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Privacy Notification

Introduction

Welcome to Medibank. We value your privacy and are committed to protecting your personal information. This Privacy Policy governs how MediBank, collect, use, share and process the information, that you provide to us through your use of the app and website www.medibank.in in the course of availing services that are made available on the said app and website (“Services”) as defined in the Terms and Conditions of the app privacy link.

This Privacy Notification explains how we collect, use, disclose, and safeguard your information when you visit our website www.Medibank.in. Please read this Privacy Policy carefully. By accessing or using this Website / App, you agree to be bound by the terms described herein and all the terms incorporated by reference. If you do not agree to all of these terms, please do not use this Website / App.

WHAT IS PERSONAL INFORMATION

Personal information is information that can be used to directly or indirectly identify you. It includes de-identified data that, when linked to other information available to us, would enable us to identify you. Personal data does not include data that has been irreversibly anonymized or aggregated so that we cannot identify you through it, even in conjugation and/or conjunction with other information.

“Sensitive Personal Data or Information” means personal information of any individual relating to password; financial information such as credit or debit card, bank account or other payment instrument details; physical, physiological, and mental health condition; sexual orientation; health information such as medical records and history; biometric information; any detail relating to the above as provided to or received by us for processing or storage. However, any data/information relating to an individual that is freely available or accessible in the public domain or furnished under the Right to Information Act, 2005, or any other law shall not qualify as Sensitive Personal Data or Information.

By signing up on the App or proceeding to the Website, and/or using our Services you represent that you voluntarily provide us with personal information including medical and financial information, and consent to their collection, use, and disclosure by this Privacy Policy. You also represent that you are duly authorised by any third party (including a child or an employee) whose information you share with us. We shall act as per your representation of authority and shall not make any independent enquiries to ascertain the veracity of your authorisation. In the event you do not have sufficient authorisation you shall be solely responsible for your acts and omissions including sharing of information with us by you and the consequential processing and actions taken by us under this Privacy Policy.

The Website/App, like many other websites, uses “Cookies”. Cookies are small data files that a website stores on your web browser. These are used to store your preferences, previous activities browse activities, profiling, and tracking behaviour on this Website. By visiting the App or Website, you acknowledge, accept and expressly authorise the placement of cookies on your web browser. We recommend that you clear the cookies stored on your browser from time to time.

When you sign up or register on the App or Website to use our Services, and during the course of actual usage of our Services, the types of information that will be collected by us include the following:

  • Contact information: Name, Address, Contact details, Email ID, Phone Number;
  • Demographic information: Gender, Date of Birth, Nationality;
  • Data regarding your usage of the Services such as search history and history of the appointments made by you through the use of Services;
  • Financial information such as bank account or other payment instrument details and billing information other than credit card or debit card or payment account number, subject to applicable laws;
  • Your browsing history including the URL of the site that you visited prior to visiting the Website as well as the Internet Protocol (IP) address of your computer (or the proxy server you used to access the World Wide Web), your computer operating system and type of web browser you are using, the name of your ISP;
  • Any additional information that you provide to us during the use of the Services, through any mode of communication or during any interaction with our employees, doctors, technicians, consultants, etc., of or any other entity in the company including while availing its services;
  • Health information such as your medical records and history which you voluntarily provide or is generated on the usage of any of the services availed by you from the company;
  • Information regarding your insurance coverage (such as your insurance carrier and insurance plan) which you voluntarily provide or is generated on availing any of the Services;
  • Information regarding your physical, physiological, and mental health condition which you voluntarily provide or is generated on the usage of the Services including information such as (a) inpatient and emergency department data; (b) outpatient registration, scheduling, and encounter data; (c) laboratory data; (d) radiology data; (e) pharmacy orders data; (f) e-prescribing data; (g) pharmacy dispensing data; (h) medical administration data; (i) administrative and operational data; (j) transaction data;
  • Any other information that is collected or generated in the course of availing the Services;
  • Data regarding your medical qualifications, registrations, and certifications;
  • Any other detail relating to the above as voluntarily provided to us by you, for providing value-added service; and
  • Any other information relating to the above which you may have shared with us prior to this Privacy Policy for availing any of the Services.

WHERE DO WE COLLECT YOUR DATA FROM

For end users:

  • Any information that you voluntarily choose to provide to us through the App, Website, email, during interaction with us on call or chat, and other modes of communication;
  • Information that we collect from healthcare service providers (“HSPs”) such as doctors, hospitals, diagnostic centres, chemists, etc. in the company, to whom you have permitted the sharing of your personal information;
  • Data you have provided to the Company, affiliates, associates, subsidiary, holding company of the Company, associates, and subsidiaries of holding company of the Company, to whom you have given consent for sharing of such information.

