PRIVACY POLICY
PaxEM Health Platform
Future Path Health Private Limited
Effective Date: 6 November 2026 | Version: 1.1
OUR COMMITMENTS TO YOU
Before you read this policy, here is what matters most:
We do not sell your personal data. Ever.
We do not share your Health Score or health data with any insurer for underwriting or eligibility purposes.
We do not use your health data, diagnoses, or medical history to target advertisements at you.
We do not record your video consultations. The only audio we ever record is when your doctor starts the Medical Scribe feature during a consultation, which requires your consent — see Clause 9.6.
Where AI features process your data through a third-party provider located outside India, we tell you exactly who that is, what they receive, and what they do with it.
You can access, correct, and delete your data at any time.
If you have a concern, our Grievance Officer will respond within 48 hours.
PLAIN LANGUAGE SUMMARY
We collect your personal and health data to connect you with doctors, store your medical records, process payments, send you relevant notifications, and improve the Platform. We share data only with the specific vendors named in this policy, with doctors you consult, and with authorities as required by law. For certain features, including health Data storage, AI features, and the Health Score, we ask for your separate, specific consent through our Consent for Collection of Health Data document, in addition to this policy. Our Grievance Officer is reachable at all times at the contact details in Clause 20.
1. DEFINITIONS
1.1 "Data Fiduciary" A person who alone or in conjunction with others determines the purpose and means of processing personal data, as defined under the DPDP Act. PaxEM is the Data Fiduciary for personal data collected through the Platform.
1.2 "Data Principal" - The natural person to whom personal data relates. You are the Data Principal in respect of your own personal data.
1.3 "Data Processor" -A person who processes personal data on behalf of a Data Fiduciary, under the instruction of the Data Fiduciary.
1.4 "Data Protection Board of India" -The statutory authority established under the DPDP Act to adjudicate complaints and enforce data-protection obligations.
1.5 "Personal Data" -Any data about an individual who is identifiable by or in relation to such data.
1.6 "Processing" - Any operation performed on personal data, including collection, storage, use, sharing, alteration, and deletion.
1.7 "Sensitive Personal Data" -Personal data that is sensitive in nature, including health and medical data, financial data, and biometric data, as defined under the SPDI Rules and the DPDP Act.
1.8 "Significant Data Fiduciary (SDF)"- A Data Fiduciary notified by the Central Government as such under the DPDP Act on the basis of the volume and sensitivity of personal data processed and such other criteria as specified.
1.9 "Sub-processor" - A third party engaged by a Data Processor to process personal data on behalf of the Data Fiduciary.
2. ABOUT THIS POLICY
2.1. Future Path Health Private Limited ("PaxEM", "we", "us", "our") is committed to protecting the privacy and security of your personal data. This Privacy Policy ("Policy") explains what personal data we collect from you, why we collect it, how we use it, who we share it with, how long we keep it, and what rights you have over it, when you use the PaxEM Health platform comprising the mobile application "PaxEM Health," the website(s) www.paxem.health & www.paxemhealth.com & www.paxemhealth.ai etc., and all related services ("Platform").
2.2. This Policy applies specifically to patients and end-users of the PaxEM Health application. Registered medical practitioners using PaxEM Docs are separately governed by the Doctor Onboarding Agreement and the PaxEM Docs Terms and Conditions.
2.3. This Policy is to be read together with PaxEM's Terms and Conditions, Cookie Policy (for users of the website version of the Platform), Telemedicine Consent and Medical Disclaimer, and Consent for Collection of Health Data (together, the "Platform Policies"). Where those documents contain provisions specific to a particular feature or data category, those provisions apply in addition to this Policy. In the event of a conflict between this Policy and the remaining Platform Policies on a matter specifically addressed by that Platform Policy, such Platform Policy shall prevail to the extent of that conflict.
2.4. This Policy is framed in accordance with the Digital Personal Data Protection Act, 2023 ("DPDP Act"), the Information Technology Act, 2000 ("IT Act"), the Telemedicine Practice Guidelines, 2020, and the Consumer Protection Act, 2019.
2.5. PaxEM is incorporated under the Companies Act, 2013, bearing CIN U86909TS2026PTC214451, with its registered office at 1-89/24, Plot 6A, Durgam Cheruvu Road, RBI Colony, Phase 2, Kavuri Hills, Hitech City, Hyderabad – 500081, Telangana. PaxEM is the Data Fiduciary in respect of all personal data processed through the Platform.
2.6. Purpose Limitation Commitment. PaxEM shall collect and process your personal data solely for the purposes for which it was originally obtained, as described herein and in the Platform Policies, and will not process such information for any other purposes without your specific, informed, and explicit consent. In the event PaxEM seeks to process your personal data for a different purpose, PaxEM shall notify you of its intention to do so, inform you of that new purpose, and secure your consent before doing so. This requirement applies to all types of personal information, including but not limited to health information, financial information, and account information, subject always to Applicable Law.
2.7. Post-Termination. This Policy continues to apply to any personal data we retain after your account is closed or terminated, for the retention periods described in Clause 15. Closing your account does not automatically result in the deletion of all data. Some data is retained as required by Applicable Law and as described in Clause 15.
2.8. Future Features. When PaxEM introduces new features involving new categories of data collection or new data-sharing arrangements (including, without limitation, the planned pharmacy, medical finance, diagnostic lab, and hospital integrations), this Policy will be updated before those features go live.
3. WHO THIS POLICY APPLIES TO
3.1. This Policy applies if you:
(a) create or use a PaxEM Health patient account;
(b) are listed as a family member by a registered user (see Clause 12 for specific provisions about family member data);
(c) visit any of our websites without creating an account; or
(d) contact us for support, feedback, or any other purpose.
3.2. The Platform is intended for users who are at least 18 years of age. We do not knowingly collect personal data from minors.
3.3. Registered medical practitioners accessing the Platform through PaxEM Docs are separately governed by the Doctor Onboarding Agreement and the PaxEM Docs data terms. This Policy does not apply to them in that capacity.
