QurPro PRIVACY POLICY

This policy should be read in conjunction with our QurPro Terms of Service, into which this policy is incorporated by reference.

Overview

Thank you for choosing to be part of our community at QurHealth Solutions India Private Limited (“QSIPL”, “Company,” “we,” “us,” or “our”), an authorized licensee in the territory of India of QurHealth, which is incorporated as QurHealth Inc. and part of Ventech Solutions Inc. Columbus, Ohio, USA. The Users being the Consultants as defined in the QurPro Terms of Use (hereinafter be referred to as “you”, “your” as applicable) can access and use the applications, websites and all related sub-domains and/or mobile applications (“QurPro Application“) and the Company is committed to respecting the privacy rights of our Consultants customers, visitors, and other users of the QurPro Services (as defined in the QurPro Terms of Use of the Company available at www.qurpro.com) provided via the QurPro Application. We are committed to protecting your Personal Information (as defined below) and the information of the Patients as defined in the QurPro Terms of Use. If you have any questions or concerns about our policy or our practices with regards to your Personal Information, please contact us at DocSupport@qurhealth.in.

When you visit our QurPro Application, or use the QurPro service or any QUR Suite Services, you trust us with your Personal Information. We take your privacy very seriously. In this privacy policy (“QurProPolicy“), we seek to explain to you in the transparent way possible what information we collect, how we use it, and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. By using our QurPro Application and QurPro Service, you agree to the terms of this QurPro Policy. This QurPro Policy may change from time to time. Your continued use of our QurPro Application and QurPro Service after we make changes is deemed to be acceptance of those changes, so please check the QurPro Policy periodically for updates. If there are any terms in this QurPro Policy that you do not agree with, please discontinue the use of our QurPro Application and our QurPro Service.

This QurPro Policy applies to all information collected through our QurPro Application, and/or any related QurPro Service including Teleconsulting Services (as defined under the QurPro Terms of Use). This QurPro Policy does not apply to websites, applications, or other domains that are maintained or operated by third parties or our affiliates. Our QurPro Application may link to third-party websites and services, such as but not limited to Amazon, Microsoft, Adobe, Google, and Facebook, but these links are not endorsements of these sites, and this QurPro Policy does not extend to them. As this QurPro Policy is not enforced on these third-party websites, we encourage you to read any posted policies of third party websites before using the service or site and providing any information.

This QurPro Policy as amended from time to time forms part and parcel of the QurPro Applications terms of Use (“QurPro Terms“) and is included therein by this reference. The capitalized terms which have been used herein but are not specifically defined shall have the same meaning as attributed to such term in the QurPro Terms. The QurPro Terms and this QurPro Privacy Policy are to be interpreted harmoniously at all events

Also, we do not warrant or represent that this QurPro Policy or the QurPro Application’s use of the Personal Information complies with the laws of any particular jurisdiction. To provide you with our QurPro service or any QUR Suite services, we may store, process, and transmit information in India.

This document is an electronic record in terms of Information Technology Act, 2000 and rules there under as applicable and the amended provisions pertaining to electronic records in various statutes as amended by the Information Technology Act, 2000 (together with any statutory amendments or modifications thereof). This electronic record is generated by a computer system and does not require any physical or digital signatures.

Please read this QurPro Policy carefully as it will help you make informed decisions about sharing your Personal Information with us.

You can, however, visit the www.qurpro.com website without revealing who you are or any information that concerns yourself.

1. THE TYPE OF DATA COLLECTED FROM USERSWe might ask you to voluntarily provide information such as your name, phone number, email, and address and for market research purposes, your demographic information, personal interests, and your experience related to the use of the product.

   Our primary goal is to provide you a safe, efficient, smooth and customized experience. This allows us to provide QUR Suite services and features that most likely meet your needs, and to customize the QurPro Application to make your experience safer and easier. More importantly, while doing so, we collect personal, non-personal and other information and correspondences from you, as detailed below, that we consider necessary for achieving this purpose.

   In order for you to access certain QUR Suite Services, we may require you to provide us with certain information that personally identifies you (” Personal Information“). Personal Information is inclusive of, but not limited to, the following categories: (i) Contact Data (such as your e-mail address, phone number and account password); (ii) Demographic Data (such as your gender, your date of birth and your zip code); (iii) Registration Data (your registration id, degree, speciality and clinic name); (iv) Data regarding your usage of the Application and history of the appointments and other transactions made by or with You through the use of the Application and (v) Details of Mode of Payment (such as your card/account number and expiration date of the card).

