PURPOSE : 
Clirnet recognizes the expectations of its Users with regard to privacy, confidentiality and security of their personal and sensitive personal information that resides with CLIRNET. Keeping personal and sensitive personal information secure and using it solely for activities related to CLIRNET and preventing any misuse thereof is a top priority of Clirnet. Clirnet has adopted the privacy policy aimed at protecting the personal information entrusted and disclosed by You [“the Policy”]. This policy governs the way in which CLIRNET collects, uses, discloses, stores, secures and disposes of personal information and sensitive personal data or information.
This Privacy Policy is published in compliance of provisions of the Information Technology Act 2000 and Rules notified thereunder for collection, use, disclosure and retention of Personal and Sensitive Personal Information.
 
SCOPE : 
The Privacy Policy sets out:
<ul class="ul1">
<li class="li1">The type of information collected from You</li>
<li class="li1">The purpose, means and modes of usage of such information</li>
<li class="li1">How and to whom CLIRNET may disclose such information</li>
<li class="li1">How will the information be retained by CLIRNET</li>
</ul>
 
APPLICABILITY :
 
The Policy is applicable and binding on all Users hereinafter referred to as “You”
This Policy is applicable to personal information and sensitive personal data or information collected by CLIRNET or it’s affiliates directly from You or through CLIRNET’s online portals, mobile apps and electronic communications as also any information collected by CLIRNET’s server from the User’s browser.
You are expected to read and understand the Privacy Policy, so as to ensure that You the knowledge of:
<ul class="ul1">
<li class="li4">the fact that the information is being collected;</li>
<li class="li4">the purpose for which the information is being collected;</li>
<li class="li4">the intended recipients of the information;</li>
<li class="li4">the name and address of the entity that is collecting the information and the entity that will retain the information ; and</li>
<li class="li4">the various rights available to such Users in respect of such information.</li>
</ul>
<ul class="ul1">
<li class="li5">DEFINITIONS OF PERSONAL INFORMATION AND SENSITIVE PERSONAL  INFORMATION AS DEFINED IN IT ACT 2000 AND RULES</li>
</ul>
 
Personal Information is defined to mean any information that relates to a natural person, which, either directly or indirectly, in combination with other information available or likely to be available with a body corporate, is capable of identifying such person.
 
Sensitive Personal Data or Information of a person means such personal information which consists of information relating to-
<ul class="ul1">
<li class="li5">password</li>
<li class="li5">financial information</li>
<li class="li5">physical, physiological and mental health condition</li>
<li class="li5">sexual orientation</li>
<li class="li5">medical records and history</li>
<li class="li5">biometric information</li>
<li class="li5">any detail relating to the above clauses as provided to body corporate for providing service</li>
<li class="li5">any of the information received under the above clauses by body corporate for processing, stored or processed under lawful contract or otherwise;</li>
</ul>
 
A. Collection of Personal Information  
CLIRNET collects all or any of the following Personal information from you directly or indirectly such as :
<ul class="ul1">
<li class="li9">Name</li>
<li class="li9">Age</li>
<li class="li9">Sex</li>
<li class="li9">Postal address</li>
<li class="li9">Phone number(s)</li>
<li class="li9">Email address</li>
<li class="li9">Educational qualifications</li>
</ul>
 
CLIRNET may also collect or gather information about you indirectly in the background including but not limited to IP address, location details, Date-Time stamp, demographic information, platform usage information by way of cookies or other technical method.
 
CLIRNET also has access to the personal information of your Patients as stored by You using CLIRNET Program and Services. However, the Patient information is owned by You.
 
By using CLIRNET Program and Services you have assured Clirnet that you have taken express consent in writing from your patient to collect or gather personal and sensitive information about the patient directly or indirectly and share the same with Clirnet for purposes mentioned hereinbelow.
 
B. Collection of Sensitive Personal Information
 
CLIRNET collects only Personal Information from You and does not collect any sensitive personal data or information from you at any time.
CLIRNET provides a platform or storage where You can store the sensitive personal information of your patients. The Sensitive Personal Information collected by you from your patient is stored in an encrypted form by CLIRNET and is password protected. Only You have access to the Sensitive Personal Information of Your patients. CLIRNET has access to the Sensitive Personal Information of Your patients only in an anonymised form. You may specifically give access to the sensitive personal in your custody to CLIRNET for the purpose of maintenance or trouble shooting of CLIRNET Program and Services. This authorization must be in writing and with express consent of your patients.
You shall be responsible for obtaining explicit consent from your patients before storing the Personal and Sensitive Personal Information of Your patients on CLIRNET platform.
 
