Privacy Policies

Leading Bird Web Services Private Limited (“us”, “we”, or “Leading Bird”, “ConnectedH” which also includes its affiliates) is the owner of https://www.connectedh.com (“Website”) as well as the software provided by Leading Bird.

This Privacy Policy help you understand how we collect, use, store, process, transfer and protect all your information when you visit any of our Website and use our products and services.

PLEASE READ THIS PRIVACY POLICY CAREFULLY. YOU INDICATE THAT YOU UNDERSTAND, AGREE AND CONSENT TO THIS PRIVACY POLICY. HENCE BY VISITING OUR WEBSITE OR BY USING / AVAILING ANY OF OUR SERVICE OR PRODUCT, YOU HEREBY GIVE YOUR UNCONDITIONAL CONSENT OR AGREEMENTS TO LEADING BIRD AS PROVIDED UNDER SECTION 43A AND SECTION 72A OF INFORMATION TECHNOLOGY ACT, 2000 FOR COLLECTION, USE, STORAGE, PROCESSING AND TRANSFER AND DISCLOSURE OF YOUR INFORMATION.

YOU ACKNOWLEDGE THAT YOU HAVE ALL LEGAL RIGHTS AND LAWFUL AUTHORITY TO SHARE THE INFORMATION WITH US AND FURTHER ACKNOWLEDGE THAT BY COLLECTING, SHARING, PROCESSING AND TRANSFERRING INFORMATION PROVIDED BY YOU, THIS SHALL NOT CAUSE ANY LOSS OR WRONGFUL GAIN TO YOU OR ANY OTHER PERSON.

IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY, PLEASE DO NOT ACCESS / USE OUR WEBSITE OR AVAIL ANY OF OUR SERVICE OR PRODUCT ON OUR WEBSITE.

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 Leading Bird will disclose such information.

1.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, 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 Leading Bird. 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);

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 Leading Bird 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:

vi. passwords;

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

viii. physical, physiological and mental health condition;

ix. sexual orientation;

x. medical records and history;

xi. biometric information;

xii. information received by body corporate under lawful contract or otherwise;

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

xiv. call data records.

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

PRIVACY STATEMENTS

3.1 ALL USERS NOTE:

This section applies to all users.

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

3.1.2 All the information provided to Leading Bird by a User, including Personal Information or any Sensitive Personal Data or Information, is voluntary. You understand that Leading Bird 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 of booking appointments and for obtaining feedback in relation to the Practitioners and their practice, (e) debugging customer support related issues. Leading Bird 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. Contacting End-Users for offering new products or services.

iii. Contacting End-Users for taking product and Service feedback.

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

v. Analyzing anonymized practice information for  commercial use.

If you have voluntarily provided your Personal Information to Leading Bird for any of the purposes stated above, you hereby consent to such collection and use of such information by Leading Bird. However, Leading Bird shall not contact You on Your telephone number(s) for any purpose including those mentioned in this sub-section 4.1(iii), if such telephone number is registered with the Do Not Call registry (“DNC Registry”) under the PDPA without your express, clear and un-ambiguous written consent.

3.1.3 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.

3.1.4 Leading Bird does not control or endorse the content, messages or information found in any Services and, therefore, Leading Bird 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 Leading Bird relating to same, and to the extent such waiver may be ineffective, you agree to release any claims against Leading Bird relating to the same.

3.1.5 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 by contacting us through [email protected] 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 Leading Bird has reasonable grounds to suspect that the information provided by you is untrue, inaccurate, out of date or incomplete, Leading Bird may, at its sole discretion, discontinue the provision of the Services to you. There may be circumstances where Leading Bird 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.

3.1.6 If you wish to cancel your account or request that we no longer use your information to provide you Services, contact us through [email protected] . 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 Leading Bird being unable to provide you with its Services or to terminate any existing relationship Leading Bird may have with you.

3.1.7 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 [email protected]

3.1.8 Leading Bird may require the User to pay with a credit card, wire transfer, debit card or cheque for Services for which subscription amount(s) is/are payable. Leading Bird 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, Leading Bird 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.

3.1.9 Due to the communications standards on the Internet, when a User or the End-User or anyone who visits the Website, Leading Bird automatically receives the URL of the site from which anyone visits. Leading Bird also receives the Internet Protocol (IP) address of each User’s computer (or theproxy 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 Leading Bird improve its Service. The linkage between User’s IP address and User’s personally identifiable information is not shared with or disclosed to third parties. Notwithstanding the above, Leading Bird may share and/or disclose some of the aggregate findings (not the specific data) in anonymized form (i.e., non-personally identifiable) with advertisers, sponsors, investors, strategic partners, and others in order to help grow its business.

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

3.1.11 This Privacy Policy applies to Services that are owned and operated by Leading Bird. Leading Bird 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 Leading Bird is not responsible or liable. Accordingly, Leading Bird does not make any representations concerning the privacy practices or policies of such third parties or terms of use of such websites, nor does Leading Bird 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 Leading Bird 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. Leading Bird encourages the User to read the privacy policies of that website.

3.1.12 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 Leading Bird representatives or agents, and their opinions or statements do not necessarily reflect those of Leading Bird, and they are not authorized to bind Leading Bird to any contract. Leading Bird hereby expressly disclaims any liability for any reliance or misuse of such information that is made available by Users or visitors in such a manner.

