DRAFT: not yet legal advice or a final document. This text was prepared as a starting point and must be reviewed and completed by a qualified Indian lawyer before launch. Highlighted [brackets] are details still to be filled in.
Privacy Policy
Last updated 13 October 2026
This policy explains what personal information CliniZentro handles, why, who sees it, how long we keep it, and what rights you have. [COMPANY LEGAL NAME] (“CliniZentro”, “we”) provides the service from [REGISTERED ADDRESS].
1. Two roles: who decides what happens to the data
- Patient information is the clinic’s. When a clinic stores a patient’s details, notes, prescriptions, invoices, files or messages in CliniZentro, the clinic decides why and how they are used. CliniZentro acts only on the clinic’s behalf, as its service provider (“processor”), under the Data Processing Terms. If you are a patient, the clinic that treats you is responsible for your information, and you should contact it first (see section 8).
- Account information is ours. For the people who use CliniZentro (clinic owners and staff) and for billing, we decide how the information is used, and this policy applies to us directly.
2. What we handle
| Whose | What | Where it comes from |
|---|---|---|
| Clinic staff | Name, email address, role, a hashed password (we never store the password itself), two-step sign-in secret (stored encrypted) and recovery code hashes, record of when you accepted our terms, and sign-in history (time, IP address, device type) kept in the audit log. | You, your clinic’s admin, and your use of the service |
| Clinic (business) | Clinic name, address, phone, plan and subscription status. Payment details are handled by our payment provider; we receive a customer and subscription reference, not your card number. | The clinic and our payment provider |
| Patients (on behalf of the clinic) | Name, phone, email, gender, date of birth, address, notes, appointments, visit notes and diagnoses, prescriptions, invoices and payments, photos and documents, WhatsApp conversations and delivery status, consent records for messages and marketing. | The clinic and its staff, the patient (for example through the clinic’s online booking page or a WhatsApp reply) |
| Doctors and clinics in the public directory | What they choose to publish: name, photo, qualifications, medical registration number and council, experience, languages, services, consultation fee, clinic name, address and city, and the free appointment times patients can book. We also record whether we checked the registration number against the council register. | The doctor and the clinic |
| People using a clinic’s booking page | Name, phone number, optional email and reason for the visit, and the appointment requested. | You, when you book |
| Everyone | Technical information needed to run and protect the service: IP address, browser type, request logs, error logs. | Your device |
Patient information includes health information, which is sensitive. We handle it only to run the service for the clinic.
Cookies and similar storage
CliniZentro does not use advertising or tracking cookies. To keep you signed in, the app stores a sign-in token in your browser’s local storage (platform administrators’ tokens use session storage). It is removed when you sign out.
3. Why we use it
- To provide, secure and support the service: store and show the clinic’s records, send reminders and messages the clinic has chosen to send, produce invoices, and keep an audit trail of who accessed what.
- To manage accounts and billing, send security and service emails (verification, password reset, sign-in alerts, payment and closure notices), and respond to support requests.
- To protect against abuse, fraud and security incidents, and to meet our legal obligations.
- To improve the service, using aggregate counts and error information. We do not look at the contents of patient records for this, and we do not sell personal information or use it for advertising. Our staff cannot sign in as a clinic user or open patient records through the platform tools. Access to patient data is limited to what is needed to keep the service working and is recorded where the system supports it.
4. Who we share it with (sub-processors)
We use these providers to run the service. Each handles information only to provide its part. We choose providers carefully and require them to protect it.
| Provider | Purpose | Information involved |
|---|---|---|
| [HOSTING PROVIDER AND CITY, INDIA] | Servers, database and file storage | All information in the service |
| Meta Platforms (WhatsApp Business Platform) | Sending and receiving WhatsApp messages the clinic chooses to send | Patient phone numbers and message content, files sent over WhatsApp. Meta’s own policies also apply to those messages. |
| Razorpay | Subscription billing for clinics | Clinic billing contact and subscription references. Not patient information. |
| [EMAIL SERVICE PROVIDER] | Sending our emails to clinic staff | Staff names and email addresses, and the text of the notice. No patient information. |
| [BACKUP STORAGE PROVIDER] | Encrypted backups | Encrypted copies of all information. We hold the decryption key, not the provider. |
| AI provider (Anthropic), only if the clinic uses AI features | Draft campaign messages; summarise notes the user submits | Only the text the user chooses to send to the AI feature. Each use is recorded in the clinic’s audit log. [CONFIRM the provider’s data-use and retention terms.] |
We may also disclose information where the law requires (for example a valid order from a court or authority), or to protect people’s safety, and to a successor if our business is transferred, on the same terms as this policy. [LAWYER: confirm whether any information is processed outside India and add the required transfer wording.]
