Privacy Policy

1. General

1.1 Company & Platform

E-KAAYA HEALTHCARE PRIVATE LIMITED, a company incorporated under the provisions of the Companies Act, 2013, having its registered office at A-2, B1, Mahaveer Udhyan Marg, Bajaj Nagar, Jaipur, Rajasthan, India, 302015, (hereinafter referred to as "Jivo Care", "Company", "we", "us" or "our") operates and manages a mobile application under the brand name Jivo Care ("App") and the website located at https://jivocare.com/ ("Website"). The App and Website are collectively referred to as the "Platform".

1.2 Scope & Consent

This Privacy Policy (the "Policy"), together with our Terms and Conditions, governs your use of the Platform and outlines our practices and procedures regarding the collection, use, disclosure, processing, storage, and protection of the information provided by you as a user ("User", "you" or "your"). By accessing, using, browsing, or registering on the Platform, you agree to be bound by this Policy and consent to the collection, handling, use, disclosure, and transfer of your information as described herein.

1.3 Electronic Record

This document is an electronic record as defined under the Information Technology Act, 2000 and applicable rules, including the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011. It is generated electronically and does not require physical or digital signatures.

1.4 Purpose & Withdrawal of Consent

This Policy sets out the types of information we collect from the Users, including any sensitive personal data or information (as defined under applicable law), the purpose of collecting such data, the manner in which it is used and processed, and the circumstances under which it may be disclosed or transferred. You may, at any time, withdraw your consent to the collection and processing of your personal information. However, please note that such withdrawal of consent may affect our ability to provide you with certain services on the Platform. Your withdrawal will not affect the legality of any processing undertaken based on consent given prior to such withdrawal.

1.5 Your Choice

We encourage you to read this Policy carefully. If you do not agree with any part of this Privacy Policy or the Terms and Conditions, please refrain from accessing or using the Platform.

2. What Jivo Care Collects About You

2.1 You may be asked to provide your information anytime you visit, access, use or browse the "Website". We may share information and use it consistent with the provisions of this Privacy Policy. We may also combine it with other information to provide and improve our Products, services, content and advertising.

2.2 You agree that it is your responsibility to ensure the accuracy and currency of the information you provide on the Platform. You confirm that you have the necessary rights, authority, and consent to share such information with us. If any of your information changes or if you wish to access, update, correct, or delete your data (subject to applicable law), you may write to us at info@jivocare.com. We will take reasonable steps to accommodate such requests in compliance with applicable data protection laws.

2.3 The Platform is not intended for use by individuals under the age of 18 (eighteen). We do not knowingly collect personal data from minors. If we become aware that we have inadvertently collected personal data from a person under the age of 18, we will take appropriate steps to delete such data within a reasonable period. Parents or legal guardians who believe their child has submitted personal information without their consent may contact us to request deletion. The Company disclaims all liability for any use of the Platform by minors in violation of this Policy or our Terms and Conditions.

2.4 We may collect a variety of information from you, including your name, password, mailing address, phone number, email address and contact preferences, including any other usage and interaction details with us or our affiliates. We may collect such information which when combined with other pieces of information available with us could reasonably allow you to be identified ("Personal Information"). Personal Information shall include but is not limited to your full name, personal contact numbers, residential address, email address, gender or date of birth.

2.5 We may also collect, receive, process, or store certain sensitive personal data or information, consisting of but not limited to:

• 2.5.1 Password;
• 2.5.2 Financial information such as bank account, credit card, debit card, or other payment instrument details;
• 2.5.3 Physical, physiological, and mental health conditions;
• 2.5.4 Any detail relating to the above Personal Information categories as provided to us for providing service;
• 2.5.5 Any of the information received under the above Personal Information categories by us for processing, storing, or otherwise under lawful contract;
• 2.5.6 Biometric information;
• 2.5.7 Any detail relating to the above Personal Information categories as provided to us for providing service, and any of the information received under these categories by us for processing or storing under lawful contract or otherwise (collectively referred to as "Sensitive Personal Data or Information").