   Please note that the above list is not an exhaustive list and is only an illustrative list and is without prejudice to our right to seek further Personal Information, as may be required for the provision of the QUR Suite Services to You.

   All Personal Information that you provide to us must be correct, complete, and accurate, and you must notify us of any changes to such Personal Information.

   Apart from the Personal Information, pursuant to the Teleconsulting Services provided by you on the QurPro Application, you will be required to upload notes and records of your prognosis and diagnosis of Patients of whom you have conducted Counselling Sessions (as defined under the QurPro Terms), we will require you to upload and provide access to such data (“Consultant’s Notes“).

   The information including the Consultant Notes that you provide in each case will vary. We will ask you to create a username and password that should only be known to you.

   It is expressly undertaken herein that the Company shall not record any of the Counselling Sessions (as defined in the QurPro Terms of Use) between you and the Patient. You agree and understand that you will be provided access to the Personal Information of Patients which will also include information relating to their Insurance Data (such as the Patient’s insurance carrier and insurance plan) and Medical Data (such as the Patient’s allergies, prescriptions, medication history lab report, previous doctors and dentists visited, Patient’s reason for visit and other medical information such as investigation reports, images, etc. as that the Patient chooses to share with you during the Counselling Session and us)(collectively referred to as the “Patient Data.”.

   You agree and undertake that you will at all points of time maintain utmost confidentiality of the Patient Data and you agree and undertake to immediately report to us of any breach of such confidentiality. You agree and understand the importance of maintaining the confidentiality of any and all Patient Data made available to you through the QurPro Application and during the Counselling Sessions. You will maintain the confidentiality of the said information per applicable laws. You further agree and understand that we are not responsible for the validity or authenticity of such Patient Data made available to you either on the QurPro Application or made available to you through the Patient. Further you agree and undertake to indemnify for any claims raised by any Patient or the family members or legal heirs of any Patient for any improper use or misuse of the Patient Data shared with you vide the QurPro Application or the Patient.

   You further agree and undertake not to use the Patient Data for any other purpose apart from providing medical counselling and agree and undertake to use it per the QurPro Terms and this QurPro Privacy Policy.

   Note: Any content on the QurPro Application shared by Users via reviews, blogs, online chat or instant messages, discussion boards, forums, user testimonials etc. are not considered as Personal Information and is not subject to the terms of this QurPro Policy. We will not be responsible for the accuracy or filtration of any of the content posted on our Application by any User, however, we will be entitled to remove any content posted by any User on our QurPro Application which we, in our sole discretion, consider offensive, discriminatory, racist, defamatory or inappropriate in nature.

2. INFORMATION AUTOMATICALLY COLLECTEDWe automatically collect certain information when you visit, use, or navigate through the Application. This information does not reveal your specific identity (like your name or contact information). Still, it may include device and usage information, such as your IP address, browser, and device characteristics, operating system, language preferences, referring URLs, and device name. This information is primarily needed to maintain the security and operation of our Application, and for our internal analytics and reporting purposes.

   Like many businesses, we also collect information through cookies and similar technologies.

   Online Identifiers. We collect cookie identifiers, or others such as the ones used for analytics and marketing, and other similar data.

