Tracky Health Privacy Policy

Tracky Health Legal Agreement and Privacy Notice

Version Date: January 2025

Introduction

Please read this Privacy Notice (the “Privacy Notice”) for the Tracky Health App carefully before accepting it. Acceptance of this Privacy Notice will transmit your personal information, including health-related information, into a Tracky Health account which stores information in the cloud within your local region. BY ACCEPTING THIS PRIVACY NOTICE AND USINGTRACKY HEALTH APP , YOU AFFIRM THAT YOU ARE OF LEGAL AGE TO ACCEPT THIS PRIVACY NOTICE, AND THAT YOU ARE AGREEING EITHER ON YOUR OWN BEHALF, OR ON BEHALF OF ANOTHER INDIVIDUAL FOR WHOM YOU HAVE ACTUAL AUTHORITY TO LEGALLY ACCEPT TO THIS PRIVACY NOTICE.

Definition

According to the EU General Data Protection Regulation (GDPR), personal information refers to any information related to an identified or identifiable natural person ("data subject"), and an identifiable natural person refers to a person who can be directly or indirectly identified by referring to his/her name, ID number, location data, online identifier or one or more factors specific to the physical, physiological, genetic, psychological, economic, cultural or social status of the natural person. Personal information in this privacy policy is your personal information that we collect, transmit, store, use and share for the purpose of providing services to you.

Business data, unlike personal information refers to the data that you upload, download, store and process by using our service.


Drstore Healthcare Services India Pvt Ltd., of SA 44, 2nd Floor Lake City Mall, Ghod Bunder Road, Kapurbawdi, Thane, Maharashtra, INDIA 400607, is the product owner, developer and controller of personal information transmitted through the Tracky Health App and the Tracky Health cloud. 

You may contact us at the addresses above or at info@drstore.in

You,” “your,” or the “user” in this Privacy Notice are referring to the individual using the Tracky Health App . “Drstore,” “us,” “our,” or “we” in this Privacy Notice are referring to Drstore Healthcare Services India Pvt Ltd.

Drstore recognizes the importance of data protection and privacy and is committed to protecting your personal information, including health-related information.

Legal Statement

Rights

  • Our logo, "Drstore, Tracky, Tracky Health, and other logos, characters, graphics and their combinations, as well as our other identifiers, emblems, the names of our services are registered trademarks of us and Drstore Healthcare Services India Pvt Ltd. in India and other countries. Without our written authorization, no one is allowed to display, use or otherwise process them (including but not limited to copying, spreading, displaying, mirroring, uploading or downloading), or show others that you have the right to display, use or otherwise process them.

  • The intellectual property rights of all our products, services, technologies and applications (hereinafter referred to as "technical services") are owned by us or the right holders.

  • Unless otherwise stated, we own all rights (including but not limited to copyright, trademark right, patent right, trade secret and all other related rights) of the published documents and other information (including but not limited to words, graphics, pictures, photos, audio, video, icons, colors, layout and electronic documents) in the software. Without our permission, no one may use the above contents (including but not limited to monitoring, copying, broadcasting, displaying, mirroring, uploading and downloading any contents in our software through programs or devices). If you are authorized to browse, copy, print and disseminate information in our software, such information shall not be used for commercial purposes, and all information content and any part thereof must include this statement of rights.


This Privacy Notice explains how we handle personal information including health-related information that you provide to us through your use of the Tracky Health App. Drstore uses and disclosures of Protected Health Information (sometimes called ‘PHI’) are subject to the Health Insurance Portability and Accountability Act (HIPAA).

This Privacy Notice does not apply to personal information collected by Drstore (including its subsidiaries and affiliates) via other methods, such as websites, customer call centers, or other software; nor does this Privacy Notice apply to other third-party web sites.

YOUR USE OF THE TRACKY HEALTH APP CONSTITUTES, AND IS CONDITIONED UPON, YOUR ACCEPTANCE OF THIS PRIVACY NOTICE. IN CERTAIN EXCEPTIONAL CIRCUMSTANCES, DRSTORE’S DATA PROCESSORS MAY NEED TO ACCESS YOUR PERSONAL INFORMATION, INCLUDING HEALTH-RELATED INFORMATION. BY ACCEPTING, YOU EXPLICITLY ACKNOWLEDGE THAT THIS PRIVACY NOTICE WILL APPLY TO YOUR USE OF THE TRACKY HEALTH APP AND TO YOUR USE OF THE TRACKY HEALTH CLOUD AND TO THE PROCESSING AND TRANSFER OF YOUR PERSONAL INFORMATION, INCLUDING HEALTH-RELATED INFORMATION, AS SET OUT IN THIS PRIVACY NOTICE.

