PRIVACY POLICY

Your privacy is important to us. This Privacy Policy (“Policy”) applies to services provided through the Cough against TB application for mobile and handheld devices (‘Application’). By accessing the Application, whose ownership is jointly and severally vested with the Central TB Division (CTD), which is the apex institution for managing the National TB Elimination Programme (NTEP) for the entire country at the central level and Artificial Intelligence unit of National Entrepreneurship Network (NEN-AI) under their brand name Wadhwani AI, a non-profit organization with a registered office at Tower no. 3, 6th floor, SJR I park, EPIP Zone-1, Whitefiled road, Bangalore 560066, KA, India and Program office at C/o Okhla NSIC Phase III, Metro station building, 1st Floor, 5th Level, Shambhu Dayal Bagh, New Delhi-110020, India, (hereinafter referred jointly to as ‘The Organization’, ‘we’ or ‘us’) and our Application explains what information we collect from users of our Application (a “user”, “you”, or “your”), including information that may be used to personally identify you (“Personal Information”) and how we use it. We encourage you to read the details below. This Policy applies to the user of our services. This Application is operated and managed by NEN-AI and you hereby expressly consent to have read, understood and agreed to be bound by this Privacy Policy. We will be the controller of your personal data provided to, or collected for, or processed in connection with our services.

Personal information is collected from and about you when you use the Application. We are committed to protecting this information’s security and privacy. This privacy policy sets out the details of the personal information collected, how it is collected, by whom, and the purposes for which it is used. At registration, you are requested to accept the terms of this Privacy Policy, and your use of the Application signifies your continued acceptance thereof. This Privacy Policy may be revised occasionally, and you will be notified of all such changes. To use the Application, you will be required to consent to the terms of the Privacy Policy.

Intended Users

This Application is currently intended for use by the healthcare staff (HCW) to screen individuals between the ages of 07 years to 100 years for identification of Presumptive TB.

Context for Use

A compatible smartphone with a working internal microphone is required to get the inference from the Application about the likelihood of Pulmonary tuberculosis. The audio (cough and background sounds) must be recorded in a well-ventilated, noise-free environment.

1. Information we Collect and Manner of Collection

1. We are committed to respecting your online privacy. We further recognize your need for appropriate protection and management of any Personal Information you share with us. When you register on the Application, the following information is collected from you and stored securely on a cloud operated and managed by the Organization–
   i. Full Name;
   ii. Date Of birth; and
   iii. Gender.
   iv. To receive the inference/result of your or another individual’s likelihood of Pulmonary Tuberculosis as per the current AI model used in the Application, the relevant vital statistics, symptomatic data, cough (audio), and background (audio) data are requested.
   This information will be stored on the cloud, and a unique digital id (uuid) will be assigned to your information. The ‘uuid’ will, after that, be used to identify you in all subsequent Application related transactions and will be associated with any data or information uploaded from the Application to the cloud. Your location details are also captured and uploaded to the cloud at registration.
2. Before or at the time of collecting personal information, we will identify the purposes for which information is being collected. If the same is not identified to you, you have the right to request us to elucidate the purpose of collection of said personal information, pending the fulfillment of which you shall not be mandated to disclose any information whatsoever. Each time you complete the assessment test, the Application will collect your result, and location data, along with the data you shared, is securely stored on your device and will be uploaded to the cloud with your consent. We only collect and use such information from you that we consider necessary for achieving a seamless, efficient and safe experience including:
   i. To enable the provision of services opted by you;
   ii. To enable the viewing of content in your interest;
   iii. To communicate the necessary account and service-related information from time to time;
   iv. To allow you to receive quality services from our data collection;
   v. To comply with applicable laws, rules and regulations;
3.  The Application shall facilitate the verification of the User identity through mobile number-based OTP verification.
4. The Application shall facilitate the storage of and the medical diagnostic tests done for the subject and their Ni-Kshay ID.
5. We will collect and use your Personal Information solely to fulfill those purposes specified by us, within the scope of the consent of the individual concerned or as required by law. We will only retain Personal Information as long as necessary for the fulfillment of those purposes. We will collect Personal Information by lawful and fair means and with the knowledge and consent of the individual concerned.
6. Your Personal Information shall be relevant to the purposes for which it is to be used, and, to the extent necessary for those purposes, should be accurate, complete, and up-to-date.
7. For more details about the nature of such communications, please refer to our Terms of Use. Further, your data and Sensitive Personal data may be collected and stored by us for internal record.

