Privacy Policy — Healthcare Providers

Looking for the other version? Privacy Policy for patients

1. Introduction

This Privacy Policy explains how NeXora Health Systems Private Limited, CIN U86909TS2026PTC215305, registered office at 4-12-927/1, Plot No. E1, RD-1, Portion C, Auto Sai Nagar Colony, Vanasthalipuram, Hyderabad, Rangareddy District, Telangana – 500070 ("NeXora", "we", "us") processes the personal data of doctors, dentists, and nurses ("Providers", "you") who register on the provider-facing HoMedi application (the "Platform").

NeXora is the Data Fiduciary for this processing under the Digital Personal Data Protection Act, 2023 ("DPDPA") and the Digital Personal Data Protection Rules, 2025 ("DPDP Rules"). This Policy serves as the notice required under Section 5 of the DPDPA. It should be read with the Terms & Conditions — Healthcare Providers.

2. Personal Data We Collect

2.1 Data you provide

2.2 Data collected automatically

• Location: your home-base location (latitude/longitude) for discovery; while you toggle yourself "live", your availability and location make you discoverable to patients within approximately 2 km; during an accepted visit, your live location may be shared with the booked patient for arrival coordination. Location is not tracked when you are offline.

• Device and app data: push-notification token (Firebase), app version, device type, crash diagnostics.

• Security and audit logs: login attempts (with hashed technical identifiers), OTP events, and an append-only audit trail of actions on the Platform.

2.3 Verification data from third parties

To verify your eligibility we query official registers — the National Medical Commission / Health Professional Registries for doctors, the State Dental Council registers for dentists, and the State Nursing Council registers for nurses — and record the verification outcome. Register lookups, the DigiLocker Aadhaar check, and the face liveness and face-match checks are carried out through our verification provider, Surepass (Section 6.1).

If Surepass's face match is inconclusive, the same two images (your live selfie and your Aadhaar or ID card photo) are also compared by Amazon Rekognition, run by Amazon Web Services in the Mumbai region (ap-south-1, India), as a second check. Amazon Rekognition compares the two images without building a face collection from them, and we have opted out of Amazon using them to improve its services; Amazon keeps them only as needed to provide the service. We record only the similarity score. The second check can only confirm a match: it never rejects you on its own. If neither check confirms a match, a member of our verification team compares your live selfie with your ID photo and documents before deciding.

If you link your HPR ID, we confirm it with the ABDM Healthcare Professionals Registry and check that the name registered there matches yours. Your listing is activated only after successful verification, and we may re-verify periodically.

What we keep from your Aadhaar: only the fields listed in Section 2.1, encrypted. Your full Aadhaar number, your Aadhaar photo, your street address, and the Aadhaar document itself are not stored. Your Aadhaar photo is used in memory to compare against your live selfie (by Surepass and, where needed, Amazon Rekognition) and is then discarded.

2.3A Payment data from Google and Razorpay

When you purchase or renew your Subscription on the Provider Portal (provider.homedi.in), the payment and the recurring payment mandate (UPI Autopay, card, or another method Razorpay offers) are processed by Razorpay. We receive only the payment, subscription and mandate identifiers, amount, and status needed to activate and renew your Subscription and issue the GST tax invoice; we never see or store your card, UPI, or bank credentials.

When you purchase or renew your Subscription within the HoMedi provider app, Google (Google Play) sends us the transaction and subscription-status information needed to activate and maintain it. Google processes your payment details as an independent party under its own terms and privacy policy; we never receive your card, UPI, or bank credentials.

When you buy ECG Interpretation Credits, the payment is processed by Razorpay (UPI, cards, or netbanking). We receive only the payment identifier, amount, and payment status needed to add the Credits to your balance and issue the GST tax invoice; we never see or store your card, UPI, or bank credentials.

2.3B ECG data processed through the Spandan software

If you offer the ECG Service, the Spandan software made by Sunfox Technologies Private Limited ("Sunfox") runs on your phone within the provider app during an ECG Booking. It processes the patient's ECG recording and the patient details described in Section 6.1A, and sends them to Sunfox for report generation and cardiologist interpretation. The reports are returned to HoMedi and stored in the patient's HoMedi records.

2.4 What we do not collect

• We do not collect your bank or payout details: your fees (including the ECG Package Price) are paid to you directly by patients in cash/UPI and never pass through the Platform, Subscription payments are processed by Razorpay (Provider Portal) or Google (Google Play), and Credit payments are processed by Razorpay. Where a refund under the Refund & Cancellation Policy must be made by bank transfer, we collect only the bank details needed for that refund.

• If you record your earnings, we store only the amount and payment method you enter (Section 2.1); we do not receive any payment.

