Paloma Health and Wellness

1. WHAT THIS POLICY COVERS

This privacy policy aims to give you information on how we collect and process your data through your use of our Platform.

Paloma Health and Wellness and Clinics – Web Application

Paloma – APPs

Paloma Pro for Professionals

2. WHAT DATA WE COLLECT ABOUT YOU

2.1 For Patients

This privacy policy aims to give you information on how we collect and process your data through your use of our Platform.

Personal Data - Name, Date of Birth, Address, E-mail, Telephone

If you are giving information about another person, you are confirming that you are authorised to do For children's and dependants Registrations – The parent or legal guardians' details collected as Personal data.

Special Data – We collect your Gender.

2.2 For Health and Care Professionals and Organisation

We collect only the data relevant to conduct our legal contract.

• Personal – Name, Address , Professional details, Photo ID , E-mail, and Telephone

2.3 Health Data

Using our Mobile APP and Web Application we process information about your health.

• General Health -Symptoms, Treatments, Advice, Medications, Allergies
• Health Parameters – Personal health monitoring entries
• Symptom entries and Health data entries, which are shared with your healthcare professional.
• Video and online consultation details and recordings
• Messaging, Chats, Notifications, SMS Texts
• Your Appointments and chat messages.

Other Details

We hold details of your conversations with us for support, technical calls, Chats, Messages, and` Visit notes.

2.4 Data from other sources

If you use a third-party device or Mobile App to connect to Paloma , we ask your permission to receive health data from third-party devices.

Credit and Debit Card information

If you make a payment on the app, your credit and debit card details are processed by a third-party provider. We do not store any credit or debit card information and we only keep the details of the transaction securely for your reference.

2.5 What Technical Data do we collect ?

• Log in date, Time, location, IP
• Browser information or login
• APP downloaded device, Model, and Version
• Your visits to our site and your browsing information in our site (Help, Information and Services)
• We may use your browsing information on our website to share with analytical partners to improve our user experience and check our performance.

2.6 Cookies

We use cookies saved on your phone, tablet, or computer when you visit our site's external pages only. They collect information about how you browse our website pages. We do not use cookies on your personal health and medical Information.

2.7 APP Permissions

Our web and Mobile APPs require the below permissions for APP functions .

Location services

Our web and APP solutions ask you to update your location, this is to help you find the nearest services from your current location. You can switch these services On and Off at any time. This service is also used to validate your health and well-being diary, Appointments times depending on your time zone to provide you with an entry appropriate to the time zone.

Camera –The use of a camera is to take pictures, videos and to conduct a video consultation with our health care professional.

Microphone – To conduct a Video Consultation and to record audio.

Bluetooth – – To sync with blue tooth devices to obtain readings – Example – Blood pressure, pulse oximeter.

You can disable or enable them from Phone settings

• On your phone –Open settings, tap privacy and turn off camera and Microphone access.
• On your Phone – Open settings and disable Bluetooth

3. WHAT WE USE YOUR DATA FOR

This is how we use your data and legal reasons for it

Providing you with a service

We need your details for your registration to enter a contract to deliver General medical, Pharmacy, Lab, and Diagnostic services.

3.1 Health Data

The health data and health information provided by you and your health care provider are shared between both with consent. We allow our healthcare professional to share clinical information, treatments, Medication details, Appointments, and health parameter details and provide medical services on your condition with or without using online and Video Consultation tools with you and with other health and care professionals involved in your care. (GPs, Hospitals, Community Care, Therapist, Pharmacist)

The information is about

• Legitimate interest in your health (Planning, Advice, and Treatment)
• Clinic, Home visits and Online and Video consultations, medical details, Prescriptions, Health Parameters, and Symptom checklist and their severity

We use your feedback to improve our Health information platform. We collect unidentified health information from health diary entries such as the number of appointments, chat numbers, Online transactions, Blood Pressure entry, Weight, BMI, and Mood. This data is collected only to analyze and measure the benefits of early intervention by our health team in risk reduction.

We collect data from devices when you have an outage using our product to find out the reasons behind the outage.