2. Use of Information

1. The personal information collected from you at the time of registration under Clause 1 above shall be stored on the cloud and only be used by the Government of India in anonymized, aggregated datasets to generate reports, heat maps, and other statistical visualizations for the management of Tuberculosis in the country or to provide you general notifications about Tuberculosis as may be required.
2. The information collected from any other user’s mobile device and uploaded and stored on the cloud under Clause 1(2) will be used to calculate the probability of the screened individual being infected with Tuberculosis.
3. The information provided by you shall be used to provide, enhance and improve the service for you and all users, and for maintaining an internal record and also for maintaining record under the legal and statutory provisions.
4. The information collected under Clause 1 will not be used for any purpose other than those mentioned in this Clause 2.

3. Retention

1. All personal information collected from you under Clause 1 at the time of registration will be retained for as long as your account remains in existence and if any medical or administrative interventions have been commenced under Clause 2, subject to Clause 3(2) below, for such period after that as is required for such interventions to be completed.
2. All personal information collected under Clause 1 will be retained on the mobile device for an indefinite period from the date of collection, after which, if it has not already been uploaded to the cloud, will be purged from the Application. All information collected under Clauses 1(2), 1(3) , and 1(4) and uploaded to the cloud will, to the extent that such information relates to people who have not tested positive for Tuberculosis, will be purged from the cloud after an indefinite period after being uploaded. All information collected under Clauses 1(2), 1(3), and 1(4) of persons who have tested positive for Tuberculosis will be purged from the cloud after an indefinite period of such persons have been declared cured of Tuberculosis.
3. Nothing set out herein shall apply to the anonymized, aggregated datasets generated by the personal data of registered users of the Application or any reports, heat maps, or other visualization created using such datasets. Nothing herein shall apply to medical reports, diagnoses, or other medical information generated by medical professionals during treatment.

4. Rights

1. As a registered user, you can access your profile anytime to add, request, remove or modify any registration information you have supplied from all the platforms where the data resides.
2. You cannot manage the communications you receive from us or how you receive them. If you no longer wish to use the Application, you are free to uninstall the Application. Please note that deleting the Application will delete all the information collected and stored on your phone but will not delete any information stored on the cloud. If you wish to delete the registration information referred to in Clause 1(1) and store it on the backend clouds, you may email to coughagainsttb@wadhwaniai.org with the relevant information. Once you confirm that you want to cancel the registration, all the information you provided to us under Clause 1(1) will be deleted after acknowledgment of the request in 30 days.

5. Data Security

We treat data as an asset that must be protected against loss and unauthorized access. We employ many different security techniques to protect such data from unauthorized access by members inside and outside the Firm. We follow generally accepted industry standards to protect the Personal Information submitted to us and information that we have accessed.
The Application is equipped with standard security features to protect the confidentiality and security of your information. Data is encrypted in transit as well as at rest. Personal information provided during registration is encrypted before being uploaded to the cloud, stored in a secure encrypted cloud. Personal information stored in the Applications of other registered users you come in contact with is securely encrypted and incapable of being accessed by such users. The Personal Data shall be collected, stored, and disposed of per the international Standard IS/ISO/IEC 27001.

The Personal Data shall be disposed of once the purpose is achieved in the manner as is legally permissible.

6. Disclosures and Transfer

As a matter of policy, we do not sell or rent any personally identifiable information about you to any third party. We cooperate with law enforcement inquiries, as well as other third parties to enforce laws, such as intellectual property rights, fraud and other rights. We can (and you authorize us to) disclose any information about you to law enforcement and other government officials as we, in our sole discretion, believe necessary or appropriate, in connection with an investigation of fraud, intellectual property infringements, or other activity that is illegal or may expose us or you to legal liability. We do however assure you that any disclosure of your personally identifiable information shall be personally intimated to you through an email sent to your provided email address.

7. Grievances

If you have any concerns or questions in relation to this Privacy Policy, you may address them by sending an email to: coughagainsttb@wadhwaniai.org

8. Severability

Each clause of this Policy shall be and remain separate from and independent of and severable from all and any other clauses herein except where otherwise expressly indicated or indicated by the context of the Policy. The decision or declaration that one or more of the clauses are null and void shall not affect the remaining clauses of this Policy.

9. Changes to this Policy

We may occasionally update this Policy to keep abreast with new technologies, regulatory requirements, and new practices, among other reasons, per the Applicable Law. We shall ensure the updated /revised Policy is displayed on the Application with the date. Any changes to this Policy will become effective upon posting the revised Policy on this page. Your continued use of the Application following such revision constitutes your acceptance of the revised Policy.