Privacy Policy

1. Overview

Medismo LifeTech ("Medismo", "we", "us") operates the Medismo Connex platform ("Platform") — a doctor-controlled speed-meeting service for doctor-pharma engagement.

Our privacy promise in one line: doctor contact details never leave Connex. Pharma and MRs see your slots, not your phone number, email, or address. We don't sell personal data. We don't share it for marketing. Everything below is the formal version of that.

This policy applies to all users — Doctors, Medical Representatives (MRs), Hospital Administrators, Pharma Administrators, Clinic Assistants, and Medismo operational staff — and is designed to align with India's Digital Personal Data Protection Act 2023 ("DPDP Act") and other applicable Indian privacy regulations.

2. Data We Collect

2.1 Information You Provide

• Account Information: Full name, email address, phone number, role, and organisational affiliation.
• Professional Information: Medical registration number (for Doctors), speciality, hospital/clinic details, pharmaceutical company details.
• Communication Data: Messages sent through the Platform, meeting notes, support tickets.
• Billing Information: Organisation billing details, subscription plan selection. Payment card details are processed directly by Razorpay and are never stored on our servers.

2.2 Information Collected Automatically

• Usage Data: Pages visited, features used, time spent, interaction patterns.
• Device Information: Browser type, operating system, screen resolution, device type.
• Log Data: IP addresses, access timestamps, error logs, API request metadata.
• Location Data: Approximate location derived from IP address (city-level only, not precise GPS).

2.3 Information from Third Parties

• Organisation Data: Your employer or affiliated organisation may provide your details during onboarding.
• WhatsApp Data: If you interact with our WhatsApp bridge service, your WhatsApp phone number and messages sent to our business number.

2.4 Virtual Visit Data (only applies if you join a virtual MR visit)

If a Doctor has opted in to virtual MR visits and a meeting is conducted on the Platform as a video call, the following additional categories of personal data are processed only for the duration of that call and the audit trail it produces:

• Audio & Video Streams: Live audio and video between participants. These streams are transmitted via our video-media sub-processor (see Section 5) and are not recorded by default.
• Consent Attestations: A time-stamped record of each participant's acceptance of the pre-call disclosure, including the version of the disclosure text shown. This is a compliance requirement under UCPMP 2024.
• Call Metadata: Room identifier, participant join and leave timestamps, duration, connection-quality events.
• Recording (opt-in only): If both the Doctor and the Doctor's pharma-partner company have separately enabled recording, AND the Doctor confirms consent at the start of that specific call, the call is recorded as a single MP4 file. Recording is off by default and requires all three conditions to be true.

Recording status is shown unambiguously on-screen before every call. A Doctor may disable virtual visits or recording at any time from their profile settings — changes apply to all future calls.

3. How We Use Your Data

We process your personal data for the following purposes:

4. Data Storage & Encryption

Your data is stored on secure servers hosted by Contabo GmbH, with primary infrastructure located in data centres that comply with industry-standard security certifications.

• Encryption in Transit: All data transmitted between your device and our servers is encrypted using TLS 1.2 or higher.
• Encryption at Rest: Sensitive personal data, including authentication credentials, is encrypted at rest using AES-256 encryption.
• Access Controls: Access to personal data is restricted to authorised personnel on a need-to-know basis, with role-based access controls (RBAC) enforced at every level.
• Database Security: Our PostgreSQL databases are configured with connection encryption, parameterised queries to prevent injection attacks, and regular automated backups.
• Password Security: User passwords are hashed using bcrypt with appropriate salt rounds. We never store passwords in plain text.

5. Third-Party Services & Sub-Processors

We share data with the following sub-processors, strictly as needed to operate the Platform. Each is engaged under a written data-processing agreement and may only process Platform data on documented instructions from Medismo.

A current, authoritative list of active sub-processors is maintained at privacy@medismo.in and is available to enterprise customers on request. We will notify affected customers at least 15 days in advance of engaging any new sub-processor that materially changes data handling.

We do not sell, trade, or otherwise transfer your personal data to any third party for marketing purposes.

6. Virtual MR Visits

Virtual MR visits are an optional feature that lets a Doctor accept a pharmaceutical Medical Representative's (MR) meeting as a video call instead of an in-person visit. This section describes the privacy handling specific to that feature. For the core data categories involved, see Section 2.4.

6.1 Doctor Opt-In

Virtual visits are disabled by default on every Doctor account. A Doctor must explicitly enable them in their profile settings, and may disable them at any time. MRs may not book a virtual visit with a Doctor who has not opted in.

6.2 Consent Before Every Call

At the start of every virtual visit, both parties are shown a one-screen disclosure covering: the promotional nature of the interaction, the scheduled slot, whether the call is being recorded, and links to these Terms and this Policy. The call cannot begin until each party has independently accepted. Each acceptance is time-stamped and stored in the Platform's compliance audit log for seven (7) years to satisfy UCPMP 2024 audit requirements.

6.3 Recording (Off by Default)

A virtual visit is only recorded when all three of the following conditions are met:

• The Doctor has enabled recording in their profile settings; AND
• The MR's pharmaceutical company has recording enabled on their Platform tier; AND
• Both parties confirm consent at the pre-call disclosure screen for that specific call.