4. WHAT PERSONAL DATA WE COLLECT AND WHY
Data that is collected have both Mandatory and Optional requirements. Data is collected specifically for the purposes mentioned herein:
4.1. Upon registration, the following Data shall be collected solely for the purposes described below:
a. Mobile phone number. Used to create and verify your account thorough OTP as your primary account identifier.
b. Email address. Used to send you service communications, receipts, and policy updates.
c. Full Name. Used to personalise your experience and to appear on prescriptions and records associated with your account.
d. Age/Date of Birth and Gender. Required to display your profile to treating doctors, and to calculate your Health Score if you use that feature.
e. Location. Used to show you available doctors near your location and to remember your city preference across sessions.
f. Payment information. Provided when you pay for a consultation or subscription. Includes the amount paid, transaction reference, and payment method type. We do not collect or store your card number, UPI PIN, CVV, or bank account credentials. These are handled entirely within Razorpay's PCI-DSS-compliant environment and are never transmitted to or stored on PaxEM's servers.
Data taken while using the Platform.
4.2. While the Platform is in use, you may optionally provide the following Data which Pax EM shall collect and process solely for the purposes described herein:
a) Health and medical data. Includes prescriptions, diagnostic and laboratory reports, discharge summaries, vaccination records, and general health history that you choose to upload to your Health Wallet, as well as symptoms, health complaints, and other health information provided by you. This is sensitive personal data and is handled with additional protections described in Clause 7. Specific consent for this data is obtained through our separate Consent for Collection of Health Data.
b) Health metrics/fitness Data. It may be provided only if you use the Health Score feature. Includes biometrics such as heart rate, step count, sleep data, and other metrics synced from a third-party health application you specifically authorise. We do not independently access your device's sensors.
c) Insurance information. It may be provided only if you use the Insurance Assist feature. Includes your existing insurer name and cover amount, if you choose to enter this when using the insurance flow. This information is stored in your account solely to display it back to you and to your treating doctor during a consultation if a doctor uses the Insurance Assist feature to help you. It is not shared with any insurer for underwriting or eligibility-assessment purposes.
d) Lab test orders. It gets generated when your doctor orders a lab test during a consultation. Includes the name of the test ordered, the ordering doctor's details, and the date of the order. This data is stored in your Health Wallet under "Lab Orders" and is used to display your ordered tests to you.
e) Review and rating content. It may be provided after a completed consultation. Includes your written review and star rating for a doctor. By submitting a review, you grant PaxEM a non-exclusive, royalty-free, perpetual licence to display and publish that review on the Platform.
f) Support Communications. Provided when you contact our support team. Includes the content of your message, the email address or number from which you contact us, and any attachments you share. Used to resolve your query and to improve support quality.
g) Health Courses Engagement Data. It gets generated when you access the Health Courses feature. It includes the courses you viewed and your engagement time. For PaxEM's own free wellness content, this data is used only for in-house analytics and product improvement, in anonymised form where reasonably practicable. For third-party paid courses accessed through the Platform, engagement data may be shared with the relevant course provider to facilitate access and track completion. We will identify the specific third-party provider and the data shared at the point you access any such paid course, before you enrol.
4.3. Data Related to Your Account Security Features
a. MPIN Used for authentication on subsequent logins. Your MPIN is stored in hashed form and is never stored or readable in plain text by PaxEM.
b. Two-factor authentication Data. Where you enable this, we store the cryptographic binding between your account and your chosen Two-factor authentication method (mobile OTP). No Two-factor authentication encryption or token is stored in recoverable form.
c. Active session records. When you log in, we create a session record that includes your login timestamp, device identifier, device type, and IP address. This is used to power the "Active Sessions" view in your security settings, which allows you to see and terminate sessions across devices. Session records are retained for 30 (thirty) days after session expiry or logout. You may view and terminate active sessions at any time through the Security settings in your account.
4.4. Data We Collect Automatically
a. Device and technical data. This is collected when you access the Platform. It Includes your device type, operating system version, app version, device identifier, and mobile network information. It shall be used for troubleshooting, security, and compatibility.
b. Usage and behavioural data (profiling). This includes features accessed, doctor and specialisation searches, pages viewed, time spent, buttons tapped, and in-app navigation paths. This data constitutes a behavioural profile of your use of the Platform. It is used solely for in-house analytics and product improvement. We do not share this data with third-party analytics providers. Health-related behavioural data (for example, the specialisations you search for or the health content you view) is included in these analytics, and is analysed in aggregate form where reasonably practicable to reduce the risk of individual identification. You may contact our Grievance Officer to opt out of behavioural analytics. Opting out will not affect your ability to use the Platform but will mean your usage data is excluded from our analytics.
c. Session and login data. This is collected at login and shall include your login timestamp, session duration, and IP address. Its purpose lies for security, fraud detection, and session management.
d. Risk Assessment data. This is generated automatically from your account activity and the health profile data you provide. Refer Clause 10.
e. Cookies and similar technologies. These are collected when you use the website version of the Platform. Refer Clause 15 (standalone Cookie Policy).
4.5. Data We Collect from Third Parties
a. Connected health applications. If you authorise a third-party health or fitness application (such as Google Health Connect) to share data with us, we receive only the specific categories of health metrics you have authorised. We do not access any data from that application beyond what you have specifically authorised.
b. Razorpay. We receive transaction confirmation, status, and reference numbers from Razorpay upon payment completion. We do not receive your raw payment credentials.
5. HOW WE COLLECT YOUR DATA
We collect your personal data:
a. directly from you, when you register, book appointments, upload records, use features, set reminders, or contact us;
b. automatically, through the Platform's technical systems as you use it;
c. from connected third-party applications, where you have given that application permission to share data with us;
d. from our payment gateway partner, Razorpay, to confirm successful transactions; and
e. from doctors using PaxEM Docs, in the case of walk-in patients whose details are entered by a doctor (see Clause 12).
