1. Introduction
This Privacy Policy (“Policy”) describes how Online Chikitsa Mitra (“OCM”, “we”, “our”, or “us”), a digital healthcare technology platform and e-clinic network owned and operated by Salubrious Technologies Pvt. Ltd. (“Salubrious Technologies”), collects, receives, records, stores, organises, uses, processes, shares, transfers, retains, and otherwise handles personal data of individuals who access or use OCM’s website, mobile applications, telemedicine platform, e-clinic services, and other digital healthcare services (collectively, the “Services”).
Salubrious Technologies Pvt. Ltd. is the legal entity responsible for the operation and management of OCM and for the processing of personal data in connection with the Services. This Policy applies to patients, prospective patients, healthcare professionals, healthcare establishments, pharmacies, diagnostic partners, business partners, authorised representatives, individuals making enquiries, and visitors accessing the OCM Website.
By accessing or using the Services, or by voluntarily providing personal data through the Services, you acknowledge that your personal data may be processed in accordance with this Policy, applicable laws, and any additional consent forms, service agreements, or platform-specific terms that may apply to particular services.
2. Nature of OCM’s Role in Healthcare Services
OCM operates as a digital healthcare technology platform that facilitates interactions between patients and registered healthcare professionals and healthcare service providers through technology-enabled services, including telemedicine consultations and e-clinic services. OCM provides digital infrastructure, appointment management systems, communication tools, electronic health record functionalities, and other related technological services necessary for facilitating such interactions.
OCM itself does not practise medicine or independently provide medical diagnosis, clinical advice, prescriptions, or treatment. Medical assessment, diagnosis, prescriptions, treatment recommendations, and other clinical decisions remain solely the professional responsibility of the consulting Registered Medical Practitioner (“RMP”) or other authorised healthcare professional providing the healthcare service.
3. Categories of Personal Data Collected
Depending upon the nature of your interaction with OCM and the Services used by you, OCM may collect and process various categories of personal data. This may include personal identification information such as your name, age, date of birth, gender, photograph, government-issued identification information where required under applicable law, and any unique identification details generated for your account or records.
OCM may collect your contact information, including your mobile number, email address, residential or correspondence address, emergency contact information, and other communication details provided by you.
For the purpose of facilitating healthcare services through the OCM platform, OCM may process health-related personal data, including medical history, symptoms, health conditions, consultation records, clinical notes, prescriptions, diagnostic reports, laboratory results, medication history, allergies, treatment plans, follow-up information, and any other health information voluntarily provided by you or lawfully provided on your behalf.
OCM may also collect information relating to your use of the Services, including account credentials, appointment history, consultation schedules, communications made through the platform, customer support interactions, payment and transaction information, and records relating to services availed through OCM. Where payments are processed through third-party payment service providers, OCM may receive transaction-related information necessary for payment verification, accounting, fraud prevention, or customer support, but does not represent that it stores complete payment card details unless required and permitted under applicable law.
OCM may additionally collect technical and usage-related information such as Internet Protocol (IP) address, device identifiers, device type, operating system information, browser type, application version, access dates and times, system logs, error reports, and information regarding how users interact with the Services. Such information may be collected directly or through cookies and similar technologies in accordance with OCM’s Cookie Policy.
4. Sources of Personal Data
OCM may obtain personal data directly from you when you create an account, book a consultation, use telemedicine services, communicate with healthcare professionals, submit forms, upload medical documents, make payments, contact customer support, or otherwise interact with the Services.
Personal data may also be received from authorised representatives, parents or legal guardians where applicable, healthcare professionals involved in your care through the OCM platform, healthcare establishments, pharmacies, diagnostic partners, technology service providers, and other lawful sources where such collection is permitted under applicable law.
5. Purposes of Processing Personal Data
OCM processes personal data for purposes including providing and improving the Services, creating and managing user accounts, verifying user identity where necessary, scheduling appointments, facilitating telemedicine consultations, enabling communication between patients and healthcare professionals, maintaining healthcare records, processing payments, providing customer support, managing business relationships, ensuring platform security, preventing fraud and misuse, analysing and improving platform performance, complying with legal and regulatory obligations, responding to lawful requests from authorities, and protecting the rights, safety, property, and legitimate interests of OCM, users, healthcare professionals, and other stakeholders.
6. Legal Basis and Consent
OCM processes personal data in accordance with applicable data protection laws, including the Digital Personal Data Protection Act, 2023, the Information Technology Act, 2000, and applicable rules and regulations issued thereunder. Where required under applicable law, OCM shall obtain your consent before collecting or processing personal data, including health-related information. In other circumstances, OCM may process personal data where such processing is necessary for providing the Services, complying with legal obligations, protecting lawful interests, or on any other basis permitted under applicable law.
