Privacy Policy – divergenthealthcare.in

PRIVACY POLICY Divergent Healthcare Pvt. Ltd.

Last Updated: April 2026

I. INTRODUCTION

Divergent Healthcare Pvt. Ltd. (“Divergent Healthcare”

“we”,”our”, or “us”) respects the privacy of individuals and is committed to protecting your personal data and respecting your privacy. This Privacy Policy details our practices concerning the collection, use, disclosure, and protection of your personal data when you interact with our services, products, and digital platforms. We take reasonable precautions to protect your Personal Information and Sensitive Personal Data or Information (“SPDI”) (together referred to as “Information”) and comply with all legal, regulatory, and contractual obligations related to data privacy. This Privacy Policy has been drafted to ensure compliance with the Information Technology Act, 2000 – Section 43A, the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, and other applicable laws of India.

II. DEFINITIONS

For the purposes of this Privacy Policy, the following terms shall have the meanings as defined under applicable laws:

“Body Corporate” means any company and includes a firm, sole proprietorship or other association of individuals engaged in commercial or professional activities as defined under the Information Technology Act, 2000.

“Personal Data” means 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.

“Sensitive Personal Data or Information (SPDI)” means personal information which consists of information relating to passwords, financial information, health condition, sexual orientation, medical records and history, and biometric information.

“Biometrics” means technologies that measure and analyze human body characteristics such as fingerprints, eye retinas and irises, voice patterns, facial patterns, hand measurements, and DNA for authentication purposes.

“Provider of Information” means persons who provide sensitive personal data or information to a body corporate.

III. SCOPE AND APPLICABILITY

This Policy applies to all personal information and Sensitive Personal Data or Information collected and processed by Divergent Healthcare Pvt. Ltd. through:

Our website(s), mobile application(s), or any other digital platform
Communications with Divergent Healthcare representatives
Business relationships with Divergent Healthcare
Offline interactions with customers, patients, and business partners
Participation in events, conferences, and other professional settings

Divergent Healthcare operates nationally across India. By accessing our website(s), mobile application(s), or any other digital platform and/or by providing your Information to us, you consent to the terms of this Privacy Policy and the processing of your Information as described herein.

IV. INFORMATION WE COLLECT

Sensitive Personal Data or Information (SPDI) collected may include:

Passwords
Financial information such as bank account, credit card, debit card, or other payment
instrument details
Physical, physiological, and mental health condition
Sexual orientation
Medical records and history
Biometric information
Any detail relating to the above categories as provided to Divergent Healthcare for rendering services

Personal Information collected may include:

Identity Data: Full name, personal contact numbers, residential address, email address, gender, and date of birth
Technical Data: Internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on devices used to access our platforms
Usage Data: Information about how you use our website(s), mobile application(s), or other digital platforms, products, and services
Marketing & Communications Data: Your preferences for receiving marketing communications from us
Audio & Visual Information: Recordings from video conferences or calls
Geolocation Data: Precise location data from mobile devices or applications

For healthcare professionals, we may additionally collect:

Professional role(s) and qualifications
Specialty and employer information
Professional experience and publications
Information about prescribing practices (aggregated and de-identified)
Other profession-related information

Please note that any information freely available or accessible in the public domain or furnished under the Right to Information Act, 2005, or any other law for the time being in force shall not be regarded as SPDI.

V. HOW WE COLLECT INFORMATION

We collect Information through various methods:

Direct Interactions: When you voluntarily provide information through forms, registrations, surveys, or correspondence
Automated Technologies: Through cookies, server logs, web beacons, pixels, and similar technologies
Third-Party Sources: Including public databases, demographic data providers, joint marketing partners, professional organizations, and social media platforms
Events & Professional Settings: Through our interactions at conferences, health camps, and other professional settings

VI. PURPOSES FOR INFORMATION COLLECTION AND PROCESSING

Divergent Healthcare collects and uses Information for legitimate business purposes, including but not limited to:

To enable visitors of our digital platforms to access information, products, and features
To provide information or interactive services through our website(s) and mobile application(s)
To seek feedback or contact visitors regarding services offered
To process orders or applications submitted by visitors
To administer or fulfill obligations in relation to any agreement with Divergent Healthcare
To anticipate and resolve problems with goods or services supplied
To create products or services that may meet visitors’ needs
To process and respond to requests, improve operations, and communicate about our products and services
To comply with regulatory, tax, and pharmacovigilance requirements
To respond to government information requests
To manage medical inquiries and quality-related matters
To fulfill transparency and disclosure obligations
To detect, investigate, and prevent fraudulent transactions and other illegal activities
For responding to a medical emergency involving a threat to life or immediate threat to health

Divergent Healthcare shall collect only the minimum Information required to meet the purposes mentioned in this policy.

