1. Core Health Data Privacy Principles
At Tello Healthcare Technologies Private Limited (operating "TelloDoc"), we hold patient confidentiality and doctor clinical record privacy as sacred. We believe clinical information must never be treated as commercial advertising collateral.
The TelloDoc 4-Point Health Privacy Guarantee:
- Zero Third-Party Advertising Pixels: We never deploy Meta Pixel, Google Remarketing, or ad tracking SDKs inside clinical case sheets, prescriptions, or patient token queues.
- Strict Data Minimization: We only collect data strictly necessary to facilitate walk-in token queues, clinical documentation, and billing receipts.
- No Sale of Data: Patient health records, medical conditions, and prescriptions are never sold, rented, or brokered to insurance agents, pharma marketing reps, or data aggregators.
- Indian Sovereign Storage: Platform clinical records reside exclusively in data centers located within the territorial borders of the Republic of India.
2. Categories of Data We Collect
Depending on whether you use TelloDoc as a Patient, a Doctor, or a Channel Partner, we process the following categories of information:
Patient / Citizen Data
Phone number (for OTP verification and token SMS alerts), full name, age, gender, known drug allergies, presenting chief complaints, and optional Ayushman Bharat Health Account (ABHA) address.
Doctor & Clinic Data
Full name, email, phone number, NMC / State Medical Council Registration Number, medical qualifications, clinic physical address, geo-coordinates, consultation fee schedules, and bank/UPI payout details.
Clinical Consultation Records
S.O.A.P. notes (Subjective, Objective, Assessment, Plan), recorded vitals, prescribed pharmaceutical items, follow-up dates, diagnostic advice, and cryptographic signature verification hashes.
Technical & Operational Logs
IP address, browser user-agent, session timestamps, and WebRTC peer connection signaling telemetry used strictly for audio/video call connectivity quality.
3. Lawful Basis & Purpose under DPDP Act
Under DPDP Act 2023 Section 4 and Section 6, we process personal and health data strictly pursuant to informed consent or specified lawful purposes:
- Live Queue Management: To allocate token numbers, calculate live estimated wait times, and alert patients when their turn arrives.
- Clinical Documentation: To allow the Registered Medical Practitioner to construct, digitally sign, and archive clinical case sheets and prescriptions compliant with NMC (2023) regulations.
- Receipts & Invoices: To generate patient billing receipts and allow doctors to reconcile daily cash and UPI collections.
- Continuity of Care: To dispatch automated medicine refill reminders and scheduled follow-up check-ins configured by the treating doctor.
- Telemedicine Signaling: To establish encrypted peer-to-peer WebRTC video and audio channels between patient and doctor.
4. Your Statutory Data Principal Rights
As a Data Principal under India's Digital Personal Data Protection Act, 2023, you possess clear statutory rights:
- Right to Access Summary: You have the right to obtain a summary of personal data held about you and a list of identities of all data processors with whom your data was shared.
- Right to Correction & Updation: You can request the correction of inaccurate or incomplete personal data via your patient profile or by emailing our Data Protection Officer.
- Right to Erasure / Deletion: You may request the deletion of your account and personal identifiers, subject to statutory medical record retention obligations imposed on Registered Medical Practitioners under NMC regulations.
- Right to Withdraw Consent: Where processing is based on consent, you may withdraw your consent at any time via your settings or written notice.
- Right to Nominate: You have the right to nominate any other individual to exercise your privacy rights in the event of death or incapacity.
5. Zero Behavioral Profiling & Isolation from Ads
We enforce strict architectural isolation between our clinical software and any external promotional networks:
- No Cross-Site Tracking: We do not track patient browsing behavior across external websites or build consumer profiling dossiers.
- ABDM Health Locker Isolation: Prescriptions and lab records linked to Ayushman Bharat Health Accounts (ABHA) remain isolated in accordance with the National Health Authority (NHA) ABDM data sandbox standards.
- Sponsor Disclosures: Any institutional banners displayed on neutral directory sections (e.g. NABL accredited pathology services) are contextual and non-targeted; they do not access patient diagnostic queries or health histories.
6. Technical Architecture & Data Security
We deploy defense-in-depth technical safeguards to protect sensitive electronic health records:
- Data Encryption in Transit: All HTTP traffic is enforced over TLS 1.3 / HTTPS using HSTS. WebRTC video and audio streams utilize SRTP with AES-128/256 bit end-to-end media encryption.
- Data Encryption at Rest: Database storage volumes, backups, and file attachments are encrypted with AES-256 encryption.
- Access Control: Clinic records are protected by role-based access control (RBAC). Only the patient and their authorized treating doctor have access to the patient's full longitudinal case history.
- Audit Logging: All access to clinical case sheets and administrative modifications is logged with immutable timestamps for medical-legal audit readiness.
7. Data Retention & Statutory Medical Storage
Data retention is balanced between data minimization principles and mandatory Indian medical record compliance:
- NMC 3-Year Record Mandate: In accordance with the NMC Professional Conduct Regulations, 2023, medical practitioners are legally required to maintain OPD consultation records, prescriptions, and case sheets for a minimum period of 3 (three) years from the date of consultation.
- Inactive Patient Accounts: If a patient account remains inactive for greater than 3 years and there are no active medico-legal holds, identifying demographic records may be anonymized or purged upon request.
8. Infrastructure & Technical Sub-Processors
We engage high-compliance infrastructure partners bound by rigorous Data Processing Addendums (DPAs):
- Cloud Infrastructure: AWS Asia Pacific (Mumbai) / DigitalOcean (Bengaluru) sovereign Indian data center regions.
- Transactional SMS / WhatsApp: TRAI DLT-registered Indian telecom gateways for OTP and token delivery.
- Payment Aggregators: RBI-licensed payment gateways (Razorpay / Cashfree) adhering to PCI-DSS Level 1 compliance.
9. Data Protection Officer & Contact Details
To exercise your DPDP statutory rights, request data correction/erasure, or submit a privacy grievance, please reach out to our designated Data Protection Officer:
Designation: Data Protection & Legal Compliance Desk
Entity: CloudEye Technologies
Email: support@tellodoc.in
Office Address: Siripuram, Vizag, Andhra Pradesh, India
All data subject requests are acknowledged within 24 hours and addressed within 7 business days. You also retain the statutory right to escalate unresolved privacy grievances to the Data Protection Board of India (DPBI).