• Personal data never appears in system logs; logs reference internal record identifiers only.

• We do not sell personal data and do not use it for third-party advertising.

3. Purposes of Processing and Legal Basis

We process your personal data on the basis of your consent (DPDPA Section 6) and, where applicable, for legitimate uses under DPDPA Section 7 (including compliance with law). Purposes:

Records storage as a technology service: the visit records, procedure notes, and prescriptions you create on the Platform are stored by NeXora as a technology service so that every Provider — including a Provider who does not maintain a clinic or premises of their own — can meet their professional record-keeping obligations and retrieve those records when needed. This does not create any employment, agency, or partnership relationship between you and NeXora, and does not make NeXora a healthcare provider. The clinical content of every record remains your professional responsibility; retention and erasure follow Section 8.

4. What Patients and Others Can See

• Patients within your discovery radius see your professional profile: name, provider type and category, specialization, languages, Rate Card, locality/apartment-complex proximity badge, distance, and verification status. Your exact home address and phone number are not shown in discovery.

• During a masked call, the patient sees a HoMedi number, not your phone number.

• A booked patient additionally receives arrival coordination information, including your approach location during "on my way", for that visit only.

• Your registration number may be displayed on prescriptions you issue, as required by prescribing regulations.

• We may indicate that a provider was removed from the Platform, without publishing reasons, except as required by law or a regulator.

5. Consent — and How to Withdraw It

• At registration we present an itemised notice and request your consent by clear affirmative action.

• You may withdraw consent at any time from Settings → Privacy & Data or by writing to the contacts in Section 11. Withdrawal is as easy as giving consent. Because discovery, verification, and booking cannot operate without the associated data, withdrawal of consent for core processing will be treated as a request to delist; processing before withdrawal remains lawful.

• Going "offline" in the app immediately stops discovery and location processing without affecting your account.

• You can remove your HPR link, or unlink your ABHA, at any time in the app. We then delete the linked identifiers we hold; records already shared through ABDM are not recalled.

• Communication preferences: transactional messages (booking alerts, OTPs, policy and safety notices) are part of the service and continue while you are listed. Promotional messages are sent only with your separate, optional consent, withdrawable at any time in Settings; we honour TRAI DND preferences for promotional content.

• You can review and update your profile information at any time in the app; if you cannot correct something in-app, contact providers@homedi.in or the Grievance Officer. Changes to credential data trigger re-verification.

• Once Consent Managers registered under the DPDP Rules are operational, we will support consent management through them.

6. Sharing of Personal Data

6.1 Service providers (Data Processors)

Google (Google Play) processes Subscription payments made within the HoMedi provider app as an independent party under its own terms and privacy policy, not as our processor.

6.1A Sunfox Technologies (Spandan) — ECG Service

• What is sent: to record and interpret an ECG, the Spandan software on your phone processes and sends to Sunfox's servers: the ECG signal (waveform) and the measurements derived from it; the patient's first and last name, age, gender, height, and weight; and a visit reference. The patient's HoMedi account ID and phone number are not sent.

• What comes back: Sunfox generates an automated preliminary report and arranges interpretation by a Spandan cardiologist. The reports are returned to HoMedi and stored in the patient's HoMedi records.

• Roles: Sunfox acts as our service provider (Data Processor) for the ECG technology. Spandan cardiologists act as healthcare professionals in interpreting the ECG.

• Location: as informed by Sunfox, this data is processed in India.

6.1B Masked calls and call recording

• Calls between you and a patient for a confirmed or in-progress visit are placed by MSG91 as masked calls: MSG91 rings the caller first and then connects the other party, and each party sees a HoMedi number, not the other's phone number. Masked calls are available only around the scheduled visit time, and the number of calls per hour is limited.

• Calls are recorded. Recordings of masked calls are stored by MSG91 on NeXora's behalf. They are used only to resolve complaints and grievances, investigate safety incidents, and meet legal requirements. Access to recordings is restricted to authorised personnel.

• NeXora and MSG91 also keep call metadata — the time, duration, and status of the call, and the numbers used for routing.

• Recordings and call metadata are kept for 90 days, as set out in Section 8.

6.2 Regulators, government, and others

• Professional councils / registries: we query NMC/HPR/State Dental Council/SNC registers to verify you, and may report credible findings of impersonation, practice without registration, or serious professional misconduct to the relevant council where required or permitted by law.

• ABDM / National Health Authority (NHA): HoMedi takes part in the Ayushman Bharat Digital Mission as a Health Information Provider and Health Information User. If you link an ABHA, verification is performed through ABDM systems. If you link your HPR ID, we confirm it with the Healthcare Professionals Registry run by the NHA. When a patient who has linked an ABHA completes a visit with you, the visit is registered with ABDM under HoMedi, and the records you created for it (prescriptions, notes, vital signs, and reports) can be shared with other providers the patient consents to; those records carry your name and, if linked, your HPR ID. When you ask for a patient's records from other providers, the request is sent through ABDM with your name and registration number, and the patient sees both in their ABHA app before deciding.

