Privacy Policy

1. Who We Are

India: Saluent Technologies Private Limited, registered in India. Operating through OduDoc, a healthcare SaaS platform serving hospitals, clinics, laboratories, pharmacies, and patients across India and the UAE.

UAE: Saluent Technologies FZCO (or its UAE subsidiary), operating under applicable UAE health data and payment regulations.

Data Protection Officer: [email protected]. For general privacy queries: [email protected].

2. Data We Collect

3. How We Use Your Data

• Delivering healthcare services: booking appointments, opening treatment episodes, routing lab samples, teleconsults.
• Identity & safety: KYC verification, two-factor auth, attendance (GPS + QR anti-fraud).
• Billing & payments: generating invoices, processing card / UPI / wallet payments, issuing refunds.
• AI-assisted features: symptom checker, disease suggestion, audio transcription, language translation (credits debited per use).
• Regulatory & audit: ABDM / ABHA integration, FHIR R4 record export, biomedical waste tracking, e-HPI reporting.
• Communications: appointment reminders, OTP, marketing (only with consent, opt-out any time).
• Product improvement: aggregated analytics, A/B tests (never individual health data).

4. OduDoc Wallet — Closed-Loop Credits

• Credit denomination mirrors local currency — credits have no cash value and cannot be cashed out.
• Credits can only be spent on OduDoc services: consultations, medicines, lab bookings, or transferred to another OduDoc member.
• Credits cannot be transferred outside the OduDoc ecosystem, exchanged for cash, or used at third-party merchants.
• Your wallet balance is a data record held in our secure server (not a bank account). We are not a payment bank or NBFC.
• Loading credits via card / UPI is processed by our licensed payment gateway partner (Stripe / Razorpay). Card / UPI data is never stored on OduDoc servers.
• Expired / unused credits: we currently have no expiry. If that changes, we will give 30 days notice and offer a spend period.

Regulatory basis: RBI's Master Directions on PPIs (2021) exempt closed-loop instruments issued by a service provider redeemable only against that provider's own goods/services. OduDoc Wallet credits qualify as such an instrument. UAE: these credits fall under the CBUAE's stored-value facility carve-out for non-transferable service credits.

5. Health Data — Special Category

Health data (diagnoses, prescriptions, vitals, imaging, genetic data) is a special category of personal data. We collect it only:

• With your explicit consent at registration and at each teleconsult / episode opening.
• To provide the specific healthcare service you requested.
• As required by Indian health regulations (ABDM/NHP, Clinical Establishments Act) or UAE HAAD / DOH regulations.

Who can see your health records: only you, the treating doctor(s) you consent to, the hospital/lab/pharmacy involved in your episode, and — with your explicit written consent — your insurer for a specific claim.
Super-admins (OduDoc platform team) can view anonymised logs for debugging only, never the clinical content of records.

ABDM / ABHA: if you link your ABHA number, your health records may be shared with the National Health Authority (NHA) of India as required by the ABDM framework. You control this consent via your ABHA app.

6. Payments & Financial Data

• Card / UPI / net-banking transactions are processed by Stripe (international) or Razorpay (India). OduDoc receives only a tokenised payment reference — never raw card numbers.
• Invoices and receipts are stored in our database for 7 years as required by Indian GST / UAE VAT law.
• Refunds are processed back to the original payment method (or credited to your OduDoc Wallet at your option).
• Gratitude / referral commissions are settled via our internal billing system; large payouts go via NEFT/IMPS to a bank account you verify during setup.
• Cryptocurrency (where an organisation enables it): for USDT / USDC / ETH / BTC checkout we store only the destination wallet address, on-chain transaction hash (txid), amount, and confirmation count to verify payment. Blockchain records are public; we never hold your private keys and cannot reverse an on-chain transfer.

7. Who We Share Data With

We never sell your personal or health data to any third party.

7A. Social Sign-in (Google, Apple & Facebook/Meta)

You may create or access your account using Google, Apple, or Facebook instead of a password. We request the least-privilege scopes and never post on your behalf or read anything beyond the fields below.

• Google: we access only your name, email, and profile picture (email + profile scopes), used solely to create and secure your account. OduDoc's use of Google user data adheres to the Google API Services User Data Policy, including its Limited Use requirements. We do not sell it, use it for advertising, or send it to AI models.
• Apple: we receive your name and an Apple email. If you pick "Hide My Email", that is a private relay address forwarding to your inbox — we store only the relay and use it only for account contact. Revoke access any time in your Apple ID settings.
• Facebook / Meta: we request only email and public_profile(name, picture, email), used only to create and secure your account. Remove OduDoc from Facebook → Settings → Apps and Websites at any time.

To delete all data obtained through any social login, delete your account (see Your Rights and odudoc.com/account/delete). This page is also OduDoc's data-deletion instructions URL for Meta / Facebook Login.

7B. Third-Party Sub-processors

We use the following sub-processors to run the service. Each is bound by a data-processing agreement (and a BAA where health data requires it), receives only the minimum data it needs, and may not use it for its own purposes. We give at least 30 days' notice before adding a new sub-processor.

8. Data Retention

9. Your Rights

Under India's Digital Personal Data Protection Act 2023 (DPDP), UAE's PDPL, and GDPR (for EEA users):

• Access: request a copy of all data we hold about you.
• Correction: update incorrect personal data in your profile or contact us.
• Erasure: delete your account yourself at odudoc.com/account/delete or in-app (Profile → Delete account). This removes your login and any linked Google/Apple/Facebook association. Clinical records may be retained for the statutory period, in pseudonymised form, even after deletion; an audit record that the erasure occurred is preserved.
• Portability: export your health records as a FHIR R4 bundle from your health passport.
• Withdraw consent: for marketing, withdraw via profile settings. For health data sharing, revoke via ABHA app or contact us.
• Nominate a representative: under DPDP, you may nominate someone to exercise rights on your behalf.

Submit a request to [email protected]. We respond within 30 days (or 72 hours for urgent health-data breaches).

10. Security

• All data in transit: TLS 1.3 encryption.
• All health records and KYC documents: AES-256 encryption at rest.
• Authentication: multi-factor authentication (TOTP + email OTP).
• Access control: role-based, per-organisation scoping — no cross-tenant data leakage.
• Intrusion detection: rate limiting, geo-fencing, anomaly alerts in Cloudflare.
• Pen-testing: performed before major releases. Responsible disclosure: [email protected].

11. Cookies & Tracking

We use strictly necessary cookies for authentication (session token, CSRF) and one analytics cookie (aggregated, no personal data). No third-party advertising cookies are used. See our full Cookie Policy.

12. Children's Data

OduDoc is not intended for use by children under 18 independently. Parental/guardian consent is required for minors. The My Family feature allows a parent to manage a child's health records under their account with explicit consent.

13. International Data Transfers

Data is primarily stored on dedicated servers in the patient's regional pod (e.g. India, UAE) with Cloudflare R2 object storage, delivered via Cloudflare's global edge network. For global features (AI transcription, maps), data may transit through the EU or US. We rely on standard contractual clauses (SCCs) and data processing agreements to safeguard transfers.

14. Changes to This Policy

We will notify you by email and in-app banner at least 15 days before any material change to this policy. Continued use after the effective date constitutes acceptance.

15. Contact Us

Privacy queries: [email protected]
Data Protection Officer: [email protected]
Grievance Officer (India): [email protected] · Response within 72 hours as required by DPDP Act.

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