Privacy Policy
Narayana Hrudayalaya Ltd. ("NHL") is committed to respecting the privacy of every person who shares information with NHL. Your privacy is important to us, and we strive to take reasonable care and protect the information we receive from you, the User. In this regard, we adhere to the applicable governing laws in India related to Privacy and Personal Data Protection.
This Privacy Policy (“Privacy Policy”) applies to the collection, storage, processing, disclosure and transfer of your Personal Information (defined below) as per the above-mentioned laws, when such Personal Information is shared with NHL for any prupose or transaction or services (“Services”).
The terms ‘You’ or ‘Your’ refer to you as the User of our Services and the terms ‘We’, ‘Us” and ‘Our’ refer to NHL and it’s Group Companies along with Business Partners.
1. Definitions
1.1 “Personal Data / Personal Information” means any data about an individual who is identifiable by or in relation to such data.
1.2 “Processing / Process / Processed” in relation to personal data, means a wholly or partly automated operation or set of operations performed on personal data, and includes operations such as collection, recording, organization, structuring, storage, adaptation retrieval, use, alignment or combination, indexing, sharing, disclosure by transmission, dissemination or otherwise making available, restriction, erasure, or destruction.
1.3 “Data Principal” means the individual to whom the personal data relates and where such individual is:
- A child, includes the parents or lawful guardian of such a child;
- A person with disability, includes her lawful guardian, acting on her behalf.
1.4 “Data Fiduciary” means any person who alone or in conjunction with other persons determines the purpose and means of processing of personal data.
1.5 “Data Processor” means any person who processes personal data on behalf of a Data Fiduciary.
1.6 “Group Companies” means NHL, its subsidiaries, business affiliates, or any other entity that directly or indirectly controls, is controlled by, or is under common control of NHL including its subsidiaries, associate companies, affiliates, and joint venture entities. The term "control" shall mean the possession, directly or indirectly, of the power to direct or cause the direction of the management and policies of an entity, whether through ownership of voting rights, by contract, or otherwise.
1.7 “Business Partners” shall mean any person, entity, association, society, educational institution, partnership firm, sole proprietorship or organization with whom NHL or its Group Companies is having business collaboration for providing or availing the healthcare and allied and incidental services, either directly or indirectly.
2. Collection
We collect Your Personal Information directly from You, from third parties and automatically through Our Website or Our Applications. This Personal Information, for instance, would relate to the type of device You are using, the time that You have logged on to Our Website or Our Applications, Your IP address and other Personal Information as listed in Section 6 below. The personal information collected shall be used and disclosed for various purposes in accordance with your Consent and this Privacy Policy.
You can further choose to share additional Personal Information with Us, by writing to Us via the contact details provided in Section 14.
3. Consent
- By virtue of the Consent separately provided by you, it is agreed by You that You have, freely consented to the collection, storage, processing, disclosure and transfer of Your Personal Information in accordance with the provisions of this Privacy Policy and the Consent.
- You acknowledge that You have provided Your Personal Information out of your free will and after understanding how it will be used. You also consent that the collection, storage, processing, disclosure and transfer of any Personal Information shall not cause any wrongful loss to You, if it is done in accordance with the provisions of this Privacy Policy and the Consent. However, we shall not be liable for any loss that may happen to you owing to the provision of wrongful Personal Information by You.
4. Control Over Your Personal Information
- You have the right to withdraw Your consent at any point, provided such withdrawal of the consent is intimated to us in writing through an email at grievance.digital@narayanahealth.org requesting the same. If You wish to rectify the Personal Information that we may have collected to offer You healthcare services, other personalized services and offers, you may reach out to us through the contact information set out in Section 14 of this Privacy Policy for raising a request, citing the reason for such rectification of Personal Information.
- However, once You withdraw Your Consent to share the Personal Information collected by Us, we shall stop processing your personal information and by which You may not be able to avail the online services we offer, and usage of Our website and Our Applications might get restricted. Additionally, withdrawing your consent will not affect the lawfulness of any Processing we have conducted prior to your withdrawal, nor will it affect Processing of your Personal Data conducted on lawful Processing grounds other than consent.
5. Changes to Privacy Policy
- We may update this Privacy Policy from time to time with or without advance notice. However, You shall be notified only if there are material changes to this Privacy Policy. Additionally, the top part of the Privacy Policy indicates when the Privacy Policy was last updated. Your continued use/availing of our services shall be deemed acceptance of the subsequent amendments/revisions, unless such consent is specifically withdrawn.
