Privacy Notice

Draft pending review by counsel. This text has not yet been reviewed by a lawyer and may change before it takes effect.

The short version

• Your health record is stored in India. A doctor, clinic or pharmacy sees it only when you approve, and only for a limited time.
• You can stop any sharing at once. Every access appears in your access log the same day.
• We never ask for or store your Aadhaar number. Your fingerprint and face never leave your phone.
• We do not sell your personal data, and we do not use your health record for advertising.
• You can download your data, correct it, ask us to delete it, and withdraw your consent at any time from the Consent centre.
• Questions and complaints go to our Grievance Officer, Grievance Officer (to be appointed), at grievance@veripres.example.

1. Who we are

Veripres is run by Obelisk Techno Solution Private Limited, a company registered in India with its registered office in Ahmedabad, Gujarat (CIN: to be added; registered office: registered office address to be added). "We", "us" and "our" mean that company.

Under the Digital Personal Data Protection Act, 2023, we are the "data fiduciary" for the personal data described in this notice. That means we decide why and how it is used, and we are responsible for it.

The doctors, clinics and pharmacies you share with are separate from us. They are responsible for how they use what you show them, under their own professional and legal duties. A pharmacy's dispensing register belongs to that pharmacy (section 6).

2. What this notice covers

This notice covers the Veripres app and website during the pilot. It applies to patients, to the professionals we invite (doctors, clinic staff, pharmacists and pharmacy owners), and to anyone who uses the public doctor directory or the prescription checking page.

3. What we collect

If you are a patient

• Who you are: your name, date of birth, sex, mobile number and email address, and the Veripres ID we give you.
• Your health profile: height, weight and blood group; smoking and alcohol habits, if you add them; long-term conditions; allergies; medicines you take; past operations and hospital stays; family history; and any reports, scans, images or past prescriptions you upload. These are marked as self-reported.
• What doctors add: visit notes (symptoms, vital signs such as blood pressure, examination findings, diagnoses, notes, images, tests ordered, advice and follow-up dates), corrections to visit notes, documents, and the prescriptions they sign.
• What pharmacies add: what each pharmacy dispensed to you, including the brand, the quantity, whether it was a substitute, and the batch number if recorded.
• Appointments: the doctor, clinic, time, status and type of visit.
• Consent and sharing records: the consents you give or withdraw, with the date, the version of this notice and how you confirmed; requests to see your record and your answers; and your access log.
• Sign-in records: your passkeys (a public key only, see section 7), your sign-in sessions, and records of the one-time codes we sent you.
• Your requests: for example, a request to delete your account.

If you are a doctor

• Your name, email address, password (stored only in scrambled form) and passkey.
• Your registration number and medical council, qualifications, specialty, years in practice, languages, services, letterhead text, and the registration certificate you upload for checking.
• The clinics where you work, your consultation fees, availability and leave days, and your prescription templates.
• Your digital signing key. We create it, keep the private part encrypted, and use it only when you choose to sign a prescription.
• A record of what you open, write and sign.

If you work at a clinic (reception or clinic owner)

• Your name, email address, password (stored only in scrambled form), role and clinic.
• The clinic's name, address, phone number, map link and facilities.
• A record of the appointments you book or change, and of what you open.

If you are a pharmacist or pharmacy owner

• Your name, email address, password (stored only in scrambled form), passkey, role and pharmacy, and for pharmacists, your registration number.
• The pharmacy's name, address, phone number, drug licence number, registered pharmacist and premises details.
• A record of what you open and dispense, and the pharmacy's dispensing register (section 6).

For everyone

• Device and security data: the type of device and browser you use, when you sign in, and the internet (IP) address your requests come from. We use these to keep accounts safe, for example to block repeated sign-in attempts.
• Feedback: what you write with the Feedback button, your role, the screen you were on and your screen size. We do not attach your name or account. Please do not include health details.
• Usage counts: records of events such as "prescription signed" or "medicine dispensed", with the role, the time and, for professionals, the clinic or pharmacy. They never include a patient's name, Veripres ID or health details. For patients, see consent 4 in section 5.
• Cookies: we use only the cookies needed to keep you signed in and to complete passkey sign-in. We do not use advertising or analytics cookies.

If you only browse the directory or check a prescription, we do not ask who you are.

