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.
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.
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, user images and documents. 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.
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.
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.
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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 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
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.
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.
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.
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 [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.
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.
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.
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.
Date Last Updated: August 1, 2023.
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