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PRIVACY POLICY

MedEzee V3 — Hospital Information System Version 1.0 · Effective [OWNER: date of publication] · Last updated [OWNER: date]


1. Who this policy is for

MedEzee V3 is software that hospitals, clinics, laboratories and diagnostic centres ("Healthcare Providers") use to run their operations. This policy explains how [OWNER: S Solutions legal entity name] ("S Solutions", "we", "us") handles personal data in connection with the hosted MedEzee V3 service at medezee.com and its subdomains (the "Service").

If you are a patient, this policy is probably not the document you are looking for. Your medical records in MedEzee V3 belong to, and are controlled by, the hospital or clinic that treats you — not by us. We hold that data only on their instructions. Please ask your hospital for their privacy notice and direct requests about your records to them. Section 13.3 explains what we can and cannot do for you directly.

If you are a Healthcare Provider signing up for, evaluating or using MedEzee V3, this policy describes what we do with your organisation's and your staff's data, and the limits we place on ourselves in handling the patient data you entrust to us.

This policy does not apply to on-premise or locally installed deployments of MedEzee software, where we host nothing and hold no copy of your data. Section 16 covers those.

2. Who we are, and how to reach us

DetailValue
Entity[OWNER: full registered name and constitution]
Registered address[OWNER: address], Vellore, Tamil Nadu, India
GSTIN / CIN[OWNER]
General contact[OWNER: e.g. privacy@medezee.com]
Grievance Officer[OWNER: name] · [OWNER: email] · [OWNER: phone]

The Grievance Officer is our designated contact for privacy complaints under Rule 5(9) of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, and will serve as our point of contact under the Digital Personal Data Protection Act, 2023 as its provisions commence. We aim to acknowledge every complaint within 3 working days and resolve it within 30 days.

3. Our two roles — please read this section

Indian data protection law distinguishes between the party that decides why and how personal data is processed (the Data Fiduciary) and the party that merely processes it on instructions (the Data Processor). We are both, for different data:

3.1 — Account data: we are the Data Fiduciary. When your staff create accounts, when you subscribe and pay, when you contact support, when your users' browsers hit our servers — we decide what to collect and why. We answer for that data directly, and Sections 4.1, 5, 10 and 13 apply to it.

3.2 — Patient and clinical data: we are the Data Processor. You are the Data Fiduciary. Everything your staff enter about patients — demographics, clinical notes, diagnoses, prescriptions, lab and imaging results, bills, insurance claims — is processed by us only to provide the Service to you, only on your documented instructions, and for no purpose of our own.

This means:

  • Obtaining patient consent is your responsibility, not ours. We have no relationship with your patients and cannot lawfully take consent on their behalf. Your registration process, your consent forms and your patient-facing privacy notice are the instruments that make the processing lawful.
  • We do not decide retention. You configure it; we apply it. See Section 11.
  • We do not use your patient data for our own purposes. Not to build features, not to train models, not for analytics we sell, not for marketing. See Sections 6 and 7.
  • We will not disclose your patient data to a third party — including in response to a government or law-enforcement request — without referring the request to you first, unless we are legally prohibited from telling you. See Section 8.3.

The binding form of these commitments is Annex A (Data Processing Terms) of the MedEzee V3 Terms of Service, which forms part of your contract with us.

4. What we collect

4.1 As Data Fiduciary — your organisation and your staff

CategoryExamplesSource
Registration dataOrganisation name, type and address; tenant code; admin name, designation, work email, mobileYou, at signup
Account & identity dataUsernames, hashed passwords, roles and permissions, branch allocation, login history, password-change history, lock/unlock eventsYou and the Service
Subscription & billing dataPlan tier, add-on packs, billing contact, billing address, GSTIN, invoices, payment status and referencesYou and our payment provider
Support dataTickets, emails, chat and call notes, screenshots and logs you send us, remote-support session recordsYou, when you contact us
Technical and usage dataIP address, browser and device type, pages and features used, timestamps, error traces, performance telemetryAutomatically
Security dataAuthentication events, failed login attempts, audit-trail entries attributable to a named user, anti-abuse signalsAutomatically

We do not ask your staff for government identity numbers, financial account numbers or any special-category data about themselves in order to use the Service. If your subscription includes the HR module, any such data your organisation enters about its own employees is Customer Data under Section 4.2 — we are a processor for it, exactly as with patient data.