4. Why we use it

We use personal data only to:

• create your account, keep your health record and show it to you;
• let doctors, clinics and pharmacies see your information when you approve;
• book and manage appointments;
• let doctors sign prescriptions, and let anyone check that a prescription is genuine without seeing who it is for;
• let pharmacies record what they dispense and keep the register the law requires;
• check professionals' registrations and licences, and publish factual directory listings;
• send one-time codes and messages about your account;
• keep Veripres secure, keep the access log, prevent misuse, and investigate access you report;
• count totals for the pilot, such as how many prescriptions were issued and dispensed, without names or health details;
• improve the pilot using anonymised usage data, if you agree (consent 4);
• answer your requests and complaints, and meet our legal duties.

We do not sell your personal data. We do not use your health record for advertising, and we do not share it with employers or insurers.

5. Your four consents

When you sign up, we ask for four separate consents. Each has its own tick box.

1. Store my health record on Veripres. Required. Without it, Veripres cannot work for you.
2. Let doctors see my record when I approve or confirm an appointment. Optional.
3. Let pharmacies see my prescriptions when I approve. Optional.
4. Use anonymised, aggregated usage data to improve the pilot. Optional. If you agree, events from your use of the app are included in our usage counts, without your name, Veripres ID or health details. If you say no, we leave your activity out.

Consents 2 and 3 do not open your record by themselves. Each time, you still choose whether to share. You can change any consent at any time in the Consent centre. The Consent and Sharing page explains each one in more detail.

6. Who sees what

Nobody can search for you. A clinic or pharmacy cannot look you up by name or phone number, and your Veripres ID on its own opens nothing.

Your full health record means your visit notes from every clinic, conditions, allergies, medicines, vital signs, documents, prescriptions and what pharmacies dispensed. A pharmacy never sees your visit notes, diagnoses, symptoms, vital signs or documents. Clinic reception never sees anything clinical.

While a doctor has access, they can add visit notes, documents and prescriptions to your record. When a pharmacy dispenses, it adds what it gave you.

You can stop any of this sharing at any time. Every access is written to your access log.

Others who may see some of your data:

• Anyone holding your prescription PDF can scan its QR code. The checking page shows only the prescribing doctor and their registration details, the clinic, the dates, the number of medicines, and whether it has been dispensed. It never shows your name or your medicines.
• The pharmacy's dispensing register. When a pharmacy dispenses to you, Indian drug rules require it to record details including your name and age, the medicine and quantity, and the prescribing doctor. Veripres writes this entry for the pharmacy at the time of dispensing. The register belongs to the pharmacy, which can look at it later without asking you again, because the law requires it to keep the register.
• Veripres admin staff manage accounts, invitations and checks on professionals, and look into security reports. They see accounts, counts and security records. They never see clinical content, such as your visit notes, diagnoses, symptoms, documents or prescriptions.
• Our service providers host Veripres and deliver our SMS and email messages. They get only what they need for that job, and act on our instructions. Our Grievance Officer can give you a current list.
• Authorities. We share personal data with courts, regulators or the police only when the law requires it.

7. What we never collect

• We never ask for or store your Aadhaar number. No screen in Veripres asks for it. If a report you upload shows it, please cover it before uploading.
• We never receive or store your fingerprint or face. When you sign in with a passkey, your phone checks your fingerprint, face or screen lock itself. We receive only a public key. See the Passkey and Biometrics Notice.
• We do not collect payment details during the pilot.

8. How we keep your data safe

• Sharing needs your live approval each time: your Live QR, an approval or code, or an appointment you confirm.
• Your Live QR code changes every 30 seconds. Each code works only once and expires after 90 seconds.
• One-time codes go only to your own phone or email. They never appear on a clinic or pharmacy screen.
• Documents and images are encrypted when stored. When someone with access opens one, they get a link that expires after 60 seconds.
• Every access is written to an append-only access log: entries can be added, but not changed. You can see it the same day.
• Visit notes and signed prescriptions cannot be changed once finalised. Corrections are added next to the original.
• Each prescription carries the doctor's digital signature, so any change to it can be detected.
• Only doctors and pharmacies whose registration or licence we have checked can open records. Professionals sign in with a password, and doctors and pharmacists also with a passkey.
• Veripres admin staff never see clinical content.