USE OF INFORMATION BY CLIRNET (PURPOSE) 
Use of Personal Information  
CLIRNET uses personal information concerning You in order to:
<ul class="ul1">
<li class="li4">Manage your relationship with CLIRNET</li>
<li class="li4">provide member benefits, which could include notifications of upcoming events, newsletters, publications, etc.</li>
<li class="li4">to promote or market products and services of CLIRNET or of a third party which CLIRNET thinks may be of interest or beneficial to you</li>
<li class="li4">to communicate with you for other purposes</li>
<li class="li4">to enable you to effectively use CLIRNET</li>
<li class="li4">for analytics such as studying user behaviour</li>
<li class="li4">to evaluate or improve CLIRNET Program and Services design</li>
<li class="li4">to enhance the User experience</li>
<li class="li4">for technical support</li>
<li class="li4">debugging customer support related issues</li>
<li class="li4">to provide safety and security measures</li>
<li class="li4">to comply with applicable laws</li>
<li class="li4">for statutory compliances  </li>
</ul>
Use of personal information of your Patients provided by you to Clirnet. 
CLIRNET may use the personal information of your patients for sharing it with third parties in anonymized form.
CLIRNET also reserves the right to use the personal information of your patients for analytics, research, etc and also for providing analytics and business intelligence based on the  personal information of your patients to the third parties in an anonymised form
 
Clirnet reserves the right to use the following types of information stored by the User in respect of its patients in CLIRNET Platform :
<ul class="ul1">
<li class="li19">End-Users/ Patient  demographic information as anonymized form;</li>
<li class="li19">End-Users/ Patient  information in relation to his health and history (anonymized form); </li>
</ul>
Use of sensitive personal information of your Patients provided by you to Clirnet 
CLIRNET reserves the right to use the sensitive personal information of your patients in anonymized form for analytics, research, etc. and also for providing analytics and business intelligence to the third parties
 
DISCLOSURE OF PERSONAL AND SENSITIVE INFORMATION 
The personal information collected by CLIRNET shall not be disclosed to any other organization except where:
<ul class="ul1">
<li class="li9">the disclosure has been agreed in a written contract or otherwise (e.g. electronic consent) between CLIRNET and You</li>
</ul>
 
<ul class="ul1">
<li class="li9">where CLIRNET is required to disclose the personal information to a third party on a need-to-know basis, provided that in such case CLIRNET shall inform such third party of the confidential nature of the personal information and shall keep the same standards of information/ data security as that of CLIRNET.</li>
</ul>
 
<ul class="ul1">
<li class="li9">CLIRNET also outsources the processing of certain functions and/or information to third parties and may disclose your personal information to such third parties to carry out the agreed functions.</li>
</ul>
 
<ul class="ul1">
<li class="li9">CLIRNET ensures that the third parties shall also provide the same level of protection as offered by CLIRNET to protect your personal information with appropriate security measures and prohibit them from using your personal information for their own purposes or from disclosing your personal information to others.</li>
</ul>
 
<ul class="ul1">
<li class="li9">CLIRNET reserves the right to disclose any personal information in CLIRNET’s custody if CLIRNET is compelled to do so by a court of law or requested to do so by a governmental entity or if CLIRNET determines it is necessary or desirable to comply with the law or to protect or defend CLIRNET’s rights or property.</li>
</ul>
 
NOTIFICATION AND CONSENT  
IT Act 2000 does not require to obtain your consent for the collection, use or disclosure of personal information for the purpose of establishing, managing, terminating your relationship with CLIRNET or for tendering Customer services to you.  By expressly entering into a contractual relationship with CLIRNET, Clirnet assumes, unless you advise CLIRNET otherwise, that you have consented to CLIRNET collecting, using and disclosing your personal information for the purposes stated above (including any other purposes stated or reasonably implied at the time such personal information was provided to CLIRNET).
 
