Privacy Policy

Positra ("Positra", "We", "Us" or "Our") has formulated this privacy policy ("Privacy Policy") for the benefit of the users of its website ("You", "Your" and "Yourself") at https://www.positra.com (the "Site") to demonstrate Our serious commitment to protecting the privacy of the data that We collect through the Site. This Privacy Policy sums up how Positra handles the personally identifying information that You voluntarily provide when You use the Site and that We may automatically collect when You visit the Site ("Personal Information"). Your use of this Site will be deemed conclusively to constitute Your acceptance of and agreement to this Privacy Policy and all portions hereof.

PRIVACY POLICY COMPLIANCE

This Privacy Policy is published in compliance with, inter alia:
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”);
III. Regulation 3(1) of the Information Technology (Intermediaries Guidelines) Rules, 2011.
This Privacy Policy states the following:
a. The type of information collected from the Users, including Personal Information (as defined in paragraph 2 below) and Sensitive Personal Data or Information (as defined in paragraph 2 below) relating to an individual;
b. The purpose, means and modes of collection, usage, processing, retention and destruction of such information; and
c. How and to whom Positra will disclose such information.

INFORMATION COLLECTION

Personal Information
Positra may ask You to provide us with personally identifiable information that can be used to send You e-mail notification of new features or information available through the Site, understand Your interests and needs and to provide You with a more personalized and smart service. Personal Information may include, but is not limited to, your name, phone number, e-mail address, date of birth, zip code, IP address, demographics, health information and medical needs. The e-mail address You provide for booking a doctor appointment will only be used to send you information and updates pertaining to your appointment.

Positra collects this Personal Information that You voluntarily provide through the use of on-line data entry, survey, and registration forms. Positra gathers most of this Personal Information from You during an initial voluntary User registration process for the Site. You can determine to a large extent what Personal Information You wish to submit on a voluntary basis to Positra.

Non-Identifiable Information
Positra may also monitor the use of our Services by collecting anonymous and non-identifiable information. Typically, Non-Identifiable Information tracks users’ site usage and traffic patterns, and it may include information such as the browser and OS you are using, the date and time stamp of your visit, domain name, referring URLs (the website you came from), the number of pages visited, statistics about the number of visitors to the Site and user response time. Non-Identifiable Information enables us to provide a more enjoyable and personalized experience on our Services, as well as to track errors.

Cookies
When you use our Services, we may collect information about your use of the Services through the use of "cookies." Cookies are small pieces of information that a website transfers to the memory or hard drive on your computer, tablet, phone or any other device. We use both session ID cookies and persistent cookies. A session ID cookie expires when you close your browser. Most web browsers have options that allow you to control whether or not to accept cookies. However, disabling cookies in your browser may prevent access to some parts of our Services. Positra cookies store tracking codes to enable our system to locate information from past visits to our website, but do not contain information that identifies you personally. Cookies are also used to facilitate a user’s log-in, as navigation aids and as session timers. To learn more about Cookies, please visit http://allaboutcookies.org/. Although most web browsers are initially set up to accept Cookies, if You prefer, You may decline the placement of a Cookie on Your hard drive by using the appropriate feature(s) of Your web browser software (if available) to delete the Cookie. But You should understand that certain areas within this Site may not function properly if the web browser will not accept Cookies.

Social Media Widgets
The Services may include social media features, such as widgets. These features may collect your IP address, which page you are visiting on that website, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on the Services. Your interactions with these features are governed by the Privacy Policy of the company providing it. To view the privacy policies of any company providing a social media feature, please visit that company’s website.

INFORMATION USAGE

We use the information we collect, including Personal Information, to provide the Services, operate, improve and personalize the Services, provide customer service and to administer our business activities. The Personal Information that you provide is used to provide you personalized and clinically relevant information.
We may also use your Personal Information to communicate with you, your family member or your doctor. For example, we may correspond with you to respond to your comments or questions, send you emails about our Site and to inform you about material changes to this Privacy Policy.