3. INFORMATION COLLECTED THROUGH OUR APPLICATIONIf you use our QurPro Application, we may also collect the following information:
   • Geo-Location Information. We may request access or permission to and track location-based information from your mobile device, either continuously or while you are using our QurPro Application, to provide location-based services. If you wish to change our access or permissions, you may do so in your device’s settings.
   • Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device’s camera, sensors, reminders, SMS messages, storage, and other features. our secured cloud storage will save these data collected. If you wish to change our access or permissions, you may do so in your device’s settings.
   • Mobile Device Data. We may automatically collect device information (such as your mobile device ID, model, and manufacturer), operating system, version information, and IP address.
   • Your Connection: We may request access to the contact list in your device address book. If any of your contacts aren’t yet using our Services, we’ll manage this information in a way that is designed to ensure that those contacts cannot be identified by us. You can share and invite them with your permission via QurPro to avail the App services.
   • Push Notifications. We may request to send you Push Notifications regarding your account or the mobile application. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings.
   • ” Sheela G ” Conversational Voice Assistant. Our voice-assistant “Sheela G ” is your conversational health assistant. A native voice assistant application that listens for and responds to voice queries and commands from the users (which may include ambient noise and background conversations) and then stores the incoming data in our application databases. The voices from the Consultants could be processed and used for voice identification matching. All voice recordings or queries can be transcribed and stored as search results, which can still be associated with a particular user even after the original voice recording has been deleted.
4. THE PURPOSE AND USE OF DATA COLLECTEDWe use (i)Personal Information, (ii)Patient Data and (iii) the Consultant Notes collected via our QurPro Application (i, ii and iii collectively referred to as “QurPro Data“) for a variety of business purposes described below. We process the QurPro Data for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, allow you to provide the Teleconsulting Services on the QurPro Application with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.

   We use the information we collect or receive:

   • To facilitate account creation and logon process. If you choose to link your account with us to a third party account (such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process for the performance of the contract.
   • Request Feedback. We may use your information to request feedback and to contact you about your use of our QurPro Application.
   • To enforce our terms, conditions, and policies for business purposes, legal reasons, and contractual.
   • To respond to legal requests and prevent harm. If we receive a notice from a legal authority or a governmental authority or other legal request, we may need to inspect the data we hold to determine how to respond.
   • To manage user accounts. We may use your information to manage your account and keep it in working order.
   • To contact you and to customise our communication with You and the marketing material we share with You.
   • To avoid fraud and other prohibited or illegal activities;
   • To protect the security or integrity of the QurPro Application, our business, the QurPro Service and users
   • To allow the Patients, business partners to present customised messages to You;
   • We may disclose Information, in good faith, wherein the access, use, preservation or disclosure of such information is reasonably necessary to (i) satisfy any applicable law, regulation, legal process or enforceable governmental request, (ii) enforce applicable QurPro Terms, including investigation of potential violations thereof, (iii) detect, prevent, or otherwise address fraud, security or technical issues, or (iv) protect against imminent harm to the rights, property or safety of the Company, its users or the public as required or permitted by law.
   • To better understand our site content, how much of it is beneficial, and how much of it needs improvement in terms of improved user experience.
   • For other Business Purposes. We may use your information for other business purposes, including but not limited to data analysis, Artificial Intelligence (AI)/Machine Learning (ML) model predictions, identifying usage trends, and determining the effectiveness of our promotional campaigns. All these functions are necessary to improve our Application, products, marketing, and user experience. We may use and store this information in aggregated and anonymized form so that it is not associated with individual end-users and does not include Personal Information. We will not use identifiable Personal Information without your consent.
5. SHARING AND PROCESSING OF QurPro DATA To comply with laws, to provide you with QUR Suite services, to enable you to provide Teleconsulting Services on the QurPro Application to protect your rights, or to fulfill business obligations.

   We may process or share data based on the following legal basis:

   • Consent: We may process the QurPro Data if you and the Patient have given us specific consent to use the QurPro Data for the purpose of enabling you to provide the Teleconsulting Services and enabling you to use the QurPro Service.
   • Legitimate Interests: We may process the QurPro Data when it is reasonably necessary to achieve our legitimate business interests.
   • Performance of a Contract: Where we have entered into a contract with you, we may process your Personal Information to fulfill the terms of our contract.
   • Legal Obligations: We may disclose the Personal Information and the Consultant Notes where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal processes, such as in response to a court order (including in response to public authorities to meet national security or law enforcement requirements).
   • Vital Interests: We may disclose Personal Information and the Consultant Notes where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies or QurPro Terms of Use and suspected fraud. Also, this disclosure would happen under situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

   More specifically, we may need to process the Personal Information and the Consultant in the following situations:

