Last Updated On: 28/11/25

1. Introduction

1.1 Purpose of This Policy

This Privacy Policy explains how Octor Health Tech Private Limited collects, uses, processes, stores, transfers, shares, protects, and deletes Personal Data and Protected Health Information (PHI) across our digital health services.

1.2 Commitment to Compliance

Octor complies with:

Digital Personal Data Protection Act (DPDP), India
GDPR (EU)
CCPA / CPRA (California)
Singapore PDPA
UK GDPR
HIPAA-aligned safeguards (administrative, technical, physical)

1.3 Services Covered

This Policy applies to:

Octor Website (octor.health)
Octor Mobile Applications
Clinic & Hospital Portal
Doctor Dashboard
Teleconsultation System
APIs, SDKs, Webhooks
Device Integrations (Bluetooth, BLE, USB, Wi-Fi)
AI-assisted clinical documentation tools

1.4 Acceptance

By accessing or using the Services, you acknowledge and agree to this Privacy Policy.

2. Definitions

2.1 Personal Data

Information that identifies or relates to an individual. Examples:

Name, phone number, email
Identification numbers
IP address, location
Device metadata

2.2 Protected Health Information (PHI)

Health-related information that identifies or can identify a patient. Examples:

Symptoms, diagnoses, vitals
Prescriptions and history
Uploaded reports, radiology images
Consultation notes and recordings

2.3 Sensitive Personal Data

Includes:

Health information
Disabilities
Sexual life or orientation
Biometric identifiers (excluding medical vitals)

2.4 Data Fiduciary / Data Controller

Determines purpose and means of processing. Octor is Controller for:

Account information
Authentication metadata
Support request data
Usage analytics

2.5 Data Processor

Processes data on behalf of Controller. Octor is Processor for:

PHI from clinics/hospitals
Device vitals
Reports & clinical documentation
Teleconsultation data

2.6 User

Any authorized individual (doctor, staff, administrator, patient).

2.7 Customer

Hospitals, clinics, healthcare networks licensing Octor.

2.8 Sub-Processor

Third parties engaged to process data on behalf of Octor.

2.9 AI Output

Any summary, note, or suggestion generated by Octor’s AI systems.

2.10 Processing

Includes collecting, recording, storing, structuring, retrieving, transmitting, erasing, or destroying data.

3. Scope & Applicability

3.1 Where This Policy Applies

This Policy applies to Personal Data processed:

On the Octor platform
Through mobile applications
During teleconsultations
Through BLE/Wi-Fi medical devices
Via HIS/EMR integrations
Through Octor APIs

3.2 Who This Applies To

Doctors
Nurses
Clinic administrators
Patients using teleconsultation
Hospital IT teams
Sub-processors

3.3 Exceptions

This Policy does not apply to:

External third-party websites
Clinic/hospital internal systems
Third-party HIS/EMR systems

4. Roles & Responsibilities (Controller + Processor)

4.1 Octor as Data Controller

For account-level data, analytics.

4.2 Octor as Data Processor

For PHI controlled by clinics/hospitals.

4.3 Shared Responsibility Model

| Component | Responsibility | |---|---| | PHI accuracy | Clinics/Hospitals | | PHI storage security | Octor | | Device reading accuracy | Device manufacturer | | Consent for teleconsultation | Clinic/Doctor | | AI output verification | Doctor |

4.4 Customer Responsibilities

Healthcare providers must:

Ensure legal basis for PHI collection
Obtain patient consent
Configure role-based access
Not misuse or export PHI

5. Categories of Personal Data Processed

5.1 Personal Identification Information

Name
Email
Phone number
Credentials
Role/Designation

5.2 PHI (Clinical Data)

5.2.1 Vitals

Temperature
BP
Heart rate
ECG
SpO₂
Respiratory rate

5.2.2 Clinical Documentation

SOAP notes
Differential diagnoses
AI-generated summaries
Medical impressions

5.2.3 Uploaded Content

Prescriptions
Lab reports
Radiology images
PDFs

5.3 Teleconsultation Data

Audio/video metadata
Chat transcripts
Shared files
AI-assisted transcription

5.4 Technical & Behavioral Data

IP address
Browser metadata
Device identifiers
App analytics
Crash logs

6. Lawful Basis for Processing

6.1 Consent

Obtained voluntarily
Withdrawable anytime
Required for teleconsultation recordings

6.2 Contractual Necessity

Required for:

Account creation
Authentication
Device connectivity
Teleconsultation
Reporting
Billing

6.3 Legitimate Interest

Used for:

Security and incident detection
Fraud prevention
Analytics
Optimization
Load balancing
Debugging
Feature development

6.4 Legal Obligation

Compliance with healthcare laws
Responding to authorities
Record retention

6.5 Vital Interests

Processing to protect life during emergencies.