6. LEGAL BASIS FOR PROCESSING YOUR DATA
In line with the DPDP Act, 2023, we will only process your personal data on the following legal grounds:
a. Consent. Your consent will be required for the collection and processing of health data (including Medical Records, Medication Reminders data, biometric/fitness data, and Health Score data), your use of AI-assisted features, and marketing communications. For your health data, the consent is required as per PaxEM’s individual Consent for Collection of Health Data form that you need to sign the first time you use one of our health data functionalities, but not as a consequence of accepting the Terms and the Privacy Policy, which do not constitute consent to processing of sensitive personal Data. You may withdraw any consent at any time as described in Clause14.
b. Contractual Necessity. In order to provide the services requested by you, the processing of your personal data will be absolutely necessary for the activities included but not limited to: booking and arranging Consultations, communication with doctors, payment processing, sending transactional notices, and managing your account. Since the above-mentioned operations are essential in order to provide the Platform’s services, you may not refuse from the above-mentioned processing when using the Platform.
c. Legitimate interests. PaxEM may process your personal data in cases where such processing required for furtherance of PaxEM’s legitimate business including the purposes of detecting fraud, protecting security of accounts, monitoring of systems, auditing, handling disputes, internal analysis and product development, provided that such processing is conducted proportionately, respects your rights in accordance with Applicable Law and uses only minimum personal data needed for the specified purpose.
d. Legal requirement. For processing required by Applicable Law, including disclosures to law enforcement, courts, or regulatory authorities, and retention of records for regulatory compliance.
7. SENSITIVE PERSONAL DATA AND HEALTH DATA
7.1. The following categories of data are considered sensitive personal data under Indian law:
a. health and medical data which includes prescriptions, diagnoses, symptoms, health history, medical report(s);
b. medications data obtained through the Medications Reminder feature;
c. biometric and fitness data whether obtained automatically through connections or manually input;
d. data on insurance coverage; and
e. financial payment data, as far as such data is kept by PaxEM.
Such data will enjoy special protection and will be processed solely for the purposes indicated in these Terms and Platform Policies.
7.2. PaxEM shall not at any time collect or process any class of sensitive personal information without your prior, freely-given, explicit, and unequivocal consent, provided in your Consent for Collection of Health Data form. Without limiting the foregoing, the acceptance of PaxEM’s Privacy Policy by you shall not be considered as consent for the collection or processing of any sensitive personal information.
7.3. Processing of Sensitive Data. PaxEM will process your personal data only for the purposes for which you have given explicit consent for such processing, and PaxEM will not use such personal data for any of the following purposes: (i) targeted advertising; (ii) non-health profiling; (iii) insurance underwriting; (iv) any other purpose which is not explicitly mentioned in these Terms of Service or Platform Policies, unless PaxEM receives your explicit consent for such purpose.
7.4. You may withdraw your consent for processing of sensitive personal data at any time through the Data Sharing & Consent section of your account settings or by contacting our Grievance Officer. Withdrawing consent will stop further processing for that purpose but will not affect the lawfulness of any processing already carried out, and may limit your ability to use the features that depend on that data.
8. HOW WE USE YOUR DATA
PaxEM shall use your personal information for certain purposes, including account creation and maintenance; appointment scheduling and consultation; doctor searching; prescription generation and storage in your Health Wallet; operation of your Health Wallet with encrypted Medical Records which can be accessed by you and, at your discretion, by the doctors who treat you, sending medicine reminders; calculation and presentation of your Health Score and wellness risk factors; payment and refund processing; delivery of transaction-related notices essential to the service; distribution of marketing communications, if you opt in separately; providing AI-based services; detection of fraud and maintaining account security; compliance with Applicable Law; internal analysis and product development without sharing with third parties; and account, transaction, and session data accuracy.
9. WHOM WE SHARE YOUR DATA WITH
9.1. Doctors (on the Platform). Upon making a Consultation booking, PaxEM will provide to the attending Doctor your name, contact information, and health records that you have specifically selected to be disclosed or provided access to, strictly for the purpose of the Consultation and any further treatment. Doctors are professionally bound to uphold patient confidentiality, as well as being subject to the data protection clauses contained in their Doctor Onboarding Agreement. Prior Consultation health records pertaining to another Doctor are not shared automatically. A separate consent is required through the Data Sharing & Consent settings under Clause 14.
9.2. Doctor-Initiated WhatsApp Broadcast. Doctors can use the PaxEM Docs app to send WhatsApp messages to the patients listed in their roster (which includes both patients registered via PaxEM app and walk-in patients). However, such messages shall only consist of those WhatsApp message templates approved by PaxEM. These templates include appointment reminders, follow-up messages, or well-being messages. For this, your mobile number may be accessed by the Doctor through Gallabox’s WhatsApp Business API.
9.3. The templates cannot be customised freely by Doctors. Should you wish not to receive such messages, you may unsubscribe by informing the Grievance Officer at PaxEM or by requesting removal from the Doctor’s broadcast list.
9.4. Payments via our Payment Gateway: Razorpay Software Private Limited. PaxEM shares Transaction details (amount, booking reference) with Razorpay to process payments. Razorpay operates under its own privacy policy and is responsible for the security of your payment credentials as part of its own environment that adheres to the PCI-DSS standard. PaxEM does not pass or store any card numbers, UPI PIN, CVV, or banking credentials.
9.5. Cloud Hosting Provider: Amazon Web Services (AWS). All the data that is stored on the Platform, whether it relates to accounts, Medical Records, or Health Wallet data, will be stored on the AWS servers that are located in the region ap-south-1 (Mumbai, India). AWS only acts as the data processor for PaxEM and processes all the aforementioned data only on the instruction of PaxEM.
