Privacy Notice

Version 3 · Effective 28 Sep 2026

1. About this notice

This notice explains how your personal data is handled when you use your clinic's booking assistant on Telegram: what is collected, why, who handles it, where it is kept, for how long, how it is protected, what happens if something goes wrong, and the rights you have over it, including how to withdraw consent and how to complain to the Data Protection Board of India.

"Your clinic" means the clinic whose Telegram bot you are using, which is named in the consent message the bot shows you before it does anything else. The clinic's name and its contact for questions about your data are in that consent message. This notice is the same for every clinic that uses the service.

This notice is written to meet the Digital Personal Data Protection Act, 2023 ("DPDP Act"), the Digital Personal Data Protection Rules, 2025 ("DPDP Rules"), the Information Technology Act, 2000 and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 ("SPDI Rules"), and other Indian law that applies. The DPDP Rules were notified on 13 November 2025, and most of the duties they place on those who hold personal data begin on 13 May 2027. Until then, section 43A of the Information Technology Act and the SPDI Rules continue to apply. The safeguards this notice describes are already in place.

The patients' Terms of Use, which explain how the booking service works, are a separate document: /terms/v3/

2. Who is responsible for your data

Your clinic is the Data Fiduciary. The clinic decides why your data is collected and how it is used, and it is answerable to you for it. Questions and requests about your data go to the clinic first.

Omvora Media & Automation provides the software, as the clinic's Data Processor. Omvora is a registered partnership firm at Hawal, Srinagar, Jammu & Kashmir 190011, India. It runs the booking, queue, reminder, payment and messaging software for the clinic. Omvora handles your data only on the clinic's instructions and only to provide this service. It does not decide what your data is used for, and it does not use your data for its own purposes.

The assistant tells you this in its first message: it is powered by Omvora and it acts for your clinic.

3. The assistant is automated

The assistant you chat with is software, not a doctor and not a member of clinic staff.

If a message you send contains words that suggest an emergency, the assistant does not try to handle it. It directs you to emergency help.

4. What personal data is collected

4.1 From you, through the chat

4.2 Created as you use the service

4.3 Recorded by the clinic

4.4 Health information is treated as sensitive

The reason for your visit, visit notes, observations, documents and prescriptions are health information. They are handled as sensitive personal data, with the stronger protections set out in section 12.

The only other sensitive personal data involved is payment information, and card and UPI details are entered with Easebuzz, not with the clinic or Omvora (section 11). The service has no passwords: it recognises you by your Telegram account.

4.5 If you choose not to give information

4.6 What is not collected

The assistant does not read your Telegram contacts, your location or your other chats, and it does not track you on other apps or websites.

5. Why your data is used

Purpose What it covers
Booking Creating, changing and cancelling your appointments
Queue Giving you a token and telling you your position
Reminders Messaging you before your appointment and about changes to it
Payment Taking consultation fees, confirming payment, and handling refunds
Your care Letting your treating doctor and the clinic staff involved in your visit see your record
Safety Recognising a message that suggests an emergency, or that the patient may be a child, and responding to it
Your rights Answering your access, correction, erasure, nomination and complaint requests
Security and records the law requires Protecting the service, keeping an audit trail, and keeping payment and medical records for the periods the law sets
Optional purposes Only the optional purposes you choose in section 6

Your data is not sold or rented, and it is not shared with anyone for their own marketing.

Lawful basis. The clinic relies on your consent for each purpose in section 6. Where the law itself requires a record to be kept, such as tax records or medical records, the clinic keeps it because the law requires it, even if you withdraw consent.

The DPDP Act also allows some uses without consent (section 7 of the Act). The clinic relies on them only here:

Use Ground under section 7 of the DPDP Act
Recognising a message that suggests a medical emergency and directing you to emergency help Responding to a medical emergency involving a threat to life or health (section 7(f))
Giving information that a law requires to be given to a government authority Fulfilling a legal obligation to disclose information to the State (section 7(d))
Complying with a court judgment, decree or order Compliance with a judgment or order (section 7(e))