6.6 Public Interest / Public Health

Where mandated by law.

7. Methods of Collection

7.1 Data Provided by Users

Account creation
Patient registration
Clinical workflows
Uploading PHI

7.2 Automatically Collected Data

Device/app diagnostics
Cookies
Crash logs
API call logs
Authentication metadata

7.3 Data from Clinics/Hospitals

Imported patient records
HIS/EMR integration

7.4 Data from Integrated Devices

Bluetooth oximeters, BP monitors
USB ECG devices
WiFi medical equipment

7.5 Data from Third Parties

Lab integrations
Pharmacy integrations
Insurance systems
Government health registries

8. How We Use Personal Data

8.1 Clinical Workflow Management

OPD management
Queues
Consultation notes
Patient history

8.2 Device-Generated Data Handling

Real-time vitals
Syncing to medical records
Trend analysis

8.3 AI-Assisted Documentation

AI summaries, drafts, SOAP notes
Must be clinician-reviewed
Not a replacement for medical judgment

8.4 Teleconsultation & Remote Care

Video/audio
Chat
Follow-ups
Reporting

8.5 Security & Monitoring

Unauthorized access detection
Audit trails
System integrity

8.6 Analytics (Non-identifiable)

Usage trends
Performance
Crash diagnostics

8.7 Compliance & Legal

Regulatory responses
Audit support
Retention logs

9. AI-Generated Outputs & Automated Processing

9.1 AI-Assisted Features

Summarization
Template suggestions
Speech-to-text
Vitals interpretation assistance

9.2 Human Review Required

AI outputs must be reviewed
AI never provides medical advice

9.3 Transparency

Users are informed wherever automation is used.

9.4 No Automated Decision Making

No clinical decisions are made without human oversight.

10. How We Disclose Personal Data

10.1 Clinics & Authorized Staff

PHI is shared only with authorized clinical staff.

10.2 Sub-Processors

Used for:

Hosting
Email delivery
SMS/OTP
Monitoring
Error logging

10.3 Government Authorities

If required by applicable law.

10.4 Business Transfers

During mergers or acquisitions.

11. International Data Transfers

11.1 Cross-Border Flow

Data may be processed in:

India
Singapore
Japan
EU
USA (SOC2/HITRUST-compliant)

11.2 Safeguards

SCCs
DPDP-compliant mechanisms
Data minimization

11.3 User Notification

Users may be notified if legally required.

12. Data Security Measures

12.1 Technical Safeguards

AES-256 encryption at rest
TLS 1.3
Tokenization
Encrypted backups
Key rotation

12.2 Administrative Safeguards

Confidentiality agreements
RBAC
Least privilege
Security training

12.3 Physical Safeguards

Biometric access
Surveillance
Redundant environments

12.4 Monitoring

IDS
Log monitoring
API verification

13. Data Retention & Archival

13.1 Retention Policy

Governed by:

Controller
Local laws

13.2 Log Retention

6–24 months.

13.3 Data Deletion

Upon request or termination.

13.4 Archival Rules

Encrypted archival storage.

14. Your Rights (DPDP, GDPR, CCPA, Global)

14.1 Under DPDP (India)

Access
Correction
Erasure
Grievance redressal

14.2 Under GDPR

Right to be informed
Access
Rectification
Erasure
Restrict processing
Portability
Object

14.3 Under CCPA

Right to know
Delete
Opt-out
Non-discrimination

Requests: support@octor.health

15. Children’s Privacy

15.1 Not designed for direct use by minors.

15.2 Clinics must ensure proper consent for child PHI.

15.3 We do not knowingly collect data directly from minors.

16. Cookies & Tracking Technologies

16.1 Octor uses essential, functional, and performance cookies.

16.2 No advertising cookies.

16.3 Details are in the Cookie Policy.

17. Third-Party Links & Integrations

17.1 External links may be provided.

17.2 Octor is not responsible for external privacy practices.

17.3 Integrations must comply with clinic agreements.

18. Data Breach Response

18.1 Incident Management

24x7 monitoring
Risk assessment
System isolation

18.2 Notification

We will notify:

Clinics/hospitals
Authorities (as required)
Users (as required)

18.3 Documentation

All breaches are logged.

19. Confidentiality Obligations

19.1 Employees sign confidentiality agreements.

19.2 Access is limited to operational necessity.

20. Data Integrity & Accuracy

20.1 Clinics must ensure PHI accuracy.

20.2 Users may request corrections.

21. Cross-Border Teleconsultation & Regulatory Compliance

21.1 Telemedicine laws vary by region.

21.2 Doctors must ensure compliance.

21.3 Octor acts solely as a technology platform.

22. Responsibilities of Clinics, Hospitals & Practitioners

Clinics must:

Obtain consent
Configure access roles
Validate AI outputs
Maintain compliance
Avoid unlawful PHI export