9.6. Our AI Service Provider. The AI-assisted features on the Platform are powered by a third-party artificial intelligence service provider (our "AI Service Provider"). Our current AI Service Provider is Groq, Inc., incorporated in the United States, which processes this data on servers in the United States (its privacy policy: https://groq.com/privacy-policy/). Data processed by these features is therefore transferred outside India; this transfer is necessary for the AI features to function. Before any typed text is sent to the AI Service Provider, we automatically remove names, phone numbers, email addresses, and Aadhaar and ABHA numbers that we can detect, for both patients and doctors. This removal does not apply to images or audio recordings. The following features send data to the AI Service Provider:
a. AI Chat Assistant (patients). The text of the messages and questions you enter, together with any image you attach to the conversation.
b. Medical Scribe (PaxEM Docs). The audio recording of your consultation, which is transcribed and then converted into a structured clinical note. Please see Clause 9.6.1 below, which explains how this recording is handled.
c. Quick Diagnose (PaxEM Docs). The patient age, sex, presenting symptoms and medical history that your doctor enters.
d. Drug Interaction Check (PaxEM Docs). The drug names and dosages your doctor enters.
e. Radiology Assist (PaxEM Docs). The diagnostic image your doctor uploads, together with any modality, body region and clinical context your doctor enters.
f. Health Score and insurance policy matching. The health and lifestyle inputs you provide to those features, where you have enabled them.
g. Display of doctor names in Hindi and Telugu. Doctor names only, sent once the doctor's profile has been verified. No patient data and no health data is involved in this processing.
h. AI Chat (PaxEM Docs). The messages your doctor types and your doctor's specialty and years of experience, and, when your doctor opens the chat from your appointment, your age, sex, chief complaint, chronic conditions and current medications. Your name is removed before these details are sent.
i. Case Study (PaxEM Docs). The messages your doctor types, any clinical images your doctor attaches, voice recordings your doctor dictates, and your doctor's specialty and years of experience.
9.6.1. Consultation Audio. Medical Scribe is the one feature on the Platform that records consultation audio, and it operates only when your doctor starts it during a consultation. The recording is transmitted to the AI Service Provider for transcription, and is also stored on our servers in India so that the resulting note can be reviewed and corrected. Deleting the note deletes the stored recording along with it. Retention is described in Clause 15. No other consultation, whether in person or by teleconsultation, is recorded by the Platform.
9.6.2. Consent. Where a patient is identified on the consultation, Medical Scribe will not process the recording unless that patient has given consent for AI processing under the Consent for Collection of Health Data, which should be separately accepted before using any AI feature on the Platform. That consent may be withdrawn at any time through the Data Sharing & Consent settings described in Clause 14, and withdrawal takes effect immediately for all future use of the feature.
9.6.3. Contractual Protections. We use an AI Service Provider only under a written agreement that requires it to: (a) process the data only on our documented instructions and only to provide the service to us; (b) not use the data to train, fine-tune or improve any AI model; (c) treat the data as confidential and protect it with appropriate administrative, technical, physical and organisational security measures; (d) use sub-processors only under written obligations that protect the data to the same standard; (e) not keep the content of AI requests after returning the result, other than temporary logs kept for no more than 30 days for system reliability and abuse monitoring; and (f) delete the data on our request and when our agreement ends. These obligations give your personal data the same as or equal protection to that described in this Policy. We rely on your specific consent, and on the necessity of the transfer to provide the feature you have asked for, as the basis for this processing.
9.6.4. Your Choice. If you do not wish for your data to be processed on these terms, you may decline to use the AI-assisted features, or withdraw the AI processing consent. Doing so does not affect your ability to book consultations, hold a teleconsultation, store records in Health Wallet, or use any other non-AI functionality of the Platform. Your doctor is likewise able to conduct and document your consultation without using any AI tool.
9.6.5. Notice and Permission in PaxEM Docs. Before an AI feature in the PaxEM Docs app sends any data to the AI Service Provider for the first time, the app shows the doctor a notice that states what data that feature sends and names the AI Service Provider and the country where it processes the data. Nothing is sent unless the doctor taps Allow. The doctor can withdraw this permission at any time in Profile → Privacy & Data → AI Data Sharing.
9.6.6. Change of AI Service Provider. We may change our AI Service Provider. Any new provider must accept every obligation in Clause 9.6.3. Before any data is sent to a new provider, we will update Clause 9.6 to name it, notify registered users, and the PaxEM Docs app will ask for permission again under Clause 9.6.5.
9.7. WhatsApp Communication Provider through Gallabox (Meta Platforms, Incs. We use Gallabox, operating on the WhatsApp Business API (a service of Meta Platforms, Inc.) to deliver one-time password (OTP) verification messages, transactional notifications via WhatsApp, and to facilitate the doctor-initiated WhatsApp broadcast described in Clause 9.2. For the limited purpose of delivering WhatsApp messages, your mobile number is shared with Gallabox and Meta. We do not share health data with Gallabox or Meta through this integration. Meta's own data policies apply to messages delivered through WhatsApp.
9.8. Push Notification Provider Google Firebase (FCM)We use Google Firebase Cloud Messaging (FMC) to deliver push notifications such as appointment reminders, prescription alerts, and system notifications. To facilitate this, your device registration token is shared with Firebase in accordance with Google Data Policies. We do not share health data with Firebase.
9.9. Maps Provider (MapmyIndia — CE Info Systems Limited) Mappls. We use Mappls to provide location-based features, including showcasing doctors near your selected city. For this limited purpose, your city-level location is shared with Mappls. We do not share health data with Mappls.
9.10. Video/Audio Infrastructure Provider Cloudflare. We use Cloudflare's TURN (Traversal Using Relays around NAT) server infrastructure for real-time communication relay during teleconsultations. For this limited purpose, your IP address and connection metadata are processed by Cloudflare. Consultations are not recorded and Cloudflare does not receive the content of your consultation. In addition, Cloudflare also provides network-level security services (including DDoS protection and CDN services) for the PaxEM website. In that capacity, Cloudflare processes the IP addresses and request metadata of all website visitors as part of its standard network-routing function. This processing by Cloudflare does not involve your health data or account content. Cloudflare's global infrastructure may route traffic through servers outside India as part of its standard CDN operation.
9.11. Email Communication Provider. We use GMAIL to deliver emails to you, including transactional emails appointment confirmations, receipts, password reset) and marketing emails (where you have opted in). To deliver an email, your email address and the email content are shared with this provider. The provider operates under its own privacy policy and processes email data on our behalf. We do not share health data in marketing emails.