4.2 As Data Processor — Customer Data you place in the Service

We hold whatever your staff enter or upload. Depending on the modules you subscribe to that will typically include patient demographics and contact details; identifiers you choose to record; clinical notes, diagnoses, vitals and treatment records; prescriptions and medication administration; laboratory, radiology and pathology orders and results, including uploaded files and images; admission, ward, bed and discharge records; billing, payment, insurance and claim records; appointments and queue records; and, where enabled, employee records in the HR module.

We do not inspect, profile, index for our own purposes, or analyse the contents of Customer Data. Our staff access it only in the circumstances in Section 10.4.

4.3 What we never collect

We do not buy personal data from data brokers. We do not run advertising, advertising pixels or third-party marketing trackers on the authenticated Service. We do not sell personal data to anyone, in any form, at any price.

5. Why we process account data, and on what basis

PurposeBasis
Creating and administering your account and user accountsPerformance of our contract with you
Providing, maintaining and securing the ServiceContract; our legitimate interest in a service that works
Billing, invoicing, tax records and recovering unpaid feesContract; legal obligation under Indian tax law
Responding to support requestsContract; your consent when you send us data
Security monitoring, fraud and abuse prevention, audit trailsLegal obligation; legitimate interest
Service notices — outages, security advisories, changes to this policy, renewal and expiryContract; legal obligation
Product improvement using aggregated usage statistics (see Section 7)Legitimate interest, subject to your opt-out
Marketing about MedEzee products to your business contactsConsent — withdrawable at any time, with no effect on the Service

Service notices are not marketing. You cannot opt out of being told that your system is down, that your subscription is expiring, or that there has been a security incident.

6. What we will never do with your patient data

Stated plainly, because in healthcare software this is the question that matters:

  1. We will not sell, rent, licence or share Customer Data with any third party for that party's own purposes.
  2. We will not use Customer Data to train, fine-tune or evaluate any machine-learning or AI model — ours or anyone else's — without a separate, specific, written agreement with you that you are free to decline without losing access to the Service.
  3. We will not use Customer Data for advertising, market research or commercial profiling.
  4. We will not disclose patient-level data to another MedEzee tenant, under any feature, for any reason. Section 7 is bounded by this.
  5. We will not retain Customer Data after termination beyond the windows in Section 11.

If we ever intend to change any of these, we will give you at least 60 days' notice and a route to terminate without penalty. They are also written into Annex A of the Terms, so this is a contractual promise and not merely a statement of policy.

7. Aggregated insights and cross-tenant features

MedEzee V3 includes, or will include, features that draw on patterns across the whole platform rather than a single hospital — for example supplier reliability signals, bed-availability handshakes between participating hospitals, and group purchasing indicators.

These operate under strict limits:

  • They use operational and commercial data only — never patient or clinical data. A supplier's delivery record is operational. A patient's diagnosis is not, and is categorically out of scope.
  • Data is aggregated and de-identified before it leaves your tenant boundary. No output of these features identifies, or can reasonably be used to identify, an individual, and no output attributes a figure to a named hospital without that hospital's participation.
  • Bed-availability handshakes and any other feature that exchanges information with a named hospital are opt-in, configured by your tenant admin, and show you exactly what is shared.
  • You can opt out of contributing to aggregated insights at any time from your tenant settings, or by writing to the Grievance Officer. Opting out does not degrade any other part of the Service.

We also compute aggregated statistics about how the Service is used — which screens, how often, how fast — to find bugs and prioritise work. These are counts and timings, not content.

8. Who we share data with

8.1 Within your organisation

Your data is visible to the users your tenant admin authorises, under the roles and branch allocations you configure. We do not control those decisions. Getting them right is your responsibility, and the audit trail records who saw what.