The on-screen disclosure before every call states unambiguously whether recording is on or off for that session. If any of the three conditions is not met, the call is not recorded and no audio or video data is persisted beyond the transient media transport.

6.4 Recording Retention & Access

• Retention period: Recordings are retained for seven (7) years from the date of the call, after which they are deleted automatically. This period matches the UCPMP audit-trail retention standard.
• Storage: Recordings are stored encrypted at rest in our Cloudflare R2 bucket; access is restricted to signed URLs issued only to the participants and to the Doctor's pharma-partner's compliance officer (where applicable).
• Doctor access: The Doctor may download a copy of any recording in which they participated at any time during the retention period.
• Right to erasure: The Doctor may request deletion of a recording at any time by contacting the Data Protection Officer (Section 12). We will action the request within 30 days, subject to any overriding legal-hold obligation on the pharma company under UCPMP — in which case the Doctor will be notified of the hold and its expected duration.

6.5 What Is Not Recorded

In no case is a call recorded without the on-screen opt-in described in Section 6.3. Even when recording is enabled, we do not transcribe calls automatically, do not use call content to train AI models, and do not share recordings with anyone outside the participants and (where applicable) the MR's pharma-company compliance team.

6.6 Virtual Visits Are Not Clinical Consultations

Virtual MR visits are promotional interactions between a Doctor and a pharmaceutical Medical Representative. They are not clinical tele-consultations with patients, are not governed by the Telemedicine Practice Guidelines 2020, and must not be used to provide clinical advice, diagnosis, or prescription to any person. The Platform enforces this by only permitting MR accounts to join the MR side of a virtual visit.

7. Cookies & Tracking

The Platform uses the following types of cookies:

• Essential Cookies: Required for authentication, session management, and security. These cannot be disabled without breaking core functionality.
• Preference Cookies: Remember your settings and preferences (e.g., language, theme) for a better experience.
• Analytics Cookies: Help us understand how users interact with the Platform. These are anonymised and aggregated. You may opt out of analytics cookies.

We do not use advertising or third-party tracking cookies. We do not engage in cross-site tracking or behavioural advertising.

8. Your Rights Under the DPDP Act 2023

• Right to Access: You may request a summary of your personal data that we process, including the processing activities performed.
• Right to Correction: You may request correction of inaccurate or incomplete personal data.
• Right to Erasure: You may request deletion of your personal data, subject to legal retention requirements.
• Right to Grievance Redressal: You have the right to register a complaint with us if you believe your data has been mishandled.
• Right to Nominate: You may nominate another person to exercise your data rights in case of your death or incapacity.

To exercise any of these rights, please contact our Data Protection Officer at the address provided in Section 13 below. We will respond to your request within 30 days.

9. Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes outlined in this policy:

• Active Account Data: Retained for the duration of your account's active status.
• Post-Termination: Account data is retained for 90 days after termination to allow for reactivation or data export requests.
• Billing Records: Retained for 8 years as required under Indian tax and financial regulations.
• Audit Logs: Retained for 3 years for compliance and security purposes.
• Communication Data: Messages and support tickets are retained for 2 years after the last interaction.
• Virtual Visit Consent Attestations: Retained for 7 years, matching the UCPMP audit-trail retention standard.
• Virtual Visit Recordings (opt-in only): Retained for 7 years from the date of the call; deleted automatically thereafter. Subject to the Doctor's right to earlier deletion described in Section 6.4.
• Analytics Data: Aggregated and anonymised data may be retained indefinitely as it no longer constitutes personal data.

10. Children's Privacy

The Platform is not intended for use by individuals under the age of 18. We do not knowingly collect personal data from children. If we become aware that we have inadvertently collected data from a child, we will take steps to delete it promptly.

11. Cross-Border Data Transfers

Your Platform data (accounts, bookings, messages, documents, recordings) is primarily stored and processed on servers located in India and served via edge infrastructure globally.

Certain sub-processors listed in Section 5 may process data outside India as an inherent part of providing their service:

• LiveKit (virtual-visit media): Routes real-time audio and video through its nearest edge, which for Indian participants is typically a South or South-East Asia point of presence. Streams terminate at the other participant's edge. LiveKit's servers are located globally; individual call streams may transit jurisdictions outside India as part of optimal routing. When recording is enabled, the recording file is written directly to our Cloudflare R2 bucket — LiveKit does not retain the recording on its own infrastructure.
• Cloudflare R2 (storage): Uses Cloudflare's global edge network. Objects may be cached at edge nodes outside India but are durably stored only in the configured primary region.
• Meta / WhatsApp, Google Workspace, AI model providers: Operate globally as described in each provider's own documentation.

All sub-processors with cross-border transfer implications are engaged under data-processing agreements that impose contractual safeguards equivalent to the DPDP Act 2023 standards. We will comply with any future whitelist or blacklist of jurisdictions issued by the Data Protection Board of India under Section 16 of the Act.

12. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be communicated via email or an in-app notification at least 15 days before taking effect. The "Last updated" date at the top of this page will always reflect the most recent revision.

Continued use of the Platform after changes take effect constitutes acceptance of the revised policy.

13. Contact & Data Requests

For any privacy-related queries, data access requests, or to exercise your rights under the DPDP Act, please contact:

If you are not satisfied with our response, you have the right to file a complaint with the Data Protection Board of India as established under the DPDP Act 2023.