The index and headings in this Privacy Notice are for your convenience only, and do not limit, define, or fully explain each section.

  1. Background of the Tracky Health App and the Tracky Health cloud.

  2. No medical advice.

  3. Unauthorized third party products.

  4. What does this Privacy Notice apply to?

  5. What information does this Privacy Notice govern?

  6. How is personal information handled?

  7. How long does Drstore store personal information?

  8. Does Drstore share personal information with third parties?

  9. How does Drstore secure personal information?

  10. Where does Drstore store and transfer personal information?

  11. Will Drstore send me marketing material?

  12. How does Drstore protect the privacy of children?

  13. How may I access and/or correct my personal information?

  14. What rights do I have over my personal information?

  15. How do I delete my Tracky Health account?

  16. How can I contact Drstore?

  17. Changes to this Privacy Notice.

1. Background of the Tracky Health App.

Drstore is the developer of continuous glucose monitoring, blood pressure, and other vitals, management software. You can use the TRACKY HEALTH app to collect data from Your recommended Bluetooth enabled continuous glucose monitor, and other vital signs devices, with your mobile device which connects with tracky health app, or by manually entering the glucose, blood pressure, heart rate, weight, and other vitals values from a non-Bluetooth enabled medical device. The TRACKY HEALTH app will then use that collected data to display your glucose, blood pressure and other vitals values and calculate an average, which will be uploaded to and stored in the TRACKY HEALTH Cloud. In turn, the TRACKY HEALTH app, being a secure, cloud-based platform, connects to the TRACKY HEALTH Cloud, which is used by healthcare professionals to view user (patient) data. This aids in the review, analysis, and evaluation of historical data, and user-entered information, including blood pressure, heart rate, weight, height, glucose, respiratory rate, oxygen saturation, temperature, food logs, activity, and basic clinical medical history (hence forth known as biometric data), to support an effective health management program. Use of the TRACKY HEALTH app may require: compatible devices, internet access, data usage (charges may apply), certain software (fees may apply), and periodic updates, and the performance of the TRACKY HEALTH App may be affected by these requirements.

2. No medical advice.

THE TRACKY HEALTH APP IS NOT INTENDED FOR THE DIAGNOSIS OF OR SCREENING FOR METABOLIC HEALTH, DIABETES OR HYPERTENSION OR ANY OTHER MEDICAL CONDITION. USERS SHOULD BE AWARE THAT THE TRACKY HEALTH APP IS AN INFORMATION MANAGEMENT SERVICE TO ENABLE THE ANALYSIS OF BIOMETRIC DATA AND IS NOT INTENDED TO BE A SUBSTITUTE FOR THE ADVICE OF A HEALTH CARE PROFESSIONAL. INDIVIDUALS SHOULD ALWAYS CONSULT THEIR DOCTOR OR OTHER QUALIFIED HEALTH CARE PROFESSIONAL WITH ANY QUESTIONS THEY MAY HAVE REGARDING A MEDICAL CONDITION, INCLUDING ANY QUERIES OR CONCERNS ABOUT METABOLIC HEALTH, BLOOD PRESSURE, DIABETES OR OTHER MEDICAL CONDITION MANAGEMENT. YOU SHOULD NEVER DISREGARD PROFESSIONAL MEDICAL ADVICE OR DELAY IN SEEKING IT BECAUSE OF INFORMATION TRANSMITTED TO OR CONTAINED IN YOUR TRACKY HEALTH CLOUD. You should follow customary guidelines set by Your doctor or other healthcare professional(s) when  Your glucose and other biometric readings are abnormal, or You experience any other changes in your medical condition that are related to diabetes or any other health conditions 


DRSTORE IS NOT A PROVIDER OF MEDICAL CARE AND DRSTORE IS NOT RESPONSIBLE FOR NOTIFYING AN INDIVIDUAL’S DOCTOR OR OTHER HEALTHCARE PROFESSIONAL(S) OF ANY CHANGES IN YOUR READINGS. 

The TRACKY HEALTH App is designed to help individuals and their healthcare professionals better manage their health conditions through information, analysis and communication. You and Your doctor and other qualified healthcare professional(s) are solely responsible for communicating Your biometric data, and discussing and recommending testing and treatment options. Drstore does not recommend or endorse any specific tests, products, procedures or opinions. 

