a. What is personal data? 

 “Personal data” means any information relating to an identified or identifiable natural person, known as ‘Data Subject’, who can be identified directly or indirectly; it may include name, address, gender, email address, phone number, IP address, location data, cookies, call records and similar information. It may also include “special categories of personal data” such as racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a Data Subject, data concerning health or data concerning a natural person’s sexual orientation. 

b. What Personal data does Qure collect and process? 

Qure receives, processes and stores two distinct sets of personal data.  We will process the following personal data on the Services: 

1. User profiles

• First and Last Name 
• E-mail address at the time of sign up 

2. Technical usage data

• such as the URL you are accessing the Services from, your IP address, unique device ID, network and computer performance, browser type, language and identifying information and operating system;  
• information about your use of the Services, such as what you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks and mouse-overs), consultation length(s), recurrence of visits and other interaction information, methods used to browse away from the page. 

3. A third set of personal data is processed using the QureApp, which you as a User will upload the data on the platform and Qure will act as Data Processor on behalf as of you as Data Controller for this data:

• Anonymised patient case information pseudonymized DICOM images including embedded metadata;  
• content that you post, upload and/or contribute to the Services; 

For the data listed in clause II (b) (3) above, where you as a User of the Services will act as Data Controller and Qure  as provider of Services, will act as a Data Processor, you hereby acknowledge and agree for Data Processing Agreement which is effective from the date of your first use of Services. The Data Processing Agreement outlines what kind of processing we are instructed to perform on your behalf regarding Personal data pertaining to Data Subjects where you are the Data Controller. 

Information about third parties should only be provided to us if you have demonstrable permission and consent of Data Subjects i.e., your patients, to do so or if the information is available in the public domain. You shall be solely responsible for receiving all informed, written, explicit or implicit consents as required under applicable laws, from the Data Subjects i.e., your patients or similar data owners. Your use of Services is deemed that such consents have been duly received by you and will be available upon request for Qure to audit. We will rely on you to provide information which is accurate, complete and up to date and you agree to ensure this.  

Qure will process the Personal data sets described above for the following purposes:  

• To enable you to verify your account, to administer your account, to enable and provide the Services and integration with third party services, and to provide, personalize and improve your experience with the Services, and to otherwise provide the Services according to the Terms of Service;  

• to send you alerts or messages by email or otherwise, including to provide you with marketing of our and our related parties’ products and services; 
• to inform you about updates of the Services or the terms and conditions of Services; 
• to improve and develop the Services or new services and to analyse your use of the Services; 
• to ensure the technical functioning of the Services and to prevent the use of the Services in breach of the Terms (including the Universal Terms and any other terms in relation to Application or Services); 
• to enforce the Terms and any additional Terms (including the Universal Terms and any other terms in relation to Application or Services), including to protect our rights, property and safety and the rights, property and safety of third parties if necessary;  

• to fulfil our obligations as Data Controller and Data Processor; 
• to respect and fulfil our obligations in regards to the Rights of the Data Subject; 
• to respond to any queries you raise with us and to provide customer support; and  
• to fulfil requirements by law (see clause VIII below).  

We will be unable to provide you the Services unless you provide us with the Personal data listed in clause II.b above. The processing of the Personal data above is necessary to enter into the Terms (including Universal Terms) with us and to maintain the contractual relationship between you and us, where Qure will act as Data Processor for the collected data. Some of this collected information is subject to processing of third parties, both within and outside the European Union (third countries). 

The data listed in clause II.b.2 above is solely collected and used for performance and issue handling pertaining to the platform and will not be used for identifying you as a user, unless this is requested by official legal investigations as in provided in clause VIII below. 

The processing of your Personal data for the purposes listed above is conducted on the basis of the legitimate interest of Qure. Our legitimate interest for the processing is maintaining sufficient IT security through logging data when you use our Services and to evade fraud and to protect the Services from cyber threats. We also log data for the maintenance and improvement of our Services. 

Personal data about registered users will be retained for as long as the user has an active profile on the Services. users who have not used our Services will have all personal data deleted after 1 year of inactivity on the Services. 

If you agree to be added to our mailing list, we will keep your personal information for that purpose unless and until you tell us that you want to unsubscribe or be removed from the list. If you advise that you do not want to be added to our mailing list or you ask to be removed, we will delete your Personal data (aside from keeping a record that you have asked us not to send you marketing information). 

The QureApp and the Services provided under it are not directed at, marketed to, nor intended for, children under 18 years of age. The Website does not knowingly collect or solicit information from anyone under the age of 18 or allow anyone under the age of 18 to sign up for the Service. In the event that you learn that you have gathered personal information from anyone under the age of 18 without the consent of a parent or guardian, you will delete that information as soon as possible. 

You are required under the Children’s Online Privacy Protection Act (“COPPA”) as well as the GDPR and other Personal Data Protection laws (as those may apply) to obtain verifiable parental consent (or from the child’s legal representative) in order to collect, use or disclose Personal Data pertaining to that child. 

If you are a parent or guardian of a person under the age of 18 and you become aware of that the child has provided personal data to us without your consent, please contact dpo@qure.ai  to exercise your access, rectification, erasure, limiting of processing and objection rights. 

The importance of security for Personal data is of great concern to us. At Qure, we have gone to great lengths to manage the security and integrity of the Services and to ensure that we use best–in-class services when providing secure transmission of information from your device. Personal Data collected via the Services is stored in secure environments that are not available or accessible to the public; only those duly authorised people, officers, employees or agents of Qure who need access to your information in order to do their jobs are allowed access.  

Anyone who violates our privacy or security policies is subject to disciplinary action, including possible termination of their contract with Qure and civil and/or criminal prosecution. Qure uses the latest technologies to ensure utmost security, including utilising several layers of firewall security and encryption of Personal data to ensure the highest level of security. As a result, while we strive to protect your Personal data, you acknowledge that: 

(a) there are security and privacy limitations of the Internet which are beyond our control; 

(b) the security, integrity and privacy of any and all information and data exchanged between you and us through this Website cannot be guaranteed; and 

(c) any such information and data may be viewed or tampered with in transit by a third party. 

To exercise your rights, or if you have any questions or complaints regarding our processing of your personal data, please contact us our grievance officer, Vivek Anand at the following email ID – dpo@qure.ai. In your letter/email please state your full name, your username (if you are a user) and which institution you are linked to. Note that you should sign the request to receive information about the processing of your personal data yourself. 

If we make changes to this Privacy Notice, we will notify you by posting a copy of the updated policy on our Services prior to any change becoming effective. We will post a copy of the updated policy on our Services prior to any change becoming effective. If your consent is required due to the changes, we will provide you additional prominent notice as appropriate under the circumstances and ask for your consent in accordance with applicable law.