No system is completely secure. If a breach affects your personal data, we will tell you without delay and report it to the authorities as the law requires.

9. Where your data is stored

We store your data in India. In the pilot's target setup, our database and file storage run on Supabase in its Mumbai region. During development we use a local database, also in India.

We do not plan to transfer your personal data outside India. If that changes, we will update this notice before it happens.

10. How long we keep it

These are our proposed defaults for the pilot. They are still to be confirmed by our legal advisers.

If you withdraw consent 1, your record is paused, not deleted. It stays paused until you turn consent 1 back on or ask us to delete your account.

We keep data for longer only if the law requires it, for example to comply with a court order.

11. Your rights

The Digital Personal Data Protection Act, 2023 gives you these rights. You can use most of them yourself, in the app.

See your data

You can see your whole record, every prescription and your full access log in the app at any time. You can also ask our Grievance Officer for a summary of the personal data we hold about you, how we use it, and who we have shared it with.

Correct or update it

You can ask us to correct, complete or update information about you. Write to our Grievance Officer. Visit notes and signed prescriptions cannot be edited. If you think something a doctor wrote is wrong, ask that doctor to add a correction. It will be shown with the original.

Delete it

You can ask us to delete your account in the Consent centre. We erase your record within 30 days, except the items in section 10 that we or a pharmacy must keep. Download your data first if you want a copy. After deletion, the QR codes on your old prescription PDFs will no longer show as valid.

Withdraw consent

You can withdraw any consent at any time in the Consent centre. It is as easy as giving it.

• Consent 2 off (doctors): all doctor access ends at once, including access for upcoming appointments, and no doctor can be given access. You can still book appointments.
• Consent 3 off (pharmacies): all pharmacy access ends at once, and no pharmacy can open your prescriptions through Veripres. You can still show your prescription PDF at any pharmacy.
• Consent 4 off (usage data): we leave your activity out of usage counts from then on.
• Consent 1 off (store my record): your record is paused. All sharing stops and nobody can be given access. Your data is not deleted unless you ask us to delete your account.

Withdrawing consent does not undo sharing that already happened. A doctor or pharmacy may already have noted what they saw.

Nominate someone

You can nominate a person to use your rights if you die or become unable to act. Write to our Grievance Officer with their name and contact details.

Complain

You can complain to our Grievance Officer about how we handle your personal data (section 15).

Before we act on a request, we may need to confirm that it comes from you.

12. Downloading your data

In the Consent centre you can download all your data at any time. You get a ZIP file with:

• a file in a standard format (JSON) holding your record, appointments, prescriptions, consents and access log; and
• a PDF of each prescription.

13. Children

A child is anyone under 18. A child's account must be set up and managed by a parent or lawful guardian, who gives the consents and uses the rights for the child. A child should not set up or manage an account alone. The same applies to an adult with a disability who has a lawful guardian.

Guardian accounts, which will let a parent or guardian manage a child's record from their own account, are planned but not yet available.

14. Response times

15. Grievance Officer

Our Grievance Officer handles complaints and answers questions about how we use your personal data.

• Name: Grievance Officer (to be appointed)
• Email: grievance@veripres.example
• Post: Grievance Officer, Obelisk Techno Solution Private Limited, registered office address to be added, Ahmedabad, Gujarat, India

When you write, include the mobile number or email address on your account, or your Veripres ID. Never send us a one-time code. The Grievance Officer page has more detail.

16. Data Protection Board of India

Please raise your complaint with our Grievance Officer first. The law asks you to do this. If you are not satisfied with our answer, or we do not answer within the times above, you can complain to the Data Protection Board of India.

The Board's complaint process applies once the relevant parts of the Digital Personal Data Protection Act, 2023 are in force, currently scheduled for May 2027. Until then, you can use the other remedies available under Indian law, including the Information Technology Act, 2000.

17. Your duties

The law also asks you to give true information, not to pretend to be someone else, and not to make false or frivolous complaints.

18. Changes and languages

We will update this notice when our practices change. Each version has a version number and date. If a change affects what we collect or why, we will tell you in the app before it takes effect, and ask for your consent again where needed.

This notice is in English. Hindi and Gujarati versions are planned. If you need it in another language listed in the Eighth Schedule to the Constitution of India, write to our Grievance Officer.