   • We may share your data with third-party vendors, service providers, or the users/ Patients who avail the Teleconsulting Services on the QurPro Application. We may allow selected third parties to use tracking technology on the QurPro Application, which will enable them to collect data about how you interact with the QurPro Application over time. This information may be used to, among other things, analyse and track data, determine the popularity of certain content, and better understand online activity. Unless described in this policy, we do not share, sell, rent, or trade any of QurPro Data with third parties for their promotional purposes.
   • Further, you, your employees, and your agents should be particularly aware of your obligations of patient confidentiality, both in communicating with the Company and in responding to a review of the services posted on the QurPro Application. The Company does not have, and will not accept, any obligations of confidentiality with respect to any communications other than those expressly stated in this QurPro Policy and QurPro Terms.
   • Business Transfers. We may share or transfer your Personal Information, Consultant Notes in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company. Under these circumstances, it may be necessary to share or receive Personal Information, Consultant Notes with prospective or actual partners or affiliates. In such circumstances, the Company will ensure that the QurPro Data is used in accordance with this policy.
   • Third-Party Advertisers. We may use third-party advertising companies to serve ads when you visit the Application. Advertisers and sponsors are responsible for ensuring that material submitted for inclusion on the QurPro Application is accurate and complies with applicable laws. We are not responsible for the illegality or any error, inaccuracy or problem in the advertiser’s or sponsor’s materials. In addition, the Company reserves the right to refuse acceptance of any advertisement it considers inappropriate.
   • We use third-party payment processors (“Payment Processors“) for any payments made to you via this QurPro Application. The processing of payments will be subject to the terms, conditions and privacy policies of the Payment Processors in addition to the QurPro Terms. You acknowledge that neither the Company nor any of its directors, shareholders or other representatives shall be liable to You under any circumstances for any direct, indirect, punitive, incidental, special or consequential damages that result from or arise out of your use of the Payment Processors, your payment through the Payment Processors or your ability or inability to complete the payment
6. USE OF TRACKING TECHNOLOGIESWe may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information.
   

   Cookies: A “cookie” is a small data file transmitted from a website to your device’s hard drive. Cookies come in two types, and we may use both of them: (1) session cookies, which do not stay on your device after you close your browser, and (2) persistent cookies, which remain on your device until you delete them or they expire. If you do not wish to have cookies on your devices, you may turn them off at any time by modifying your internet browser’s settings.

   However, by disabling cookies on your device, you may be prohibited from full use of the QurPro Service or the Application’s features, or lose access to some functionality.

   Third-party Websites and Services. We work with a number of service providers of marketing communications technology. These service providers may use various data collection methods to improve the performance of th marketinge campaigns we are contracting them to provide. The information collected can be gathered on our QurPro Application and also on the websites where our marketing communications are appearing.

   For example, we may collect data where our banner advertisements are displayed on third-party websites.

7. RIGHT TO CONTROL YOUR PERSONAL INFORMATIONWhen accessing our QurPro Application and QurPro service or any QUR Suite services, you will have complete control of your Personal Information. As a registered user of the Application, you can update or modify the Personal Information you have included in your profile. In case of a request for the deletion of your Personal Information, you could send an email to info@qurhealth.in. Upon receiving your request mail, we will take appropriate action and duly keep you notified. However, it may be impossible to remove your account without some residual information being retained by the Application.
8. DATA SECURITYWe have implemented appropriate technical and organizational security measures designed to protect the security of any Personal Information and the Consultant Notes we process. We use reasonable security measures to protect Information from unauthorized access, maintain data accuracy, and help ensure the appropriate use of information. The QUR Suite services can be accessed in such versions of specified web browsers as detailed in the frequently asked questions tab on the Application from time to time. Secure Socket Layer (“SSL “) technology may protect Information using both server authentication and data encryption. We host our QurPro Application in a secure server environment that uses firewalls and other advanced technology to prevent interference or access from outside intruders. However, please also remember that we cannot guarantee that the internet is 100% secure. You have a responsibility, as well, to safeguard your Personal Information, consultant Notes and the Patient Data accessed by you through the proper use and security of any online credentials used to access the QurPro Data, such as a username and password. If you believe your credentials have been compromised, please change your password. Please also notify us of any unauthorized use. Although we will do our best to protect your Personal Information and the QurPro Data the transmission of Personal Information, Consultant Notes and Patient Data to and from our QurPro Application is at your own risk. You should only access the services within a secure environment.
   

   Website Links

   Our QurPro Application and QurPro service or any QUR Suite services may have links to other websites belonging to parties from its distribution and sales networks. However, the Company cannot assume any responsibility for the content or privacy policies pertaining to these sites. At the same time, we make sure we link only to sites that share our high standards of privacy.