IT Act 2000 requires your express consent for collection, use or disclosure of your sensitive personal information. By accepting this policy electronically you have given your express consent to the terms and conditions embodied herein. You may, at any time, subject to legal or contractual restrictions and reasonable notice, withdraw your consent. 
 
All communications with respect to such withdrawal or variation of consent should be in writing and addressed to the Privacy Officer at <a href="mailto:support@clirnet.com">support@clirnet.com</a>.
 
In case You do not provide consent or withdraw your consent at a later stage, CLIRNET shall have the option of not providing you the services for which the said information was sought including termination of contract between You and CLIRNET.
 
On termination of your relationship with CLIRNET or withdrawal of consent, all personal and sensitive information will be retained for the period so required as per the retention policy of CLIRNET or as per law.
 
CHANGES TO THE POLICY 
This Policy may change from time to time. To assist you, this Policy is dated and has an associated version number.
 
REQUEST FOR ACCESS TO PERSONAL INFORMATION / QUESTIONS OR COMPLAINTS 
If you have any questions about this Policy, or any concerns or complaints with regard to the administration of the Policy, or if you want to know more about the personal or sensitive information that CLIRNET maintains about you, you may write to or submit a request in writing for access to support@clirnet.com.
 
RETENTION  
The information submitted by the You shall be held as per the data retention policies of  CLIRNET  or as required by law.
 
REVIEW OR AMEND  
You may review and amend your personal information or sensitive personal information provided by you and ensure that any personal information or sensitive personal information found to be inaccurate or deficient shall be amended or corrected by You. CLIRNET shall not be responsible in any manner for the authenticity of the personal information or sensitive personal information or information supplied by You.
 
REASONABLE SECURITY PRACTICES  
The security of personal and sensitive information is a priority and is protected by maintaining physical, electronic, and procedural safeguards that meet applicable laws. CLIRNET shall take reasonable steps and measures to protect the security of your personal and sensitive information from misuse and loss, un-authorized access, modification or disclosure. CLIRNET maintains its security systems to ensure that your personal and sensitive information is appropriately protected and follows the extant standard encryption norms followed for the transmission of information. CLIRNET ensures that its employees and affiliates respect the confidentiality of any personal and sensitive information held by CLIRNET.
CLIRNET maintains ‘reasonable security practices and procedures’ to protect the Sensitive Personal Information provided by you   and has implemented the International Standard IS/ISO/ IEC 27001 on ‘Information Technology – Security Techniques – Information Security Management Systems – Requirements’.
CLIRNET is not liable for any loss of any personal or sensitive personal information provided by you, due to reasons or causes or conditions beyond its control including but not limited to corruption of data, strike, riots, civil unrest, Govt. policies, tampering of data by unauthorized persons like hackers, war and natural calamities. 
Cookie policy 
CLIRNET’s digital platforms use various third party analytical tools. These tools use cookies which are downloaded to your device when you visit a website in order to provide a personalized browsing experience. Cookies are used for lots of tasks like remembering your preferences &amp; settings, provide personalized browsing experience and analyze site operations. These cookies collect information about how users use a website, for instance, how often visited pages. All information collected by third party cookies is aggregated and anonymous. By using our website user/s agree that these types of cookies can be placed on his/her device. User/s is free to disable/delete these cookies by changing his/her device / browser settings. CLIRNET is not responsible for cookies placed in the device of user/s by any other website and information collected thereto. 
Privacy Undertaking by the User  
The User agrees and acknowledges that the User is required to comply with the Privacy law as per provisions of the Information Technology Act and ensure that the Personal Information and the Sensitive Personal Information collected by the User from its patient can be used and shared only on obtaining an express consent in writing from their Patient. 
The User states and undertakes that it shall obtain the requisite consent from the patient in writing as per the ‘Consent form’ provided by Clirnet before using the relevant services of Clirnet. 
Redressal of Grievance 
Should you have questions about this Privacy Policy or CLIRNET's information collection, use and disclosure practices, you may contact, the Data Protection Officer appointed by CLIRNET. CLIRNET will use reasonable efforts to respond promptly to any requests, questions or concerns, which you may have regarding our use of your personal information. If you have any grievance with respect to our use of your information, you may communicate such grievance addressed to the Data Protection Officer / Grievance Officer at <a href="mailto:support@clirnet.com">support@clirnet.com</a>

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