2.6 By clicking "I Accept" on the App or Website and using our Services, you voluntarily consent to the collection and processing of your personal and sensitive personal data by Jivo Care

3. How Jivo Care Utilizes Your Data

We collect, use, store, and process your Personal Information and Sensitive Personal Data or Information (collectively, "Your Information") for the following purposes, in accordance with applicable laws:

• 3.1 To register your profile and provide secure access to your account on the Jivo Care mobile app and/or website ("Platform").
• 3.2 To operate and improve our healthcare services, features, and digital tools, and to personalize your user experience based on your interactions and preferences.
• 3.3 To keep you informed through confirmations, updates, billing details, alerts, and other transactional or administrative communications relevant to your use of the Platform.
• 3.4 To share information about new services, wellness programs, discounts, offers, events, and health-related alerts that may be useful or relevant to you. You may choose to opt out of promotional messages at any time.
• 3.5 To conduct internal research, audits, and analytics to better understand user needs, enhance our services, and improve your overall experience with Jivo Care.
• 3.6 To comply with applicable laws, legal processes, regulatory mandates, or valid requests from government or judicial authorities.
• 3.7 To address and resolve any issues, queries, disputes, or concerns you raise in connection with your use of the Platform or services.
• 3.8 To safeguard your data, detect suspicious or unlawful activity, and ensure the overall security and integrity of our systems and services.

4. When and How Jivo Care Discloses Your Personal Information

4.1 We may disclose your information, including Personal and Sensitive Personal Data, to trusted third-party service providers who assist us in providing services through the Jivo Care App and Website. These may include technology partners, payment processors, diagnostic labs, logistics partners, and customer support providers. Such third parties are contractually obligated to use the data only for the intended purpose and implement appropriate data protection measures consistent with the DPDP Act and prevailing industry standards.

4.2 We may also disclose your information when such disclosure is requisitioned under any law or judicial decree or when we, in our sole discretion, deem it necessary in order to protect our rights or the rights of other Users, to prevent harm to persons or property, or to fight fraud and credit risk.

4.3 We may also disclose or transfer your information to any third party as part of a reorganization or a sale of assets, division, or transfer of a part or whole of our business. We shall ensure that any third party to which we transfer or sell our assets will have appropriate confidentiality and security measures, at least as protective as those described in this Privacy Policy, to handle your Personal Information. You will have the opportunity to opt out of any such transfer if the new entitys planned processing of your information differs materially from that set forth in this Privacy Policy.

4.4 A third-party payment gateway provider may be required to collect certain financial information from you, including but not limited to your credit/debit card number or bank account details (collectively referred to as "Financial Information"). All Financial Information collected from you by such third-party payment gateway providers will be used only for billing and payment processes. The Financial Information collected from you is transacted through secure digital platforms of approved payment gateways, which are encrypted and compliant with reasonably expected technology standards. The verification of the Financial Information shall be accomplished only by you through a process of authentication in which we shall have no role, and hence, we shall bear no liability in relation to the same. We shall neither be liable nor responsible for any actions or inactions of the third-party payment gateway providers or any breach of conditions, representations, and warranties given by them. We shall also not be obligated to mediate or resolve any dispute or disagreement between you and such third-party payment service providers.

4.5 Third-party payment gateway providers engaged by us may be required to collect certain financial details from you, including but not limited to your credit/debit card number or bank account information (collectively, "Financial Information"), for the purpose of processing payments. Such Financial Information is collected and transmitted through secure digital platforms managed by authorised payment gateways that employ industry-standard encryption and security protocols. Please note that all authentication of Financial Information is carried out solely by you. Jivo Care does not play any role in this verification process and shall not be liable for any issues arising from the same. We disclaim responsibility for any acts, omissions, breaches, or failures on the part of third-party payment gateway providers, including any representations or warranties they may have provided. Further, Jivo Care is under no obligation to mediate or resolve any disputes or claims between you and such third-party service providers.

4.6 While we make every reasonable effort to ensure the safety and confidentiality of your information, including Personal Information, Financial Information, and Sensitive Personal Data or Information, through the implementation of legally prescribed security practices, we urge you to exercise sound discretion while sharing such details on our platform. Given the inherent vulnerabilities of the internet, we cannot provide an absolute guarantee against potential security breaches.