   Data Legalities

   Data is lawfully collected and processed at the Company, and the data rights subject to the user and the Consultant is always safeguarded at the Company.

   Purpose of Processing

   The Personal Information and the QurPro Data being processed is only to fulfill the purpose defined, and even if there are subsequent alterations to the said purpose, the changes of it would be limited and would entail further justification.

   Transparency

   As and when applicable per applicable laws in principle, data should be collected directly from the data subject. There must be prior communication with the subject with regards to the usage of this data. The subjects should be duly informed of the following:

   • The identity of the party using the data
   • The purpose of data collection
   • The time periods till which the data would be stored
   • Transfer of the data to any third parties concerned.

   Data Avoidance and Data Minimization

   Before personal data collection takes precedence, the purpose of collection has to be thoroughly understood. If anonymized data or statistical data can solve the purpose, then it can always be preferred over the primary data collection efforts.

9. RETENTION & DELETION OF USER DATAWe will only keep your Personal Information and Consultant Notes for as long as it is necessary for the purposes set out in this QurPro Policy unless a longer retention period is required or permitted by Applicable Law (such as tax, accounting, or other legal requirements.)

   When we have no ongoing legitimate business need to process your Personal Information and Consultant Notes, we will either delete or anonymize it, or, if this is not possible (for example, because your Personal Information and Consultant Notes has been stored in backup archives), then we will securely store your Personal Information and Consultant Notes and isolate it from any further processing as may be required under Applicable Law until deletion is possible.

   In instances where there is a need to store the personal data owing to its historical significance or reasons worthy of storing the information, then the personal data can remain stored, provided the further retention time is legally specified or clarified.

   Factual Correctness

   Personal Information and Consultant Notes provided by the Consultant and stored must be factually correct, complete, and, up-to-date. Incorrect, outdated, or incomplete data will be accordingly corrected, updated, completed, supplemented, or deleted from the QurPro Application and the Company will not be liable for such deletion.

   Data Confidentiality & Security

   Personal data is always entitled to security and confidentiality. Suitable organizational and technical measures should always be in place to protect the personal data against unauthorized access, unlawful processing, disclosure, alteration, loss and destruction.

   Commitment

   All staff members at QSIPL strives to pursue and observe the aforementioned goals and regulations pertaining to data protection to the best of their abilities. In this regard, QSIPL depends on its organizational and technical measures, risk management strategies, training and privacy procedures, and methods that are constantly developed to pursue the same.

10. CHANGES TO THE QurPro POLICYYes, we will update this QurPro Policy as necessary to stay compliant with relevant laws.

    We may update this QurPro Policy from time to time. The updated version will be indicated by an updated “Revised ” date, and the updated version will be effective as soon as it is accessible. The Company reserves the right to modify these policies in any manner, from time to time, entirely at its own discretion, with or without any notification to you. The Company shall be under no obligation to notify or intimate the implementation of any modifications to the QurPro Policy at any time. You are responsible for checking the Policy periodically to remain in compliance with these terms at all times. Your access to and use of our QurPro Application and/or QurPro service or any QUR Suite Services after any amendment to the QurPro Policy shall constitute your deemed acceptance of such modified terms We encourage you to review this QurPro Policy frequently to be informed of how we are protecting your information.

11. REVIEW, UPDATE OR DELETE YOUR PERSONAL INFORMATIONYou may have the right to request access to the Personal Information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please write to us at DocSupport@qurhealth.in , we will respond to your request within 30 days.
12. CONTROLS FOR DO-NOT-TRACK FEATURES
    

    In Short: Since no uniform Technology standard for recognizing and implementing DNT signals has been finalised, we currently do not respond to DNT requests.

    Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT “) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy policy.

13. Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list – however, we will still need to send you service-related emails that are necessary for the administration and use of your account. To otherwise opt-out, you may:■ Contact us using the contact information provided.
14. USE OF GOOGLE MAPSThis website, mobile application, or Facebook application uses Google Maps APIs. To better understand Google’s Privacy Policy, please refer to the privacy policy of Google.

    By using our Maps API Implementation, you agree to be bound by Google’s Terms of Service.

15. SUPPORTIf You have any questions or concerns about our policy, or our practices with regards to your Personal Information, please contact us at DocSupport@qurhealth.in

Last updated: 29^th January, 2021