Privacy Policy

Health Q Lifesciences Private Limited ยท Brand: EverQ

HEALTH Q LIFESCIENCES PRIVATE LIMITED ("EverQ", "Company", "we", "our", or "us") is committed to protecting the privacy and security of the personal information entrusted to us. EverQ acts as a "Data Fiduciary" within the meaning of the Digital Personal Data Protection Act, 2023 ("DPDP Act") in respect of the personal data it processes. This Privacy Policy explains how EverQ collects, uses, stores, shares, protects, and otherwise processes personal information through our website, mobile applications, AI-powered facial skin analysis, dermatology teleconsultation, electronic prescription, online pharmacy, customer support, and any other digital services operated by EverQ.

This Privacy Policy should be read together with our Terms and Conditions (Part A), AI Disclaimer, Medical Disclaimer, Cookie Policy, and any additional notices displayed on our Platform. This Policy is issued in compliance with the DPDP Act, the Information Technology Act, 2000, the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 ("SPDI Rules"), and other Applicable Law.

1. Scope

This Privacy Policy applies to:

  • Visitors to the EverQ website;
  • Registered users of EverQ mobile applications;
  • Patients using AI-assisted facial skin analysis;
  • Individuals booking online consultations;
  • Customers purchasing products through EverQ;
  • Healthcare professionals using EverQ services where applicable; and
  • Individuals communicating with EverQ through email, chat, WhatsApp, telephone, or customer support.

This Privacy Policy does not apply to third-party websites, applications, or services linked from the Platform. Those services are governed by their own privacy policies.

2. Definitions

  • Account means a registered EverQ user profile.
  • AI Analysis means automated analysis of facial images and related information to generate skin-health observations and skincare recommendations.
  • Applicable Law means all applicable laws, regulations, and governmental requirements, including data protection, healthcare, consumer protection, and e-commerce laws in force in India.
  • Data Principal means the individual to whom personal data relates, as defined under the DPDP Act.
  • Health Information means information relating to an individual's physical or mental health, medical history, consultation records, symptoms, prescriptions, treatment plans, laboratory reports, or other health-related information processed through EverQ.
  • Personal Data means any information relating to an identified or identifiable individual.
  • Platform means the EverQ website, mobile applications, APIs, software, and associated digital services.
  • Sensitive Personal Data means health information, biometric information, facial images processed for AI analysis, passwords, financial information, and any other data requiring enhanced protection under the SPDI Rules or other Applicable Law.

3. Information We Collect

Depending on how you use our services, we may collect the following categories of information.

3.1 Information You Provide. This may include full name, date of birth, and gender; mobile number, email address, and residential or delivery address; login credentials and profile information; consultation details and medical history voluntarily shared; prescription uploads; payment information processed through authorized payment partners; and customer support communications.

3.2 Health Information. Where required to provide our services, we may collect skin concerns, medical history, allergies, current medications, consultation notes, electronic prescriptions, treatment recommendations, follow-up records, and uploaded laboratory reports or medical documents. Health Information is processed only for legitimate healthcare and service-related purposes and is subject to additional safeguards as Sensitive Personal Data.

3.3 Facial Images and AI Analysis. If you choose to use EverQ's AI-assisted skin analysis features, we may process facial photographs uploaded by you, images captured using your device camera with your permission, image quality information, and skin characteristics relevant to the requested analysis. AI-generated results are intended to support skincare guidance and are not a substitute for professional medical diagnosis or treatment. Facial images will not be used for purposes unrelated to the Services - including training of AI models on identifiable images - unless expressly stated and separately consented to where required by Applicable Law.

3.4 Automatically Collected Information. When you use our Platform, we may automatically collect IP address, device identifiers, browser type, operating system, mobile device model, app version, language preferences, log files, crash reports, diagnostic information, session identifiers, and usage analytics.

3.5 Cookies and Similar Technologies. We may use cookies and similar technologies to remember user preferences, maintain secure sessions, improve website performance, understand user interactions, measure platform usage, and enhance user experience. Additional information is available in our Cookie Policy.

4. Purposes of Processing

We process personal information for purposes including:

  • Creating and managing user accounts;
  • Providing AI-assisted skin analysis;
  • Scheduling and facilitating teleconsultations;
  • Supporting healthcare professionals in delivering services;
  • Processing electronic prescriptions;
  • Processing product purchases and deliveries;
  • Providing customer support;
  • Verifying user identity where necessary;
  • Detecting fraud, abuse, or unauthorized access, and maintaining platform security;
  • Improving our products and services;
  • Complying with applicable legal and regulatory obligations;
  • Sending service-related notifications; and
  • Sending promotional communications where permitted by law or with your consent, where required.