4.7 Your information may also be transferred, stored, or processed in any country other than the country in which you access the Website. For purposes of sharing or disclosing data in accordance with this Privacy Policy, we reserve the right to transfer your information outside of your country. By using the Website, you consent to such transfer of your information outside of your country and also within our affiliates, subsidiaries, and partners whose personnel and subcontractors have agreed to ensure the same level of data protection as prescribed under this Privacy Policy and the data protection laws of India. Such transfers may be necessary for the performance of services, operation of the Website, and provision of Products as agreed between us and the third party.

5. Data Security and Protection at Jivo Care

5.1 At Jivo Care, safeguarding your Personal Information is a top priority. We have implemented comprehensive security policies, protocols, and technical safeguards in compliance with applicable laws, including the Digital Personal Data Protection Act, 2023. These measures include firewalls, Transport Layer Security (TLS), encryption, and both physical and electronic security controls to prevent unauthorized access, misuse, alteration, disclosure, or destruction of your data. When you submit your information through the Jivo Care platform, it is protected by these robust security systems, aligned with internationally recognized industry standards.

5.2 Your information is stored within secure networks and is accessible only to a limited group of authorized personnel who require access to perform their duties as outlined in this Privacy Policy. All such authorized individuals are contractually and legally bound to maintain the confidentiality and security of your information.

5.3 While we strive to ensure your data is stored and transmitted securely, no security system is entirely infallible. You acknowledge that Jivo Care cannot guarantee absolute security against all risks, including unauthorized disclosures or cyberattacks. You agree not to hold Jivo Care responsible for any breach of security or for any action of any third parties that receive your Personal Information or events that are beyond our reasonable control, including acts of government, computer hacking, unauthorized access to computer data and storage devices, computer crashes, breaches of security, encryption failures, etc.

6. Jivo Care Cookies and Tracking Policy

6.1 When you visit, access, or browse the Jivo Care Website, we automatically collect certain technical information due to Internet communication standards. This includes the URL of the site from which you accessed the Website, the URLs of the sites you visit after leaving the Website, your devices IP address, operating system, web browser type, email usage patterns, and your Internet Service Providers name. This information is solely used to analyse overall user trends and help improve our services. Please note that your IP address is not linked to your personally identifiable information without your consent, except when required by law or necessary to provide or facilitate services. However, aggregate and anonymized data, which does not identify any individual, may be shared with advertisers, sponsors, investors, strategic partners, and others to support business growth. The extent of information shared with us depends on your web browser settings, which you can review to understand what data is being provided.

6.2 Our Website uses temporary cookies to store certain information. These cookies do not store any personal information. Data collected by us that does not personally identify you (such as usage patterns) is owned exclusively by Jivo Care and may be used by us or third-party service providers for technical administration, user management, research, development, and related purposes.

6.3 You have the option to set or modify your web browser settings to delete or disable cookies. Please be aware that disabling cookies may impair or limit your access to certain features or areas of the Website.

6.4 We may permit third-party companies or entities, including advertisement servers, agencies, and technology vendors, to serve advertisements on the Website. Some advertisements may be targeted to you based on general profiles; however, we do not use your Personal Information for ad targeting. Authorized third parties may place or recognize unique cookies on your browser to serve or optimize advertisements.

6.5 We may maintain records of all communications, including voice calls, digital chats, and emails exchanged with Users, for purposes such as service administration, research, training, business intelligence, and user management. Such records may be shared with third parties when required by law or to provide or facilitate services.

6.6 By submitting testimonials or reviews related to Jivo Care services or products on the Website, you grant us consent to reproduce and publish them. We may edit or paraphrase your testimonials and reviews before publication. If you have any concerns regarding the use of your testimonials or reviews, please contact us at info@jivocare.com.

7. Retention of Information

7.1 Jivo Care will retain your Personal Information and other data only for as long as necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by applicable law.

8. Modification

8.1 Jivo Care reserves the right to update or amend this Privacy Policy at any time. The revised Privacy Policy will be promptly posted on the Website with the effective date updated. We encourage you to regularly review this Privacy Policy to stay informed about how we collect, use, and protect your Personal Information.

