circumstances:

    • Consent: We may Process your User Information where we have obtained your prior, express consent to the Processing (this legal basis is only used in relation to processing that is entirely voluntary – it is not used for processing that is necessary or obligatory in any way);
    • Contractual necessity: We may Process your User Information where the processing is necessary for connection with any contract that you may enter into with us;
    • Compliance with applicable law: We may process your User Information where the Processing is required by applicable law;
    • Vital interests: We may process your User Information where the processing is necessary to protect the vital interests of any individual; or
    • Legitimate interests: We may process your User Information where we have a legitimate interest in carrying out the processing for the purpose of managing, operating or promoting our business, and that legitimate interest is not overridden by your interests, fundamental rights, or freedoms.

7.Customer Support

 7.1 All telephone conversations from the Users to our Customer Support Centre may be recorded both to assist us in training and in quality management, and to allow for the speedy resolution of the queries.

7.2 All communications with Medical Dialogues and its Customer Support shall be conducted in the parliamentary language (a language which is not offensive and/or abusive). Medical Dialogues prevents and prohibits any such use of offensive and/or abusive language and strictest of actions shall be taken against the User who uses such offensive and/or abusive language including but not limited to suspension and/or termination of the User Account.

8.User’s Choices

8.1 Medical Dialogues will process your personal information in accordance with this Privacy Policy, and as part of that Medical Dialogues provides you with certain choices about how we process your personal information.

8.2 You can access and update certain personal information Medical Dialogues holds about you at any time by logging into your account via the Site/Service. You can update your marketing preferences and whether or not you would like us to send you newsletters in your account. You can also unsubscribe to marketing emails and newsletters by using the ‘unsubscribe’ feature in the communication.

8.3 We may occasionally send display media to you, in a targeted way, whether through web or mobile browsers or mobile applications. You may opt out of many third parties that support and send this type of targeting advertising and you may learn more about this type of advertising in the below Section titled “Third Party Advertising and Analytics.” You may opt out of tracking for mobile advertising through the settings on most smartphones, and you may learn more about these settings through those mobile device platforms, i.e., Google (https://support.google.com/ads/answer/2662922?hl=en) and Apple (https://support.apple.com/en-in/ht202074). [Please note that these companies may either change the way these settings operate, the content or the availability of these pages].

8.4 We may occasionally send you push notifications to your device. You can turn off certain push notifications in the account settings of your Medical Dialogues Account. You can also turn off push notifications specific to our Service in the settings on your mobile device.

 

9.Third-Party Sharing, Advertising, and Analytics

9.1 Certain ads that may appear on our Site/Service are delivered by our advertising partners. Our advertising partners may use cookies and other similar technologies, often in conjunction with unique (anonymous) cookie identifiers, to collect data about your activities and interests, including the technologies described above. Some of these partners may use mobile device identifiers, such as Apple IDFAs and Google/Android Advertising IDs. Doing this allows the ad companies to recognize your computer or device each time they send you an online or mobile advertisement. In this way, the ad companies may compile information about where you, or others who are using your computer or device, saw their advertisements and measure your interaction with each advertisement. This information allows advertisement companies to deliver targeted advertisements that may be of increased interest to you, both on our Site/Service and elsewhere online. Just as these technologies may be used to target ads on our websites and apps, we, or our advertising partners, may use these same technologies and data points (e.g., mobile identifiers, cookie identifiers, location-based data), through our Site/Service or through other services, to target advertising (for ourselves or other companies) on other sites or mobile apps. Sometimes, these identifiers may be derived from a hashed or encrypted version of personal information such as your email address. We may use this information to measure the performance of our advertising as well, for instance, to evaluate which ads or content our users prefer, or which are most effective. In addition, sometimes we or an advertising partner may tailor advertising to you across different devices.

9.2Medical Dialogues may disclose the information it collects about the User to:

9.2.1 to its service providers, to its affiliates, sponsors, suppliers and others who help provide the platform to the User;

9.2.2 to licensors, activity and event partners and other third parties for their own marketing purposes, such as to provide information to the User about their new developments, special events, programs, services, activities, products, attractions, promotions and other important information;

9.2.3 third parties to provide analytics or to confirm/update information provided by the User;third parties in the event of any reorganization, merger, sale, joint venture, assignment, transfer or disposition of all or any portion of Medical Dialogues’ business or other operations (including without limitation in connection with bankruptcy or any similar proceedings); and9.2.5or as otherwise authorized by the User.

