01 Data Fiduciary & Data Processor
Under the Digital Personal Data Protection Act, 2023 (DPDPA):
The Clinic = Data Fiduciary
The healthcare provider that registers on the Platform determines the purpose and means of processing personal data. The clinic is responsible for patient consent, data accuracy, and responding to patient rights requests.
Anvera = Data Processor
Anvera Technologies Pvt. Ltd. processes personal data solely on behalf of the clinic, under their instructions. We implement security measures and assist with compliance obligations.
This distinction is critical: Anvera does not independently decide what data to collect or how to use it — that responsibility lies with the clinic (Data Fiduciary). Anvera provides the tools and infrastructure.
02 Data We Collect
The Platform processes the following categories of data:
2.1 — Clinic & Staff Data
| Data Type | Examples | Encrypted |
|---|---|---|
| Clinic information | Name, address, contact email, phone, GST number, logo | No |
| Admin/Doctor credentials | Email, hashed password, first name, last name | Password: bcrypt hashed |
| Doctor profile | NMC registration number, phone, profile picture, specialty, custom attributes | Phone: Yes (Fernet) |
2.2 — Patient Data
| Data Type | Examples | Encrypted |
|---|---|---|
| Identity | Full name, gender, blood group, profile picture | No |
| Contact | Phone number, email address | Yes (Fernet) |
| Date of birth | Full date of birth | Yes (Fernet) |
| Health identifiers | ABHA ID, billing category (CGHS/ECHS/Standard) | No |
| Medical history | Pre-existing conditions, allergies, notes | Yes (Fernet) |
| Clinical records | SOAP notes, conditions, ICD codes, prescriptions, specialty chart findings, attachments | No (structured clinical data) |
| Financial | Invoices, payment amounts, payment methods, ledger entries | No |
| Appointments | Date, time, doctor, status, check-in/out timestamps | No |
2.3 — Usage & Technical Data
We may collect standard web server logs including IP addresses, browser type, and access timestamps for security monitoring and debugging. We do not currently deploy third-party analytics or advertising trackers.
03 Purpose of Data Processing
Personal data is processed for the following purposes:
- Healthcare delivery: Managing patient records, appointments, consultations, prescriptions, and treatment plans
- Billing & invoicing: Generating GST-compliant invoices, tracking payments, and maintaining financial records
- Notifications: Sending appointment reminders, birthday wishes, payment confirmations, and follow-up notifications via SMS, WhatsApp, or email on behalf of the clinic
- Platform operations: User authentication, role-based access control, audit trail, and security monitoring
- Analytics: Aggregated, non-personally-identifiable KPI dashboards for clinic administrators (revenue, appointment counts, treatment plan conversion)
- AI-assisted documentation: Generating SOAP note suggestions and clinical assessment summaries (processed locally, not shared with third-party AI services unless explicitly configured)
- Legal compliance: Maintaining medical records per NMC retention rules, audit trails per regulatory requirements
04 Legal Basis for Processing
We process personal data under the following legal bases:
- Consent: The clinic (Data Fiduciary) obtains patient consent for data collection. The clinic administrator consents to these terms upon registration.
- Legitimate interest: Platform operations, security monitoring, and debugging to ensure reliable service delivery.
- Legal obligation: Retention of medical records per NMC guidelines. Retention of financial records per applicable tax and accounting laws.
- Performance of contract: Processing necessary to deliver the services described in our Terms of Use.
05 Data Encryption & Security
We implement multiple layers of security:
Encryption at Rest
PII fields (date of birth, contact information, medical history) are encrypted using Fernet symmetric encryption at the application level before being written to the database.
Encryption in Transit
All communication between the client application and server is encrypted via HTTPS/TLS 1.2+.
Authentication
JWT-based authentication with bcrypt password hashing (cost factor 12). Role-based access control (RBAC) restricts data access by user role and clinic.
Database Security
PostgreSQL with parameterised queries (ORM-level SQL injection prevention). Connection restricted to application server only.
Additionally, we employ rate limiting on authentication endpoints, immutable audit logs for critical actions, and soft-deletion of medical records (flagged, not physically removed) to comply with record-retention regulations.