For doctors:

  • Before Onboarding you, we may request information regarding your qualifications, experience, public profile, and representations made by you to us;
  • During your usage of the App /Website, we may collect information based on your use of the Services;
  • We may collect other information that you voluntarily choose to provide to us through the App, Website, email, during interaction with us on call or chat, and other modes of communication;
  • We may collect information from any group company, affiliates, associates, subsidiary, holding company of the Company, associates, and subsidiaries of holding company of the Company to whom you have given consent for sharing of information for availing value-added service.

HOW DO WE USE YOUR DATA

We use your personal information except information received from Medibank APIs via app or website for purposes that include the following:

General (end users and doctors):

  • Your registration to receive our Services, identification, communication, notification, and for the fulfilment of the Terms and Conditions;
  • Offering you personalized Services and targeted advertisements of various healthcare and wellness plans and offering you customized health insights;
  • Addressing your requests, queries, and complaints, if any, pertaining to our Services; taking feedback, assisting you with the completion of transactions or other issues relating to the use of Services and other customer care-related activities;
  • Leveraging services from the company and customising suggestions for appropriate medical products and services;
  • Creating insights for corporate/business strategy and marketing operations of the company;
  • Developing machine learning algorithms and tools to improve targeting of services, diagnostics and treatment protocols, and other products and services;
  • Contacting you to provide information on new Services, features, products, special promotions or offers, both of the company and affiliates as well as third-party offers or products with whom we have a tie-up and which are relevant to the use of the Services;
  • Technical administration and customization of Website, and other general administrative and business purposes;
  • Research (internal or otherwise), fraud, security, risk management, and analysis for the development and improvement of products and services including the provision of tokenisation services offered by Payment Aggregators/ Card Networks, etc. as per Card Networks Rules;
  • Disclosure as required to government authorities in compliance with applicable law;
  • Carrying out our obligations in relation to any agreement with affiliate companies, our business partners, or contractors including, but not limited to, the provision of tokenisation services to Payment Aggregators / Card Networks / Card Issuers, on a global basis as necessary to provide the tokenisation services, or for compliance of applicable laws, regulatory requirements or investigations;
  • Investigating, enforcing, and resolving any disputes or grievances;
  • Any other purpose required by applicable law.

For end users only:

  • Creation and maintenance of health records in electronic form in the Health Record (EHR) database for use by the company, affiliates, etc., to provide relevant services;
  • Create your unified profile with analytics and insights generated through processing your personal information;
  • For sharing with your chosen HSP in the Company like doctors, hospitals, diagnostic centres, and chemists who may provide you services under the App or Website;
  • Processing any orders/requests you may place using our Services.

For doctors only:

  • For verifying your professional credentials and any representations you have made to us;
  • For processing any payments made to you;
  • For providing recommendations to end users based on your expertise and specializations;
  • For providing any other service to you.

HOW LONG WILL WE RETAIN YOUR DATA

We store your personal information in accordance with applicable laws, which means we keep your data for as long as necessary to provide you with our Services or as may be required under any law. We shall store your personal information for lawful purposes only. We keep de-identified data for research and statistical purposes for a longer period.

If you close your account, we have no obligation to retain your data, and we may delete any or all of your data without liability. However, we may retain data related to you if we believe it may be necessary to prevent fraud or future abuse, if required by law, or for other legitimate purposes. We may continue to store your data in anonymized or de-identified form for analytical, research, or other purposes for which your information is collected as previously indicated.

DISCLOSURE AND TRANSFER OF YOUR DATA

We may share, disclose and in some cases transfer your personal information except information received from Medibank APIs via app or website to such entities as required to provide Services to you, improve our Services, and provide value-added services or other third-party products and services, to the extent permitted by applicable law. These entities may be located outside India, which you hereby consent to. We require such entities to protect your information through equivalent security measures as we would adopt. An indicative list of entities we may disclose or transfer information except information received from … APIs, is provided below:

Service Providers:

We share personal information with companies that provide Services on our behalf, such as website hosting, data storage, software services, email services, marketing, fulfilling customer orders, providing payment-related services including payment aggregation, data analytics, data mining, providing customer services, and conducting surveys, as permitted by applicable law. These companies may be located within or outside India, but in any case, are obligated to protect your data.