9.2.4 We may also share the User’s personal information in response to a legal order or official request; when we believe the User have acted in violation of the Terms & Conditions of Medical Dialogues; to investigate, prevent or take action regarding suspected illegal activities, fraud or potential threats; to exercise legal rights or defend against claims; or as otherwise permitted or required by law.

9.2.5 We also may use, share or sell non-personally identifiable information with third parties. Additionally, we may take personally identifiable information and de-identify it and share it in a de-identified form with advertisers, business partners, and/or third parties in order to analyse usage of the services in order to improve our services and the User experience or for any similar purposes. Such data shall not be re-identified, and the contracting parties would be asked to agree to keep the data in its de-identified form after such use.

 

10.User Rights under this Privacy Policy

10.1Right to withdraw consent

10.1.1 The User shall have the right to withdraw his or her consent at any time with respect to the processing and disclosure of the personal data/information provided to Medical Dialogues.

10.1.2 Such withdrawal of consent shall not affect the lawfulness of any processing/disclosure based on User consent carried on by Medical Dialogues before its withdrawal.

10.2 Right to Transparency and Communication

10.2.1 Medical Dialogues shall take appropriate measures to provide any information referred to in this Privacy Policy and any communication under this Privacy Policy relating to processing to the User in a concise, transparent, intelligible and easily accessible form, using clear and plain language. Such information shall be provided in writing, or by other means, including, where appropriate, by electronic means. When requested by the User, the information may be provided orally, provided that the identity of the User is proven by other means.

10.2.2 Medical Dialogues shall facilitate the exercise of User’s rights under this Clause 10 and offer full co-operation and support towards the same.

10.2.3 Medical Dialogues shall provide information on action taken on a request under this Clause 10 to the User without undue delay and in any event within one month of receipt of the request. That period may be extended by two further months where necessary, taking into account the complexity and number of the requests. Medical Dialogues shall inform the User of any such extension within one month of receipt of the request, together with the reasons for the delay. Where the User makes the request by electronic form means, the information shall be provided by electronic means where possible, unless otherwise requested by the User.

10.2.4 If Medical Dialogues does not take action on the request of the User, Medical Dialogues shall inform the User without delay and at the latest within one month of receipt of the request of the reasons for not taking action and on the possibility of lodging a complaint with a supervisory authority and seeking a judicial remedy.

10.2.5 Information provided under Clause 10 and any communication and any actions taken under this Clause and Privacy Policy shall be provided free of charge. Where requests from a User are manifestly unfounded or excessive, in particular, because of their repetitive character, Medical Dialogues may either:

a)charge a reasonable fee taking into account the administrative costs of providing the information or communication or taking the action requested; or

b)refuse to act on the request. Medical Dialogues shall bear the burden of demonstrating the manifestly unfounded or excessive character of the request.

10.2.6 Without prejudice to this Clause, where Medical Dialogues has reasonable doubts concerning the identity of the natural person making the request referred to herein, Medical Dialogues may request the provision of additional information necessary to confirm the identity of the User.

10.3Right to information

10.3.1 Where personal data relating to a User are collected from the User, Medical Dialogues shall, at the time when personal data are obtained, provide the User with all of the following information:

a)the identity and the contact details of Medical Dialogues and, where applicable, of the Medical Dialogues’ representative;

b)the purposes of the processing for which the personal data are intended;

c)the recipients or categories of recipients of the personal data, if any;

d)categories of personal data concerned;

e)where applicable, the fact that Medical Dialogues intends to transfer personal data to a third party, third country or international organization.

 10.3.2 In addition to the information referred to in Clause 10.3.1, Medical Dialogues shall, at the time when personal data are obtained, provide the User with the following further information necessary to ensure fair and transparent processing:

a)the period for which the personal data will be stored, or if that is not possible, the criteria used to determine that period;

b)where the processing is based or would be carried out;

c)the existence of the User’s right to request from Medical Dialogues access to and rectification or erasure of personal data or restriction of processing concerning the User or to object to processing;

d)the existence of the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal;

e)whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether the User is obliged to provide the personal data and of the possible consequences of failure to provide such data.

10.3.3 Where Medical Dialogues intends to further process the personal data for a purpose other than that for which the personal data were collected, Medical Dialogues shall provide the User prior to that further processing with information on that other purpose and with any relevant further information as referred to in Clause 10.3.2.

10.3.4 The above-stated provisions under Clauses 10.3.1, 10.3.2 and 10.3.3 shall also apply where Medical Dialogues intends to collect information from the User.