5. Legal Basis for Processing and Notice

EverQ processes personal data primarily on the basis of your free, specific, informed, unconditional, and unambiguous consent, obtained through clear affirmative action, as required under the DPDP Act. In addition, and where applicable, processing may be based on:

  • Performance of a contract with you (e.g., fulfilling an order you place);
  • Compliance with legal obligations (e.g., maintaining prescription records);
  • Certain legitimate uses recognized under Section 7 of the DPDP Act, including voluntary provision of data for a specified purpose, medical emergencies, and compliance with law or court orders; and
  • Protection of vital interests.

At or before the time consent is sought, EverQ will provide a notice describing the personal data to be processed, the purposes of processing, the manner in which you may exercise your rights, and the manner in which you may lodge a complaint with the Data Protection Board of India. Where consent is required, you may withdraw it at any time with ease comparable to the ease with which it was given, subject to legal or contractual limitations.

6. AI-Assisted Skin Analysis

EverQ uses artificial intelligence and computer vision technologies to assist in evaluating facial skin characteristics and providing personalized skincare insights. The AI system assists users and healthcare professionals; it does not replace professional medical judgment, does not independently diagnose diseases, and may generate recommendations based on image analysis and user-provided information. Users should consult a qualified healthcare professional before making healthcare decisions based on AI-generated insights. EverQ implements appropriate safeguards to protect facial images and related information throughout processing.

7. Sharing of Personal Information

EverQ does not sell your personal information. We may share your personal information only where necessary to provide our services, comply with legal obligations, protect our legitimate interests, or where you have provided consent. Your information may be shared with the following categories of recipients:

  • Healthcare Professionals: registered doctors, dermatologists, and other authorized medical professionals, for providing teleconsultations, reviewing AI-assisted analysis results, preparing treatment plans, issuing electronic prescriptions, and providing follow-up care. Healthcare professionals are required to maintain the confidentiality of patient information in accordance with applicable professional and legal obligations.
  • Pharmacy Partners: where you purchase medicines or healthcare products, we share only the information required to process and fulfil your order - patient name, delivery address, contact details, prescription details (where applicable), and ordered products.
  • Logistics and Delivery Partners: name, delivery address, contact number, and order reference number, solely for fulfilling deliveries.
  • Payment Service Providers: payments are processed through authorized third-party payment providers. EverQ does not store complete payment card information. Payment providers process payment information in accordance with their own privacy and security standards and RBI requirements.
  • Technology and Cloud Service Providers (Data Processors): trusted providers for cloud hosting, data storage, application monitoring, security services, email communications, customer support, analytics, and infrastructure management. These providers are contractually required to implement appropriate security measures and process information only as instructed by EverQ.
  • Legal and Regulatory Authorities: where required by law, court orders, government authorities, law enforcement agencies, or regulatory bodies, during investigations, to protect legal rights, or to prevent fraud or misuse of the Platform.

8. AI Processing and Automated Decision Support

EverQ uses artificial intelligence technologies to assist users and healthcare professionals. The AI system may process facial images, user-provided skin concerns, questionnaire responses, previous consultation information, and product preferences. AI-generated outputs are intended to support decision-making and should not be interpreted as definitive medical diagnoses. Healthcare professionals remain responsible for independent clinical judgment where medical advice is provided.

9. Telemedicine Services

Where teleconsultation services are offered, EverQ processes personal and health information to schedule appointments, verify user identity, facilitate communication between patients and healthcare professionals, maintain consultation records, generate consultation summaries, and issue prescriptions where appropriate. Teleconsultation services are intended to operate in accordance with the Telemedicine Practice Guidelines, 2020 and applicable professional standards.

10. Electronic Prescriptions

Where permitted by Applicable Law, EverQ may facilitate the issuance and management of electronic prescriptions. Prescription information may be shared only with the consulting healthcare professional, authorized pharmacy partners, and the patient. Prescription records may be retained for legal, medical, and operational purposes in accordance with applicable requirements, including the Drugs and Cosmetics Rules, 1945 and pharmacy record-keeping norms.

11. Data Security

EverQ implements reasonable security safeguards, and reasonable technical and organizational measures, designed to protect personal information against unauthorized access, alteration, disclosure, destruction, or loss, consistent with the DPDP Act and the SPDI Rules. These measures may include:

  • Encryption of data in transit using industry-standard protocols;
  • Encryption of sensitive information at rest where appropriate;
  • Role-based access controls;
  • Multi-factor authentication for administrative access where implemented;
  • Security monitoring and logging;
  • Secure development practices;
  • Vulnerability assessments and periodic security testing; and
  • Employee confidentiality obligations and security awareness training.

In the event of a personal data breach, EverQ will notify the Data Protection Board of India and affected Data Principals in the form and manner prescribed under the DPDP Act and rules thereunder. No method of electronic storage or transmission is completely secure; while EverQ seeks to protect your information using appropriate safeguards, absolute security cannot be guaranteed.

