Thito App

Privacy Policy

Applicability

The provisions of the Privacy Policy shall apply to the visitors/users of THITO mobile application and website of the Steigen Healthcare India Private Limited (“App”, “Website”, “Site”).

Purpose of the Privacy Policy

Steigen Healthcare India Private Limited (“We”, “Us”, “Our” or ” Steigen Healthcare India Private Limited”), is a company registered under the Companies Act, 2013, having its registered office at E-101, Suncrest Accolade CHS, Louiswadi, Green Road, Thane (West), Thane, Maharashtra, 400604. We are the author, publisher and owner of the internet resource at [www.steigenhealthcare.com; www.thito.in] with any subdomain thereof, mobile/tablet/console applications, or other present or future electronic modes (“THITO”, www.steigenhealthcare.com”, “www.thito.in”) and are committed to protecting the privacy and security of personal data belonging to and/or shared by the users/visitors (“User”/ “You” / “Your”) of the App including but not limited to third-party diagnostic services providers (“Third Party Labs”), third party doctor(s), medical consultancy service providers (if any), other medical and healthcare professionals or institutions (“Medical Professionals”). The Third-Party Labs, Third-Party Applications and Medical Professional shall hereinafter be collectively referred to as “Third Parties”. Your use of the Website, and/or registration on the App and submission of personal information (or if You are a minor, the submission of Your personal information either by Your parents (or Your guardian) or by You with the permission of Your parents (or guardian)) to the App and/or Website will be deemed as your acceptance of this Privacy Policy. In the event You do not wish to be bound by these terms, You have a choice, which is free from any form of coercion or undue influence, to not access the Website and/or App. We value Your privacy and advise You to carefully read this privacy policy (“Privacy Policy”) as this Privacy Policy describes the types of personal data or personal information we collect, how we use the information, how we process and protect the information we collect, for how long we store it, with whom we share it, to whom we transfer it and the rights that individuals can exercise regarding our use of their personal data in compliance with the Ayushman Bharat Digital Mission (ABDM) Health Data Management Policy (“HDM Policy”). Any collection of personal or sensitive personal data under Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011 may be done only with the consent of the User. We also describe how You can contact us about our privacy practices and to exercise your rights.

This document is an electronic record in terms of the Information Technology Act, 2000 (as amended / re-enacted) (“IT Act”) and rules thereunder.

  1. SERVICES
    We provide services which are facilitated by us and/or made available for the Users of the App. The Services are governed by the Terms and Conditions available at https://steigenhealthcare.com/terms-of-use/.

    We provide services as set out under the Terms of Use (“Services”).

  2. CONSENT
    We request You to carefully read this Privacy Policy and Terms of Use available at https://steigenhealthcare.com/terms-of-use/ & https://steigenhealthcare.com/privacy-policy-2/ of the App and/or Website before sharing personal information with Us. This Privacy Policy applies to current and former Users of the App. By visiting and/or accessing the App (or searching for any of the Services on Our App), You explicitly consent and agree to the Privacy Policy laid out herein, and by providing Us Your personal information yourself or by making use of the services provided through the App or through Third-Party Service Providers, You hereby acknowledge and consent for the collection, receipt, storage, use, processing, disclosure and transfer of Your personal information in accordance with the provisions of this Privacy Policy. No liability pertaining to the authenticity/ genuineness/ misrepresentation/ fraud/ negligence, etc. of the information disclosed shall lie on Us nor will we in any way be responsible for verifying any information obtained from You or the Third Parties.

Collection, use, and disclosure of information that has been designated as Personal Information under the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011 requires express consent of the User. By affirming Your assent to this Privacy Policy, You provide Your consent to Us for such use, collection, and disclosure for the provision of Services.

Collection of Information and Use of Information:

  1. We may collect information such as Your name, address, email, phone number, medical records, and medical history; physical, psychological, and mental health condition, payment information such as credit card information and other such information as provided by You while rendering Services. We may also collect information that You share in the process of User registration, and posts of Your feedback, reviews, comments, etc. on the App.

