Effective Date: 2nd July 2025

Last Updated: 2nd July 2025

We, DEVENDARI HEALING PRIVATE LIMITED, a company incorporated under the Companies Act, 2013, having our registered office at AKOLA, MAHARASHTRA (hereinafter referred to as "we", "us", "our" or "Company"), are committed to protecting the privacy and personal data of all users ("you", "your", or "User") who access, browse, or use our website located at devendari.com and/or our related mobile applications and digital interfaces (collectively, the "Platform"). This Privacy Policy ("Policy") sets out the manner in which we collect, process, store, use, disclose, and protect your Personal Data and Sensitive Personal Data or Information (collectively, "Data") in connection with our provision of healthcare-related services including, but not limited to, consultations with doctors (Registered Medical Doctors), dieticians, Ayurvedic practitioners, and fitness professionals (collectively, the "Services").

This Policy is made in compliance with the Information Technology Act, 2000, the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, and where applicable, the Digital Personal Data Protection Act, 2023, together with applicable rules and guidelines issued by competent authorities.

By accessing our Platform or using our Services, you agree and consent to the collection and use of your Data as described in this Policy. If you do not agree with the terms of this Policy, we advise you not to use our Platform or Services.

1. DEFINITIONS

For the purposes of this Policy, the following terms shall have the meanings assigned below:

1.1 "Personal Data"

Refers to any information relating to an identified or identifiable natural person, including but not limited to name, contact details, government-issued identifiers, and location data.

1.2 "Sensitive Personal Data or Information" ("SPDI")

a. Includes categories of data such as:

  • Passwords;
  • Financial details (e.g., credit/debit card or bank account information);
  • Physical, physiological, and mental health conditions;
  • Medical records and history;
  • Biometric data;
  • Sexual orientation;
  • Any other information as classified under applicable law.

b. However, any data/information relating to an individual that is freely available or accessible in the public domain or furnished under the Right to Information Act, 2005, or any other law shall not qualify as Sensitive Personal Data or Information.

c. By signing up on the App or proceeding to the Website, and / or using our Services you represent that you voluntarily provide us with personal information including medical and financial information, and consent to their collection, use, and disclosure in accordance with this Privacy Policy. You also represent that you are duly authorized by any third party (including a child or an employee) whose information you share with us. We shall act as per your representation of authority and shall not make any independent enquiries to ascertain the veracity of your authorization. In the event you do not have sufficient authorization you shall be solely responsible for your acts and omissions including sharing of information with us by you and the consequential processing and actions taken by us in accordance with this Privacy Policy.

1.3 "Processing"

Means any operation or set of operations performed on Data, including collection, storage, retrieval, use, disclosure, transfer, or deletion, whether or not by automated means.

1.4 "Applicable Law"

Refers to all relevant Indian laws, rules, and regulations including, but not limited to, the Information Technology Act, 2000, the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, and the Digital Personal Data Protection Act, 2023 (once in force).

2. SCOPE AND APPLICABILITY

This Policy applies to all persons (hereinafter referred to as "Users", "you" or "your") who access, browse, or use our Platform or avail of any healthcare advisory or consulting services offered by us, including but not limited to:

  • Health consultations and second opinions;
  • Lifestyle advisory;
  • Preventive health guidance;
  • Interpretation of diagnostic reports;
  • Care coordination and remote advisory services by qualified professionals.

This Policy does not apply to any third-party services, products, or websites that may be linked on our Platform, and we disclaim any responsibility for the data practices of such third parties.

3. CATEGORIES OF DATA COLLECTED

We may collect and process the following categories of Data:

3.1 Personal Data

  • Full name, gender, date of birth, address, phone number, and email address;
  • Identification documents such as Aadhar, PAN, passport, etc.;
  • Emergency contact information, nationality, marital status, and occupation.

3.2 SPDI and Medical Information

  • Medical records, consultation notes, diagnostic results, allergies, prescriptions, health status, symptoms, lifestyle information, and fitness goals;
  • Communications and interactions with healthcare providers on our Platform;
  • Audio, video, and chat-based interactions between you and our professionals.

 

3.3 Technical and Behavioural Data

  • IP address, browser type, device type, operating system, access logs, and usage data;
  • Application usage logs, crash reports, location data, and cookies or tracking scripts.

3.4 Financial Data

• Transaction details, billing information, and payment status, as processed via secure third-party payment gateways.

4. LAWFUL BASIS FOR PROCESSING

We only process your Data on one or more of the following legal grounds:

4.1 Consent

When you provide your explicit and informed consent for us to collect and use your Data for one or more specified purposes.

4.2 Contractual Necessity

When processing is required for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into such a contract.

4.3 Legal Obligation

When processing is necessary for compliance with a legal or regulatory requirement.

4.4 Legitimate Interests

When we process your Data to serve our legitimate interests, provided that such interests do not override your fundamental rights and freedoms.

5. PURPOSES FOR WHICH WE PROCESS YOUR DATA

We may collect and use your Data for the following purposes:

  • To register you on our Platform and verify your identity;
  • To facilitate consultations with medical professionals, dieticians, Ayurvedic practitioners, or fitness experts;
  • To maintain and manage Electronic Health Records (EHRs);
  • To customize and recommend health, dietary, and fitness plans;
  • To send appointment reminders and manage follow-up communications;
  • To process payments, raise invoices, and maintain accounts;
  • To conduct research and analytics (subject to anonymization or aggregation);
  • To comply with applicable legal and regulatory requirements;
  • To monitor Platform usage, ensure data security, and troubleshoot technical issues;
  • To enhance user experience and optimize our Platform and Services.