8.2 Sub-processors

We use a small number of service providers. Each is bound by written terms no less protective than Annex A, may process data only on our instructions, and is listed here:

Sub-processorWhat it doesData involvedLocation
[OWNER: hosting provider]Application and database hosting, backupsAll Service data[OWNER: region]
[OWNER: email/SMTP provider]Transactional email — verification, password reset, notificationsRecipient name, email, message content[OWNER]
[OWNER: SMS / WhatsApp provider]OTP and patient notifications, where you enable themRecipient mobile number, message contentIndia
Razorpay Software Private LimitedSubscription payment processing, when card/UPI payment is enabledBilling contact, payment instrument data handled by Razorpay directlyIndia
Google LLC — reCAPTCHABot protection on public forms [OWNER: confirm in production]IP address, browser signals, interaction dataGlobal

We maintain the current list at [OWNER: URL] and will give you at least 30 days' notice before adding a sub-processor that will handle Customer Data, during which you may object and, if we cannot resolve the objection, terminate the affected service without penalty.

AI and machine-learning providers: we do not currently send Customer Data to any third-party AI or large-language-model provider. [OWNER: confirm — strike or amend if untrue.] If we introduce AI-assisted features that would, they will be opt-in per tenant, disclosed here first, and governed by Section 6.2.

8.3 Legal and regulatory disclosure

We may disclose data where compelled by a valid order of an Indian court or a lawful demand from a competent authority. Where the demand concerns Customer Data, we will notify you and give you a reasonable opportunity to respond or challenge it, unless we are legally prohibited from doing so or there is an immediate risk to life. We will disclose only the minimum the order requires, and we keep a record of such requests.

8.4 Business transfer

If the MedEzee business is acquired or merged, data may transfer to the acquirer, who will be bound by this policy until it is superseded by a notice giving you at least 30 days to object and exit. We will tell you before it happens, not after.

9. Where your data is stored

All Service data, including all Customer Data and all backups, is stored [OWNER: confirm — in India, in the ___ region]. Our support and engineering team operates from India.

[OWNER: If any component — a CDN, an email relay, an error-tracking service, reCAPTCHA — processes data outside India, it must be named here, with the country. Do not publish this section until it is true.]

10. How we protect data

  • In transit: TLS on all connections to the Service. HTTP is redirected, not served.
  • At rest: encrypted database and backup storage.
  • Passwords: stored as salted one-way hashes; we cannot read them, and neither can our staff.
  • Tenant isolation: every query is scoped to a tenant; cross-tenant access is blocked at the data layer, not merely hidden in the interface.
  • Access control: role- and permission-based, configured by your tenant admin, with branch-level scoping.
  • Audit trail: the platform records amendments as versioned records rather than silent edits, so who changed what, and when, is reconstructable.
  • Our staff (10.4): access Customer Data only when you raise a support request that requires it, when required to restore the Service, or when compelled by law. Access is least-privilege, time-bounded and logged, and staff are under binding confidentiality obligations that survive their employment.
  • Backups: taken on a regular schedule and tested for restorability.
  • [OWNER: state your actual backup frequency, retention and RPO/RTO, or delete the last bullet rather than imply more than you do.]

No system is perfectly secure, and we do not claim otherwise. What we do claim is that we apply reasonable security practices proportionate to holding health data, and that we will tell you promptly when something goes wrong.

11. How long we keep data

Customer Data. For as long as your subscription is active, under the retention rules you configure. We do not impose our own retention period on clinical records, because the applicable period is a matter of medical-records law and professional regulation that binds you — including the National Medical Commission's requirement to retain indoor patient records for at least three years from the commencement of treatment, and longer for medico-legal records. We will not delete Customer Data under you.

After termination. Your data remains available for export for 30 days after your subscription ends. After that we delete it from live systems within a further 60 days, and it ages out of encrypted backups within [OWNER: backup cycle, e.g. 90 days]. Where you instruct us to delete sooner, we will, subject to any legal obligation to retain.

Account data. Kept for the life of your account and for 3 years afterwards, to handle disputes, defend claims and meet audit obligations.

Billing records. Kept for 8 years, as Indian tax and company law requires.

Logs and security records. Kept for [OWNER: e.g. 180 days], then deleted or aggregated.