We may also share information with employees, data processors, consultants, business partners, and technology partners on a need-to-know basis. Such entities would be contractually obligated to maintain confidentiality with your data.

If you are an end user, your personal information will also be shared with your chosen Service Providers.

Business Affiliates:

We may disclose or transfer some of your information to companies, affiliates, associates, subsidiaries, the holding company of the Company, associates, and subsidiaries of the holding company of the Company including foreign entities, and in particular group companies and affiliates who are involved in the provision of products and services, to the extent permitted by applicable law.

In the event of a merger, reorganization, acquisition, joint venture, assignment, spin-off, transfer, asset sale, or sale or disposition of all or any portion of our business, including in connection with any bankruptcy or similar proceedings, we may transfer any and all personal information to the relevant third party with the same rights of access and use.

Law Enforcement Agencies:

We may share information with law enforcement agencies pursuant to lawful requests for information, and otherwise as required under any law applicable at the given time, both in India and outside India.

Other Third Parties:

We may also disclose personal information if we determine in good faith that disclosure is reasonably necessary to protect our rights and pursue available remedies, enforce our terms and conditions, investigate fraud, or protect our operations or users;

We may disclose personal information to any third party if necessary to provide or improve our Services, fulfil any lawful contractual obligation we are bound by, and any other activity related to the purposes identified in this privacy policy and the terms and conditions you agree to when you use our Services; and

Anonymised, aggregated data may be shared with advertisers, research firms, and other partners.

HOW DO WE PROTECT YOUR DATA

We are committed to maintaining the privacy of the information uploaded by you on the Website and complying with the industry-standard security safeguards for the purpose of securing the Website and the information provided/uploaded by you.

We use reasonable technical, administrative, and physical security measures for the purpose of safeguarding all data you share with us. We also have comprehensive internal policies in place to prevent unauthorized access to your data. We take adequate steps to ensure that third parties we share data with also adopt reasonable levels of security practices and procedures to ensure the privacy and security of your information.

However, we are not responsible for any loss, unauthorized access, safety issue, or any harm caused to you by any misuse of your personal information, unless it is a direct and foreseeable consequence of negligence and non-compliance on our part only. You hereby acknowledge that we are not responsible, in particular, for any third-party action or action on your part leading to loss, damage, or harm to you or any other person.

For any data loss or theft due to unauthorized access to your electronic devices through which you avail our Services, the Company shall not be held liable for any loss whatsoever incurred by you. Further, you are liable to indemnify the Company as per the Terms of Use.

WHAT ARE YOUR RIGHTS

We take reasonable steps to ensure that your personal information is accurate, complete, and up to date. However, you have the sole responsibility of ensuring that you review the accuracy of the information provided by you and contact us in case of discrepancies, or in case you wish to discontinue the use of our Services. You have the following rights with regard to your personal information:

You have the right to access your personal information and request updation, correction, and deletion. 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 contact@Medibank.in. 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 subsequently becomes untrue, inaccurate, out of date or incomplete), or we have reasonable grounds to suspect that the information provided by you is untrue, inaccurate, out of date or incomplete, we may, at our sole discretion, discontinue the provision of the Services to you. There may be circumstances where we will not correct, delete or update your personal information, including (a) where the personal information is opinion data that is kept solely for evaluative purposes; (b) the personal information is in documents related to a prosecution if all proceedings relating to the prosecution have not been completed; and (c) where your information has already been processed in de-identified form.

You are free not to share any medical or other information that you consider confidential and withdraw consent for us to use data that you have already provided. In the event that you refuse to share any information or withdraw consent to process information that you have previously given to us, we reserve the right to restrict or deny the provision of our Services for which we consider such information to be necessary.

THIRD-PARTY WEBSITES AND SERVICES

Our Website and App may contain links to third-party services, and give you the ability to access such third-party websites, products, and services. Please note that you may proceed to the use of such third-party websites or services at your own risk and the Company will not be held liable for any outcome or harm arising as a result of your use of such third-party websites or services. Please read the privacy policies of any third party before proceeding to use their websites, products, or services.

CHANGES TO THIS PRIVACY POLICY

Any changes to our Privacy Policy will be posted on the Website/App and will become effective as of the date of posting. Please review the Privacy Policy from time to time to make sure you are aware of any changes. If you do not agree with any such revised terms, please refrain from using our Services and contact us to close any account you may have created.