  2. We seek permission to share Your personal and sensitive information with any third party as and when it is required by the applicable law.

  3. We additionally seek permission to read & write files on external storage to allow You to upload and save medical records on the App which you have full control over whether to share further with Third Parties or not.

  4. We don’t scan any other files from your storage system other than the files You’re explicitly uploading.

  5. We require express consent to use images or capture images from the camera for updating profile photos, uploading images as medical records on the App.

  6. We shall only save images when the User explicitly chooses to save images with the App.

  7. We need access to the camera, images, and files to upload in order to:
    1. Store medical records and other information and documents
    2. Update User Profile photo

  8. We may collect your personal information and non-personal information to provide Services on the App.

Personally-Identifiable Information

While opening an account on the App, you may be asked for certain sensitive personal data or information to complete your KYC (‘Know Your Customer’).
We collect Personal Information from you in the following situations:

  1. when you voluntarily use the services provided by Us and/or Third Parties; and/or

  2. enquire to begin an association with Us and/or Third Parties; and/or

  3. complete the process of opening an account with Us.

We may or may not, request for sensitive Personally Identifiable Information and Non-Personal Information from the User at the time of account opening/ use of the account to enable Us to use this information to either validate and process Your request for services of the Website and/or App, which could include but not be limited to:

  1. setting or resetting a password;

  2. financial information such as bank account or credit card or debit card or UPI or any other payment instrument details;

  3. creating platform specific unique health ids or to communicate with You (regarding the services You wish to avail) through call, chat or electronic modes of communication.;

  4. information such as name, contact number, email, gender, date of birth, bank account details, scans/copies of document of proof of address & identity such as Photograph, PAN, Aadhaar etc.

  5. Preferred language and currency.

  6. uploading signature proof/photo/signature etc.

  7. Birthdate;

  8. Location;

  9. Photographs, images and videos;

  10. Services reviews;

  11. Analytic information;

  12. Communications with Us;

  13. Your geolocation;

  14. Diagnostic and Troubleshooting information;

  15. Information about how Your interaction with the App

  16. Any other information You provide.

We may conduct routine surveys and market research for which the following information may be collected: Your age, gender, work status, region, race, income, education and other demographic information;

  1. App shall ensure that:
    1. We will provide a clear primary notice along with request for consent from the User(s);

    2. No personal data shall be transferred by the App to any other Third Parties without the obtaining of valid consent of the User;

    3. collection and use of personal data from User is done as may be necessary for rendering services;

    4. the processing of all personal data will be done in a fair and reasonable manner, ensuring the privacy of the User;

    5. Verifiable consent will be obtained from parent and/or guardian for processing the data of children and/or User(s) of unsound mind and/or User(s) with disability;

    6. Data collected by Us will be deleted within a reasonable period of time when the User ceases to be a User of the App or the User deletes their respective account created for accessing the App from our system. It is clarified that uninstallation of the App will not count as ceasing to be a User.;

    7. the personal data collected will not be retained beyond the period necessary to satisfy the purpose for which it is collected.

  2. The user has the right to withdraw their consent. Any consent granted can be withdrawn as per the following procedure:
    1. The User needs to delete his Account with TITHO if it is wants to withdraw any consent provided in the App

  3. The personal data of the User may not be retained if it is no longer necessary for the purpose for which it was processed.

PURPOSE LIMITATION

All Personally Identifiable Information (“PII”) collected and processed by the App will be used for the purpose identified as below.

  1. The PII of the User may be processed for the following purposes:
    1. Create an ABHA & THITO UID and manage the User’s account.

    2. The data is fetched for displaying the records to the User with consent.

    3. Providing health records to Health Information Users (HIUs) based on the consent provided by the User.

    4. Additionally, the personal data of the User may be processed for the following purposes:

    5. To keep a record of registered Users.

    6. To allow Us to customize services based on Users’ preferences.

  2. The Personally Identifiable Information of the user may be shared with the following individuals or entities:
    1. Any Medical Professional, Third Parties, individual or entity with whom the User consents to sharing such data.