YOUR DECISION TO TAKE ACTION BASED ON ANY INFORMATION TRANSMITTED TO OR STORED ON THE TRACKY HEALTH APP OR ON ANY INFORMATION RECEIVED FROM DRSTORE OR DRSTORE EMPLOYEES, AGENTS, OR SUPPLIERS IS SOLELY AT YOUR OWN RISK.

3. Unauthorized third-party products.

Please be aware that third parties may offer services, software, mobile apps, and biometric devices not authorized by Drstore and which they claim may be compatible with the Tracky Health App, and/or the Tracky Health cloud. Drstore does not recommend using the Tracky Health App with these unauthorized third-party products, and is not responsible if you do. If you do use these third-party products or services, your use is subject to their respective privacy policies and terms of use. 

4. What does this Privacy Notice apply to?

This Privacy Notice applies only to the personal information you submit through the Tracky Health App when creating a Tracky Health account, and to the personal information, including health-related information, that we may receive from you or others (as explained in this notice) and stored within the Tracky Health cloud. Data will be uploaded to the Tracky Health cloud when you use the Tracky Health App to connect with your biometric device, or if data is entered manually, and through any customer services we provide that are connected to your use of the Tracky Health cloud. This Privacy Notice does not apply to any other personal information provided by you or collected from you by Drstore.

5. What information does this Privacy Notice govern?

This Privacy Notice covers the following information:

  • The Tracky Health account profile that you complete and which includes the name, date of birth, country, and email address of adult users for your own use or for use by another adult (where you have authority to do so), and in the case of pediatric use, in addition to the email address of the parent/guardian, the child’s name, date of birth and country.

  • Health-related information sent from your authorized biometric device and manually entered by You, such as how often you use your biometric device and biometric data. Information we receive about your mobile device, including information about your interaction on the cloud and other troubleshooting and analytical data to help us provide the Tracky Health App and Tracky Health cloud to you.

The Tracky Health App transmits personal information and data directly to the Tracky Health cloud pursuant to this Privacy Notice. In addition, you may manage your Tracky Health interaction with your healthcare provider by accessing the Tracky Health App settings. 

6. How is personal information handled?

When you register for a Tracky Health account, registration data (name, date of birth, email address) are kept separate from the information you upload from your Tracky Health App . Drstore uses technical and administrative measures to ensure data separation and will never combine these data.

Personal information

Drstore uses personal information, including health-related information and data derived from your biometric device and your mobile device in the following ways:

  • Disclose your personal data from the Tracky Health App to the Tracky Health cloud.

  • to provide you with a Tracky Health account to give you access to and present your information, including health-related information, in an easy-to-use and effective manner, to allow you to store, back-up and retrieve your historic glucose and biometric values, and to ensure continuous access to information about how you manage your biometric data in case your mobile device is lost or stolen.

  • to help us fix any issues with the Tracky Health App or the Tracky Health cloud, including where we respond to your questions or respond to your request for support, troubleshooting, or other any performance issues.

  • if you are a parent or guardian, to enable you to create a Tracky Health account for use by your child, and to allow you to manage their use of the Tracky Health account.

Data Analysis

Drstore uses de-identified, pseudonymized, aggregated, and/or anonymized information for limited purposes. This is information which Drstore securely holds and will not be used to identify you individually by your name or email address. The purposes for which Drstore will use this information are:

  • to improve the quality, security and effectiveness of biometric devices and clouds and to allow for the development of innovative and effective treatment for and management of DIABETES, BLOOD PRESSURE, METABOLIC HEALTH OR OTHER MEDICAL CONDITION in the interests of public health.

  • to create, access, retain, use, and disclose to our affiliated companies and to third-party researchers, healthcare entities or professionals or public health authorities for the purposes of scientific research, statistical purposes and analysis.

  • to research, develop and test healthcare care clouds and management.

  • to validate upgrades, and to keep the Tracky Health cloud safe and secure.

7. How long does Drstore store personal information?

Drstore will continue to store your personal information while you have an active Tracky Health account. The section entitled “How do I delete my Tracky Health account” below explains how you can delete your account and what happens to your personal information once your account has been deleted.

8. Does Drstore share personal information with third parties?

i. Sharing

We will not share your user information with other organizations and individuals, except in the following circumstances:

a. Sharing with explicit consent: After obtaining your explicit consent, we will share your user information with other parties;

b. Sharing under legal circumstances: We may share your user information with others in accordance with laws and regulations, litigation, arbitration, or legal requirements of administrative and judicial authorities;

c. Sharing with authorized partners: We may entrust trusted partners to provide services, so we may share some of your personal information with our partners to provide better customer service and optimize the user experience. We will only share your user information for legal, legitimate, necessary, specific and explicit purposes, and will only share user information necessary to provide services. Our partners have no right to use the shared user information for any other purpose. 

We may share, and you hereby consent to us sharing such de-identified, pseudonymized, aggregated, and/or anonymized information with affiliated Drstore companies and with other third parties for the purposes relating to “Data Analysis” set out above.


9. How does Drstore secure personal information?

As required by Information Technology Act, 2000 ('the IT Act') and Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 ('the SPDI Rules') HIPAA, USA, PIPEDA, HIA, or any other applicable laws, we have implemented administrative, technical, and physical safeguards to protect your personal information, including health-related information, from accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access, including through the use of cryptographic technologies. Drstore restricts access to personal information by its employees on a need to know basis. Please keep in mind that no internet or Wi-Fi transmission is 100% secure, so please exercise caution when uploading personal information, especially health-related information, to your Tracky Health account.

You are responsible for protecting against unauthorized access to your devices and your Tracky Health account. We recommend securing access to your mobile device by locking your mobile device, choosing a robust password that nobody else knows or can easily guess, and keeping your account information and password private. Drstore is not responsible for any lost, stolen, or compromised passwords or for any activity on your Tracky Health account from unauthorized users where caused by you. If you think your Tracky Health account has been compromised, please contact us as soon as you are able at info@drstore.in.

10. Where does Drstore store and transfer personal information?

The personal information transmitted to the Tracky Health cloud will be stored in the cloud on secure regional servers located in the India (managed by Amazon Web Services), , and will be allocated as such depending on your current location. AWS implements and maintains technical and organizational security measures applicable to AWS cloud infrastructure services under globally recognized security assurance frameworks and certifications, including ISO 27001ISO 27017ISO 27018PCI DSS Level 1, and SOC 1, 2, and 3. These technical and organizational security measures are validated by independent third-party assessors, and are designed to prevent unauthorized access to or disclosure of customer content. These comprehensive measures are consistent with those of HIPAA and PIPEDA. 

We will not transfer your user information to any company, organization or individual, except in the following circumstances:

a. Transfer with explicit consent: After obtaining your explicit consent, we will share your user information with other parties;

b. In the event of a merger, acquisition or bankruptcy liquidation between us and other legal entities, or other circumstances involving a merger, acquisition or bankruptcy liquidation, if the transfer of user information is involved, we will require new companies and organizations that hold your user information to continue to be bound by this policy. Otherwise, we will require the companies, organizations and individuals to seek authorization from you again. we will require the company, organization and individual to seek authorization from you again.

Public disclosure

We will only publicly disclose your user information under the following circumstances:

a. We may publicly disclose your user information with your explicit consent or based on your active choice;

b. We may disclose your user information in accordance with applicable laws or our relevant agreements and rules to protect the personal and property security of users of our platform and its affiliated companies or the public from infringement.

Exceptions for sharing, transferring, and publicly disclosing user information with prior authorization and consent

In the following cases, sharing, transferring and publicly disclosing your user information do not require your prior authorization and consent:

a. Information related to national security and national defense security;

b. Information related to public security, public health and major public interests;

c. Information related to criminal investigation, prosecution, trial and enforcement of the judgment;

d. Situation where it is for the protection of your or other individuals' life, property and other major legitimate rights and interests and it is difficult to obtain the consent of the person;

e. Personal information that you disclose to the public by yourself;

f. Personal information collected from legally publicly disclosed information, such as legal news reports, government information publicity and other channels.

11. Will Drstore send me marketing material?

Drstore (or its affiliates) may send you advertising and marketing-related information about biometric values management or their other products and services if (where required by law) you opted-in to receive such communications when you set up your Tracky Health account profile. You may receive marketing information which is tailored to your specific needs based on the information uploaded or connected to your Tracky Health account (including health-related information). We may also invite you to participate in surveys about our products, provide you with news and newsletters, or to notify you about special offers and promotions. You may opt out from receiving marketing-related communications by either clicking on the unsubscribe link at the bottom of marketing-related emails we send you, by changing your Tracky Health preferences, or by contacting us at info@drstore.in We will process opt-out requests without undue delay.

Neither Drstore nor its affiliates or licensors will send advertising or marketing-related information to children.

Drstore will not sell your personal information to third parties for direct marketing.

Where you opt out of receiving marketing-related information about glucose and biometric data management, we may continue to send you non-marketing related information. This information may be in relation to necessary cloud and service updates or issues including product safety.

12. How does Drstore protect the privacy of children?

Each user is required to enter his or her date of birth and country so that we may establish whether the user is a child under the law of the user’s country. If a date of birth attributable to a child is entered, the user will be required to enter the email address of a parent/guardian before a Tracky Health account will be created. The parent/guardian must consent to the child’s use of the Tracky Health account. Upon such consent, a Tracky Health account will be created for the parent/guardian for use by a child.

At any time, a parent/guardian may stop the collection of a child’s personal information, including health-related information, by requesting that Drstore delete the Tracky Health account used by a child by contacting us at info@drstore.in. This action will delete the account being used by the child but we retain aggregated and de-identified information and may need to retain certain personal information as required by law.

13. How may I access and/or correct my personal information?

You may correct your profile information through the settings within the Tracky Health App. 

If you wish to correct/amend your biometric readings stored in the Tracky Health account, you should reach out to Drstore.

14. What rights do I have over my personal information?

i. Access to personal information

After you complete the account registration and login of the platform and perform reasonable and necessary identity verification, you may consult, modify and delete the personal information you have submitted to the platform software and related services. 

ii. Modification/deletion of personal information

You can modify your personal information and clear the data stored locally in this platform application by using the edit/delete function on the settings page, clearing cache, uninstalling this platform application and contacting our customer service staff. 

iii. Access of privacy policy

You can view this privacy policy on the registration page, at the bottom of My - Settings page or on My - Settings - About page. 

iv. Withdrawal of your authorization

If you want to change the authorization of relevant permissions (such as location, camera, photo album, microphone), you can modify it through your hardware ventilator or operate it in the related function setting interface of this product (or service). You can also permanently withdraw all authorization for us to continue collecting and using your personal information by canceling your account. 

v. You can request us to delete user information in the following cases:

a. Our processing of user information violates laws or regulations;

b. We collect and use your user information without your explicit consent as required;

c. Our processing of user information seriously violates the agreement with you.

For security purposes, you may need to provide a written request or otherwise prove your identity. We may ask you to verify your identity before processing your request.

vi. Cancellation of the account

You can cancel your account in [Tracky Health App - Left Pull Menu - About - Cancel]. Once your account is cancelled, the relevant agreements and other documents of rights and obligations that you have signed with us will be terminated accordingly (unless it is agreed to continue to take effect or otherwise stipulated by law).


15. How do I delete my Tracky Health account?

If you would like to delete your Tracky Health app You can cancel your account in [Tracky Health App - Left Pull Menu - About - Cancel]. Once your account is cancelled, the relevant agreements and other documents of rights and obligations that you have signed with us will be terminated accordingly (unless it is agreed to continue to take effect or otherwise stipulated by law).

If you would like to delete your Tracky Health account, please contact us at info@drstore.in. Please be aware that if you delete your account, we will retain aggregated and de-identified information and may need to retain certain personal information as required by law.

Once your Tracky Health account and any associated personal information has been deleted, you will no longer have access to the Tracky Health cloud and deletion of your account is irreversible. You may not therefore be able to reactivate your Tracky Health account or retrieve any personal information, including health related information, so you may want to download and save any required information before requesting that we delete your account from the Tracky Health.

If you delete your account, your Provider will no longer be able to view your biometric data . Your deletion of your Tracky Health account will have no effect on the account or patient profile created by your Provider.

16. How can I contact Drstore?

If you have questions, comments, or complaints about our privacy practices, please contact us at info@drstore.in Alternatively, you may send a letter to the following address: of SA 44, 2nd Floor Lake City Mall, Ghod Bunder Road, Kapurbawdi, Thane, Maharashtra, INDIA 400607.


In all communications to us, please include the email address used to create your Tracky Health account and a detailed explanation of your request.

17. Changes to this Privacy Notice.

If we change our privacy practices, an updated version of this Privacy Notice will reflect those changes. You will be alerted to updates to this Privacy Notice by email or via the Tracky Health App. You will be notified if there is a new version of this Privacy Notice and will be prompted to read and accept it so that you can continue to access and use your Tracky Health cloud via the Tracky Health App. Without prejudice to your rights under applicable law, we reserve the right to update and amend this Privacy Notice without prior notice to reflect technological advancements, legal and regulatory changes and good business practices to the extent that it does not change the privacy practices as set out in this Privacy Notice.

If you do not agree to the changes to the Privacy Notice, you should delete the Tracky Health App from your device, or request deletion of your Tracky Health account by contacting us at info@drstore.in.

Doc ID: V1.0 Tracky Health Privacy Policy

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