 

10.4 Right to access to data

10.4.1The User shall have the right to obtain from Medical Dialogues confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data and the following information:

a)the purposes of the processing;

b)the categories of personal data concerned;

c)the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations;

d)where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;

e)the existence of the right to request from Medical Dialogues rectification or erasure of personal data or restriction of processing of personal data concerning the User or to object to such processing;

f)where the personal data are not collected from the User, any available information as to their source;

10.4.2 Where personal data are transferred to a third party, third country or to an international organization, the User shall have the right to be informed of the appropriate safeguards implemented by Medical Dialogues.

10.4.3 Upon request by the User, Medical Dialogues shall provide a copy of the personal data undergoing processing. For any further copies requested by the User, Medical Dialogues may charge a reasonable fee based on administrative costs. Where the User makes the request by electronic means, and unless otherwise requested by the User, the information shall be provided in a commonly used electronic form.

 

10.5 Right to rectification

The User shall have the right to obtain from Medical Dialogues without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the User shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

 

10.6Right to erasure (Right to be forgotten)

]10.6.1 The User shall have the right to obtain from Medical Dialogues the erasure of personal data concerning him or her without undue delay and Medical Dialogues shall have the obligation to erase personal data without undue delay where one of the following grounds applies:

a)the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;

b)the User withdraws consent on which the processing is based and where there is no other legal ground for the processing;

c)the User objects to the processing pursuant to Clause 10.9 and there are no overriding legitimate grounds for the processing;

d)the personal data has been unlawfully processed;

e)the personal data have to be erased for compliance with a legal obligation under any law to which Medical Dialogues is subject.

10.6.2 Sub-clauses 10.6.1 and 10.6.2 shall not apply to the extent that processing is necessary:

a)for exercising the right of freedom of expression and information;

b)for compliance with a legal obligation which requires processing by any law to which Medical Dialogues is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in Medical Dialogues;

c)for the establishment, exercise or defense of legal claims.

 

10.7Right to restriction of processing

10.7.1 The User shall have the right to obtain from Medical Dialogues restriction of processing where one of the following applies:

a)the accuracy of the personal data is contested by the User, for a period enabling Medical Dialogues to verify the accuracy of the personal data;

b)the processing is unlawful and the User opposes the erasure of the personal data and requests the restriction of their use instead;

c)Medical Dialogues no longer needs the personal data for the purposes of the processing, but they are required by the User for the establishment, exercise or defence of legal claims;

d)the User has objected to processing pursuant to Clause 10.9 of this Privacy Policy pending the verification whether the legitimate grounds of Medical Dialogues override those of the User.

 10.7.2 Where processing has been restricted under Sub-Clause 10.7.1 as stated above, such personal data shall, with the exception of storage, only be processed with the User’s consent or for the establishment, exercise or defence of legal claims or for the protection of the rights.

 

10.8Right to data portability

The User shall have the right to receive the personal data concerning him or her, which he or she has provided to Medical Dialogues, in a structured, commonly used and machine-readable format and have the right to transmit those data to another entity/body without hindrance from Medical Dialogues.

 

10.9Right to object

10.9.1The User shall have the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her including profiling. Medical Dialogues shall no longer process the personal data unless Medical Dialogues demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the User or for the establishment, exercise or defence of legal claims.

10.9.2Where personal data are processed for direct marketing purposes, the User shall have the right to object at any time to processing of personal data concerning him or her for such marketing, which includes profiling to the extent that it is related to such direct marketing.

10.9.3Where the User objects to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.

 

11 Information Security

11.1We are committed to protecting the security of your personal information. Protection of the User Information, including the registration details or any other information the User provides to us, is a priority for us. We use a variety of security technologies and procedures to help protect your personal information from unauthorized access, use, or disclosure.

11.2Any personal information which identifies the User will be encrypted at all times whilst in transit over the internet. The technology used by us encrypts any information sent by the User on secure pages. Our server then reads the information using a private key. This means that your information, be it any payment information provided to us or any other personal details, is turned into a code that can only be decoded with the private key or password.

11.3Whilst neither we, nor any other organization, can guarantee the security of information processed online, we have appropriate security measures in place to protect your personal information. Example: we store the personal information you provide on computer systems with limited access that are located in facilities to which access is limited.

11.4To further protect your privacy and security, we reserve the right to take reasonable steps (such as requesting your password) to verify your identity before granting you profile access or making corrections.

11.5Additionally, you should ensure your password is kept secret at all times. You will be responsible for maintaining the secrecy of your password and account information.