9. Grievance Redressal

9.1 If you have any questions, concerns, grievances, or complaints related to this Privacy Policy or your experience with the Jivo Care Platform, please reach out to our designated grievance officer using the contact details below:

10. Governing Law and Jurisdiction

10.1 This Privacy Policy shall be governed by and construed in accordance with the laws of India. Any disputes arising out of or related to this Privacy Policy shall be subject to the exclusive jurisdiction of the courts located in Gurugram, Haryana.

11. Severability

11.1 If any provision of this Privacy Policy is found to be invalid or unenforceable under applicable law, such provision shall be deemed modified or severed to the extent necessary to comply with the law, and the remainder of this Privacy Policy shall continue in full force and effect.

12. Permissions, Health Data & Platform Services Disclosure

E-KAAYA HEALTHCARE PRIVATE LIMITED (“we”, “our”, “us”) provides digital healthcare services including appointment booking, teleconsultation, wellness assessments, medical record management, and employer-based wellness and sales tracking services. We collect and process user data strictly in compliance with Google Play User Data Policy and applicable Indian data protection laws.

A. Health & Medical Information

Our platform may collect sensitive health-related information including medical history, prescriptions, lab reports, diagnostic results, consultation notes, wellness assessment scores (such as mental health questionnaires), and treatment records.

This information is collected solely to provide healthcare services and improve medical outcomes. Health data is encrypted during transmission and securely stored with restricted access limited to authorized healthcare professionals and the respective patient.

We do not use health data for advertising or sell such data to third parties.

B. Teleconsultation & Communication

The application may enable video consultations, chat communication, appointment scheduling, and secure file sharing between patients and healthcare providers. Communication records may be securely stored for medical documentation and legal compliance purposes.

C. Location Access

We may request access to your device’s precise or approximate location to:

• Help users find nearby field employee, patients, doctors, clinics, or laboratories.
• Enable appointment coordination and emergency services.
• Support employer-based attendance and field visit tracking (where applicable).

Location access is used only when necessary. Background location access is requested only where essential for employer-authorized field tracking features. Users are clearly informed before enabling such access.

Location tracking may be limited to designated working hours for employer-managed accounts. Users may disable location permissions via device settings, though certain features may not function properly.

D. Camera & Media / Storage Access

We may request access to camera and device storage/media strictly for:

• Uploading prescriptions and medical reports
• Profile photo uploads
• Scanning documents
• Teleconsultation support

Media files are accessed only when users explicitly choose to upload or capture them. We do not access or scan personal media without user action.

E. Payments & Financial Information

For appointment bookings or service purchases, we may collect payment-related information. Payment processing is handled securely by certified third-party payment gateways. We do not store complete debit or credit card details on our servers.

F. Employee / Sales Tracking Services

For employer-managed accounts, the app may collect real-time location data during working hours to enable attendance tracking, sales visit verification, and performance monitoring. Employees are informed of such tracking during account registration and login.

Tracking is limited to official business purposes and is not used for personal surveillance outside authorized operational scope.

G. Device & Usage Information

We may collect device information such as device model, operating system, app version, IP address, crash logs, and usage analytics to improve app functionality, performance, and security.

H. Third-Party Services

We may use trusted third-party service providers for cloud hosting, analytics, map services, payment processing, messaging, and infrastructure support. These providers process data on our behalf under strict contractual confidentiality and security obligations.

I. Data Retention & Security

Personal and health-related data is retained only for as long as necessary to provide healthcare services, fulfill contractual obligations, or comply with legal requirements. We implement industry-standard encryption, secure servers, and access control mechanisms to protect user data.

J. Account Deletion & Data Removal

Users may request account deletion directly through the application settings or by contacting us at info@jivocare.com. Upon verification, personal data will be deleted or anonymized within a reasonable timeframe, except where retention is legally required.

13. App Purpose & User Eligibility

13.1 Jivo Care Wellness App is a corporate employee wellness application intended only for employees of registered organizations. Access to the Platform is provided exclusively through company-approved email credentials or officially authorized login mechanisms.