5.1 What each item is used for

Personal data Used for
Name Booking, reminders, your record, and letting clinic staff recognise you
Telegram identifier and profile name Replying to you in the right chat, reminders, and identifying you when you use /privacy
Phone number Your record, and contacting you about your appointments
Reason for your visit Booking, and your doctor's care
Year of birth and preferred language Talking to you in your language, and your record
Messages and button taps Understanding what you want, and the safety checks in section 10
Appointment history, queue tokens Booking, the queue, reminders and your care
Payment records Taking fees, confirming payments and handling refunds; tax records
Visit notes, documents, prescriptions Your care by your doctor
Consent records Proving which consents you gave or withdrew
Rights requests, complaints and nominee details Answering your requests and complaints, and letting your nominee act for you

6. Consent

6.1 How you give it

Before the assistant books anything, it shows you a consent message that names your clinic, says what is collected and why, and links to this notice. You choose by tapping a button. Nothing is assumed from silence.

Consent is given separately for each purpose. The one consent the service needs is never bundled with the optional ones, and saying no to an optional consent never affects your care.

6.2 The consents you can give

Code Name What it allows Needed?
M0 Care & service Booking, reminders, payment, and your doctor's care Yes, the service cannot work without it
M1 Improve assistant Using de-identified information to improve the assistant. Your identifying details are removed first Optional
M2 Records transfer on referral If your doctor refers you to another clinic, carrying your details to that receiving clinic only. Your doctor is not paid for referring you Optional
M3 Over-the-counter product suggestions Receiving non-prescription skincare and product suggestions. These never replace your doctor's advice Optional
M4 Tips & offers Receiving tips and offers from the clinic Optional
M5 Research / aggregate insights Using de-identified information in anonymised research and aggregate insights about care. Anything that could identify you is removed first, and results are only shared as totals Optional

These six are the only consents offered. If the clinic ever wants to use your data for any other purpose, it will ask you for that separately first, and nothing changes until you say yes.

6.3 How you withdraw it

You can withdraw any consent at any time, as easily as you gave it:

Withdrawing an optional consent (M1 to M5) does not affect your care or your bookings in any way.

Withdrawing M0 (Care & service) ends the booking service for you: the assistant can no longer book, remind or manage appointments for you. Your records are then kept only for the periods the law requires (section 13). You can use the service again later by sending /start and giving consent again.

Withdrawal stops the processing from that point. It does not undo processing that was done lawfully before you withdrew. After you withdraw, the clinic stops the processing within a reasonable time and has Omvora stop it too, unless the law requires or allows it to continue.

No Consent Manager is used. You give, see and withdraw your consents directly in the chat.

6.4 Proof of consent

Each time you give or withdraw a consent, the clinic keeps a record of which consent it was, the time, how you did it, and the exact version of the text you were shown. You can see the current state of your consents at any time under /privacy.

7. AI and automated processing

7.1 What AI is used for

7.2 De-identification before any model

Before any text reaches any AI model, it passes through a de-identification check. Names (in English, Urdu, Kashmiri and Hindi scripts), phone numbers, email addresses, links and identifying numbers are removed and replaced with neutral markers. The service refuses to send text to a model if this check has not been applied. The link between the markers and your real details stays on Omvora's server and is never sent to a model.

7.3 Which models are used

Model provider Where it runs Used for
OpenAI United States Understanding reception messages
NVIDIA NIM NVIDIA's cloud service Understanding reception messages
A model on Omvora's own server Srinagar, India Reception and doctor recaps

Only de-identified text is sent to OpenAI and NVIDIA. Every call to a model is recorded in the audit trail.

7.4 People make the decisions

AI never diagnoses, prescribes or decides anything about your care. Your doctor and the clinic staff make every decision. What the models produce is checked by the software before you see it, and a person is always available: send /agent.

8. Who can see your data, and who receives it

8.1 Inside your clinic

Only clinic staff involved in your care or your appointment can see your record, and each staff member sees only what their role needs. Every time someone opens a patient record, it is recorded in the audit trail.

8.2 Other clinics

Each clinic's data is kept apart from every other clinic's data. A clinic using this software cannot see another clinic's patients. Your details go to another clinic only if you have given consent M2 and your doctor refers you there, and then only to the receiving clinic.

8.3 Omvora

Omvora, as the clinic's Data Processor, handles your data to run, secure, back up and support the service, on the clinic's instructions.