3.2 Marketing and Communication Data

We send you notifications and text messages about your Appointments and Health promotion messages to assist and remind you about your appointments. The notifications and text Messages may come from the Paloma .

We may contact you with marketing messages, product updates, surveys, and information on our product. You can opt-in or out by going to settings, privacy controls of your APP, and your account settings when using a Web application.

Regulating the quality and safety of our service

We use your health information for Training, Safety, Regulatory, and Compliance Purposes.

This means that :

• If we are legally required to, or asked by a regulator, we may need to share your information with regulatory bodies like the National Medical Council or by Courts.

4. HOW WE STORE AND MOVE YOUR DATA

Your data are stored in our secured servers.

Your Personal data

Your Medical and Health Data (Consultations, Appointments, Chats, Messages, and all about your health)

We do not hold any information locally in your devices (Mobile Devices)

4.1 Protection

We are committed to keeping your personal and Health information you provide us secure and we will take reasonable precautions to protect your personal information from loss, misuse, or alteration.

We have implemented information security policies, rules, and technical measures to protect the personal information that we have under our control from:

• unauthorized access.
• improper use or disclosure.
• unauthorised modification, and
• unlawful destruction or accidental loss.

All our employees and data processors (i.e., those who process your personal information on our behalf, for the purposes listed above), who have access to, and are associated with the processing of personal information, are obliged to respect the confidentiality of the personal information.

You are responsible for keeping your password and/or authentication method confidential. Please do not share it with anyone.

Where we store your Data .

Your Data is stored in secure cloud services with the highest standards in the industry complying with Data Regulations.

4.2 Sharing your Data

General User's data are shared between the Paloma teams by mutual consent for providing a service. You indirectly provide consent to share your health information with other health care organisation or professional about your care such as referrals, opinions and advice.

4.3 Advertising

We use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative's ("NAI") educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.

4.4 Protecting Public

We may use your health data to protect the public.

Your data could be vital to help research, monitor, track, and manage public health emergencies, like pandemics.

In a public health emergency, your information may be shared in a way that is appropriate and lawful with organisations such as:

Local authorities

We will limit the use or sharing of data to the period of the emergency and will only share data to the extent necessary.

We also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your data but is not considered personal data in law as this data will not directly or indirectly reveal your identity.

What Additional Data do we collect?

We collect the listed data in paragraph (2) for registered Ouris digital users.

5. HOW LONG WE KEEP YOUR DATA

We will only retain your personal data in line with Indian Data Protection Law.

In India Electronic Health data guidelines, for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation with respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data, and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, or other requirements.

In India, we are governed by the below:

the Indian Contract Act, of 1872,

the (Indian) Information Technology Act, 2000, and

the rules, regulations, guidelines, and clarifications framed there under, including the (Indian) Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011 (the "SPI Rules"), and the (Indian) Information Technology (Intermediaries Guidelines) Rules, 2011 (the "IG Rules")

6. Your Information and How long we keep it (its 'retention period')

Health care professionals – Team user personal and professional details are held for as long as required to comply with courts and legals. At the end of the employment, they are archived and not available to our patients.

Patients and General users - When the account is unused for over 60 days, the patients web and mobile APP access account will be blocked. Your records are stored as per the Indian Information act and Indian medical council regulations for a minimum of a 3-year period from the last treatment.

Communications with support teams, including phone calls, emails, and live chats are retained for as long as required for Paloma legal use.

You are in control of your personal information. Under data protection law, you have the right to:

To do any of these things, please contact us by addressing your email to :

Data Protection Officer to

hello@palomaclinics.com

We will ask you for proof of identity. Data protection laws give us one month to get back to you.

7. THIRD PARTY LINKS

This website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

8. CHANGES TO THIS PRIVACY POLICY

We may make changes to this privacy policy from time to time.

We may notify you by e-mail of any significant changes. However, we encourage you to review the privacy policy on our website periodically to be informed of how we use your personal information.

If you do not agree to the changes, then you can stop using our services at any time.

Last updated NOV 2023