VII. LEGAL BASIS FOR PROCESSING

We process your personal information on the following legal bases:

Consent: We will seek your free, specific, informed, and unambiguous consent before processing SPDI. You have the right to withdraw consent at any time, after which we will cease processing unless legally required.
Contract: Where processing is necessary for the performance of a contract with you or to take steps at your request before entering into a contract.
Legal Obligation: Where processing is required to comply with applicable laws, court orders, or regulatory requirements.
Vital Interests: Where processing is necessary to protect the vital interests of you or another natural person.
Legitimate Interests: Where processing is necessary for our legitimate business interests, provided your fundamental rights and freedoms do not override those interests.

VIII. SPECIAL PROVISIONS REGARDING CONSENT

We adhere to the following principles regarding consent:

Consent shall be considered given by any lawful method including checking a box, clicking an “I Agree” button, or signing a form
You have the right to withdraw your consent at any time
All requests for consent shall be presented in clear and plain language

IX. COLLECTION NOTICE REQUIREMENTS

Divergent Healthcare shall not collect sensitive personal data or information unless:

The information is collected for a lawful purpose connected with a function or activity of Divergent Healthcare
The collection is considered necessary for that purpose

We shall ensure that individuals are made aware of:

The fact that information is being collected
The purpose for which the information is being collected
The intended recipients of the information
The name and address of the agency collecting and retaining the information

Divergent Healthcare shall not retain SPDI for longer than is required for the purposes for which it was lawfully collected or as required under any applicable law.

X. SPECIAL PROVISIONS FOR CHILDREN'S DATA

Divergent Healthcare shall:

Not knowingly collect personal information online from a child under the age of 13 without obtaining prior parental consent
Obtain verifiable parental consent before processing any personal data of children
Not undertake tracking, behavioral monitoring, or targeted advertising directed at children

XI. INFORMATION SECURITY

Divergent Healthcare has implemented appropriate technical, administrative, and physical safeguards to protect the security of your Information in accordance with IS/ISO/IEC standards and approved best practices for data protection.

Our security measures include:

Documented information security policies with managerial, technical, operational, and physical controls
Comprehensive security procedures aligned with IS/ISO/IEC standards on Information Security Management Systems
Regular review and updates to security measures to meet evolving business and regulatory needs
Encryption of sensitive information during transmission
Access controls to limit access to Information on a need-to-know basis
Security incident management procedures
Regular security audits and assessments by an independent auditor at least once a year
Employee training on data security and privacy

In the event of a security incident, we will promptly investigate and, as required by law, report specific cyber security incidents to the Indian Computer Emergency Response Team (CERT-In) within the stipulated timelines. Affected individuals will be notified if a data breach is likely to cause them harm.

Despite our best efforts, no organization can guarantee absolute security of information transmitted over the Internet. We are not responsible for the circumvention of any privacy settings or security measures on our website.

XII. INFORMATION SHARING AND DISCLOSURE

Divergent Healthcare shall not use or disclose Information for purposes other than those

stated in this policy, except with your consent or as required by law. SPDI may be disclosed without prior consent in the following circumstances:

When disclosure is required by government agencies mandated by law for verification, prevention, detection, investigation, prosecution, or punishment of offences
When disclosure is made pursuant to a lawful contract between Divergent Healthcare and the provider of information
When disclosure is necessary for compliance with a legal obligation

We may share your Information with:

Other group companies and affiliates for the purposes identified in this Privacy Policy
Service providers and business partners who are contractually obligated to use data per our specifications
Government authorities and regulatory agencies, if required by law
Third parties in connection with a corporate transaction such as a merger, acquisition, or sale of assets

When sharing Information, Divergent Healthcare shall ensure that the receiving party has adopted reasonable and equivalent security practices, and that appropriate contractual provisions are in place for adequate protection of personal data.

