Harbour Medical Technologies Private Limited (“us”, “we”, or “Harbour Medical”) is the author and publisher
of the internet resource www.medharbour.com (“Website”) on the world wide web as well as the softwares and
applications (including any Mobile Application) provided by Harbour Medical, (together with the Website,
referred to as the “Services”).
about the Users of the Services, including the Practitioners (as defined in the Terms and conditions of Use),
the End-Users (as defined in the Terms and Conditions of Use), and the visitors of Website or any other service
SERVICES OR BY OTHERWISE GIVING US YOUR INFORMATION, YOU AGREE TO THE PRACTICES AND POLICIES OUTLINED IN THIS
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
- i. Section 43A of the Information Technology Act, 2000
ii. Regulation 4 of the Information Technology (Reasonable Security Practices and Procedures and Sensitive
Personal Information) Rules, 2011 (the “SPI Rules”); and
iii. Regulation 3(1) of the Information Technology (Intermediaries Guidelines) Rules, 2011.
i. The type of information collected from the Users, including sensitive personal data or information;
ii. The purpose, means and modes of usage of such information; and
iii. How and to whom Harbour Medical will disclose such 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:
i. contact data (such as your email address and phone number);
ii. demographic data (such as your gender, your date of birth and your pin code);
iii. data regarding your usage of the services and history of the appointments made by or with you through
the use of Services;
iv.insurance data (such as your insurance carrier and insurance plan); and
v.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 Harbour Medical 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:
ii. financial information such as bank accounts, credit and debit card details or other payment instrument details;
iii. physical, physiological and mental health condition;
iv.medical records and history;
vi. information received by body corporate under lawful contract or otherwise;
vii. visitor details as provided at the time of registration or thereafter; and
xiii. 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.
This section applies to all Users.
i. Accordingly, a condition of each User’s use of and access to the Services is their acceptance of the
that does not agree with any provisions of the same has the option to discontinue the Services provided by
Harbour Medical immediately.
ii. An indicative list of information that Harbour Medical may require you to provide to enable your use of
iii. All the information provided to Harbour Medical by a User, including sensitive personal information, is
voluntary. You understand that Harbour Medical 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, for (c) for sale or transfer such research, statistical or
intelligence data in an aggregated or non-personally identifiable form to third parties and affiliates.
Harbour Medical also reserves the right to use information provided by or about the End-User for the following purposes:
(a)Publishing such information on the Website.
(b)Contacting End-Users for offering new products or services.
(c)Contacting End-Users for taking product and Service feedback.
(d)Analyzing software usage patterns for improving product design and utility.
You hereby consent to such use of such information by Harbour Medical
iv.Collection of information which has been designated as ‘sensitive personal data or information’
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.
v.Harbour Medical does not control or endorse the content, messages or information found in any Services and,
therefore, Harbour Medical 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 Harbour Medical relating to same, and to the extent such waiver may be ineffective, you agree to release any claims against Harbour Medical relating to same.
vi. 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 email@example.com. 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 Harbour
Medical has reasonable grounds to suspect that the information provided by you is untrue, inaccurate, out of
date or incomplete, Harbour Medical may, at its sole discretion, discontinue the provision of the Services to you.
vii. You may choose to unsubscribe from promotional communications that you receive from Harbour Medical by
clicking the ‘unsubscribe’ link provided at the end of every such promotional communication.
viii. If you wish to cancel your account or request that we no longer use your
information to provide you services, contact us through firstname.lastname@example.org. 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.
ix.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 email@example.com
x.Harbour Medical may require the User to pay with a credit card, net banking, debit card, wallet services
for services for which any amount(s) is/are payable. Harbour Medical will 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. However, Harbour
Medical provides you an option not to save your payment details. User is advised, however, that internet technology
is not full proof safe and user should exercise discretion on using the same.
xi. Due to the communications standards on the internet, when a User or the End-User or anyone who visits the Website,
Harbour Medical automatically receives the URL of the site from which anyone visits. Harbour Medical 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 Harbour Medical 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, Harbour
Medical 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.
xii. The Website uses temporary cookies to store certain data (that is not sensitive personal data or information)
that is used by Harbour Medical and its service providers for the technical administration of the Website, research
and development, and for user administration. In the course of serving advertisements or optimizing services to its
users, Harbour Medical may allow authorized third parties to place or recognize a unique cookie on the User’s browser.