13.2 The Platform is not intended for public use without organizational authorization. Users must be valid employees, authorized representatives, patients, or healthcare providers associated with registered entities using Jivo Care services.

14. Data Collected

We may collect the following categories of data depending on the services used:

• Name and company email address
• Age, gender, height, weight
• Health inputs including BMI, activity level, and wellness data
• Mental wellness and self-assessment questionnaire responses
• Medical files, prescriptions, and reports uploaded by users
• Appointment booking and consultation records
• Ambulance enquiry and lab test request details
• Device and usage data for security and performance improvement

15. Use of Data

Your information is used strictly for legitimate healthcare and wellness purposes, including:

• Facilitating doctor consultations and telemedicine services
• Generating health calculations, dashboards, and wellness scores
• Providing mental health assessment results and wellness insights
• Processing lab test bookings and ambulance enquiries
• Supporting employer wellness program analytics in anonymized and non-identifiable formats
• Ensuring platform security, fraud prevention, and regulatory compliance

We do not sell personal or medical data. Health-related data is never used for advertising purposes.

16. Medical & Mental Health Disclaimer

Jivo Care does not provide emergency medical services. In case of a medical emergency, users must immediately contact local emergency services or visit the nearest hospital.

17. Data Sharing & Disclosure Clarification

We do not sell, rent, or trade personal or medical information to third parties.

Data may be shared only under the following circumstances:

• With authorized healthcare providers for treatment and consultation purposes
• With internal support teams strictly for resolving user enquiries and service issues
• With employer administrators in anonymized or aggregated formats where applicable
• With third-party service providers under contractual confidentiality obligations
• When required by law, regulation, or valid legal process

All such sharing is conducted with appropriate safeguards and, where required, based on user consent.

18. User Rights

Subject to applicable law, users have the right to:

• Access and review their personal data
• Request correction or update of inaccurate information
• Request deletion or anonymization of their personal data
• Withdraw consent for data processing (subject to service limitations)
• Raise complaints with the Grievance Officer regarding data usage

Requests may be submitted through the application settings or by contacting us at info@jivocare.com. We will respond within a reasonable timeframe in accordance with applicable Indian data protection laws.

19. Wellness Coach (Doctor App)

19.1 Access Restriction

The Wellness Coach Doctor App is restricted exclusively to licensed healthcare professionals authorized by the Company. Access is granted only through administrator-issued credentials. The application is not available for public registration.

19.2 Data Collected from Doctors

We may collect and process the following information from healthcare professionals:

• Name and professional contact details
• Medical registration number and qualifications
• Specializations and professional credentials
• Consultation schedule and availability
• Profile information including education, experience, awards, and memberships
• Usage logs and consultation activity records

19.3 Patient Data Access by Doctors

Doctors using the Wellness Coach App may access appointment-specific patient information strictly for consultation purposes. This may include patient name, demographic details, medical history relevant to the appointment, prescriptions, diagnostic reports, and consultation notes.

Doctors are contractually obligated to maintain strict confidentiality of all patient data accessed through the platform and to comply with applicable medical ethics guidelines and data protection laws.

19.4 Teleconsultation & Prescription Services

The Wellness Coach App enables secure video consultations and digital prescription generation where legally permitted. All medical decisions are made solely by licensed healthcare professionals using their independent clinical judgment.

The platform does not provide automated diagnosis, artificial intelligence-driven clinical decision support, or emergency medical services.

19.5 Data Security for Medical Records

Consultation records, prescriptions, and related medical documentation are encrypted during transmission and stored securely with role-based access controls. Access is limited to authorized healthcare professionals and designated administrative personnel strictly for operational and compliance purposes.

19.6 No Sale of Medical Data

Medical and consultation-related data accessed through the Wellness Coach App is never sold, rented, or used for advertising purposes.

19.7 Regulatory Compliance

The Wellness Coach platform operates in compliance with applicable Indian healthcare regulations, the Information Technology Act, 2000, the Digital Personal Data Protection Act, 2023, and other relevant laws governing telemedicine services.

19.8 Emergency Disclaimer

20. Contact Us

If you have any questions or concerns regarding this Privacy Policy, you may contact us at: