ANNEXURE – A

Privacy Policy

CURER (here-in-after referred to as “us”, “we”, or “CURER”) is the owner and publisher of the website www.curer.app as well as the related software and mobile phone applications provided by CURER. This privacy policy ("Privacy Policy") explains how we collect, use, share and protect personal information about the Users of the Services, including the Practitioners , the End Users, and the visitors of Website (here-in-after jointly referred to as “you” or “Users” in this Privacy Policy).

Your use of and access to the Services being offered by way of our Website is subject to this Privacy Policy and our aforestated Terms of Use.

BY USING THE SERVICES OFFERED ON OUR WEBSITE 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. Introduction

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”); and
Regulation 3(1) of the Information Technology (Intermediaries Guidelines) Rules, 2011 (the “IG Rules”).

This Privacy Policy states the following:

The type of information collected from the Users, including sensitive personal data or information;
The purpose, means and modes of usage of such information; and
How and to whom CURER 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:

Contact data (such as your email address and phone number);
Demographic data (such as your gender and your pin code);
Data regarding your usage of the services and history of the appointments made by or with you through the use of Services;
Insurance data (such as your insurance carrier and insurance plan); and
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 CURER 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:

Passwords;
Financial information such as bank accounts, credit and debit card details or other payment instrument details;
Physical, physiological and mental health condition;
Sexual orientation;
Medical records and history;
Information received by body corporate under lawful contract or otherwise;
Visitor details as provided at the time of registration or thereafter; and
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.

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 CURER immediately.
All the information provided to CURER by a User, including sensitive personal information, is voluntary. You understand that CURER 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, (c) for sale or transfer such research, statistical or intelligence data in an aggregated or non-personally identifiable form to third parties and affiliates. CURER also reserves the right to use information provided by or about the End User for the following purposes:
1. Publishing such information on the Website.
2. Contacting End Users for offering new products or services.
3. Contacting End Users for taking product and Service feedback.
4. Analyzing software usage patterns for improving product design and utility.
5. Analyzing anonymized practice information for commercial use.

hereby consent to such use of such information by CURER.

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.
CURER does not control or endorse the content, messages or information found in any Services and, therefore, CURER 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 CURER relating to same, and to the extent such waiver may be ineffective, you agree to release any claims against CURER relating to same.
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 support@curer.app. 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 CURER has reasonable grounds to suspect that the information provided by you is untrue, inaccurate, out of date or incomplete, CURER may, at its sole discretion, discontinue the provision of the Services to you.
If you wish to cancel your account or request that we no longer use your information to provide you services, contact us through support@curer.app. 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.
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 support@curer.app.
URER 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. CURER may 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. User is advised, however, that internet technology is not full proof safe and User should exercise discretion on using the same.
Due to the communications standards on the Internet, when a User or the End User or anyone who visits the Website, CURER automatically receives the URL of the site from which anyone visits. CURER 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 CURER 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, CURER 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.
The Website may use temporary cookies to store certain data (that is not sensitive personal data or information) that is used by CURER and its service providers for the technical administration of the Website, research and development, and for User administration.
In order to have access to the features and benefits on our Website and mobile application, 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 CURER, to identify the User: name, email address, phone number, date of birth, gender, password chosen by the User and valid financial account information. CURER may, in future, include other optional requests for information from the User to help CURER customize the Website to deliver personalized information to the User. However, CURER assumes your consent in relation to various matters, once you complete the registration process.
This Privacy Policy applies to Services that are owned and operated by CURER.

CURER 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 CURER is not responsible or liable. Accordingly, CURER does not make any representations concerning the privacy practices or policies of such third parties or terms of use of such websites, nor does CURER 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 CURER 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. CURER encourages the User to read the privacy policies of that website.

CURER 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 CURER to effectively render the Services).
CURER 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, CURER shall not be held liable for any loss whatsoever incurred by the User.
CURER 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 CURER, 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 Guidelines for Practitioners:

This section applies to all Practitioners.

