PRIVACY POLICY

01WHY THIS PRIVACY POLICY?

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

• Section 43A of the Information Technology Act, 2000;

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

• Regulation 3(1) of the Information Technology (Intermediaries Guidelines) Rules, 2011. This Privacy Policy states the following:

• 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;

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

• How and to whom Clirnet will disclose such information.

02COLLECTION OF PERSONAL INFORMATION

Generally some of the Services require us to know who you are so that we can best meet your needs. When you access the Services, or through any interaction with us via emails, telephone calls or other correspondence, we may ask you to voluntarily provide us with certain information that personally identifies you or could be used to personally identify you. You hereby consent to the collection of such information by Clirnet. Without prejudice to the generality of the above, information collected by us from you may include (but is not limited to) the following:

• contact data (such as your email address and phone number);

• demographic data (such as your gender, your date of birth and your pin code);

• data regarding your usage of the services

• other information that you voluntarily choose to provide to us (such as information shared by you with us through emails or letters).

The information collected from you by Clirnet may constitute ‘personal information’ or ‘sensitive personal data or information’ under the SPI Rules.

"Personal Information” is defined under the SPI Rules to mean any information that relates to a natural person, which, either directly or indirectly, in combination with other information available or likely to be available to a body corporate, is capable of identifying such person.

The SPI Rules further define “Sensitive Personal Data or Information” of a person to mean personal information about that person relating to:

• passwords;

• financial information such as bank accounts, credit and debit card details or other payment instrument details;

• physical, physiological and mental health condition;

• sexual orientation;

• medical records and history;

• biometric information;

• information received by body corporate under lawful contract or otherwise;

• visitor details as provided at the time of registration or thereafter; and

• call data records.

Clirnet will be free to use, collect and disclose information that is freely available in the public domain without your consent.

03PRIVACY STATEMENTS

• ALL USERS NOTE:

  This section applies to all users.

  • 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 Clirnet immediately.

  • An indicative list of information that Clirnet may require you to provide to enable your use of the Services is provided in the Schedule annexed to this Privacy Policy.

  • All the information provided to Clirnet by a User, including Personal Information or any Sensitive Personal Data or Information, is voluntary. You understand that Clirnet may use certain information of yours, which has been designated as Personal Information or ‘Sensitive Personal Data or Information’ under the SPI Rules, (a) for the purpose of providing you the Services, (b) for commercial purposes and in an aggregated or non-personally identifiable form for research, statistical analysis and business intelligence purposes, (c) for sale or transfer of such research, statistical or intelligence data in an aggregated or non-personally identifiable form to third parties and affiliates (d) for communication purpose so as to provide You a better way to manage your Practice, (e) debugging customer support related issues. Clirnet also reserves the right to use information provided by or about the End-User for the following purposes:

    i. Publishing such information on the Website.

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

    iii. Analyzing anonymized practice information for commercial use.

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

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

  • You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information provided as part of account registration. If your personal information changes, you may correct, delete inaccuracies, or amend information by making the change on our member information page or by contacting us through privacy@Clirnet.com. We will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable. If you provide any information that is untrue, inaccurate, out of date or incomplete (or becomes untrue, inaccurate, out of date or incomplete), or Clirnet has reasonable grounds to suspect that the information provided by you is untrue, inaccurate, out of date or incomplete, Clirnet may, at its sole discretion, discontinue the provision of the Services to you. There may be circumstances where Clirnet will not correct, delete or update your Personal Data, including (a) where the Personal Data is opinion data that is kept solely for evaluative purpose; and (b) the Personal Data is in documents related to a prosecution if all proceedings relating to the prosecution have not been completed.

  • If you wish to cancel your account or request that we no longer use your information to provide you Services, contact us through support@Clirnet.com. We will retain your information for as long as your account with the Services is active and as needed to provide you the Services. We shall not retain such information for longer than is required for the purposes for which the information may lawfully be used or is otherwise required under any other law for the time being in force. After a period of time, your data may be anonymized and aggregated, and then may be held by us as long as necessary for us to provide our Services effectively, but our use of the anonymized data will be solely for analytic purposes. Please note that your withdrawal of consent, or cancellation of account may result in Clirnet being unable to provide you with its Services or to terminate any existing relationship Clirnet may have with you.