8.4 Service providers

Provider What it does What it receives
Telegram (Telegram Messenger Inc.) Carries messages between you and the assistant Your messages and the assistant's replies. Telegram's servers are outside India, and Telegram's own privacy policy applies to your use of the Telegram app
Cloudflare Network security and delivery in front of Omvora's server Network information such as IP addresses and request times, to deliver and protect the connection
Easebuzz Payment processing The details you enter on the payment page to pay, and the payment amount and reference
OpenAI AI model for reception messages De-identified text only
NVIDIA (NIM) AI model for reception messages De-identified text only
Google (Google Drive) Storage for one copy of the backups Backups that are encrypted before they leave Omvora's server

8.5 When the law requires it

Your data may be disclosed where a law, a court order or a lawful authority requires it: for example to a court or tribunal, the Data Protection Board of India, CERT-In, a law-enforcement or investigating agency, or a tax authority. Only what is required is disclosed, and you will be told unless the law forbids it.

8.6 Who does not receive your data

Your data is not given to advertisers, data brokers or insurers, and it is not sold.

9. Where your data is stored

Where Indian law places conditions on processing data outside India, the clinic and Omvora follow them. Your data is not sent to any country to which the Central Government has restricted transfers under section 16 of the DPDP Act, and any requirement the Central Government sets under rule 15 of the DPDP Rules is met. Data processed outside India may also be subject to the laws of the country where it is processed.

10. Safety checks, children and emergencies

10.1 Emergencies

The assistant checks every message for words that suggest an emergency, such as chest pain, difficulty breathing, severe bleeding, loss of consciousness, poisoning or thoughts of self-harm. When it sees them, it stops and tells you to call 112 (India's emergency number) or 108 for an ambulance, or to go to the nearest hospital, and offers you a person at the clinic. This check does not replace calling for help: in an emergency, call 112 straight away.

10.2 Children

The assistant books appointments for adults. If a message suggests that the appointment is for a child, the assistant does not book it by itself: it asks the parent or guardian to arrange the appointment with the clinic's staff, and offers Talk to the clinic. The clinic's staff make the booking with the parent or guardian, who gives consent on the child's behalf.

A child's data is not used for tracking, behavioural monitoring or advertising directed at children.

If you are the lawful guardian of an adult with a disability who cannot consent for themselves, you give consent on their behalf. As with a child, the booking is arranged with the clinic's staff, who may ask to see the order of the court, designated authority or local level committee that appointed you, as the DPDP Rules require.

11. Payments

Easebuzz is the only payment provider used by the service. When you pay, you enter your card or UPI details on Easebuzz's payment page. Easebuzz processes those details. Neither the clinic nor Omvora stores your card number.

Your clinic is the merchant: your payment goes to the clinic, not to Omvora. The clinic and Omvora see the amount, the status of the payment and the payment reference, which are kept as payment records (section 13).

12. How your data is protected

These are the safeguards the DPDP Rules require as a minimum (rule 6), and they follow a documented security programme with managerial, technical, operational and physical controls, as the SPDI Rules describe (rule 8).

No system connected to the internet can be guaranteed to be completely secure. Section 16 explains what happens if something goes wrong.

13. How long your data is kept

Each kind of data has its own period, and data is not kept just because it might be useful one day. When a period ends, the data is deleted automatically, unless a legal hold applies (for instance, where a dispute or legal case needs it).

Data How long it is kept Why
Clinical records: visit notes, observations, documents, and prescriptions where the clinic records them 3 years from your last appointment Medical record norms, and the period in which a complaint can be brought under the Consumer Protection Act, 2019
Appointments and queue records 3 years Matched to the clinical records
Audit trail 3 years To show who accessed your records and what was done
Identifiers: your name, phone number and Telegram identifier 3 years, matched to the clinical records So the records above can be linked to you while they are kept
Payment, invoice and tax records For the minimum period Indian GST and income-tax law require. Under section 36 of the Central Goods and Services Tax Act, 2017, this is 72 months from the due date of the annual return for the year concerned Tax law
Processing and traffic logs, and the record used to detect duplicate messages 1 year The minimum the DPDP Rules require for logs
Rejected calls to the payment gateway 90 days Security and fraud checks
Consent records For as long as they are needed to show that consent was given or withdrawn Proof of consent
Your nominee's details No longer than your own records They exist only to act for you

You are told before scheduled deletion. Before records reach the end of their period, the assistant sends you a message listing what is due to be deleted and when. You do not need to do anything. If you want the clinic to keep those records, tap Keep my records and they will not be deleted on that date.