    2. User’s information shall not be shared with any third party until it is required by the applicable law of the land, as notified from time to time. The App has appropriate controls to protect and safeguard the privacy of User’s personal information shared or collected by it. Where appropriate, encryption methods are used to protect data, which is sensitive, or any other data that must remain secure in order to meet Central and/or State Government obligations under applicable law.

COOKIES

Cookies are alphanumeric identifiers with a small amount of data that is stored on the User’s device hard drive containing information about the User, commonly used as an anonymous unique identifier. We and other Third-Party Service Providers collect information about You using these cookies. Please note, that a cookie in no way gives Us access to Your device. Our App uses these “cookies” to collect information and to improve Our service. Some cookies and other technologies may serve to recall Personal Information previously indicated by You. Most web browsers are set to accept cookies by default. If You prefer, You can usually choose to set Your browser to remove cookies and to reject cookies. If You choose to remove cookies or reject cookies, this could affect certain features of the App. Other apps/websites may place their cookies or other files on Your device, collect data, or solicit personal information from You, for which We shall not be held responsible or liable. We encourage You to read the privacy policies of all external/third-party sites.

PRIVACY OF CHILDREN

If You are under the age of 18 years, or applicable age of majority, You may utilize the Services only with the involvement of a parent or legal guardian, under such person’s account and otherwise subject to this Privacy Policy. We do not knowingly collect or maintain personal information from persons under 18 years of age or applicable age of majority, if the same comes to the knowledge of Us, appropriate action will be taken to delete the information.

STORAGE

The App uses the mobile devices’ internal/external storage to access files/documents. The App uses the cache memory of the mobile device for the purpose of enabling the user to access medical & health records in the form of PDFs or any other format which can also be downloaded by the user on the mobile device.

SHARING OF DATA

The User of this App is to note that We may share their PII with other people/entities including but not limited to doctors, healthcare practitioners, service providers or legal entities. Any sharing of personal data shall take place with the free, clear, informed, and specific consent of the User. No personal information or health records collected by the app will be shared or disclosed to any third party without the User’s consent except otherwise provided under this Policy.

RETENTION

  1. The information so collected shall be retained only for a limited duration necessary to fulfil the purposes outlined herein unless a longer retention period is required or permitted by law. Once the purpose is achieved, all personal information is deleted in a safe and secure mode within reasonable time.

  2. You may review the sensitive personal information available at Thito App and shall have access to the same at any time and can also refuse or revoke sharing of such sensitive personal information for which you can contact us at [Link of contact us page of company website]. By revoking or refusing to share such sensitive personal information to Us and/or Third Parties it may impact us in providing our services through the App.

RETENTION

The User has the following rights provided to them

  1. The right to confirmation and access

  2. The right to correction and erasure

  3. The right to restrict or object to disclosure

  4. The right to data portability

  5. The right to withdraw their consent as specified in Clause 3 (B) above.

  6. The right to lodge a complaint or grievance with the [Mr. Parag Utekar] – Grievance Redressal Officer (“[Steigen Healthcare India Private Limited] -GRO”)

GRIEVANCES

In the event you have any grievance relating to the processing of Information provided by you, you may contact our Grievance Officer at https://steigenhealthcare.com/contact-us/ or write to us at the following address:
Grievance Officer,
Address: Unit 210, Fenkin9, Wagle Estate, Thane (W.) 400604.
Timing: Monday to Friday, 11:00 am to 4:00 pm
In the event of loss of access to the App, you may contact the abovementioned grievance officer.

OTHER INFORMATION THE APPLICATION COLLECTS

  1. You can choose not to provide us with certain types of information, but doing so may affect Your ability to avail and/or use some services.

  2. The features of the App may allow You to post content such as profile information, status update, comments, and other content and/or information (“User Content”). The ownership over the User Content created by You remains with you; however, by sharing User Content through the App, You agree to allow others to view and/or share Your User Content in accordance with this Privacy Policy.

BUSINESS TRANSITIONS

In the event We go through a business transition, including but not limited to a merger, acquisition by another organisation, or sale of all or a portion of our assets, your personal data might be among the assets transferred.

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