6. DATA SHARING AND DISCLOSURE

We do not sell or rent your Data. However, we may share your Data under strict confidentiality and for legitimate purposes with:

  • Qualified healthcare professionals providing Services through our Platform;
  • Service providers engaged by us for IT, analytics, payment processing, hosting, customer support, and communication services;
  • Government authorities, courts, or regulators where disclosure is legally required;
  • Legal or tax consultants, auditors, or compliance advisors engaged by us;
  • Prospective investors, business partners, or acquirers in the event of a business reorganization, subject to execution of appropriate non-disclosure agreements.

 

All third parties to whom your Data is disclosed are contractually obligated to safeguard your Data and use it solely for the purpose for which it was disclosed.

7. CROSS-BORDER DATA TRANSFER

In some cases, your Data may be stored or processed outside India. We ensure that such transfers are undertaken in accordance with applicable laws and that the jurisdiction provides an adequate level of data protection or appropriate safeguards are implemented through contracts and data transfer agreements.

8. DATA RETENTION

a. We store your personal information in accordance with applicable laws, which means we keep your data for as long as necessary to provide you with our Services or as may be required under any law. We shall store your personal information for lawful purposes only. We keep de-identified data for research and statistical purposes for a longer period.

b. If you close your account, we have no obligation to retain your data, and we may delete any or all of your data without liability. However, we may retain data related to you if we believe it may be necessary to prevent fraud or future abuse, if required by law, or for other legitimate purposes. We may continue to store your data in anonymized or de-identified form for analytical, research, or other purposes for which your information is collected as previously indicated.

9. SECURITY MEASURES

We have implemented appropriate administrative, technical, and organizational security measures to ensure the confidentiality, integrity, and availability of your Data, including:

  • Encryption of sensitive Data in transit and at rest;
  • Regular software and infrastructure security updates;
  • Access controls, audit logs, and secure authentication systems;
  • Firewalls, antivirus, intrusion detection and prevention systems;
  • Regular vulnerability assessments and penetration testing;
  • Staff training in data privacy and security protocols.

Despite our best efforts, no system is completely secure. We cannot guarantee absolute security of your Data and disclaim any liability in case of an event beyond our control.

10. SESSION RECORDINGS

To maintain service quality, ensure continuity of care, and for internal training or auditing purposes, certain consultations or sessions conducted through the Platform may be audio, video, or text recorded. Such recordings will be securely stored and accessed only by authorized personnel, and will be used strictly for lawful, service-related purposes.

By using our Services, you acknowledge and consent to such recordings. In the case of minors, consent must be provided by a parent or legal guardian. If you do not wish for your session to be recorded, you must notify us in writing prior to the commencement of the session, though this may limit our ability to deliver certain services.

11. USE OF THIRD-PARTY PLATFORMS

Consultations and communications facilitated through our Services may be conducted via third-party applications or platforms (such as video conferencing or messaging tools) that are not owned or operated by the Company. By participating in such consultations, you acknowledge and agree that your use of these third-party platforms is subject to their respective terms and conditions, privacy policies, and data security practices.

The Company shall not be responsible for any data collection, usage, breach, or service-related issues arising from your use of such third-party platforms. We encourage you to review the applicable terms and privacy policies of any third-party service used in connection with our Platform.

12. YOUR RIGHTS

We take reasonable steps to ensure that your personal information is accurate, complete, and up to date. However, you have the sole responsibility of ensuring that you review the accuracy of the information provided by you and contact us in case of discrepancies, or in case you wish to discontinue the use of our Services. You have the following rights with regard to your personal information:

  • You have the right to access your personal information, request updating, correction, and deletion.  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 grievance@devendari.com. 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 subsequently 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. There may be circumstances where we will not correct, delete or update your personal information, including (a) where the personal information is opinion data that is kept solely for evaluative purposes; (b) the personal information is in documents related to a prosecution if all proceedings relating to the prosecution have not been completed; and(c) where your information has already been processed in de-identified form.
  • You are free not to share any medical or other information that you consider confidential and withdraw consent for us to use data that you have already provided. In the event that you refuse to share any information or withdraw consent to process information that you have previously given to us, we reserve the right to restrict or deny the provision of our Services for which we consider such information to be necessary.

13. CHILDREN’S PRIVACY

Our Services may be used to support the health and well-being of individuals under the age of 18, but only under the direct supervision or with the explicit consent of a parent or legal guardian. We do not knowingly collect personal data from minors without appropriate parental or guardian consent. If we become aware that such data has been collected without the required consent, we shall take reasonable steps to delete it promptly.

14. AMENDMENTS TO THIS POLICY

We reserve the right to modify or update this Policy from time to time to reflect legal, regulatory, or technological developments. We will notify you of any material changes by posting the updated Policy on our Platform with a revised “Last Updated” date. Your continued use of our Services after such changes constitutes your consent to the updated Policy.

15. GRIEVANCE REDRESSAL

In case of grievance is in relation to Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021, we shall acknowledge your complaint within 48 hours and dispose of such the complaint within a period of 15 working days from the date of its receipt.  Disposal of complaint shall include all actions as considered necessary by the Company.

In accordance with applicable law, we have appointed a Grievance Officer named grievance@devendari.com to address any concerns, complaints, or questions regarding this Policy or our data practices. You may contact our Grievance Officer at:

Grievance Officer / Data Protection Officer
Name: Yogesh Kukreja
Designation: Data protection officer
Email: grievance@devendari.com
Phone: 9403892451
Address: C/O RAMCHANDRA K, KHADAN SINDHI CAMP, Gandhinagar (Akola), Akola, Akola- 444004, Maharashtra

We endeavour to respond to all legitimate grievances within the statutory timelines

By continuing to use our Platform or Services, you confirm that you have read, understood, and agreed to the terms of this Privacy Policy.