9.12. With Our Insurance Partner OneAssure (Prost Technologies Private Limited)
If you choose to use the insurance feature, you will be redirected to OneAssure's own portal. Once you click through, you are leaving the PaxEM Platform and your data is governed by OneAssure's own privacy policy from that point onward. PaxEM does not transmit your Medical Records, Health Score, Medication Reminders data, or any health data to OneAssure at any stage, whether before or after the redirect.
9.13. With Law Enforcement and Regulatory Authorities. We may disclose your data to courts, law enforcement agencies, regulatory bodies, or government authorities as prescribed by law. Where permitted by law, such requests shall be notified to you.
9.14. In the Event of a Business Transfer. In the event of a merger, acquisition, restructuring, or sale of all or substantially all of PaxEM's assets, your personal data may be transferred to the acquiring entity. We will notify you before any such transfer and ensure the acquiring entity is bound by privacy obligations at least equivalent to those set out in this Policy.
9.15. Sub-Processors. PaxEM's data processors (AWS, our AI Service Provider (Clause 9.6), Razorpay, Gallabox, Firebase, Mappls, Cloudflare, and our email provider GMAIL) may engage their own sub-processors and infrastructure providers for providing services to PaxEM. Our contracts with direct processors include obligations to apply data-protection standards to any sub-processor are at least equivalent and in no case weaker, than those we impose on our direct processors. PaxEM does not directly control sub-processors but takes reasonable steps to ensure that the chain of processing remains secure and that your data is not further disclosed beyond what is described in this Policy.
10. DATA WE DO NOT SHARE
We in no way:
a. Sell your personal data to any third party.
b. Share your health data with advertisers or marketing companies.
c. Share your Health Score with any insurer, insurance partner, or any entity that could use it for underwriting or eligibility assessment.
d. We do not share your Medication Reminders data with any third party, including your doctor, unless you choose to share it.
e. Share your consultation history, medical data, or Health Score with OneAssure or any insurance partner.
f. Use your health data such as diagnoses, conditions, medications, or history to target advertisements or promotional content at you.
g. Share identifiable user data with the Platform's development agency (Square Innovations Soft Labs Pvt. Ltd.) for any ongoing post-launch purpose.
11. AUTOMATED DECISION-MAKING AND RISK ASSESSMENT
11.1. The Platform uses automated processing to generate two wellness indicators that are displayed to you:
a. The Risk Assessment Panel. This is displayed on your home screen, this feature analyses your account activity and the health profile information you have provided (or the absence of it) to generate a risk indicator, which may display messages such as "No Recent Health Checkup — medium risk" or similar. The inputs used to generate this indicator include the date of your last consultation or health record uploaded, the completeness of your health profile, and whether certain categories of health information (such as vaccination records or diagnostic reports) are present in your Health Wallet.
b. The Health Score Risk Band. The Health Score feature produces a risk-band classification ("At Risk," "Moderate Risk," etc.) as described under Clause11.
11.2. Nature and Effect. These automated assessments are wellness indicators displayed to you for your own information and to encourage proactive engagement with healthcare. They do not constitute a medical diagnosis, a clinical opinion, or a determination that has any legal or similarly significant effect on you. They are not shared with any insurer, employer, financial institution, or other third party. They do not automatically restrict your access to any feature of the Platform or determine which doctors or services are available to you.
11.3. Opt-Out. If you do not wish to receive Risk Assessment or Health Score outputs, you may choose not to enter data into the Health Score and health profile features.
11.4. Human Oversight. These automated assessments are not reviewed by a PaxEM employee before being displayed to you. If you believe an indicator is inaccurate or misleading, please contact our Grievance Officer.
11.5. AI-Assisted Clinical Tools. The AI tools available to doctors in PaxEM Docs — Quick Diagnose, Drug Interaction Check, Radiology Assist and Medical Scribe — produce suggestions and draft documentation for the treating doctor's consideration. They do not make any diagnosis, prescription, or treatment decision. Every output is reviewed by your doctor, who remains solely responsible for your clinical care, and no output is acted on or added to your records without that review.
12. FAMILY MEMBER DATA
12.1. The Platform allows you to list the details of family members using the "My Family" feature in your account. By listing a family member's details, you confirm that you are authorised to provide such information to PaxEM on that family member's behalf.
12.2. Data collected about family members includes name, age/date of birth, gender, and relationship to you.
12.3. Current use: As of the date of this Policy, the Family feature allows you to list family member details for your own record-keeping purposes only. It does not currently enable you to book a consultation on behalf of a listed family member. If and when such feature is introduced, this Policy will be updated and additional consent requirements will be introduced before that feature goes live.
12.4. Family member details are stored within your account and are not used to create a separate account for that family member or shared with doctors, or any other third party.
12.5. If a person is listed as a family member on another user's account and wishes to request access to, correction of, or deletion of their details, they may contact our Grievance Officer directly. We will verify the request and act on it in accordance with applicable law.
12.6. Deletion: If you delete a family member listing from your account, that family member's details will be removed from your account. You may also contact our Grievance Officer to request deletion of a family member's details.
13. WALK-IN PATIENT DATA
13.1. The PaxEM Docs application used by registered doctors allows doctors to maintain a patient roster that includes both app-registered patients and "walk-in" patients who visited the doctor's clinic without creating a PaxEM account but whose details the doctor has entered into PaxEM Docs manually.
13.2. What data is collected about walk-in patients: Name, mobile number, and visit count, as entered by the doctor.
13.3. Legal basis: This data is collected on the basis of PaxEM's legitimate interest in providing a complete patient management tool to the registered doctors it has contracted with, and on the basis of the doctor's own duty to maintain patient records under medical council regulations. The doctor who enters this data is themselves a licensed healthcare professional bound by professional confidentiality obligations.
13.4. How this data is used: Walk-in patient data stored in PaxEM Docs is used solely to display the patient roster to the relevant doctor. If the walk-in patient creates a PaxEM Health account in the future and books a consultation with the same doctor, their walk-in record may be linked to their new account.
13.5. Doctor WhatsApp Broadcast: As described in Section 8.1, a doctor may use PaxEM Docs' WhatsApp broadcast feature to send defined-template WhatsApp messages to patients on their roster, including walk-in patients. If you are a walk-in patient and do not wish to receive such messages, please contact our Grievance Officer.
13.6. Rights of walk-in patients: If you are a walk-in patient (i.e., you have not created a PaxEM account but believe your details have been entered by a doctor using PaxEM Docs) and you wish to access, correct, or request deletion of your details, please contact our Grievance Officer with your full name and the doctor's name or clinic. We will verify your request and act accordingly.
13.7. Notification: Walk-in patients are not automatically notified that their details have been entered into PaxEM Docs by a doctor. We rely on the doctor's own duty of disclosure to their patients under applicable medical regulations. If you would like to know whether your details have been entered into PaxEM's systems by a doctor, please contact our Grievance Officer.
14. DATA SHARING & CONSENT CONTROLS
14.1. The Platform provides you with a dedicated "Data Sharing & Consent" section in your account settings (under Settings > Data Sharing & Consent), which allows you to see and manage which and whether a doctor can access your Medical Records.
14.2. When a doctor requests access to your Medical Records (for example, before a consultation), you will receive a notification which you must approve or decline that request within the app. If you approve, the doctor gains access to the specific records you have authorised for the duration of the consultation and any follow-up clinical care. All active grants of access are visible to you at all times under “Active Grants.”
14.3. You may revoke a doctor's access to your records at any time through the Data Sharing & Consent section. Upon revocation, the doctor will no longer be able to access those records through the Platform. However, records already reviewed by the doctor prior to revocation cannot be recalled.
14.4. This feature controls doctor access to your Medical Records stored in the Health Wallet. It does not control the transactional data associated with your appointment (such as appointment details and payment records), which remain accessible to the relevant doctor for administrative and billing purposes.
14.5. All pertinent activity concerning access requests, approvals, denials, grants, and revocations is logged for posterity by the platform in order to assure accountability, transparency, and compliance with applicable law.
15. DATA RETENTION
We retain your personal data only for as long as it is necessary for the purposes described in this Policy, or as required by Applicable Law.
a. Account data (name, contact details, login records) are retained for the duration your account is active, and for 90 (ninety) days after account deletion to handle disputes, legal claims, or regulatory requirements.
b. Medical Records stored in Health Wallet are retained for the duration your account is active. Upon account deletion, your Medical Records will be deleted within 30 (thirty) days, except to the extent a treating doctor is independently required to retain a copy under applicable medical council regulations, for a period which has be disclosed upon receiving a request for deletion.
c. Medication Reminders data is retained for the duration your account is active. This data is deleted upon account deletion or upon your deletion of the reminder within the app, whichever is earlier.
d. Lab Orders data is retained for the duration your account is active and for 3 (three) years thereafter, to comply with applicable medical records retention obligations.
e. Risk Assessment and Health Score data is retained for the duration your account is active. It shall be deleted upon account deletion.
f. Family Member data is retained until you delete the family member listing from your account, or until you or the family member requests deletion, or until your account is deleted.
g. Walk-in patient data is retained for as long as the relevant doctor's account remains active on the Platform, or until a deletion request is made by the walk-in patient to our Grievance Officer.
h. Payment transaction records are retained for a minimum of 8 years from the date of such transaction, in accordance with Indian financial record-keeping requirements.
i. Audit logs and system records are retained for 6 (six) years from the date of creation, for security, fraud prevention, and legal compliance.
j. Active session records are not retained.
k. Medical Scribe recordings and the clinical notes generated from them are retained for the duration of the treating doctor's account, or until the doctor or you delete the note, whichever is earlier. Deleting the note deletes the recording with it.
l. The history of AI tool queries and their outputs (AI chat, Case Study, Quick Diagnose, Drug Interaction Check, Radiology Assist) is retained until deleted by the user who created it. Each user can delete individual entries or clear the entire history at any time from within the feature, and the history is deleted on account deletion.
m. Our AI Service Provider does not keep the content of AI requests beyond the limits in Clause 9.6.3(e), and must delete any data it holds on our request.
n. Support communications are retained for a period of 12 (twelve) months from the date of the communication.
o. Marketing email/WhatsApp opt-in records are retained for the duration of your account and for 3 (three) years after deletion, to demonstrate your consent where required.
p. NOTE: Specific retention periods marked above as "[to be specified]" will be finalised and published in the next version of this Policy before the relevant feature goes live. We will notify registered users when updated retention periods are published.
16. COOKIES AND TRACKING TECHNOLOGIES
16.1. The website version of the Platform uses cookies and similar technologies. Our mobile application does not use browser cookies but uses equivalent session-management and authentication token technologies.
16.2. We use the following types of cookies on our websites:
16.2.1. Strictly Necessary Cookies. These cookies are essential for the website to function. They do not store personally identifiable information.
(a) RefreshToken. This stores your encrypted session refresh token to maintain your login session. This is retained for the duration of session.
(b) AccessToken. This stores your encrypted short-lived authentication token for API calls. This is retained for the duration of the session.
(c) Cookie-parser / helmet (CORS). This enforces same-site cookie and cross-origin request security rules. This is retained for the duration of session.
16.2.2. Functional Cookies. These cookies enable enhanced functionality and personalisation. Disabling them may affect how the website works. These may include:
a. NEXT_LOCALE. This stores your language/locale preference. Persistent.
b. City ID / city name — This stores your selected city to display relevant doctors without requiring re-entry. Persistent.
c. Latitude and longitude. This stores approximate latitude and longitude corresponding to your selected city (not your device's precise GPS location). Persistent.
d. Notifications. Stores your push notification preference (opted in or out). Persistent.
16.2.3. Analytics Cookies. We do not use third-party analytics cookies. Our website analytics are conducted entirely using in-house systems.