06 Cross-Clinic Data Isolation
anvera care operates on a multi-tenant architecture with strict data isolation:
- Every database query is scoped by
clinic_id, ensuring no cross-clinic data leakage - A doctor associated with Clinic A and Clinic B can only view Clinic A's data when logged into Clinic A's context, and vice versa
- Patient records, appointments, invoices, and clinical notes are bound to the clinic that created them
- Clinic Administrators cannot access data from sibling clinics, even within the same billing account
- Cross-clinic doctor linking (for quota purposes) does NOT grant cross-clinic data access
07 Data Retention
| Scenario | Retention Period | Notes |
|---|---|---|
| Active subscription | Indefinite | Data retained as long as the account is active |
| Post-termination | 90 days | Data available for export; permanently deleted after 90 days |
| Soft-deleted records | Per NMC rules | Medical records marked as deleted are retained per regulatory requirements |
| Audit trail | Indefinite | Immutable logs are never deleted |
| Subscription expiry (no renewal) | 90 days grace | Access restricted; data available for export during this period |
08 Third-Party Processors
We may engage the following categories of third-party sub-processors to deliver Platform services:
| Service | Purpose | Data Shared |
|---|---|---|
| Cloud hosting (AWS) | Application & database hosting | All platform data (encrypted at rest) |
| Frontend CDN (Vercel) | Frontend application delivery | No patient data (static assets only) |
| SMS provider | Appointment reminders, notifications | Patient phone number, message content |
| WhatsApp BSP | WhatsApp notifications | Patient phone number, template variables |
| Email service | Transactional emails | Recipient email, message content |
We do NOT sell, rent, trade, or otherwise share personal data with third parties for marketing, advertising, or any purpose beyond delivering Platform services.
09 Data Principal Rights (DPDPA 2023)
Under the DPDPA 2023, patients (Data Principals) have the following rights with respect to their personal data:
- Right to Access: Request a summary of personal data processed and the processing activities undertaken
- Right to Correction: Request correction of inaccurate or incomplete personal data
- Right to Erasure: Request deletion of personal data, subject to medical record retention requirements under NMC regulations and applicable law
- Right to Grievance Redressal: Lodge a complaint with the clinic (Data Fiduciary) or with the Data Protection Board of India if the complaint is not resolved satisfactorily
- Right to Nominate: Nominate another individual to exercise rights on your behalf in case of death or incapacity
How to exercise your rights: Since the clinic is the Data Fiduciary, data access, correction, and erasure requests should be directed to the clinic that holds your records. Clinics can contact us at info@anveracare.com for technical assistance in fulfilling these requests. The Platform provides CSV export functionality to support data portability.
10 Cookies & Local Storage
The Platform uses the following client-side storage mechanisms:
- localStorage ("token"): Stores the JWT authentication token for maintaining your logged-in session. This is essential for Platform functionality and is not a tracking mechanism.
- localStorage ("clinics"): Stores your clinic membership list for the clinic switcher functionality.
We do not use:
- Third-party tracking cookies (Google Analytics, Facebook Pixel, etc.)
- Advertising cookies or retargeting pixels
- Cross-site tracking mechanisms
If we introduce analytics in the future, we will update this Privacy Policy and provide appropriate notice.
11 Children's Data
The Platform is designed for use by healthcare professionals and clinic administrators. It is not intended for direct use by children under 18 years of age. However, patient records for minors may be created and managed by the clinic with the consent of the patient's parent or legal guardian, as required by the DPDPA 2023.
Clinics are responsible for ensuring they have appropriate parental or guardian consent before creating records for minor patients.
12 Data Breach Notification
In the event of a personal data breach:
- Anvera will notify affected clinics (Data Fiduciaries) within 72 hours of becoming aware of the breach
- The notification will include: nature of the breach, categories and approximate number of affected records, likely consequences, and measures taken to mitigate the breach
- As the Data Fiduciary, the clinic is responsible for notifying affected patients (Data Principals) and the Data Protection Board of India, as required under the DPDPA 2023
- Anvera will cooperate fully with the clinic and any regulatory authority during the investigation
13 International Data Transfers
All Platform data is currently hosted on servers located in India (AWS Mumbai / ap-south-1 region). We do not transfer personal data outside India.
If cross-border data transfer becomes necessary in the future (e.g., for disaster recovery or using international sub-processors), we will:
- Ensure compliance with DPDPA 2023 provisions on cross-border data transfer
- Only transfer data to jurisdictions approved by the Central Government
- Update this Privacy Policy accordingly
14 Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, services, or applicable law. Material changes will be communicated to registered users via email or an in-platform notification at least 30 days before the effective date.
Your continued use of the Platform after the effective date of the updated Privacy Policy constitutes your acceptance of the changes. The latest version of this Policy will always be available at anveracare.com/privacy.
15 Grievance Officer
In accordance with the DPDPA 2023, we have appointed a Grievance Officer to address your concerns regarding data processing:
Grievance OfficerAnvera Technologies Pvt. Ltd.Email: info@anveracare.comWe will acknowledge your complaint within 48 hours and endeavour to resolve it within 30 days.
If you are not satisfied with our response, you have the right to approach the Data Protection Board of India established under the DPDPA 2023.
16 Contact
For any privacy-related questions or concerns, please contact us:
Anvera Technologies Pvt. Ltd.Email: info@anveracare.comJurisdiction: Noida, Uttar Pradesh, India