The cookies however, do not store any personal information of the user.
xiii. A User may have limited access to the Website and make appointments with the doctors without creating an
account on the Website. Unregistered users can make appointments with the doctors by providing their name and
phone number. We may create a user account for the user and send the details of the same to his e-mail, wher
e the user will be required to set a password on first login. In order to have access to all the features and
benefits on our Website, 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 Harbour Medical, to identify the User: name, User ID, email address,
country, ZIP/postal code, age, gender, phone number, password chosen by the user. Other information requested
on the registration page, including the ability to receive promotional offers from Harbour Medical, is optional.
Harbour Medical may, in future, include other optional requests for information from the User to help Harbour
Medical to customize the Website to deliver personalized information to the User. However, Harbour Medical assumes
your consent in relation to various matters, once you complete the registration process.
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 user’s computer, collect data or solicit personal
information from the Users, for which Harbour Medical is not responsible or liable. Accordingly, Harbour Medical
does not make any representations concerning the privacy practices or policies of such third parties or Terms and
Conditions of use of such websites, nor does Harbour Medical 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 Harbour Medical 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. Harbour Medical encourages the user to read the privacy policies of that website.
xv.The Website may enable user to communicate with other users or to post information to be accessed by others,
whereupon other users may collect such data. Such users, including any moderators or administrators, are not
authorized Harbour Medical representatives or agents, and their opinions or statements do not necessarily
reflect those of Harbour Medical, and they are not authorized to bind Harbour Medical to any contract. Harbour
Medical hereby expressly disclaims any liability for any reliance or misuse of such information that is made
available by users or visitors in such a manner.
xvi. Harbour Medical 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 and Conditions
of use in order for Harbour Medical to effectively render the Services).
xvii. Harbour Medical maintains a strict "No-Spam" policy, which means that Harbour Medical does not intend to sell,
rent or otherwise give your email address to a third party without your consent.
xviii. Harbour Medical 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,
Harbour Medical shall not be held liable for any loss whatsoever incurred by the user
xix.Harbour Medical implements reasonable security practices and procedures and has a comprehensive documented
information security programme and information security policies that contain managerial, technical, operational
and physical security control measures that are commensurate with respect to the information being collected and
the nature of Harbour Medical’s business. The reasonable security practices and procedures implemented by Harbour
Medical include but are not limited to: encrypting data when it is on the move using industry standard practices,
keeping all the data within private cloud, regularly changing production keys and password, secure and very limited
access to all production servers, performing regular security updates on our servers and more.
xx.Harbour Medical 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 Harbour Medical,
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 and Conditions of use.
This section applies to all Practitioners
i. As part of the registration as well as the application creation and submission process that is available
to Practitioners on Harbour Medical, certain information, including sensitive personal data or information is
collected from the Practitioners.
required to read and understand the privacy
statements set out herein prior to submitting any sensitive personal data or information to Harbour Medical,
failing which they are required to leave the Services, including the Website immediately.
iii. Practitioners’ personally identifiable information, which they choose to provide to Harbour Medical,
is used to help the Practitioners describe and identify themselves. This information is exclusively owned by
Harbour Medical. Harbour Medical 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. Harbour Medical also reserves the right to use information provided
by or about the Practitioner for the following purposes:
(a)Publishing such information on the Website.
(b)Contacting Practitioners for offering new products or services.
(c)Contacting Practitioners for taking product feedback.
(d)Analyzing software usage patterns for improving product design and utility.
(e)Analyzing anonymized practice information including financial, and inventory information for commercial use.
iv.Harbour Medical automatically enables the listing of Practitioners’ information on its Website for every
‘Doctor’ or ‘Clinic’ added to a Practice using its software. The Practitioner information listed on Website is
displayed when End-Users search for doctors on Website, and the Practitioner information listed on Website is
used by End-Users to request for doctor appointments. Any personally identifiable information of the Practitioners
listed on the Website is not generated by Harbour Medical and is provided to Harbour Medical by Practitioners who
wish to enlist themselves on the Website, or is collected by Harbour Medical from the public domain. Harbour
Medical displays such information on its Website on an as-is basis making no representation or warranty on the
accuracy or completeness of the information. Harbour Medical will, however, take reasonable steps to ensure
the accuracy and completeness of this information.
v.Harbour Medical also displays information for practitioners who have not signed up or registered for the
Services. Such practitioners are verified by Harbour Medical or its associates, and Harbour Medical makes
every effort to capture accurate information for such practitioners. However, Harbour Medical does not
undertake any liability for any incorrect or incomplete information appearing on the Website for such practitioners.
This section applies to all End-Users
i. 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.
required to read and understand the privacy statements set out herein prior to submitting any sensitive
personal data or information to Harbour Medical, failing which they are required to leave the services immediately.
iii. If you have inadvertently submitted any such information to Harbour Medical 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.