 

12 Unsubscribing to Communications

12.1 If the User does not want to receive any e-mails from us in the future, they are required to let us know by dropping an email to us. We will use our reasonable endeavours to remove the User’s name from the related mailing list within 14 working days of his/her request. The User may also change his/her preferences at any time by revising his/her account profile by un-ticking the boxes for the previously opted communications.

12.2 The User may also click the “unsubscribe” link (if present) at the bottom of any emails he/she may receive from us and follow the necessary instructions provided.

13 Privacy Measures for Minors

13.1 Medical Dialogues is intended for persons who are 18 years of age or above. If the User is under 18 years of age, he/she shall not be permitted to use the platform ‘Medical Dialogues’.

13.2 If the User is a parent and/or guardian and believe that we may have inadvertently collected personal information from their child, they can notify us immediately by sending an email to [info@medicaldialogues.in].

14 Changes and Updates for Information

14.1 This Privacy Policy may be revised periodically, and this will be reflected by the “Last update posted” date above. Please revisit this page to stay aware of any changes. If a revision to this Privacy Policy, in our sole discretion, is material, we will notify you by contacting you through the email address associated with your account.

14.2 Contact Information: Please contact Medical Dialogues with any questions or comments about this Privacy Policy, including any data protection related inquiries, by emailing us at [info@medicaldialogues.in] or by normal/physical mail addressed to: [72, Ansari Road, Daryaganj, New Delhi, Delhi-110002]. Further, our Data Protection Officer (DPO) may be contacted at [info@medicaldialogues.in].

14.3 The User is responsible for keeping his/her information current. The User may update his/her information by contacting us at [info@medicaldialogues.in] and we will use reasonable efforts to process any change the User makes; provided, however, that requests to delete information are subject to our internal reporting, processing and retention policies and all applicable legal obligations.

 

15 Applicable Law & Jurisdiction

Medical Dialogues is created and controlled by [Minerva Medical Treatment Pvt. Ltd.] in India. As such, the laws of India will govern these Terms & Conditions and Privacy Policy.

The User hereby irrevocably and unconditionally consents to submit all disputes pertaining to these Terms & Conditions and Privacy Policy to the exclusive jurisdiction of a sole arbitrator appointed as per the Arbitration and Conciliation Act 1996, as amended from time to time. The seat of arbitration shall be [Delhi] and the language of the proceedings shall be English.

16 Note to Users outside of Republic of India

16.1 Medical Dialogues and our technical infrastructure are located in the Republic of India. The personal information that you provide to us is stored on servers located in the Republic of India. If you are located in another jurisdiction, you should be aware that in order to provide the Services to you, we must transfer your personal information to Republic of India where it will be stored and processed in accordance with this Privacy Policy.

16.2 We may transfer your information outside the Republic of India to service providers with operations in other countries. By using the Services, you consent to such collection, storage and processing in the Republic of India and elsewhere, though the Republic of India and other jurisdictions may not afford the same level of data protection as considered adequate in your own country.

16.3 We will take reasonable steps to protect your personal information. Note that your personal information may be available to the Government of India or its agencies under legal process made in the Republic of India.

17 COMMUNICATIONS NOT CONFIDENTIAL

Medical Dialogues does not guarantee the confidentiality of any communications provided by you through the Medical Dialogues site. Although Medical Dialogues generally adheres to the accepted industry practices in securing the transmission of data to, from and through the Medical Dialogues site, you understand, agree and acknowledge that Medical Dialogues cannot and does not guarantee the security of data transmitted over the Internet and/or public networks in connection with your use of the Medical Dialogues site.

18 Language

All communications between the User and Medical Dialogues and/or any other entity of Medical Dialogues shall be communicated in written form vide Electronic Mail (E-Mail) and in either English or Hindi language. Further, all communications between the User and the Customer Support shall also be conducted in either English or Hindi language.

Date Last Modified: This Privacy Policy was last modified on [Oct 11th 2019].

Your Choices

You may, of course, decline to submit Personally Identifiable Information through Medical Dialogues in which case Medical Dialogues may not be able to provide certain services to you. If you do not agree with our Privacy Policy or Terms & Conditions, the Users/visitors/participants are advised to not access and/or uninstall the Medical Dialogues Site/Service respectively. The Users are also requested to delete their account from the Medical Dialogues platform. Your continued usage of the Medical Dialogues Site/Service shall signify your assent to and acceptance of our Privacy Policy and Terms & Conditions (including any amendment thereof). To protect your privacy and security, we take reasonable steps (such as SMS authentication) to verify your identity before registering your contact number (mobile phone number) and granting you access to the Medical Dialogues Site/Service.