INFORMATION DISCLOSURE

We may share and disclose information as described at the time the information is collected or as follows:

Disclosure to Positra Staff and Moderators
Positra staff and moderators sometimes have limited access to your Personal Information in the course of providing the Services to you and other members, to troubleshoot problems or resolve complaints.

Disclosure to Our Service Providers
We may share your information, including Personal Information, with our suppliers, agents, contractors, or other companies or individuals that provide services for or on our behalf ("Service Providers") in connection with the services they perform. These Service Providers include vendors and suppliers that provide us with technology, services and/or content for the operation and maintenance of our Services.

Disclosure to Third Party Contractor Websites
Certain content and services offered to you through our Site are served on websites hosted and operated by companies other than Positra ("Third Party Contractor Websites"). Positra does not sell, trade, or otherwise transfer your Personal Information to these Third Party Contractor Websites without your consent, but you should be aware that any information you disclose once you access these other Third Party Contractor Websites is not subject to this Privacy Policy. Positra does not endorse and is not responsible for the privacy practices of these Third Party Contractor Websites. You should review the privacy policy posted on the other Web site to understand how that Third Party Contractor Website collects and uses your Personal Information. Positra makes an effort to make it obvious to you when you leave our Site and enter a Third Party Contractor Website by requiring you to click on a link. In addition, if you see a phrase such as "Powered by" or "in association with" followed by the name of a company other than Positra, then you are on a website hosted by a company other than Positra.

Disclosure for Legal Purposes
We may use or disclose Personal Information if we believe in good faith that such use or disclosure is necessary to (a) help identify any person attempting to break into or damage our Services, (b) to investigate, prevent, or take action regarding any illegal activities, (c) to comply with relevant laws, or legal or regulatory obligations, (d) to respond to subpoenas or warrants served on the Company, (e) to protect or defend the rights or property of Positra or its customers, or (f) in response to a physical threat to you or others, to protect property or to defend or assert legal rights. Without limiting the foregoing, we may share Personal Information with law enforcement agencies if we believe that we have evidence of a violation of computer security or related laws.

Disclosure of Aggregate Information
We may combine any Non-Identifiable Information you provide with Non-Identifiable Information from other users to create aggregate information to display on the Positra site. This aggregate information may also be disclosed to third parties. For example, we might inform third parties regarding the number of users of our Services and the activities they conduct while on our Site. We might also inform a pharmaceutical company that "20% of our users live in Chennai, TN" or that "30% of our users have the same symptoms." Depending on the circumstances, we may or may not charge third parties for this aggregate information. We require parties with whom we share aggregate information to agree that they will not attempt to make this information personally identifiable, such as by combining it with other databases.

Corporate Changes
We may transfer information, including your Personal Information, in connection with a merger, sale, reorganization, acquisition or other change of ownership or control by or of Positra or any affiliated company (in each case, whether in whole or in part). When one of these events occurs, we will use reasonable efforts to notify users before their information becomes subject to different privacy and security policies and practices.


PROTECTION OF YOUR DATA

We seek to use appropriate administrative, technical and physical security measures and safeguards to protect the confidentiality and security of Your Personal Information. However, since the Internet is not a 100% secure ecosystem, we cannot guarantee, ensure, or warrant the security of any information you transmit to us. There is no guarantee that information may not be accessed, disclosed, altered or destroyed by breach of any of our physical, technical or managerial safeguards. For extra security, we request you to keep your account credentials confidential. If, anytime, You believe that your data security with Positra has been compromised, please immediately notify Us of this problem.


