Privacy Policy

The domain name www.natcue.com, an internet based portal, and NatCue, a mobile application, is owned and operated by Natcue Healthcare Services Private Limited, a company duly incorporated under the provisions of the Companies Act, 1956 (hereinafter, referred to as “NatCue” or “We” or “Our” or “Us” or “Company”). The domain name and the mobile application are collectively referred to as “Website”. The terms 'You' or 'Your' refer to You as the user (whether You are a Registered User, Unregistered user, Pharmacies, Practitioner(s) of the Website or of the services offered by the Website ("Service").

This privacy policy (“Privacy Policy“) explains how we collect, use, share and protect personal information about the Users of the Services, including the Practitioners (as defined in the Terms of Use), the End-Users (as defined in the Terms of Use), and the visitors of Website (jointly and severally referred to as “you” or “Users” in this Privacy Policy). We created this Privacy Policy to demonstrate our commitment to the protection of your privacy and your personal information. Your use of and access to the Services is subject to this Privacy Policy and our Terms of Use. Any capitalized term used but not defined in this Privacy Policy shall have the meaning attributed to it in our Terms of Use.

BY CONFIRMING THAT YOU ARE BOUND BY THIS PRIVACY POLICY (BY THE MEANS PROVIDED ON THIS WEBSITE), BY USING THE SERVICES OR BY OTHERWISE GIVING US YOUR INFORMATION, YOU AGREE TO THE PRACTICES AND POLICIES OUTLINED IN THIS PRIVACY POLICY AND YOU HEREBY CONSENT TO OUR COLLECTION, USE AND SHARING OF YOUR INFORMATION AS DESCRIBED IN THIS PRIVACY POLICY. WE RESERVE THE RIGHT TO CHANGE, MODIFY, ADD OR DELETE PORTIONS OF THE TERMS OF THIS PRIVACY POLICY, AT OUR SOLE DISCRETION, AT ANY TIME. IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY AT ANY TIME, DO NOT USE ANY OF THE SERVICES OR GIVE US ANY OF YOUR INFORMATION. IF YOU USE THE SERVICES ON BEHALF OF SOMEONE ELSE (SUCH AS YOUR CHILD) OR AN ENTITY (SUCH AS YOUR EMPLOYER), YOU REPRESENT THAT YOU ARE AUTHORISED BY SUCH INDIVIDUAL OR ENTITY TO ACCEPT THIS PRIVACY POLICY ON SUCH INDIVIDUAL’S OR ENTITY’S BEHALF

1. WHY THIS PRIVACY POLICY?

This Privacy Policy is published in compliance with, inter alia:
i. Section 43A of the Information Technology Act, 2000;
ii. Regulation 4 of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011 (the “SPI Rules”); and
iii. Regulation 3(1) of the Information Technology (Intermediaries Guidelines) Rules, 2011.
This Privacy Policy states the following:
i. The type of information collected from the Users, including sensitive personal data or information;
ii. The purpose, means and modes of usage of such information; and
iii. How and to whom NatCue will disclose such information.

2. COLLECTION 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, we may ask you to voluntarily provide us with certain information that personally identifies you or could be used to personally identify you. Without prejudice to the generality of the above, information collected by us from you may include (but is not limited to) the following:
i. contact data (such as your email address and phone number);
ii. demographic data (such as your gender, your date of birth and your pin code);
iii. data regarding your usage of the services and history of the appointments made by or with you through the use of Services;
iv. insurance data (such as your insurance carrier and insurance plan); and
v. 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 NatCue may constitute ‘personal information’ or ‘sensitive personal data or information’ under the SPI Rules. Personal information is defined under the SPI Rules to mean any information that relates to a natural person, which, either directly or indirectly, in combination with other information available or likely to be available with a body corporate, is capable of identifying such person. The SPI Rules further define “sensitive personal data or information” of a person to mean personal information about that person relating to:
i. passwords;
ii. financial information such as bank accounts, credit and debit card details or other payment instrument details;
iii. physical, physiological and mental health condition;
iv. sexual orientation;
v. medical records and history;
vi. biometric information;
vii. information received by body corporate under lawful contract or otherwise;
viii. visitor details as provided at the time of registration or thereafter; and
ix. call data records.
Information that is freely available in the public domain or accessible under the Right to Information Act, 2005 or any other law will not be regarded as personal information or sensitive personal data or information.