XIII. INTERNATIONAL DATA TRANSFERS

The personal data we collect may be stored, accessed, or processed in countries where we maintain operations or engage service providers. When transferring personal data internationally, we ensure appropriate safeguards are in place to comply with applicable Indian data protection laws.

Divergent Healthcare may transfer SPDI to any body corporate or person in India or located in any other country only if such transfer is necessary for the performance of a lawful contract or where the individual has consented to the transfer, and the recipient ensures the same level of data protection as provided under applicable Indian law.

XIV. COOKIES AND SIMILAR TECHNOLOGIES

Our website may use cookies and similar technologies to enhance user experience, analyze website usage, and personalize content. These technologies may collect information such as your IP address, browser type, operating system, referring URLs, device information, and browsing activity. For more detailed information about the cookies we use, please refer to our Cookie Policy.

XV. TARGETED MARKETING

To communicate effectively with individuals interested in our company and health awareness campaigns, we may engage in targeted or interest-based marketing.

Our Approach:

Our targeted marketing practices are limited to our general audience websites and digital campaigns. We use information such as your general location and browsing activity on our public platforms to present advertisements that may be more relevant to your interests.

We do not use SPDI for targeted marketing. We do not use any information provided through our secure programmes or portals that could imply a specific health condition for the purposes of targeted marketing.

Your Choices:

You may opt out of interest-based advertising through the Digital Advertising Alliance (DAA) or Network Advertising Initiative (NAI)
You may modify your browser settings to block or delete cookies
You may use your mobile device’s privacy settings to limit the use of information for targeted advertising
You may contact us directly to opt out

Please note that opting out does not mean you will no longer see our advertisements — it means those ads will not be tailored based on your past browsing activity.

XVI. YOUR RIGHTS

You have the following rights regarding your personal information:

Right to Access: The right to review or amend the information provided to Divergent Healthcare
Right to Correction: The right to correct any inaccuracies in the information held about you
Right to Opt-Out: The right to opt-out of providing information at any point while availing our services
Right to Withdraw Consent: The right to withdraw consent at any time for processing based on consent Depending on your location and applicable laws, you may also have:
Right to Erasure: The right to request deletion of your personal data in certain circumstances
Right to Object: The right to oppose processing based on legitimate interests or for direct marketing
Right to Restriction: The right to request restriction of processing in specific situations
Right to Data Portability: The right to request transfer of your data to another organization in a structured, commonly used, and machine-readable format

To exercise any of these rights, please contact us using the details provided in the “Contact Us” section below.

XVII. GRIEVANCE REDRESSAL MECHANISM

Divergent Healthcare has designated a Grievance Officer to address any discrepancies and grievances with respect to the processing of your Information. The Grievance Officer shall redress grievances expeditiously but within one month from the date of receipt of the grievance. Contact details are provided in the “Contact Us” section below.

XVIII. RETENTION PERIOD

Divergent Healthcare shall not retain SPDI for longer than is required for the purposes for which it was lawfully collected, or as otherwise required under any applicable law. Thecriteria used to determine retention periods include the duration of our ongoing relationship with you, legal obligations, relevant statutes of limitations, and the period for which the personal data is required to serve the purpose for which it was collected. Once personal data is no longer necessary, it will be securely deleted or anonymized in accordance with our internal data retention policies.

XIX. CHANGES TO THIS PRIVACY POLICY

Divergent Healthcare may update this Privacy Policy from time to time. When material changes are made, we will notify you by posting the updated policy on our website with a new effective date. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your Information.

XX. CONTACT US

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at: Divergent Healthcare Pvt. Ltd. Corporate Office: Plot No. 72, Bapu Nagar, Nagpur, Maharashtra – 440009

Registered Office: B30, Galaxy City Phase 1, Amrawad Khurd, Awadhpuri, Bhopal, Madhya Pradesh

Phone: +91 99770 55280

Email:contact@divergenthealthcare.in

For grievances related to your personal data, please contact our Grievance Officer at the address above or write to us at: contact@divergenthealthcare.in