CONFIDENTIALITY AND SECURITY

Your Personal Information is maintained by Positra in electronic form on its equipment, and on the equipment of its employees. Such information may also be converted to physical form from time to time. Positra takes all necessary precautions to protect your personal information both online and off-line, 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 Positra’s business.
No administrator at Positra 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 Site when finished. Positra 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 Positra by sending an email to s[email protected] You shall be liable to indemnify Positra due to any loss suffered by it due to such unauthorized use of your account and password.
Positra makes all User information accessible to its employees, agents or partners and third parties only on a need-to-know basis, and binds only its employees to strict confidentiality obligations.
Part of the functionality of Positra is assisting the providers to maintain and organise such information. Positra may, therefore, retain and submit all such records to the appropriate authorities, or to providers who request access to such information.
Part of the functionality of the Positra is assisting the patients to access information relating to them. Positra may, therefore, retain and submit all such records to the relevant patients, or to their providers.
Notwithstanding the above, Positra 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, Positra 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 Positra including but not limited to, 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.


RIGHTS AND OBLIGATIONS RELATING TO CONTENT

As mandated by Regulation 3(2) of the IG Rules, Positra hereby informs Users that they are not permitted to host, display, upload, modify, publish, transmit, update or share any information that:
I. belongs to another person and to which the User does not have any right to;
II. is grossly harmful, harassing, blasphemous, defamatory, obscene, pornographic, pedophilic, libelous, invasive of another's privacy, hateful, or racially, ethnically objectionable, disparaging, relating or encouraging money laundering or gambling, or otherwise unlawful in any manner whatever;
III. harm minors in any way;
IV. infringes any patent, trademark, copyright or other proprietary rights;
V. violates any law for the time being in force;
VI. deceives or misleads the addressee about the origin of such messages or communicates any information which is grossly offensive or menacing in nature;
VII. impersonate another person;
VIII. contains software viruses or any other computer code, files or programs designed to interrupt, destroy or limit the functionality of any computer resource; threatens the unity, integrity, defence, security or sovereignty of India, friendly relations with foreign states, or public order or causes incitement to the commission of any cognizable offence or prevents investigation of any offence or is insulting any other nation.



INFORMATION ARCHIVAL

Positra may archive information collected from Users from its Site or Services for as long as necessary, depending on the type of information; purpose, means and modes of usage of such information; and according to the SPI Rules. Computer web server logs may be preserved as long as administratively necessary.


CONTACT INFORMATION GRIEVANCE OFFICER

If a User has any questions concerning Positra, the Site, this Privacy Policy, the Services, or anything related to any of the foregoing, Positra customer support can be reached at the following email address: [email protected] or via the contact information available from the following hyperlink: www.positra.com/contact. In accordance with the Information Technology Act, 2000, and the rules made there under, if you have any grievance with respect to the Site or the service, including any discrepancies and grievances with respect to processing of information, you can contact our Grievance Officer through Customer Support.

CHILDREN’S AND MINOR’S PRIVACY

Positra strongly encourages parents and guardians to supervise the online activities of their minor children and consider using parental control tools available from online services and software manufacturers to help provide a child-friendly online environment. These tools also can prevent minors from disclosing their name, address, and other personally identifiable information online without parental permission. Although the Positra Site and Services are not intended for use by minors, Positra respects the privacy of minors who may inadvertently use the internet or the mobile application.


CONSENT TO THIS POLICY

You acknowledge that this Privacy Policy is a part of the Terms of the Site and the other Services, and you unconditionally agree that becoming a User of the Site and its Services signifies your (i) assent to this Privacy Policy, and (ii) consent to Positra using, collecting, processing and/or disclosing your Personal Information in the manner and for the purposes set out in this Privacy Policy. Your visit to the Site and use of the Services is subject to this Privacy Policy and the Terms.


CHANGES TO OUR PRIVACY POLICY

Positra reserves the right, at its sole discretion, to change this Privacy Policy at any time. If We decide to change the Privacy Policy, We will then post the changes in appropriate places on the Site so that You are aware of the changed Privacy Policy. Your continued use of the Site after the Effective Date for any such changes to the Privacy Policy will be deemed conclusively to constitute Your acceptance of and agreement to the changed Privacy Policy; consequently, You should frequently review this Privacy Policy.

Date Last Updated: November 13, 2017.

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