As part of the registration as well as the application creation and submission process that is available to Practitioners on CURER, certain information, including sensitive personal data or information is collected from the Practitioners.
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 CURER, failing which they are required to leave the Services, including the Website and mobile application immediately.
Practitioners’ personally identifiable information, which they choose to provide to CURER, is used to help the Practitioners describe and identify themselves. This information is exclusively owned by CURER. CURER 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. CURER also reserves the right to use information provided by or about the Practitioner for the following purposes:
1. Publishing such information on the Website.
2. Contacting End Users for offering new products or services.
3. Contacting End Users for taking product and Service feedback.
4. Analyzing software usage patterns for improving product design and utility.
The Practitioner information listed on Website and Mobile is displayed when End Users search for practitioners on Website, and the Practitioner information listed on Website and Mobile Application is used by End Users to request for appointments. Any personally identifiable information of the Practitioners listed on the Website is not generated by CURER and is provided to CURER by Practitioners who wish to enlist themselves on the Website or is collected by CURER from the public domain. CURER displays such information on its Website on an as-is basis making no representation or warranty on the accuracy or completeness of the information. CURER will, however, take reasonable steps to ensure the accuracy and completeness of this information.

3.3 End Users Guidelines:

This section applies to all End Users.

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.
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 CURER, failing which they are required to leave the CURER immediately.
If you have inadvertently submitted any such information to CURER 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 and Mobile Application. In addition, you can, by sending an email to ❬❬ insert email address ❭❭, inquire whether CURER is in possession of your personal data, and you may also require CURER to delete and destroy all such information.
End User's 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 CURER from End Users (such as, patterns of utilization described above) and is exclusively owned by CURER. CURER 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, CURER reserves with it the right to use anonymized End User demographics information and anonymized End User health information for the following purposes:
1. Analyzing software usage patterns for improving product design and utility.
2. Analyzing such information for research and development of new technologies.
3. Using analysis of such information in other commercial product offerings of Curer.
4. Sharing analysis of such information with third parties for commercial use.
CURER 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.
At times, CURER may conduct 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, CURER 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 CURER collects in the registration process and through surveys is used to help CURER improve its Services to meet the needs and preferences of End Users. This may include targeting advertising to End Users about our Services.
CURER 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.
All CURER 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.
CURER 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 CURER corporation division or company. Any third party to which CURER 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.
To the extent necessary to provide End Users with the Services, CURER may provide their personal information to third party contractors who work on behalf of or with CURER to provide End Users with such Services, to help CURER 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:

No sensitive personal data or information is automatically collected by CURER from any casual visitors of this website, who are merely perusing the site.
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.
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 CURER.
You are not a casual visitor if you have willingly submitted any personal data or information to CURER through any means, including email, post or through the registration process on the Website or Mobile Application. 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

Your Personal Information is maintained by CURER 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. CURER takes all necessary precautions to protect your personal information both online and offline, 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 CURER’s business.
No administrator at CURER 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 and Mobile Application when finished. CURER does not undertake any liability for any unauthorised use of your account and password. If you suspect any unauthorized use of your account, you must immediately notify CURER by sending an email to support@curer.app. You shall be liable to indemnify CURER due to any loss suffered by it due to such unauthorized use of your account and password.
CURER 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.
Part of the functionality of CURER is assisting the practitioners to maintain and organise such information. CURER may, therefore, retain and submit all such records to the appropriate authorities, or to practitioners who request access to such information.
Part of the functionality of the CURER is assisting the patients to access information relating to them. CURER may, therefore, retain and submit all such records to the relevant patients, or to their practitioners.
Notwithstanding the above, CURER 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, CURER 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 CURER 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(s) to Privacy Policy

CURER may update this Privacy Policy at any time, with or without advance notice. In the event, there are significant changes in the way CURER treats User’s personally identifiable information, or in the Privacy Policy itself, CURER will display a notice on the Website or Mobile Application 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 support@curer.app to deactivate your account. Unless stated otherwise, CURER’s current Privacy Policy applies to all information that CURER has about You and Your account.

If a User uses the Services or accesses the Website or Mobile Application after a notice of changes has been sent to such User or published, such User hereby provides his/her/its consent to the changed terms.

6. Minor's Privacy

CURER 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 CURER’s Website and Services are not intended for use directly by minors, CURER respects the privacy of minors who may inadvertently use the internet or the mobile application.

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 CURER’s information collection, use and disclosure practices, you may contact us at the address: support@curer.app. 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.

9. Changes to Privacy Policy

We reserve the right to modify this privacy policy at any time, so please review it frequently. Changes and clarifications will take effect immediately upon their posting on the website. If we make material changes to this policy, we will notify you here that it has been updated, so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we use and/or disclose it.