5. How long we keep it
- The clinic decides. Clinics set retention periods in the app. The defaults are 7 years for clinical and billing records, 12 months for WhatsApp message text and files, 24 months for patients who never had a record, and 7 years for audit logs. Clinics can archive, export and permanently erase a patient at any time, subject to the safeguards in the app.
- When a clinic closes, everything is permanently deleted after a 30-day period during which the owner can download it or cancel the closure. We keep only a minimal record that the clinic existed (identifiers and counts, no personal or health information).
- Backups. Deleted and erased information can remain in our encrypted backups for up to [35] days until they rotate out. If a backup is restored, deletions made since are re-applied before the service resumes.
- Account and billing records may be kept for as long as the law requires (for example tax records), and security logs for a limited period.
6. How we protect it
- Traffic is encrypted in transit (HTTPS). Uploaded files and stored WhatsApp credentials are encrypted at rest; backups are encrypted before they leave the server.
- Each clinic’s data is separated from every other clinic’s. Access is role-based: for example, receptionists and accountants cannot open clinical notes.
- Passwords are stored as one-way hashes. Two-step sign-in is available, clinics can require it, and accounts lock after repeated failed sign-ins.
- An audit log records who viewed or changed patient information, and cannot be edited through the app.
- Our own administration tools are separate, require two-step sign-in, and cannot read patient records.
No system is perfectly secure. If a breach affects your information we will tell the affected clinics without undue delay [and within 72 hours of confirming it], so they can meet their own obligations, and we will cooperate with them and with the authorities.
7. Your rights
Under Indian data protection law you may have the right to access the personal information held about you, to have it corrected or completed, to have it erased, to nominate someone to exercise your rights if you cannot, and to complain. To exercise these:
- Account information: write to [SUPPORT EMAIL]. We will respond within [30] days.
- Patient information: ask your clinic. The clinic can download everything it holds about you, correct it, or erase it using tools in CliniZentro. We will help the clinic do this promptly. Where a law requires the clinic to keep a medical or accounting record, it may have to keep part of it for the required period.
- WhatsApp messages from a clinic: reply STOP to stop them, or START to resume appointment messages. Marketing messages need your separate agreement.
8. If you are a patient
Your clinic uses CliniZentro to keep your records, book appointments and send you reminders and, if you agreed, offers. The clinic is responsible for how your information is used and should give you its own privacy notice. If you book online, the details you enter are shared with that clinic and used to manage your appointment. We use them only on the clinic’s behalf. To ask questions or exercise your rights, contact the clinic first. If you cannot reach them or are not satisfied, contact our Grievance Officer below.
9. The public doctor directory
CliniZentro runs a public directory at https://clinizentro.com where anyone can search for doctors and book an appointment. It is optional. A clinic is listed only if its owner or an admin switches that on, and each doctor appears only if that doctor’s profile is switched on (by the doctor, or by an admin who confirms the doctor has agreed).
- What is public. Only what the clinic and doctor put on the public profile, as listed in section 2. Patient information is never shown. The directory shows free appointment times, not who booked them.
- Who decides. The clinic and the doctor decide whether to be listed and what to say. We decide how the directory works and why: to help patients find doctors and to keep the listing trustworthy. For that purpose we are responsible for the directory as described in this section.
- Registration checks. We may check a registration number against the public register of the medical council and show a “Verified” badge. We keep a record of who checked and when. A badge confirms the registration only. It is not an endorsement of the doctor’s treatment.
- Taking it down. Switch the profile or the clinic listing off in the app and it disappears from the directory within a minute. Search engines and caches can keep copies for a while; we ask them to drop pages that no longer exist. We may also hide a listing that is inaccurate or breaks our terms.
- Visitors. Searching the directory does not require an account, and we do not use advertising or tracking cookies. Like any website we keep ordinary request logs for security.
- Booking through the directory. The name, phone number, optional email and reason you enter go to the clinic you book with, which is responsible for them (see section 8).
10. Children
Clinics may record information about children, with the consent of a parent or guardian as the law requires; that is the clinic’s responsibility. CliniZentro is not directed at children and we do not knowingly create accounts for them.
11. Grievance Officer and contact
Grievance Officer: [GRIEVANCE OFFICER NAME]. Email: [GRIEVANCE OFFICER EMAIL]. Address: [REGISTERED ADDRESS]. We will acknowledge complaints within [48 hours] and resolve them within [30] days. If you are still not satisfied you may approach the Data Protection Board of India once it is operational, or the relevant authority.
12. Changes to this policy
We will update this policy when our practices change. We will tell signed-in users about material changes and ask them to accept the new version.