16.2.4. Advertising and Targeting Cookies. We do not use advertising cookies, targeting cookies, or third-party tracking pixels (including Meta Pixel, Google Ads remarketing tags, or similar). We do not run programmatic or display advertising on the Platform.
16.3. As of the date of this Policy, the website does not display a cookie consent banner because the cookies in use are either strictly necessary or functional and no third-party analytics or advertising cookies are used. If this changes, a cookie consent mechanism will be introduced and this Policy updated accordingly.
For complete details, please refer to our standalone Cookie Policy available on the Platform.
17. DATA SECURITY
17.1. We have implemented a layered set of technical and organisational security measures to protect personal data against unauthorised access through the following measures:
a. Encryption. All data transmitted between your device and our servers is encrypted using TLS. All data stored on our servers, including Medical Records, is encrypted at rest with industry standard algorithms.
b. Access controls. Access to your data within PaxEM's systems is restricted on a need-to-know basis. Only authorised technical team members may access Medical Records, solely for maintenance or support purposes.
c. Audit logging. All access to sensitive data generates an audit trail recording who accessed what data and when.
d. Infrastructure security. We use AWS's security infrastructure, including network-level isolation, security groups, and identity and access management policies.
e. Authentication. User accounts are protected by OTP-based verification at registration and MPIN-based authentication on subsequent logins.
f. Session management. You can view and terminate active sessions across devices at any time through Security settings.
Note: No method of data transmission or storage is 100% secure. While we take reasonable precautions, we cannot guarantee absolute security against all threats.
17.2. Data Breach Response. We are in the process of establishing a formal documented data-breach detection and incident-response process before the Platform's commercial launch. In the event of a breach likely to result in a risk to your rights, we will: (a) notify the Data Protection Board of India as required under the DPDP Act; (b) notify you as promptly as practicable; and (c) describe the nature of the breach, the data affected, likely consequences, and the remedial steps we are taking.
17.3. You are responsible for keeping your login credentials (mobile number, MPIN) confidential and for securing your device. PaxEM will not be liable for any breach resulting from your failure to maintain this security.
18. DATA PROTECTION IMPACT ASSESSMENTS
18.1. PaxEM is committed to conducting Data Protection Impact Assessments (DPIAs) before launching or significantly changing any processing activity that is likely to result in a high risk to your privacy or rights. This includes, without limitation:
a. the deployment of new AI-assisted features that process health data
b. the introduction of new data-sharing arrangements with third parties;
c. the launch of automated risk-scoring or health-profiling features;
d. the introduction of large-scale biometric or fitness data collection;
e. any planned integration with the Ayushman Bharat Digital Mission (ABDM) (described in Clause 19); and
f. any feature involving health data processing on a significantly larger scale than current operations.
18.2. Where a DPIA identifies a high residual risk that PaxEM cannot mitigate through technical or organisational measures, PaxEM will consult the Data Protection Board of India before proceeding with the relevant processing activity, in accordance with the DPDP Act.
18.3. A summary of the DPIAs conducted by PaxEM, and the key measures taken as a result, will be made available to users upon request to our Grievance Officer, to the extent this does not disclose commercially sensitive or security-sensitive information.
19. ABDM (AYUSHMAN BHARAT DIGITAL MISSION) INTEGRATION
19.1. PaxEM intends to apply for empanelment under the Ayushman Bharat Digital Mission (ABDM), operated by the National Health Authority (NHA) of India. ABDM empanelment would enable the Platform to integrate with India's national digital health infrastructure, including the Ayushman Bharat Health Account (ABHA) system.
19.2. ABDM integration is not yet live. However, when it is implemented, it will be subject to the NHA's Health Data Management Policy, which is a detailed regulatory framework that imposes specific obligations on ABDM-linked platforms regarding the collection, storage, use, and sharing of health data. Upon ABDM integration going live,
a. this Policy will be updated to describe how the integration works and what additional data is collected or shared through it
b. you will be notified and
c. fresh, specific consent will be sought from you before any ABDM-linked feature becomes active for your account.
19.3. ABDM integration will be an opt-in feature. You will not be required to link your ABHA account to PaxEM in order to use any core feature of the Platform.
20. YOUR RIGHTS
As a Data Principal under the Digital Personal Data Protection Act, 2023, and as a consumer under the Consumer Protection Act, 2019, you have the following rights:
a. Right to Access. You may request a summary of what personal data PaxEM holds about you, the purposes for which it is being processed, and any third parties with whom it has been shared. Contact our Grievance Officer (Clause 21). We will respond within [to be specified] days of a verified request.
b. Right to Correction and Updating. You may correct or update inaccurate or incomplete personal data through "My Profile" in the app, or by contacting our Grievance Officer.
c. Right to Erasure. You may request deletion of your personal data where: (a) it is no longer necessary for the purpose collected; (b) you have withdrawn consent and no other legal ground applies; or (c) Applicable Law requires erasure. Use "Privacy & Data" in your account settings or contact our Grievance Officer. We will process your request subject to lawful retention obligations in Clause 15.
d. Right to Withdraw Consent. Where processing is based on consent, you may withdraw it at any time through "Data Sharing & Consent" in your account settings or by contacting our Grievance Officer. Withdrawal does not affect the lawfulness of prior processing.
e. Right to Opt-Out of Behavioural Analytics. You may contact our Grievance Officer to opt out of your usage data being included in our in-house behavioural analytics. Opting out will not affect your ability to use the Platform.
f. Right to Grievance Redressal. You may raise any privacy concern with our Grievance Officer (Clause 21). See the timelines at Clause 21.3.
g. Right to Nominate. Under the DPDP Act, you may nominate another person to exercise your privacy rights on your behalf in the event of your incapacity or death. Nomination means that the person you designate will be able to access, correct, or request deletion of your personal data after you are no longer able to do so. To register a nomination, please contact our Grievance Officer with your nominee's name, contact details, and relationship to you. PaxEM will record the nomination against your account.
h. Consumer Rights. In addition to the above, you retain all rights available to you as a consumer under the Consumer Protection Act, 2019, which cannot be excluded or limited.