6. Personal Information Collected
The kinds of information that We may collect about You include but are not limited to the following:
- Patient / Caregiver / Parents / Doctor / Nurses / Health Care Professionals / Job Candidates Name
- Date of Birth / Age
- Gender
- Address (including country and pin/postal code)
- Phone Number / Mobile Number
- Emergency Contact Number
- Email Address
- Physical, physiological and mental health condition, provided by You and/or your Health Care Professional
- Patient Vitals
- Blood Group
- Medical Record Number
- Personal medical records and history, Lab reports
- Valid financial information at time of purchase of product / service and / or online payment
- Login ID and Password
- Ration Card Details
- Insurance e-card
- Marital Status
- Spouse / Partner Name
- CCTV footage inside our campus
- User Details, as provided at the time of registration or thereafter
- Records of interaction with Company representatives
- Your usage details of our website / applications such as time, frequency, duration and pattern of use, features used and the amount of storage used
- Master and transaction data and other data stored in Your user account
- Internet Protocol address, cookie data, browser type, browser language, referring URL, files accessed, errors generated, time zone, operating system and other visitor details collected in Our log files
- Aadhaar Card Details
- Pan Card Details
- Driving License
- Voter ID
- VISA
- Passport Details
- Bank Details
- Employment History and Educational History (Through Resume)
- Video and audio recording of your interaction with NHL and its representatives either for healthcare services or recruitment or any other purpose.
- Any biometric data or information
- Any other information that is willingly shared by You (collectively referred to as "Personal Information")
7. How we Collect Personal Information
The methods by which we collect your Personal Information include but are not limited to the following:
- By filling the patient registration form
- By providing details to a Health Care Professional or Company representative
- When You register on Our Website / Apps / any digital channel
- When You / Your representatives apply for / collect birth / death certificate
- When Your Caregiver / Parents / Attenders provide Your details
- When You provide Your Personal Information to Us while receiving services
- When You use the features on Our Website
- Using cookies (more fully detailed in Section 10 of this Privacy Policy)
- CCTV footage through the cameras installed in Our premises
- When You apply to any jobs through Our Career portal
- Health related Information generated and recorded while rendering healthcare services
- Video and audio recording of your interaction with NHL and its representatives either for healthcare services or recruitment or any other purpose
8. Use of Personal Information / Purpose(s) for the collection of Personal Information
Your Personal Information may be used by NHL, Group Companies and Business Partners for various purposes including but not limited to the following:
- To provide healthcare services including preventive, diagnostic and medical treatment services and all related ancillary and allied clinical and non-clinical enabling services
- To facilitate insurance cashless processing (pre-authorization and final approvals) with the Insurance service provider
- To facilitate payment processing by sponsors on your behalf (government and non-government)
- To operate, improve the Website and/or our Services and to enhance Your experience
- For patient engagement via phone, SMS, WhatsApp or email or any digital communication mode to ensure continued healthcare services, extension of new services or products or benefits and seeking User feedback and grievance redressal
- To maintain electronic medical records of patients, including medical & treatment history, medications, insurance details and to facilitate digital journey for the patients and providing IT support
- To perform studies, research and analysis of clinical and non-clinical nature for improving Our information, analysis, services and technologies and publication of study or research reports on aggregate anonymized basis
- To resolve any grievance/complaints received from You
- To fulfill mandate of any government, quasi-government, statutory, regulatory and judicial authority
- To archive medical records and other relevant documents as per applicable legal & regulatory requirements
- For processing refunds to patients
- To facilitate the ambulance driver to reach the correct location of the patient
- To audit any specific events/incidents reported at the hospital
- For accounting & audit purposes
- To collect and process pre-requisite information from blood donors as mandated by the Government Authorities
- To ensure safety and security of the hospital premises
- To dispense medications, consumables and implants for patients
- To report incidents involving patients to the Safety Committee
- To monitor & ensure security of systems during information processing
- To transfer information about You if we are acquired by or merged with another company
- To schedule interviews and to provide employment services
- To share with our business partners for provision of specific services to You or NHL that you have ordered to enable them to provide effective services,
- To investigate, prevent, or take action regarding illegal activities, suspected fraud, violations of our Terms of Use, breach of Our agreement with you or as otherwise required by law
- To aggregate Personal Information for research, statistical analysis and business intelligence purposes, and to transfer such research, statistical or intelligence data in an aggregated or non-personally identifiable form to third parties and affiliates, (referred to as “Purpose(s)”)
9. Sharing and Transferring Personal Information to Third Parties
- Once you have freely consented to share your Personal Information with us, You authorize us to exchange, transfer, share, part with all or any of Your Personal Information, across borders and from Your country to any other countries across the world with the Cloud Service Provider and Our affiliates / agents / third party service providers / partners / banks and financial institutions or any other persons, for the Purposes specified under this Privacy Policy or as may be required by applicable law. However, the transfer is carried out under organizational and contractual measures to ensure compliance with applicable data protection regulations to safeguard your personal data.