Where you provide personal data relating to another individual, including a child, dependent, patient, or authorised representative, you represent that you are authorised to provide such information and consent to its processing in accordance with this Policy and applicable laws.
7. Sharing and Disclosure of Personal Data
OCM may share personal data with Registered Medical Practitioners, healthcare establishments, pharmacies, diagnostic centres, and other healthcare service providers to facilitate consultations, treatment-related services, follow-up care, and other services requested by the user through the platform.
Personal data may also be shared with third-party technology providers, cloud hosting providers, communication service providers, payment processors, security service providers, customer support providers, and other operational partners engaged by OCM for the purpose of operating, maintaining, and improving the Services. Such entities shall process personal data only for authorised purposes and subject to contractual confidentiality and security obligations.
OCM may disclose personal data where required to comply with applicable law, judicial orders, governmental directions, regulatory requirements, or lawful requests from competent authorities. Personal data may also be transferred or disclosed as part of a merger, acquisition, corporate restructuring, financing transaction, or transfer of assets, subject to compliance with applicable legal requirements.
8. Data Retention
OCM retains personal data only for as long as necessary to fulfil the purposes described in this Policy, provide healthcare and technology services, maintain medical and transactional records, comply with legal, regulatory, taxation, accounting, and reporting requirements, resolve disputes, and enforce legal rights.
Upon expiry of the applicable retention period or where personal data is no longer required, OCM may securely delete, anonymise, archive, or otherwise dispose of such information in accordance with applicable legal requirements and internal retention practices.
9. Data Security
OCM implements reasonable technical, organisational, administrative, and physical safeguards designed to protect personal data from unauthorised access, misuse, alteration, accidental loss, destruction, or disclosure. Such measures may include access controls, authentication mechanisms, encryption measures where appropriate, monitoring systems, and contractual obligations with relevant service providers.
However, no method of electronic transmission, storage, or processing can be guaranteed to be completely secure. Users are responsible for maintaining the confidentiality of their account credentials and taking reasonable precautions to protect their devices and personal information.
10. Cross-Border Transfer of Personal Data
Where personal data is transferred outside India, OCM shall undertake such transfer in accordance with applicable laws, including any conditions, restrictions, or requirements prescribed under the Digital Personal Data Protection Act, 2023 and other applicable legal frameworks.
11. Your Rights and Choices
Subject to applicable law, you may have rights in relation to your personal data, including the right to obtain information regarding the processing of your personal data, request correction or completion of inaccurate or incomplete personal data, request erasure of personal data where legally permissible, withdraw consent where processing is based on consent, nominate another person to exercise your rights in accordance with applicable law, and seek grievance redressal in relation to the processing of your personal data.
OCM will consider and address such requests in accordance with applicable legal requirements and operational obligations, including obligations relating to the retention of medical records and other legally required information.
12. Children’s Data and Persons with Disabilities
Where OCM processes personal data relating to children or persons with disabilities having a lawful guardian, such processing shall be undertaken in accordance with applicable legal requirements and with the involvement, authorisation, or consent of the parent or lawful guardian, where required.
13. Third-Party Services and Links
The Services may contain links to websites, applications, platforms, payment systems, or services operated by third parties. OCM does not control and is not responsible for the privacy practices, security standards, content, or data processing activities of such third parties. Users are encouraged to review the applicable privacy policies and terms of such third-party services before sharing personal data with them.
14. Cookies and Similar Technologies
OCM may use cookies and similar technologies in connection with the operation of its website and digital Services. Such technologies may be used to maintain functionality, improve user experience, analyse performance, and support security measures. Further information regarding the use of cookies and available choices is provided in OCM’s Cookie Policy.
15. Grievance Redressal and Contact Information
If you have any questions, requests, complaints, or concerns regarding this Privacy Policy or OCM’s processing of personal data, you may contact the designated grievance officer or privacy contact at:
Privacy Officer / Grievance Officer Salubrious Technologies Pvt. Ltd. New Delhi, India Email: ocmgrievance@salubrioustech.com
OCM shall address grievances and requests in accordance with applicable laws and prescribed timelines.
16. Changes to this Privacy Policy
Salubrious Technologies Pvt. Ltd. may revise or update this Privacy Policy from time to time to reflect changes in the Services, technology, business operations, or applicable legal and regulatory requirements. Any updated version will be published with a revised “Last Updated” date. Continued use of the Services after such updates shall constitute acknowledgement of the revised Policy to the extent permitted under applicable law.
17. Governing Law and Dispute Resolution
This Privacy Policy shall be governed by and construed in accordance with the laws of India. Any disputes arising from or relating to this Policy shall be subject to the dispute resolution mechanism set out in OCM’s applicable Terms of Use, Platform Terms, or other service-specific agreements.
