System Two Online Solutions Private Limited (“us”, “we”, or “Company”) is the author and publisher of
the www.healthpotli.com, an internet based portal and the mobile application name d [heatlhpotli] (collectively referred to as the “Website”).
IF YOU USE THE SERVICES ON BEHALF OF SOMEONE ELSE (SUCH AS YOUR CHILD) OR AN ENTITY (SUCH AS YOUR EMPLOYER), YOU REPRESENT THAT YOU ARE AUTHORISED BY SUCH
(i) The Information Technology Act, 2000;
(ii) Rule 4 of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011 (the “ SPI Rules”); and
(iii) Rule 3(1) of the Information Technology (Intermediaries Guidelines) Rules, 2011.
(i) The type of information collected from the Users, including sensitive personal data or information;
(ii) The purpose, means and modes of usage of such information; and
(iii) How and to whom such information would be disclosed.
COLLECTION OF PERSONAL INFORMATION
Generally some of the Services require us to know who you are so that we can best meet your needs. When you access the Services, we may ask you to
voluntarily provide us with certain information that personally identifies you or could be used to personally identify you. Without prejudice to the
generality of the above, information collected by us from you may include (but is not limited to) the following:
(i) contact data (such as your email address and phone number);
(ii) demographic data (such as your gender, your date of birth and your pin code);
(iii) data regarding your usage of the Services; and
(iv) other information that you voluntarily choose to provide to us (such as information shared by you with us through emails or letters).
The information collected from you may constitute ‘personal information’ or ‘sensitive personal data or information’ under the SPI Rules. Personal
information is defined under the SPI Rules 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.
The SPI Rules further define “sensitive personal data or information” of a person to mean personal information about that person relating to:
(ii) financial information such as bank accounts, credit and debit card details or other payment instrument details;
(iii) physical, physiological and mental health condition;
(iv) sexual orientation;
(v) medical records and history;
(vi) biometric information;
(vii) any detail relating to the above clauses as provided to body corporate for providing service; and
(viii) any of the information received under above clauses by body corporate for processing, stored or processed under lawful contract or otherwise.
Information that is freely available in the public domain or accessible under the Right to Information Act, 2005 or any other law will not be regarded as
personal information or sensitive personal data or information.
This section applies to all Users.
3.1.2 All the information provided to us by a User, including sensitive personal information, is voluntary. You understand that we may use certain
information of yours, which has been designated as ‘sensitive personal data or information’ under the SPI Rules, (a) for the purpose of providing you the
Services, (b) for commercial purposes and in an aggregated or non-personally identifiable form for research, statistical analysis and business intelligence
purposes, for (c) for sale or transfer such research, statistical or intelligence data in an aggregated or non-personally identifiable form to third
parties and affiliates. The Company also reserves the right to use information provided by or about the User for the following purposes:
(i) Publishing such information on the Website;
(ii) Contacting Users for offering new products or services;
(iii) Contacting Users for taking product and Service feedback;
(iv) Analyzing software usage patterns for improving product design and utility; and
(v) Analyzing anonymized practice information for commercial use.
You hereby consent to such use of such information by us.
3.1.3 Collection of information which has been designated as ‘sensitive personal data or information’ under the SPI Rules requires your express consent. By
to you in the event such consent through an email is not given.
3.1.4 The Company does not control or endorse the content, messages or information found in any Services and, therefore, the Company specifically disclaims
any liability with regard to the Services and any actions resulting from your participation in any Services, and you agree that you waive any claims
against the Company relating to same, and to the extent such waiver may be ineffective, you agree to release any claims against the Company relating to
3.1.5 You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information provided as part of account
registration. If your personal information changes, you may correct, delete inaccuracies, or amend information by making the change on our member
information page or by contacting us through [firstname.lastname@example.org]. We will make good faith efforts to make requested
changes in our then active databases as soon as reasonably practicable. If you provide any information that is untrue, inaccurate, out of date or
incomplete (or becomes untrue, inaccurate, out of date or incomplete), or we have reasonable grounds to suspect that the information provided by you is
untrue, inaccurate, out of date or incomplete, we may, at our sole discretion, discontinue the provision of the Services to you.