3. PRIVACY STATEMENTS


3.1 ALL USERS NOTE:

This section applies to all Users.
i. 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 NatCue immediately.
ii. An indicative list of information that NatCue may require you to provide to enable your use of the Services is below:
ii.a Upon Installation of the Mobile App NatCue collects personally identifiable information such as (but not limited to) Mobile Device ID, phone number, and account information for the purpose of identifying and contacting the user.
ii.b Registration.
During the collection of information on the Profile Pages on the Websites and Mobile Apps, you are required to provide your applicable contact information (such as name, physician license information, e-mail address and the like). A mobile verification code and registration number is used to confirm your identity. An email address is also used to contact you about the materials and information on the Websites and Mobile Apps. When the Websites and Mobile Apps request for the confirmation of your identity, the Websites and Mobile Apps will clearly indicate the purpose of the inquiry before such information is requested. In the case of professional information, professional information provided by you to us will be authenticated against a third party provider. Professional information shall include but not limited to physician license number, details regarding qualifications and specialties and the like.
ii.c Personal Profile of Practitioner and Health Care Providers. Pursuant to registration as a doctor or a health care provider on the Website, you may provide additional information in your personal profile describing your credentials, professional experiences, academic background, biography and the like. Your personal profile shall be available for viewing by other registered participants of NatCue and will be considered non-confidential and non-proprietary. Providing additional information in your personal profile beyond what is required at registration is entirely optional and can be altered or removed by you at any time.
ii.d IP Addresses.
Every computer connected to the Internet is given a domain name and a set of numbers that serve as that computer’s Internet Protocol or IP address. When you browse the Websites and Mobile Apps, our web servers automatically recognize your domain name and IP address. The domain name and IP address reveal nothing personal about you other than the IP address from which you have accessed the Websites and Mobile Apps.
ii.e Third Party Email Addresses and contact information For the purposes of inviting and introducing third parties to NatCue, You will be given the option to import or otherwise provide email addresses and contact information of third parties to NatCue. On so doing, NatCue will not store your affiliated username and corresponding password.
we store the information collected on NatCue server. NatCue Servers mean servers owned by NatCue Healthcare Services Private Limited and other cloud services, databases and servers contracted for use, processing and storage of information.

We collect and trasmit user information including but not limited to, email address, phone number, name, social media account information, and contacts to NatCue Servers for the purpose of identifying and contacting the user, the social networks used by user, users family members and connecting user to other users of NatCue.

NatCue uses third party analytics and ad networks which may collect and transmit information about the user and the device to learn, understand the user behaviour in order to deliver services.

You may choose to invite your contacts to NatCue. In such cases, selected user contacts shall be transmitted to NatCue servers to send invitation by NatCue on behalf of the user.