21. GRIEVANCE OFFICER AND HOW TO REACH US
21.1. PaxEM has appointed a Grievance Officer to address any concern, complaint, or query relating to this Policy or the handling of your personal data, in accordance with the DPDP Act, the IT Act, and the IT (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021. The following contains the details of such Officer duly appointed
Grievance Officer:
Name: Gopinath Surey
Designation: Charted Accountant
Email: Gopinathsurey@gmail.com
Phone: 9914993333
Address: Future Path Health Private Limited, 1-89/24, Plot 6A, Durgam Cheruvu Road, RBI Colony, Phase 2, Kavuri Hills, Hitech City, Hyderabad – 500081, Telangana.
21.2. You may contact our Grievance Officer to access, correct, or request deletion of your personal data, withdraw any consent, opt out of behavioural analytics, register a nomination, ask questions about this Policy, report a suspected data breach, exercise any right (refer clause 20) or raise any other privacy concern.
21.3. Timelines. We will acknowledge your grievance within 7 (seven) days upon receipt of such request. For complex matters requiring investigation or coordination with third parties, you shall be notified about the delay along with the expected timeline for resolution.
21.4. If your grievance is not resolved to your satisfaction, you may approach the Data Protection Board of India, once established and operational under the DPDP Act or any consumer forum or commission having jurisdiction or any other court or authority of competent jurisdiction.
21.5. National Consumer Helpline: 1800-11-4000 or consumerhelpline.gov.in.
22. INTERNATIONAL DATA TRANSFERS
22.1. All Primary data storage is within India, on AWS infrastructure in the Mumbai (ap-south-1) region.
22.2. Cross Broder Transfer. The following data transfers outside India occur in connection with specific features:
a. Our AI Service Provider (Clause 9.6), in the country stated in that Clause. Inputs to every AI-assisted feature listed in Clause 9.6.
b. Google LLC / Firebase (United States). Device push notification tokens, for push notification delivery.
c. Cloudflare (United States / Global). IP addresses and connection metadata for teleconsultation relay and website security/CDN functions.
22.3. We currently rely on contractual necessity (for performance of the service) and, for health data specifically, on your specific consent as obtained through the Consent for Collection of Health Data, as the legal basis for these cross-border transfers.
22.4. We are in the process of entering into formal data transfer agreements with all international vendors before or following the Platform's commercial launch, and will update this section once those agreements are in place.
23. THIRD-PARTY LINKS AND SERVICES
23.1. The Platform may contain links to or integrations with third-party services. When you click through to a third-party service, you leave PaxEM's Platform and your data is governed by that third party's own privacy policy. We are not responsible for the privacy practices of third-party services.
23.2. Key third parties and their privacy policy links:
a. Razorpay: https://razorpay.com/privacy-policy/
b. Our AI Service Provider: the privacy policy linked in Clause 9.6.
c. Amazon Web Services: https://aws.amazon.com/privacy/
d. Firebase / Google: https://firebase.google.com/support/privacy/
e. OneAssure: https://www.oneassure.in/documents/privacy-policy/
f. Gallabox / WhatsApp / Meta: https://gallabox.com/privacy-policy
g. Mappls (MapmyIndia): https://about.mappls.com/about/privacy-policy/
h. Cloudflare: https://www.cloudflare.com/en-in/privacypolicy/
i. GMAIL: https://policies.google.com/privacy?hl=en-US
24. CHILDREN'S PRIVACY
24.1. The Platform is not directed at, and is not intended for use by, persons under 18 years of age. We do not knowingly collect personal data from minors.
24.2. If you are a parent or guardian and believe your child's data has been provided to us without your consent, please contact our Grievance Officer immediately. We will take prompt steps to verify and delete such data.
24.3. If PaxEM introduces features enabling a parent or guardian to book consultations on behalf of a minor, this Policy will be updated and additional safeguards and consent requirements introduced before those features go live.
25. MARKETING COMMUNICATIONS
25.1. With your opt-in consent, we may send you wellness tips, general health content, information about new Platform features, promotional offers from PaxEM, and information about partner services.
25.2. We will never use your health data, diagnoses, medical history, consultation content, or Medication Reminders data to target marketing communications at you, either directly or through audience segmentation.
25.3. Channels and providers used for marketing communications:
a. Email: GMAIL
b. WhatsApp: via Gallabox (WhatsApp Business API)
c. Push notifications: via Firebase Cloud Messaging
d. SMS: GMAIL
e. Social media advertising: via the advertising platforms of social networks (using non-health data such as age, gender, and city, where you have not opted out on those platforms)
25.4. For all the above communication platforms, you may opt out at any time by using the Notifications settings in your account or clicking unsubscribe in any marketing email or contacting our Grievance Officer. Opting out will not affect transactional communications necessary to your use of the service.
26. CHANGES TO THIS POLICY
26.1. We may update this Policy when we change our data practices, introduce new features, or when Applicable Law requires it.
26.2. For material changes (those that significantly affect how we collect, use, or share your data), we will:
a. publish the updated Policy with a new effective date
b. notify you by email or in-app notification; and
c. where required by law, obtain your fresh consent before processing your data under the new terms.
26.3. For non-material changes (corrections, clarifications, or additions of vendor names without a change in how data is used), we will publish the updated Policy with a new date without separate notice.
26.4. For any change involving a new use of your health data or a new category of health data collection, we will treat the change as material regardless of its apparent scale, and will obtain your fresh, specific consent through the Consent for Collection of Health Data before the change takes effect for your account.
27. GOVERNING LAW
This Policy shall be governed by and construed in accordance with the laws of India. Any dispute arising out of or in connection with this Policy shall be subject to the exclusive jurisdiction of the courts at Hyderabad, Telangana, without prejudice to your statutory right to approach any consumer forum having jurisdiction over your place of residence under the Consumer Protection Act, 2019.
For any query relating to this Privacy Policy, please contact our Grievance Officer at the details in Clause 21.
This Policy was last updated: 6 November 2026