3.1.6 You may choose to unsubscribe from promotional communications that you receive from us by clicking the ‘unsubscribe’ link provided at the end of
every such promotional communication.
3.1.7 If you wish to cancel your account or request that we no longer use your information to provide you services, contact us through [ email@example.com]. We will retain your information for as long as your account with is active and as needed to provide
you the Services. We shall not retain such information for longer than is required for the purposes for which the information may lawfully be used or is
otherwise required under any other law for the time being in force. After a period of time, your data may be anonymized and aggregated, and then may be
held by us as long as necessary for us to provide our Services effectively, but our use of the anonymized data will be solely for analytic purposes.
3.1.8 If you wish to opt-out of receiving non-essential communications such as promotional and marketing-related information regarding the Services, please
send us an email at [firstname.lastname@example.org].
3.1.9 The User may be required to pay with a credit card, wire transfer, debit card or cheque for Services for which subscription amount(s) is/are payable.
We will collect such User’s credit card number and/or other financial institution information such as bank account numbers and will use that information
for the billing and payment processes, including but not limited to the use and disclosure of such credit card number and information to third parties as
necessary to complete such billing operation. Verification of credit information, however, is accomplished solely by the User through the authentication
process. User’s credit-card/debit card details are transacted upon secure sites of approved payment gateways which are digitally under encryption, thereby
providing the highest possible degree of care as per current technology. However, the Website provides you an option not to save your payment details. User
is advised, however, that internet technology is not full proof safe and User should exercise discretion on using the same.
3.1.10 Due to the communications standards on the internet, when a User or anyone who visits the Website, we automatically receive the URL of the site from
which anyone visits. We also receive the Internet Protocol (IP) address of each User’s computer (or the proxy server a User used to access the World Wide
Web), User’s computer operating system and type of web browser the User is using, email patterns, as well as the name of User’s ISP. This information is
used to analyze overall trends to help us improve the Service. The linkage between User’s IP address and User’s personally identifiable information is not
shared with third parties. Notwithstanding the above, we may share some of the aggregate findings (not the specific data) in anonymized form (i.e.,
non-personally identifiable) with advertisers, sponsors, investors, strategic partners, and others in order to help grow the business.
3.1.11 The Website uses temporary cookies to store certain data (that is not sensitive personal data or information) that is used for the technical
administration of the Website, research and development, and for User administration. In the course of serving advertisements or optimizing services to its
Users, we may allow authorized third parties to place or recognize a unique cookie on the User’s browser. The cookies however, do not store any personal
information of the User.
3.1.12 To create an account, a User is required to provide the following information, which such User recognizes and expressly acknowledges is personal
information allowing others, including us, to identify the User: name, User ID, email address, country, ZIP/postal code, age, phone number, password chosen
by the User and valid financial account information. Other information requested on the registration page, including the ability to receive promotional
offers from us, is optional. We may, in future, include other optional requests for information from the User to help us to customize the Website to
deliver personalized information to the User. However, we assume your consent in relation to various matters, once you complete the registration process.
results or links on the Website. These other sites may place their own cookies or other files on the Users’ computer, collect data or solicit personal
information from the Users, for which we are not responsible or liable. Accordingly, we do not make any representations concerning the privacy practices or
software, sound, photographs, graphics, videos, messages or other materials available on such websites. The inclusion or exclusion does not imply any
endorsement by us of the website, the website's provider, or the information on the website. If you decide to visit a third party website linked to the
Website, you do this entirely at your own risk. We encourage the Users to read the privacy policies of that website.
3.1.14 The Website may enable User to communicate with other Users or to post information to be accessed by others, whereupon other Users may collect such
data. Such Users, including any moderators or administrators, are not authorized representatives or agents, and their opinions or statements do not
necessarily reflect those of the Company, and they are not authorized to bind us to any contract. We hereby expressly disclaim any liability for any
reliance or misuse of such information that is made available by Users or visitors in such a manner.