iii. All the information provided to NatCue by a User, including sensitive personal information, is voluntary. You understand that NatCue may use certain information of yours, which has been designated as ‘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, for (c) for sale or transfer such research, statistical or intelligence data in an aggregated or non-personally identifiable form to third parties and affiliates. NatCue also reserves the right to use information provided by or about the End-User for the following purposes:
(a) Publishing such information on the Website.
(b) Contacting End-Users for offering new products or services.
(c) Contacting End-Users for taking product and Service feedback.
(d) Analyzing software usage patterns for improving product design and utility.
(e) Analyzing anonymized practice information for commercial use.
You hereby consent to such use of such information by NatCue.
iv. Collection of information which has been designated as ‘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 collection as required under applicable law. Our Services may be unavailable to you in the event such consent through an email is not given.
v. NatCue does not control or endorse the content, messages or information found in any Services and, therefore, NatCue 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 NatCue relating to same, and to the extent such waiver may be ineffective, you agree to release any claims against NatCue relating to same.
vi. 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 info@natcue.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 NatCue has reasonable grounds to suspect that the information provided by you is untrue, inaccurate, out of date or incomplete, NatCue may, at its sole discretion, discontinue the provision of the Services to you.
vii. You may choose to unsubscribe from promotional communications that you receive from NatCue by clicking the ‘unsubscribe’ link provided at the end of every such promotional communication.
viii. If you wish to cancel your account or request that we no longer use your information to provide you services, contact us through info@natcue.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.
ix. 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 info@natcue.com
x. NatCue may require the User to pay with a credit Credit Cards, Net Banking, Debit Cards, ATM Cards, Bank's IMPS, Prepaid Instruments, or cheque for Services for which subscription amount(s) is/are payable. NatCue will collect such User’s credit card number and/or other financial institution information such as bank account numbers and will use that information for the billing and payment processes, including but not limited to the use and disclosure of such credit card number and information to third parties as necessary to complete such billing operation. Verification of credit information, however, is accomplished solely by the User through the authentication process. User’s credit-card/debit card details are transacted upon secure sites of approved payment gateways which are digitally under encryption, thereby providing the highest possible degree of care as per current technology. However, NatCue provides you an option not to save your payment details. User is advised, however, that internet technology is not full proof safe and User should exercise discretion on using the same.
xi. Due to the communications standards on the Internet, when a User or the End-User or anyone who visits the Website, NatCue automatically receives the URL of the site from which anyone visits. NatCue also receives the Internet Protocol (IP) address of each User’s computer (or the proxy server a User used to access the World Wide Web), User’s computer operating system and type of web browser the User is using, email patterns, as well as the name of User’s ISP. This information is used to analyze overall trends to help NatCue improve its Service. The linkage between User’s IP address and User’s personally identifiable information is not shared with third parties. Notwithstanding the above, NatCue may share some of the aggregate findings (not the specific data) in anonymized form (i.e., non-personally identifiable) with advertisers, sponsors, investors, strategic partners, and others in order to help grow its business.
xii. The Website uses temporary cookies to store certain data (that is not sensitive personal data or information) that is used by NatCue and its service providers for the technical administration of the Website, research and development, and for User administration. In the course of serving advertisements or optimizing services to its Users, NatCue may allow authorized third parties to place or recognize a unique cookie on the User’s browser. The cookies however, do not store any personal information of the User.
xiii. A User may have limited access to the Website and make appointments with the doctors without creating an account on the Website. Unregistered Users can make appointments with the doctors by providing their name and phone number. In order to have access to all the features and benefits on our Website, a User must first create an account on our Website. To create an account, a User is required to provide the following information, which such User recognizes and expressly acknowledges is personal information allowing others, including NatCue, to identify the User: name, User ID, email address, country, ZIP/postal code, age, phone number, password chosen by the User and valid financial account information. Other information requested on the registration page, including the ability to receive promotional offers from NatCue, is optional. NatCue may, in future, include other optional requests for information from the User to help NatCue to customize the Website to deliver personalized information to the User. However, NatCue assumes your consent in relation to various matters, once you complete the registration process.
xiv. This Privacy Policy applies to Services that are owned and operated by NatCue. NatCue 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 NatCue is not responsible or liable. Accordingly, NatCue does not make any representations concerning the privacy practices or policies of such third parties or terms of use of such websites, nor does NatCue 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 NatCue 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. NatCue encourages the User to read the privacy policies of that website.
xv. The Website 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 NatCue representatives or agents, and their opinions or statements do not necessarily reflect those of NatCue, and they are not authorized to bind NatCue to any contract. NatCue 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.
xvi. NatCue does not collect information about the visitors of the Website from other sources, such as public records or bodies, or private organisations, save and except for the purposes of registration of the Users (the collection, storage and disclosure of which each End User must agree to under the terms of use in order for NatCue to effectively render the Services).
xvii. NatCue maintains a strict “No-Spam” policy, which means that NatCue does not intend to sell, rent or otherwise give your e-mail address to a third party without your consent.
xviii. NatCue has implemented best international market practices and security policies, rules and technical measures to protect the personal data that it has under its control from unauthorised access, improper use or disclosure, unauthorised modification and unlawful destruction or accidental loss. However, for any data loss or theft due to unauthorized access to the User’s electronic devices through which the User avails the Services, NatCue shall not be held liable for any loss whatsoever incurred by the User.
xix. NatCue 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 NatCue business. The reasonable security practices and procedures implemented by NatCue include but are not limited to: encrypting data when it is on the move using industry standard practices, keeping all the data within private cloud, regularly changing production keys and password, secure and very limited access to all production servers, performing regular security updates on our servers and more.
xx. NatCue 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 NatCue, in its sole discretion, deems it necessary in order to protect its rights or the rights of others, to prevent harm to persons or property, to fight fraud and credit risk, or to enforce or apply the Terms of Use.