When records are deleted, the copies Omvora holds for the clinic are deleted too. Encrypted backups are replaced on their own schedule, so a deleted record leaves the backups when the backups that contain it expire.

14. Your rights

You have these rights over your personal data. Using them is free.

Right What it means
Access A summary of the data held about you, how it is used, and who it has been shared with
A copy of your records A list of your records in the chat, and a complete machine-readable copy from the clinic on request
Correction and updating Fixing details that are wrong, incomplete or out of date
Erasure Deleting your data, except records the law requires the clinic to keep
Withdrawing consent Stopping any consent at any time (section 6.3)
Nomination Naming someone to use these rights for you if you die or become unable to use them
Grievance Complaining about how your data is handled, and getting an answer

14.1 How to use your rights: /privacy

Send /privacy in the chat. It opens a menu that answers most requests straight away:

Button What it does
View my data Shows a summary: your record reference; how many appointments, visits, records, documents and prescriptions are held; the state of each consent; who your data has been shared with; and the date until which medical records are kept
My records Lists the records held about you. A complete machine-readable copy (in the FHIR health-record format) is available from the clinic on request within 30 days
Correct details Lets you correct your name, phone number, year of birth or preferred language. Some changes apply at once; others are checked by the clinic first, and you are told the date by which it will be done and the outcome
Erase my data Explains what erasure does, then asks you to confirm with a one-time code before anything is deleted
Raise a complaint Registers a complaint, gives you a reference, and tells you when it will be acknowledged and resolved
My complaints Shows your complaints, their status and their outcome
Nominate someone Lets you name or remove a nominee
My consents Shows each consent and lets you withdraw it

You can also contact your clinic directly, using the contact given in the consent message in the chat. For anything about how Omvora handles your data as the clinic's processor, you can write to Omvora's Grievance Officer (section 15).

The clinic may ask for reasonable information to confirm that a request really comes from you or your nominee. It will not ask for more than it needs. In the chat, your Telegram account identifies you. Outside the chat, give your name, your phone number and, if you have it, your record reference, which View my data shows.

How long requests take. Most requests under /privacy are answered at once. A complaint is acknowledged within 2 working days and resolved within 30 days of receipt (section 15). This is within the ninety days the DPDP Rules allow.

14.2 Erasure

When you confirm erasure:

When erasure is done, the assistant tells you exactly which records have been kept and that they are kept for the period the law requires. After erasure, the assistant can no longer serve you at that clinic. If a legal hold applies to your record, erasure waits, and the clinic contacts you about it.

14.3 Nominee

You can name one person to use your rights for you if you die or become unable to use them yourself. Send /privacy, tap Nominate someone, and reply with their name and phone number, and their relationship to you if you wish. Naming someone new replaces the previous nominee, and you can remove your nominee at any time from the same menu.

A nominee can act on all of your rights. The system can also record a nominee who may act only on access, or only on erasure; ask your clinic if you want your nominee limited in either way.

14.4 Your duties

The DPDP Act (section 15) asks you, when you use these rights, to:

15. Complaints

Step 1: your clinic. Raise a complaint through /privacy (Raise a complaint), or contact your clinic using the contact given in the consent message in the chat. Your complaint gets a reference. It is acknowledged within 2 working days and resolved within 30 days of receipt.

Step 2: Omvora's Grievance Officer. If the clinic has not resolved your complaint, or it concerns how Omvora handles your data as the clinic's processor, write to:

Grievance Officer: Mr Mujtaba Mirza Omvora Media & Automation Hawal, Srinagar, Jammu & Kashmir 190011, India Email: privacy@omvoramedia.com Phone: +91 90040 22222 Hours: Monday to Saturday, 10 am to 7 pm IST

Omvora acknowledges a grievance within 2 working days and resolves it within 30 days of receipt, within the one month the SPDI Rules require. Where the matter is the clinic's to decide, Omvora passes it to the clinic without delay and tells you it has done so. A grievance emailed to privacy@omvoramedia.com gets a reference number automatically; quote it, or the reference the chat gave you, to follow up.

Every complaint is handled fairly, courteously and on time, and the answer tells you how to take the matter further if you are not satisfied.