• Legal: disclosure where required by law, court order, or to state instrumentalities as permitted under the DPDPA; and to protect the safety of patients and users.

• Corporate events: on merger, acquisition, or reorganisation, data may be transferred to a successor bound by this Policy and the DPDPA, with notice.

7. Data Residency and Security

• All personal data is stored in India (AWS Mumbai region, ap-south-1).

• Data sent to Sunfox for the ECG Service is processed in India, as informed by Sunfox (Section 6.1A).

• Sensitive fields (phone number, name, date of birth, email, ABHA number) are encrypted at the field level; data in transit is protected by TLS.

• Access to production data is role-restricted and recorded in an append-only audit trail archived to tamper-evident (write-once) storage.

• OTP login is rate-limited; sessions use short-lived signed tokens revocable on logout.

• Application logs contain no personal data — internal identifiers only.

8. Data Retention and Erasure

• We retain your personal data while your account is active and as long as necessary for the stated purposes.

• After delisting or account deletion: profile data is removed from discovery immediately. Records of completed visits, prescriptions you issued, and related audit entries are retained for the periods required by medical record-keeping law, tax law, and the DPDP Rules, then erased or anonymised. Subscription transaction records, ECG Interpretation Credit purchase records, and GST tax invoices are retained for the periods required by tax and accounting law.

• Earnings records you choose to enter are retained while your account is active and, after delisting or account deletion, only as long as necessary for the purposes in Section 3 or as required by law.

• HPR and ABHA identifiers are deleted when you remove the link in the app (Section 5).

• Identity verification (KYC) records are retained while you are listed, so that we can show that verification was performed and re-verify you when required, and thereafter only as long as required by law.

• Call recordings and call metadata from masked calls are kept for 90 days from the date of the call and are then deleted. If, within that period, a recording is needed to resolve a complaint or grievance, to investigate a safety incident, or to meet a legal requirement, it is kept until that matter is closed, and then deleted.

• Erasure requests: on a valid request we erase or anonymise your personal data and instruct processors to do the same, except where retention is required by law — noting that prescriptions, visit records, and ECG reports also constitute patients' health records and are retained accordingly.

• Inactivity: if the DPDP Rules' user-inactivity erasure obligations apply to your account class, we will erase data after the prescribed period of inactivity, with at least 48 hours' prior notice.

9. Your Rights as a Data Principal

Under the DPDPA you may, free of charge, via Settings → Privacy & Data or the contacts in Section 11:

• Access a summary of your personal data, processing activities, and recipients;

• Correct and complete inaccurate or outdated data (note: changes to credential data trigger re-verification);

• Erase personal data, subject to legally required retention (Section 8);

• Raise grievances and receive a response within prescribed timelines — including grievances about verification outcomes, no-show records, or suspension;

• Nominate a person to exercise your rights on death or incapacity;

• Withdraw consent at any time (Section 5).

We verify identity via your registered phone number before acting on requests. Unresolved grievances may be escalated to the Data Protection Board of India as prescribed under the DPDPA.

10. Personal Data Breach

If a personal data breach affects you, we will notify you without delay through your registered communication channel — describing the breach, its likely consequences, mitigation taken, and recommended steps — and will notify the Data Protection Board of India in the form and timelines prescribed by the DPDP Rules (initial intimation without delay, detailed report within 72 hours).

11. Grievance Officer / Data Protection Officer

• Grievance Officer / DPO: Manoj Kumar, Data Protection Officer

• Email: dpo@homedi.in| Address: 4-12-927/1, Plot No. E1, RD-1, Portion C, Auto Sai Nagar Colony, Vanasthalipuram, Hyderabad, Rangareddy District, Telangana – 500070 | In-app: Settings → Help & Grievances

Data-protection grievances are acknowledged within 48 hours and answered within the timelines prescribed under the DPDPA and DPDP Rules, and in any case within 30 days.

12. Changes to This Policy

We may update this Policy from time to time. Material changes will be notified in the app before they take effect, and the "Last Updated" date revised. New purposes of processing will be subject to fresh notice and consent as required by the DPDPA.

13. Contact

NeXora Health Systems Private Limited, 4-12-927/1, Plot No. E1, RD-1, Portion C, Auto Sai Nagar Colony, Vanasthalipuram, Hyderabad, Rangareddy District, Telangana – 500070 (registered office). Privacy matters: dpo@homedi.in Provider support: providers@homedi.in