3.1.15 We do not collect information about the visitors of the Website from other sources, such as public records or bodies, or private organizations save
order for us to effectively render the Services).
3.1.16 We maintain a strict ‘No-Spam’ policy, which means that we do not intend to sell, rent or otherwise give your e-mail address to a third party
without your consent.
3.1.17 The Company has implemented best international market practices and security policies, rules and technical measures to protect the personal data
that it has under its control from unauthorised access, improper use or disclosure, unauthorised modification and unlawful destruction or accidental loss.
However, for any data loss or theft due to unauthorized access to the User’s electronic devices through which the User avails the Services, the Company
shall not be held liable for any loss whatsoever incurred by the User.
3.1.18 The Company implements reasonable security practices and procedures and has a comprehensive documented information security programme and
information security policies that contain managerial, technical, operational and physical security control measures that are commensurate with respect to
the information being collected and the nature of Company’s business. The reasonable security practices and procedures implemented by us include but are
not limited to: [encrypting data when it is on the move using industry standard practices, keeping all the data within private cloud, regularly changing
production keys and password, secure and very limited access to all production servers, performing regular security updates on our servers and more.]
information in the event it is required to do so by law, rule, regulation, law enforcement agency, governmental official, legal authority or similar
requirements or when we, in our sole discretion, deem it necessary in order to protect our rights or the rights of others, to prevent harm to persons or
Casual Visitors Note
3.2.1 No sensitive personal data or information is automatically collected by us from any casual visitors of this Website, who are merely perusing the
read and understand the privacy statements set out herein, failing which they are required to leave this Website immediately.
3.2.3 If you, as a casual visitor, have inadvertently browsed any other page of this Website prior to reading the privacy statements set out herein, and
you do not agree with the manner in which such information is obtained, stored or used, merely quitting this browser application should ordinarily clear
all temporary cookies. All visitors, however, are encouraged to use the “clear cookies” functionality of their browsers to ensure such clearing/ deletion,
as we cannot guarantee, predict or provide for the behavior of the equipment of all the visitors of the Website.
3.2.4 You are not a casual visitor if you have willingly submitted any personal data or information to us through any means, including email, post or
through the registration process on the Website. All such visitors will be deemed to be, and will be treated as, Users for the purposes of this Privacy
Confidentially and Security
Your personal information is maintained by the Company 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. The Company 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 Company’s business.
No administrator at the Company 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 Website when finished. The Company does not undertake any liability for any un-authorised use
of your account and password. If you suspect any unauthorized use of your account, you must immediately notify us by sending an email to [ email@example.com]. You shall be liable to indemnify the Company due to any loss suffered by us due to such unauthorized
use of your account and password.
The Company makes all User information accessible to its employees, agents or partners and third parties only on a need-to-know basis, and binds all such
employees to strict confidentiality obligations.
Part of the functionality of the Website is assisting the doctors to maintain and organise such information. We may, therefore, retain and submit all such
records to the appropriate authorities, or to doctors who request access to such information.
Notwithstanding the above, the Company 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, the Company 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 the Company including, 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.
above, so that you may review the changed terms prior to continuing to use the Services. As always, if you object to any of the changes to our terms, and
you no longer wish to use the Services, you may contact [firstname.lastname@example.org] to deactivate your account. Unless stated
If a User uses the Services or accesses the Website after a notice of changes has been sent to such User or published on the Website, such User hereby
provides his/her/its consent to the changed terms.
Children’s and Minor’s Privacy
The Company 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 Website and Services are not
intended for use by minors, the Company respects the privacy of minors who may inadvertently use the internet or the mobile application.
Consent to this Policy
Address for Privacy Questions
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
System Two Online Solutions Pvt Ltd.
Pandri, Raipur-492001 (C.G.)