  • If you wish to opt-out of receiving non-essential communications such as promotional and marketing-related information regarding the Services, please send us an email at support@Clirnet.com .

  • This Privacy Policy applies to Services that are owned and operated by Clirnet. Clirnet 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 Clirnet is not responsible or liable. Accordingly, Clirnet does not make any representations concerning the privacy practices or policies of such third parties or terms of use of such websites, nor does Clirnet 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 Clirnet of the website, the website's provider, or the information on the website. If you decide to visit a third party website linked to the Website, you do this entirely at your own risk. Clirnet encourages the User to read the privacy policies of that website.

  • The Software 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, are not authorized Clirnet representatives or agents, and their opinions or statements do not necessarily reflect those of Clirnet, and they are not authorized to bind Clirnet to any contract. Clirnet 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.

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

  • Clirnet has implemented standard 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, Clirnet shall not be held liable for any loss whatsoever incurred by the User.

  • Clirnet 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 Clirnet’s business.

  • Clirnet takes your right to privacy very seriously and other than as specifically stated in this Privacy Policy, will only disclose your 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 Clirnet, 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.

• PRACTITIONERS NOTE:

  This section applies to all Practitioners.

  • As part of the registration as well as the application creation and submission process that is available to Practitioners on Clirnet, certain information, including Personal Information or Sensitive Personal Data or Information is collected from the Practitioners.

  • 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 Clirnet, failing which they are required to leave the Services, including the Website immediately.

  • Practitioners’ personally identifiable information, which they choose to provide to Clirnet, is used to help the Practitioners describe and identify themselves. This information is exclusively owned by Clirnet. You will be the owner of your information and you consent to Clirnet collecting, using, processing and/or disclosing this information for the purposes hereinafter stated .Clirnet 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. Clirnet also reserves the right to use information provided by or about the Practitioner for the following purposes:

    i. Publishing such information on the Website.

    ii. Contacting Practitioners for offering new products or services

    iii. Contacting Practitioners for taking product feedback.

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

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

04CONFIDENTIALITY AND SECURITY

• Your Personal Information is maintained by Clirnet 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. Clirnet takes all necessary precautions to protect your personal information both online and off-line, and implements reasonable security practices and measures including certain managerial, technical, operational and physical security control measures that are commensurate with respect to the information being collected and the nature of Clirnet’s business.

• No administrator at Clirnet will have knowledge of your password. It is important for you to protect against unauthorized access to your password, your computer and your mobile phone. Be sure to log off from the Software when finished. Clirnet does not undertake any liability for any unauthorised use of your account and password. If you suspect any unauthorized use of your account, you must immediately notify Clirnet by sending an email to support@Clirnet.com. You shall be liable to indemnify Clirnet due to any loss suffered by it due to such unauthorized use of your account and password.

• Clirnet 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.

• Part of the functionality of Clirnet is assisting the doctors to maintain and organise such information. Clirnet may, therefore, retain and submit all such records to the appropriate authorities, or to doctors who request access to such information.

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

05CHANGE TO PRIVACY POLICY

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

06CONSENT TO THIS POLICY

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

07ADDRESS FOR PRIVACY QUESTIONS

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

Data Protection Officer:

Name: Ms. Pragya Singh

Clirnet Services Private Limited,

Email: support@Clirnet.com

08Practitioners using the ‘Clirnet Concierge Suite’ and ‘Clirnet Knowledge Suite’:

You will be required to create an account and may be required to provide Clirnet with information such as your name, mobile number, email address, and such other information as requested by Clirnet Practitioner registration page, in order to complete your registration.

Upon registration, Clirnet will access non-personally identifiable information of your patients from your patient records. You agree to make your patients fully aware of such access.