3.2 PRACTITIONERS NOTE:

This section applies to all Practitioners.

i. As part of the registration as well as the application creation and submission process that is available to Practitioners on NatCue, certain information, including sensitive personal data or information is collected from the Practitioners.

ii. 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 sensitive personal data or information to NatCue, failing which they are required to leave the Services, including the Website immediately.

iii. Practitioners’ personally identifiable information, which they choose to provide to NatCue, is used to help the Practitioners describe and identify themselves. This information is exclusively owned by NatCue. NatCue 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. NatCue also reserves the right to use information provided by or about the Practitioner for the following purposes:

(a) Publishing such information on the Website.

(b) Contacting Practitioners for offering new products or services.

(c) Contacting Practitioners for taking product feedback.

(d) Analyzing software usage patterns for improving product design and utility.

(e) Analyzing anonymized practice information including financial, and inventory information for commercial use.

3.3 END-USERS NOTE:

This section applies to all End-Users.

i. As part of the registration/application creation and submission process that is available to End-Users on this website, certain information, including sensitive personal data or information is collected from the Users.

ii. All the statements in this Privacy Policy apply to all End-Users, and all End- Users are therefore required to read and understand the privacy statements set out herein prior to submitting any sensitive personal data or information to NatCue, failing which they are required to leave the NatCue immediately.

iii. If you have inadvertently submitted any such information to NatCue prior to reading the privacy statements set out herein, and you do not agree with the manner in which such information is collected, stored or used, then you may access, modify and delete such information by using options provided on the Website. In addition, you can, by sending an email to info@natcue.com, inquire whether NatCue is in possession of your personal data, and you may also require NatCue to delete and destroy all such information.

iv. End-Users’ personally identifiable information, which they choose to provide on the Website is used to help the End-Users describe/identify themselves. Other information that does not personally identify the End-Users as an individual, is collected by NatCue from End-Users (such as, patterns of utilization described above) and is exclusively owned by NatCue. NatCue may also use such information in an aggregated or non-personally identifiable form for research, statistical analysis and business intelligence purposes, and may sell or otherwise transfer such research, statistical or intelligence data in an aggregated or non personally identifiable form to third parties and affiliates. In particular, NatCue reserves with it the right to use anonymized End-User demographics information and anonymized End-User health information for the following purposes:

(a) Analyzing software usage patterns for improving product design and utility.

(b) Analyzing such information for research and development of new technologies.

(c) Using analysis of such information in other commercial product offerings of NatCue.

(d) Sharing analysis of such information with third parties for commercial use.

v. NatCue will communicate with the End-Users through email, phone and notices posted on the Website or through other means available through the service, including text and other forms of messaging. The End-Users can change their-mail and contact preferences at any time by logging into their “Account” at NatCue App and changing the account settings.

vi. At times, NatCue conducts a User survey to collect information about End- Users’ preferences. These surveys are optional and if End-Users choose to respond, their responses will be kept anonymous. Similarly, NatCue may offer contests to qualifying End-Users in which we ask for contact and demographic information such as name, email address and mailing address. The demographic information that NatCue collects in the registration process and through surveys is used to help NatCue improve its Services to meet the needs and preferences of End-Users. This may include targeting advertising to End-Users about our Services.

vii. NatCue may keep records of electronic communications and telephone calls received and made for making appointments or other purposes for the purpose of administration of Services, customer support, research and development and for better profile information of Practitioners.

viii. All NatCue employees and data processors, who have access to, and are associated with the processing of sensitive personal data or information, are obliged to respect the confidentiality of every End-Users’ sensitive personal data and information.

