Privacy Policy
At Clivise, safeguarding patient confidentiality and clinical data integrity is our foundational principle. This policy meticulously governs how we handle, process, and protect clinical records, telemetry, and practitioner credentials across our diagnostic intelligence platform.
Section 01
Overview & Scope
Clivise acts as a Data Processor on behalf of your clinic (the Data Fiduciary). We process data only on your instructions, in compliance with the DPDP Act 2023.
This Privacy Policy sets forth the principles under which Clivise Healthcare Pvt. Ltd. ("Clivise", "we", "us", or "our") processes personal identifiers, institutional clinical data, diagnostic imaging parameters, and analytical streams collected through the Clivise Platform, associated APIs, and institutional interfaces.
Clivise operates exclusively as a specialized clinical software vendor and intelligence suite serving licensed health systems, hospital groups, academic medical centers, and credentialed practitioners in India. Depending on the nature of our deployment, Clivise acts primarily as a "Data Processor" on behalf of the healthcare institution (the "Data Fiduciary") under the Digital Personal Data Protection (DPDP) Act, 2023.
Enterprise Scope
Applies to all enterprise clinical nodes, EHR integrated connectors, and federated institutional endpoints.
Practitioner Context
Governs account credentials, audit trails, digital signatures, and workstation session telemetrySystem performance data.
Section 02
Information We Collect
We collect only what is necessary — account details, clinical data on your behalf, and system logs for security.
Our data ingestion protocols are structured under the principle of minimal privilege and purpose limitation as mandated by the DPDP Act. We partition our data ingest streams into distinct cryptographic tiers:
Institutional & Practitioner Account Identity
Full name, clinical specialty, national provider identifier (HPR ID), medical license credentials, institutional affiliation, hospital email address, and two-factor authentication tokens.
Clinical Observation & Diagnostic Ingestion
Structured laboratory data, diagnostic imaging metadata (DICOM headers parsed according to NHA de-identification rules), structured narrative notes, vital telemetrySystem performance data, and medication regimens.
System Audit Logs & Operational Telemetry
Cryptographically hashed user action histories, session durations, query latency metrics, API response signatures, and cryptographic validation hashes.
Section 03
Protected Health Information & DPDP Alignment
All Personal Health Data is processed under a signed DPA, with purpose limitation, no unauthorized secondary use, and 72-hour breach notification.
All handling of Personal Health Data adheres strictly to the Digital Personal Data Protection (DPDP) Act of 2023, guidelines established by the National Health Authority (NHA), and corresponding healthcare data regulations in India.
Data Processing Agreement (DPA) Guarantee
Clivise executes standard, comprehensive Data Processing Agreements (DPAs) with all institutional customers prior to live EHR pipeline initiation. Under our DPA, Clivise: • Enforces the purpose limitation standard for every automated diagnostic ingestion query. • Prohibits any unauthorized secondary usage or non-consensual monetized aggregation of identifiable health data. • Maintains an automated incident notification protocol providing immediate escalation within 72 hours of potential unauthorized access as per CERT-In guidelines. De-Identification Standard: When data is processed for clinical model verification, Clivise strictly utilizes data masking and anonymization protocols aligned with NHA standards.
Section 04
Algorithmic Processing & AI Usage
We never use your patient data to train public or commercial AI models without explicit written consent. Every AI output is explainable and traceable.
Clivise uses modern statistical and machine learning architectures to synthesize diagnostic observations and streamline clinical review. We uphold transparent, responsible artificial intelligence practices:
Model Training Boundaries
Customer health data is never used to train public, generalized, or multi-tenant commercial models without explicit, contractually governed written institutional consent. Model updates occur in isolated virtual environments.
Clinical Explainability
Every diagnostic intelligence suggestion generated by Clivise includes provenance references, source citations, confidence intervals, and direct links back to original clinical observations.
Section 05
Third-Party Custodians & Sub-Processors
We work only with audited sub-processors bound by DPAs. All personal health data is stored in India.
We partner with a strictly limited set of audited cloud service providers and infrastructure hosts. All third-party providers must sign equivalent Data Protection Agreements prior to deployment and mandate data residency within India.
| Entity | Role / Function | Data Residency | Compliance |
|---|---|---|---|
| Amazon Web Services (AWS ap-south-1) | Encrypted Compute & Object Storage | Mumbai, India | MeitY Empanelled / ISO 27001 |
| Cloudflare Enterprise | DDoS Mitigation & Edge TLS Routing | Global (Zero Ingress Storage) | SOC 2 / ISO 27001 |
| Datadog Healthcare Cloud | System Telemetry & Anonymized Logs | Mumbai, India | DPDP DPA Active |
Section 06
Security Protocols & Cryptography
We use AES-256 encryption at rest, TLS 1.3 in transit, hardware MFA, and just-in-time access controls.
Data security is engineered directly into our zero-trust runtime fabric. We mandate military-grade and industry-certified cryptographic safeguards across all layers of the Clivise stack:
Data at Rest
AES-256 GCM cryptographic encryption utilizing hardware security modules (HSM) with customer-managed keys (BYOK available).
Data in Transit
Forced TLS 1.3 protocol encryption across all API transactions, HL7 FHIR relays, and practitioner browser sessions.
Access Controls
Hardware token MFA required for all internal operations. Just-in-Time (JIT) access privilege with dual approval controls.
Section 07
Data Retention & Cryptographic Erasure
Upon termination, you get 30 days to export your data. After that, encryption keys are destroyed and storage is sanitized.
Institutional clinical data is retained strictly according to the statutory obligations stipulated in our Master Services Agreements and health system mandates. Upon contractual termination or verified deletion request:
- Institutional Export Phase: The institutional customer receives full data extraction in standard FHIR JSON or raw DICOM packages within 30 days.
- Cryptographic Key Destruction: Dedicated partition encryption keys are permanently destroyed, rendering stored data immediately un-reconstructible.
- NIST 800-88 Compliant Sanitization: Underlying storage blocks undergo multi-pass sanitization in compliance with federal guidelines.
Section 08
Clinician & Institutional Rights
You have the right to access, correct, export, and audit your data. You can also revoke consent for non-essential programs.
In accordance with applicable privacy regulations (including the DPDP Act 2023), authorized institutional liaisons and individual practitioners maintain defined prerogatives regarding their credentials and records:
Access & Portability
Request an auditable digital archive of your administrative identifiers, usage trails, and platform configurations.
Rectification
Request real-time correction of erroneous physician registry credentials or hospital unit assignments.
Consent Revocation
Withdraw participation in non-essential diagnostic benchmarking programs at any juncture.
Audit Trail Inspection
Inspect who within your medical facility accessed, queried, or modified clinical case analyses.
Section 09
Contact Our Data Protection Officer (DPO)
For privacy inquiries, contact our DPO. For DPDP Act grievances, contact our Grievance Officer. We respond within 7 business days.
If you have questions regarding this Privacy Policy, your institutional DPA agreement, or require immediate assistance from our Regulatory Compliance Officer, please reach out through our designated regulatory channels:
Grievance Officer (DPDP Act 2023)
Under Section 13 of the Digital Personal Data Protection Act, 2023, Data Principals have the right to register a grievance with the Data Fiduciary. Clivise has designated a Grievance Officer to address such complaints.
Response Time: Clivise shall acknowledge and respond to grievances within 7 business days of receipt.
Escalation: If you are not satisfied with our response, you have the right to lodge a complaint with the Data Protection Board of India under the DPDP Act 2023.