12. Data Retention

EverQ retains personal information only for as long as necessary to provide requested services, maintain medical and transaction records, comply with legal, regulatory, accounting, or reporting obligations, resolve disputes, enforce agreements, and improve and secure the Platform where permitted by law. Consultation and prescription records are retained for the minimum periods required under applicable medical record-keeping norms. After the applicable retention period expires, or where consent is withdrawn and no legal ground for retention remains, personal information will be securely deleted, anonymized, or otherwise disposed of in accordance with our internal data retention practices and Applicable Law.

13. Your Privacy Rights

As a Data Principal under the DPDP Act, and subject to Applicable Law, you have the right to:

  • Access a summary of your personal data being processed and the processing activities undertaken;
  • Correct, complete, and update inaccurate or incomplete personal data;
  • Request erasure of personal data where legally permissible;
  • Withdraw consent where processing is based on consent;
  • Nominate another individual to exercise your rights in the event of death or incapacity;
  • Obtain readily available means of grievance redressal from EverQ; and
  • Lodge complaints with the Data Protection Board of India after first approaching EverQ's grievance mechanism.

EverQ may request reasonable verification of identity before acting on certain requests, and will respond within the timelines prescribed under Applicable Law.

14. Withdrawal of Consent

Where processing is based on your consent, you may withdraw that consent at any time through your Account settings or by contacting us using the details in the Contact Us section. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal and may affect our ability to provide certain services that rely on that information.

15. Children's Privacy

EverQ services are intended for individuals aged eighteen (18) years and above. Where services are provided to or on behalf of a minor (a person under 18 years of age), the verifiable consent of a parent or lawful guardian is required as mandated under Section 9 of the DPDP Act. EverQ does not undertake tracking or behavioural monitoring of children or targeted advertising directed at children, and does not process children's personal data in a manner likely to cause any detrimental effect on their well-being. If EverQ becomes aware that personal information has been collected in violation of applicable legal requirements, appropriate steps will be taken to delete such information and address the situation.

16. International Data Transfers

Personal data is primarily processed and stored in India. Where personal information is processed or stored outside India, such transfers will be carried out only to countries or territories not restricted by the Central Government under the DPDP Act, and subject to appropriate safeguards and any sector-specific localisation requirements (including RBI requirements applicable to payment data). Cross-border transfers, where applicable, will be carried out in accordance with legal and regulatory requirements.

17. Grievance Redressal and Grievance Officer

Users who have questions, concerns, or complaints regarding this Privacy Policy or the processing of personal information may contact EverQ's designated Grievance Officer:

  • Grievance Officer: Bhisham Bhateja
  • Email: support@everq.in
  • Address: 8th floor, SPLENDOR SPECTRUM ONE, 806, Golf Course Ext Rd, Sector 58, Gurugram, Haryana 122098
  • Response timelines: acknowledgement within 48 hours; resolution within the period prescribed under Applicable Law.

If you are not satisfied with the resolution provided, you may approach the Data Protection Board of India in the manner prescribed under the DPDP Act.

18. Contact Us

  • HEALTH Q LIFESCIENCES PRIVATE LIMITED - Brand: EverQ
  • Website: https://everq.in
  • Email: privacy@everq.in
  • Customer Support: support@everq.in
  • Registered Office: 8th floor, SPLENDOR SPECTRUM ONE, 806, Golf Course Ext Rd, Sector 58, Gurugram, Haryana 122098

19. Changes to this Privacy Policy

EverQ may update this Privacy Policy from time to time to reflect changes in our services, technology, legal obligations, or business practices. The revised version will be published on the Platform with an updated "Last Updated" date. Where required by law, we will provide additional notice or obtain fresh consent before material changes take effect.

20. Governing Law

This Privacy Policy shall be governed by and construed in accordance with the laws of India. Any disputes arising from or relating to this Privacy Policy shall be subject to the exclusive jurisdiction of the competent courts having jurisdiction over HEALTH Q LIFESCIENCES PRIVATE LIMITED, unless otherwise required by Applicable Law.

Annexure A - Categories of Personal Information

EverQ may process the following categories of information, depending on the services used: identity information; contact information; account information; device information; usage information; consultation records; health information; facial images submitted for AI-assisted analysis; prescription information; order and transaction history; customer support communications; and consent records.

Annexure B - Third-Party Service Providers

EverQ may engage trusted service providers for cloud infrastructure, payment processing, SMS and email communications, authentication services, telemedicine infrastructure, pharmacy order fulfilment, logistics and delivery, customer support, security monitoring, and analytics. A current list of significant service providers may be made available upon request where appropriate and subject to applicable legal or contractual limitations.

For questions about this document, contact us at support@everq.in.