- You acknowledge that some countries where we may transfer Your Personal Information may not have data protection laws that are as stringent as the laws of Your own country. You acknowledge that it is adequate that when NHL and its Group Companies transfers Your Personal Information to any other entity within or outside Your country of residence, NHL and its Group Companies will place contractual obligations on the transferee which will oblige the transferee to adhere to the provisions of this Privacy Policy.
- We may disclose Your information to any international third-party companies/organizations & Government bodies to procure the medicine, in case the medicine is not available in India. However, the transfer is carried out under organizational and contractual measures to ensure compliance with applicable data protection regulations to safeguard Your personal data.
- We may also share your personal information with banking, legal and insurance services (who may act as Processors or Fiduciaries) to the extent we are legally obliged to share or have a legitimate use in sharing your personal information
- We may share anonymized / de-identified information with research organizations, for the advancement of medical research to improve patient outcomes in future.
- We may share Your Personal Information with our Group Companies for providing / offering healthcare services, processing data on behalf of NHL, offering any new services including but not limited to wellness, preventive, diagnostic, medical treatment and pharmacy services and packages and benefits related to healthcare and health insurance service, and providing any information for offers and discounts that may be available from time to time.
- We may share Your Personal Information with our Business Partners for availing / providing services from / by the Business Partners for either healthcare and allied services, customer engagement services or data processing and other administrative services.
- It is possible that certain information will be stored on servers in multiple other countries on the “cloud” or other similar distributed hosting platforms. By providing Your Personal Data to us, You are consenting to the transfer of Your Personal Data between India and other jurisdictions, and to our use and disclosure of Your Personal Data in accordance with this Privacy Policy. However, such transfers will be made by implementing reasonable security measures for protection of Your Personal Data.
10. Use of Cookies
- We may store temporary or permanent ‘cookies’ on your computer. You can erase or choose to block these cookies from your computer. You can set or amend your web browser controls to accept or refuse cookies. If you choose to reject cookies, you may still use the Website though your access to some functionality and areas of this Website may be restricted. How you can refuse cookies through your web browser, vary from browser to browser. You should visit your browser's help menu for more information. Also, You can delete existing cookies from your browser. If cookies are deleted, the information collected prior to the preference change may still be used; however, we will stop using the disabled cookie to collect any further information from your user experience while serving advertisements or optimizing services to its Users, NHL may allow authorized third parties to place or recognize a unique cookie on the User’s browser/device. Further, NHL 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 Your computer, collect data or solicit personal information from You, for which NHL is not responsible or liable. NHL encourages You to read the privacy policies of all external sites.
11. Security
- The security of your Personal Information is important to us. We have adopted reasonable security practices and procedures including Physical, Technical and Administrative measures to ensure that the Personal Information collected and processed is secure and to prevent unauthorized access, disclosure, modification, destruction, loss, and misuse of personal information. We restrict access to your Personal Information to Our and Our affiliates’ employees, agents, third party service providers, partners, and agencies on a need-to-know basis and in relation to the Purposes as specified above in this Privacy Policy. While We will endeavor to take all reasonable and appropriate steps to keep secure any information which We hold about You and prevent unauthorized access, You acknowledge that the internet is not 100% secure and that We cannot provide any absolute assurance regarding the security of Your Personal Information. We will not be liable in any way in relation to any breach of security or unintended loss or disclosure of information caused by Us in relation to your Personal Information.
12. Compliance with Laws
- We adhere to the applicable governing laws in India related to Privacy and Personal Data Protection.
- You are advised not to use the services of the Website or Applications if any of the terms of this Privacy Policy are not in accordance with the applicable laws of your country.
13. Retention of Personal Information
- NHL shall retain your Personal Data only for the duration it is necessary for legal, regulatory and business requirements. We maintain specific records management and retention policies and procedures, so that personal data are deleted after a reasonable time according to the retention criteria for such data in accordance with applicable legal, regulatory and business requirements.
14. Grievance Officer
- We have appointed a Grievance Officer to address any concerns or grievances that You may have regarding the processing of Your Personal Information. If you have any such grievances, please write to our Grievance Officer at grievance.digital@narayanahealth.org and Our officer will attempt to resolve Your issues in a timely manner.
Grievance Officer
Narayana Hrudayalaya Limited
Corporate Office, 261/A, 2nd Floor
Bommasandra Industrial Area
Bengaluru, Karnataka 560099
grievance.digital@narayanahealth.org