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

x. To the extent necessary to provide End-Users with the Services, NatCue may provide their personal information to third party contractors who work on behalf of or with NatCue to provide End-Users with such Services, to help NatCue communicate with End-Users or to maintain the Website. Generally these contractors do not have any independent right to share this information, however certain contractors who provide services on the Website, including the providers of online communications services, will have rights to use and disclose the personal information collected in connection with the provision of these Services in accordance with their own privacy policies.

3.4 CASUAL VISITORS NOTE:

i. No sensitive personal data or information is automatically collected by NatCue from any casual visitors of this website, who are merely perusing the site.

ii. Nevertheless, certain provisions of this Privacy Policy are applicable to even such casual visitors, and such casual visitors are also required to read and understand the privacy statements set out herein, failing which they are required to leave this website immediately.

iii. If you, as a casual visitor, have inadvertently browsed any other page of this Website prior to reading the privacy statements set out herein, and you do not agree with the manner in which such information is obtained, stored or used, merely quitting this browser application should ordinarily clear all temporary cookies installed by NatCue. All visitors, however, encouraged to use the “clear cookies” functionality of their browsers to ensure such clearing / deletion, as NatCue cannot guarantee, predict or provide for the behaviour of the equipment of all the visitors of the Website.

iv. You are not a casual visitor if you have willingly submitted any personal data or information to NatCue through any means, including email, post or through the registration process on the Website. All such visitors will be deemed to be, and will be treated as, Users for the purposes of this Privacy Policy, and in which case, all the statements in this Privacy Policy apply to such persons.

4. CONFIDENTIALITY AND SECURITY

i. Your Personal Information is maintained by NatCue 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. NatCue 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 NatCue’s business.

ii. No administrator at NatCue 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 Website when finished. NatCue does not undertake any liability for any un-authorised use of your account and password. If you suspect any unauthorized use of your account, you must immediately notify NatCue by sending an email to info@natcue.com You shall be liable to indemnify NatCue due to any loss suffered by it due to such unauthorized use of your account and password.

iii. NatCue makes all User information accessible to its employees, agents or partners and third parties only on a need-to-know basis, and binds all such employees to strict confidentiality obligations.

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

v. Part of the functionality of the NatCue is assisting the patients to access information relating to them. NatCue may, therefore, retain and submit all such records to the relevant patients, or to their doctors.

vi. Notwithstanding the above, NatCue 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, NatCue 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 NatCue including, acts of government, computer hacking, unauthorised access to computer data and storage device, computer crashes, breach of security and encryption, poor quality of Internet service or telephone service of the User etc.

5. CHANGE TO PRIVACY POLICY

NatCue may update this Privacy Policy at any time, with or without advance notice. In the event there are significant changes in the way NatCue treats User’s personally identifiable information, or in the Privacy Policy itself, NatCue 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 info@natcue.com to deactivate your account. Unless stated otherwise, NatCue’s current Privacy Policy applies to all information that NatCue 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.

6. CHILDREN’S AND MINOR’S PRIVACY

NatCue strongly encourages parents and guardians to supervise the online activities of their minor children and consider using parental control tools available from online services and software manufacturers to help provide a child-friendly online environment. These tools also can prevent minors from disclosing their name, address, and other personally identifiable information online without parental permission. Although the NatCue Website and Services are not intended for use by minors, NatCue respects the privacy of minors who may inadvertently use the internet or the mobile application.

7. CONSENT TO THIS POLICY

You acknowledge that this Privacy Policy is a part of the Terms of Use of the Website and the other Services, and you unconditionally agree that becoming a User of the Website and its Services signifies your assent to this Privacy Policy. Your visit to the Website and use of the Services is subject to this Privacy Policy and the Terms of Use.

8. ADDRESS FOR PRIVACY QUESTIONS

Should you have questions about this Privacy Policy or NatCue’s information collection, use and disclosure practices, you may contact us at the address: info@natcue.com. 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 by e-mail at info@natcue.com for any privacy concerns.

Refund and Cancellation Policy