Step 3: the Data Protection Board of India. If your grievance remains unresolved, or you are not satisfied with the answer, you may complain to the Data Protection Board of India, the body the DPDP Act sets up to enforce it, in the manner the Board prescribes. The Act requires a grievance to be raised with the Data Fiduciary (your clinic) first. The Board works as a digital office, so a complaint to it is made online. No consent you give can take away your right to complain to the Board.

16. If there is a data breach

If a personal data breach happens:

  1. it is recorded, contained and investigated at once;
  2. Omvora, as processor, informs your clinic without delay;
  3. you are told without delay, in plain language, in the chat or through another contact you gave: what happened, when and how widely, what data was involved, the likely consequences, what is being done about it, what you can do to protect yourself, and whom to contact;
  4. the Data Protection Board of India is informed without delay and given a detailed report within 72 hours, or any longer time the Board allows, as the DPDP Act and Rules require; and
  5. cyber-security incidents that must be reported to CERT-In are reported within 6 hours of being noticed, as CERT-In's directions require.

17. Languages and accessibility

This notice is written in plain English. The chat, including the /privacy menu and the consent message, is plain text that a screen reader can read aloud. If you need this notice in another language listed in the Eighth Schedule to the Constitution of India, or in another format you can use, ask your clinic, or write to privacy@omvoramedia.com.

18. Changes to this notice

This is version 3. Each version is published at its own permanent address and is never edited after it is published, so you can always see the exact notice that applied when you gave consent. A change is published as a new version with a new effective date. Version 3 corrects how the cf_clearance security cookie is described (section 19): Cloudflare adds a small bot-detection script to each page, and this cookie holds its result. Version 2 was published on 28 September 2026.

A new version is published here before it takes effect, and the consent message in the chat always links to the version in force. If a change adds a new purpose, you are asked for consent to it separately, and a consent you gave under an earlier version covers only the purposes that version named.

19. Cookies and these web pages

The booking assistant runs inside Telegram. It sets no cookies and stores nothing in your browser.

This notice and the Terms of Use are published as static web pages served by Cloudflare. The pages themselves store nothing in your browser and use no analytics and no advertising. Cloudflare, which protects them, may set its own security cookies:

Name Set by Type Category Purpose How long Needs your consent?
__cf_bm Cloudflare Cookie Strictly necessary Bot management: tells people from automated traffic, to keep the pages available. Set only when Cloudflare needs it About 30 minutes No
cf_clearance Cloudflare Cookie Strictly necessary Holds the result of Cloudflare's bot detection: Cloudflare adds a small script to each page it serves, and when that script runs in your browser, this cookie records the outcome. Also set when Cloudflare checks a visitor, and for every visitor while the pages are under attack and its "under attack" protection is on Set by Cloudflare No

Nothing on these pages needs your consent. Your browser's settings let you block or delete cookies; if you block these, Cloudflare may check your browser more often, and while the pages are under attack it may not be able to let you in.

The pages do not track you, so a browser's "Do Not Track" signal changes nothing on them.

20. Links to other services

The chat and these pages link to services run by others, such as Telegram and Easebuzz's payment page. They have their own terms and privacy policies, which apply when you use them. This notice covers only what your clinic and Omvora do with your data.

21. Protect yourself from people pretending to be the clinic

Neither your clinic nor Omvora will ever ask you, in the chat, by message or by telephone, for your card number, CVV, UPI PIN, a one-time password or a bank password. They do not call or message patients offering prizes, free gifts or lucky-draw rewards. Pay only through the Easebuzz link the assistant gives you.

If someone asks you for any of these while claiming to be your clinic, the assistant or Omvora, do not reply or pay. Tell your clinic (send /agent) or write to privacy@omvoramedia.com. If you have lost money, contact your bank and the national cyber-crime helpline 1930 or cybercrime.gov.in straight away.

22. Contact

Your clinic (Data Fiduciary): the name and contact given in the consent message in the chat. In the chat, send /privacy for your data and /agent to reach a person.

Omvora Media & Automation (Data Processor): Hawal, Srinagar, Jammu & Kashmir 190011, India. Privacy and grievances: privacy@omvoramedia.com (Grievance Officer: Mr Mujtaba Mirza). Phone: +91 90040 22222. Hours: Monday to Saturday, 10 am to 7 pm IST.

This notice: /v3/ Terms of Use: /terms/v3/