12. Cookies and similar technologies

The authenticated Service uses cookies that are strictly necessary — a session cookie to keep you logged in, an anti-forgery token to prevent cross-site request forgery, and a cookie recording your active tenant when you have access to more than one. These cannot be turned off without breaking the Service, and they carry no advertising function.

The public pages may set a reCAPTCHA cookie from Google for bot protection [OWNER: confirm]. We run no advertising or cross-site tracking cookies anywhere.

13. Your rights

13.1 If you are a user of the Service (staff of a Healthcare Provider)

Subject to the Digital Personal Data Protection Act, 2023 as its provisions commence, you may ask us to: confirm what personal data of yours we hold and why; correct or complete it; erase it where it is no longer needed and no law requires us to keep it; withdraw a consent you gave (which will not affect processing already carried out); and nominate someone to exercise these rights if you die or become incapacitated.

Write to the Grievance Officer in Section 2. We will verify your identity before acting, and will respond within 30 days.

Note that most of your account data exists because your employer asked us to create your account. Where a request would conflict with your employer's instructions or with an audit obligation — you cannot, for example, erase the audit trail of a clinical entry you made — we will tell you so and explain why.

13.2 If you are a Healthcare Provider (our customer)

You may access, export, correct and delete Customer Data at any time through the Service. You may instruct us in writing to do so on your behalf, and we will comply within a reasonable period. Annex A of the Terms sets out our obligations to assist you in answering your own patients' requests.

13.3 If you are a patient

Please contact the hospital or clinic that treated you. They hold your records and they decide what happens to them. We cannot give you access to, correct, or delete your medical records on our own initiative — doing so would mean altering a clinical record behind the back of the clinician responsible for it, which is neither lawful nor safe.

If you have contacted your hospital and cannot get a response, you may write to our Grievance Officer. We will pass your request to the hospital and press them to respond, and we will tell you that we have done so. We will not act on your records ourselves without their instruction.

You can complain to the Data Protection Board of India once it is operational, and you retain your existing rights before the consumer forums and courts.

14. Children's and minors' data

Accounts on the Service are for healthcare professionals and staff, and must be held by persons aged 18 or over. We do not knowingly create accounts for children.

Patient records in the Service routinely concern children — a hospital treats minors. Those records are Customer Data, and the lawful basis for holding them, including any parental consent the DPDP Act requires, is the treating hospital's responsibility as Data Fiduciary. We apply the same protections to them as to all Customer Data and we never use them for tracking, profiling or advertising, which the DPDP Act prohibits in respect of children in any case.

15. Changes to this policy

We will post any change here with a new version number and effective date. For changes that materially reduce your rights or expand our use of data, we will give you at least 30 days' advance notice by email to your tenant admin and a notice inside the Service, and you may terminate without penalty if you do not accept them. Every published version is archived and available on request, so you can always establish which version applied on a given date.

16. Locally installed (on-premise) deployments

Where you run MedEzee on your own servers, we do not host, store, access or hold any copy of your data. You are the Data Fiduciary and the sole custodian. This policy applies only to:

  • data you send us when you contact support, including logs, screenshots and database extracts you choose to share;
  • remote-support sessions, which happen only with your consent, on your invitation, and are logged;
  • licensing and update telemetry, limited to installation identifier, version and licence validity.

Your obligations for security, backup, retention and breach notification for an on-premise install are yours alone. We will assist under a support contract; we do not assume them.

17. Security incidents

If we become aware of a personal data breach affecting the Service, we will:

  1. report it to the Indian Computer Emergency Response Team (CERT-In) within 6 hours of detection, as the CERT-In Directions of April 2022 require;
  2. notify affected Healthcare Providers without undue delay with what we know — what happened, what data, how many records, what we are doing, and what you should do — so that you can meet your own notification obligations to your patients and regulators;
  3. once the relevant DPDP provisions commence, notify affected Data Principals without delay and file the detailed report with the Data Protection Board of India within 72 hours;
  4. tell you the outcome of our investigation, including root cause and the changes we have made.

We will not delay telling you in order to finish investigating.

18. Governing law

This policy is governed by the laws of India. Disputes are subject to Section 22 of the MedEzee V3 Terms of Service.

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