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

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

3.1.15 Leading Bird 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, Leading Bird shall not be held liable for any loss whatsoever incurred by the User.

3.1.16 Leading Bird 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 Leading Bird’s business.

3.1.17 Leading Bird 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 Leading Bird, 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 END-USERS NOTE:

This section applies to all End-Users.

3.2.1 As part of the registration/application creation and submission process that is available to End-Users on this Website, certain information, including Personal Information or Sensitive Personal Data or Information is collected from the End-Users.

3.2.2 All the statements in this Privacy Policy apply to all End-Users, and all End-Users are therefore required to read and understand the privacy statements set out herein prior to submitting any Personal Information or Sensitive Personal Data or Information to Leading Bird, failing which they are required to leave the Leading Bird immediately.

3.2.3 If you have inadvertently submitted any such information to Leading Bird prior to reading the privacy statements set out herein, and you do not agree with the manner in which such information is collected, processed, stored, used or disclosed, 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 [email protected], inquire whether Leading Bird is in possession of your personal data, and you may also require Leading Bird to delete and destroy all such information.

3.2.4 End-Users’ personally identifiable information, which they choose to provide on the Website is used to help the End-Users describe/identify themselves. Other information that does not personally identify the End-Users as an individual, is collected by Leading Bird from End-Users (such as, patterns of utilization described above) and is exclusively owned by Leading Bird. Leading Bird 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, Leading Bird reserves with it the right to use anonymized End-User demographics information and anonymized End-User health information for the following purposes:

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

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

viii. Using analysis of such information in other commercial product offerings of Leading Bird.

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

3.2.5 Leading Bird will communicate with the End-Users through email, phone and notices posted on the Website or through other means available through the service, including text and other forms of messaging. The End-Users can change their e-mail and contact preferences at any time by sending a mail to [email protected]

3.2.6 At times, Leading Bird 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, Leading Bird 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 Leading Bird collects in the registration process and through surveys is used to help Leading Bird improve its Services to meet the needs and preferences of End-Users.

3.2.7 Leading Bird 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 listing of Practitioners.

3.2.8 All Leading Bird employees and data processors, who have access to,and are associated with the processing of sensitive personal data or information, are obliged to respect the confidentiality of every End-Users’ Personal Information or Sensitive Personal Data and Information. Leading Bird has put in place procedures and technologies as per good industry practices and in accordance with the applicable laws, to maintain security of all personal data from the point of collection to the point of destruction. Any third-party data processor to which Leading Bird transfers Personal Data shall have to agree to comply with those procedures and policies, or put in place adequate measures on their own.

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

3.2.10 To the extent necessary to provide End-Users with the Services,Leading Bird may provide their Personal Information to third party contractors who work on behalf of or with Leading Bird to provide End-Users with such Services, to help Leading Bird communicate with End-Users or to maintain the Website. Generally these contractors do not have any independent right to share this information, however certain contractors who provide services on the Website, including the providers of online communications services, may use and disclose the personal information collected in connection with the provision of these Services in accordance with their own privacy policies. In such circumstances, you consent to us disclosing your Personal Information to contractors, solely for the intended purposes only.

3.3 GUEST VISITORS PRIVACY POLICY STATEMENT:

3.3.1 No sensitive personal data or information is automatically collected by Leading Bird from any casual visitors of this website, who are merely perusing the Website.

3.3.2 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.

3.3.3 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, collected, processed, stored, used, disclosed or retained, merely quitting this browser application should ordinarily clear all temporary cookies installed by  Leading Bird. All visitors, however, are encouraged to use the “clear cookies” functionality of their browsers to ensure such clearing / deletion, as Leading Bird cannot guarantee, predict or provide for the behaviour of the equipment of all the visitors of the Website.

3.3.4 You are not a casual visitor if you have willingly submitted any personal data or information to Leading Bird through any means, including email, post or through the registration process on the Website www.connectedh.com. 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

4.1 Your Personal Information is maintained by Leading Bird 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. Leading Bird 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 Leading Bird’s business.

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

4.3 Part of the functionality of the Leading Bird is assisting the patients to access information relating to them. Leading Bird may, therefore, retain and submit all such records to the relevant patients, or to their medical practioner.

4.4 Notwithstanding the above, Leading Bird 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, Leading Bird 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 Leading Bird 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.

  1. CHANGE TO PRIVACY POLICY

Leading Bird may update this Privacy Policy at any time, with or without advance notice. In the event there are significant changes in the way Leading Bird treats User’s personally identifiable information, or in the Privacy Policy itself, Leading Bird 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 [email protected] Unless stated otherwise, Leading Bird’s current Privacy Policy applies to all information that Leading Bird 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.

  1. 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

(i) assent to this Privacy Policy, and

(ii) consent to Leading Bird using, collecting, processing and/or  disclosing your Personal Information in the manner and for the purposes set out in this Privacy Policy. Your visit to the Website and use of the Services is subject to this Privacy Policy and the Terms of Use.

  1. ADDRESS FOR PRIVACY QUESTIONS

Should you have questions about this Privacy Policy or Leading Bird's information collection, use and disclosure practices, you may contact, the Data Protection Officer appointed by Leading Bird 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: Suresh Singh

Leading Bird Web Services Private Limited,

Email: [email protected]

 

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