In addition, you can, by sending an email to firstname.lastname@example.org, inquire whether Harbour Medical is
in possession of your personal data, and you may also require Harbour Medical to delete and destroy all such information.
iv.End-Users’ 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 Harbour Medical from End-Users (such as, patterns of utilization
described above) and is exclusively owned by Harbour Medical. Harbour Medical 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, Harbour Medical reserves
with it the right to use anonymized End-User demographics information and anonymized End-User health information
for the following purposes:
(a)Analyzing software usage patterns for improving product design and utility.
(b)Analyzing such information for research and development of new technologies.
(c)Using analysis of such information in other commercial product offerings of Harbour Medical.
(d)Sharing analysis of such information with third parties for commercial use.
v.Harbour Medical 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. The End-Users
can change their e-mail and contact preferences at any time by logging into their "Account" at www.medharbour.com
and changing the account settings.
vi. At times, Harbour Medical conducts 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.
The demographic information that Harbour Medical collects in the registration process and through surveys
is used to help Harbour Medical improve its Services to meet the needs and preferences of End-Users.
This may include targeting advertising to End-Users about our Services.
vii. Harbour Medical 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.
viii. All Harbour Medical 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.
ix.Harbour Medical 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 Harbour Medical corporation division
or company. Any third party to which Harbour Medical 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
and Conditions of use.
x.To the extent necessary to provide End-Users with the Services, Harbour Medical may provide their personal
information to third party contractors who work on behalf of or with Harbour Medical to provide End-Users with such
Services, to help Harbour Medical 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.
CONFIDENTIALITY AND SECURITY
i. Your Personal Information is maintained by Harbour Medical in electronic form on its equipment, and on the
equipments of its employees. Such information may also be converted to physical form from time to time. Harbour
Medical 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 Harbour Medical’s business.
ii. No administrator at Harbour Medical 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 when finished. Harbour Medical 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 Harbour Medical
by sending an email to email@example.com You shall be liable to indemnify Harbour Medical due to any loss
suffered by it due to such unauthorized use of your account and password.
iii. Harbour Medical 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.
iv.Part of the functionality of Harbour Medical is assisting the doctors to maintain and organise such information.
Harbour Medical may, therefore, retain and submit all such records to the appropriate authorities, or to doctors who
request access to such information.
v.Part of the functionality of the Harbour Medical is assisting the patients to access information relating to them.
Harbour Medical may, therefore, retain and submit all such records to the relevant patients, or to their doctors.
vi. Notwithstanding the above, Harbour Medical 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, Harbour Medical 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 Harbour Medical 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.
are significant changes in the way Harbour Medical treats User’s personally identifiable information, or in
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
firstname.lastname@example.org to deactivate your account. Unless stated otherwise, Harbour Medical’s current Privacy
Policy applies to all information that Harbour Medical has about you and your account.
If a User uses the Services or accesses the Website after a notice of changes has been sent to such User
or published on the Website, such User hereby provides his/her/its consent to the changed terms.
CONSENT TO THIS POLICY
other Services, and you unconditionally agree that becoming a User of the Website and its Services signifies
Policy and the Terms and Conditions of use.
ADDRESS FOR PRIVACY QUESTIONS
practices, you may contact us at the address: email@example.com. 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.
Schedule Indicative List of Information by Nature of Service
1) End-Users using the Website by registering for an account on the Website or ‘Medharbour’ mobile application:
You can create an account by giving us information regarding your [name, mobile number, email address], and
such other information as requested on the End-User registration page
. This is to enable us to provide you with the facility to use the account to book your appointments and store
other health related information.
Against every Practitioner listed in www.medharbour.com
, you may see a ‘reveal number’ option. When you choose this option, you choose to call the number through a
free telephone service provided by Harbour Medical, and the records of such calls are recorded and stored
2) End-Users using the Website without registering for an account on the Website or ‘Harbour Medical’ mobile
application (i.e., ‘Guest’ End-User):
You can use the Website without registering for an account, but to book an appointment, you may be asked certain
information (including your [mobile number], and such other information as requested when you choose to use the
Services without registration) to confirm the appointment. Against every Practitioner listed in www.medharbour.com,
you may see a ‘show number’ option. When you choose this option, you choose to call the number through a free
telephone service provided by Harbour Medical, and the records of such calls are recorded and stored in Harbour
3) Practitioner availing of the free listing service on the Website or ‘Harbour Medical’ mobile application by
registering for an account:
As a Practitioner, you may be required to provide us with information regarding your [name, mobile number,
email address], and such other information as requested on the Practitioner registration page to create an account.
Harbour Medical may send email and/or SMS confirmations or other communications to End-Users in connection with their
bookings, appointments or other interactions with you, if such interactions have been facilitated by Harbour Medical.