PRIVACY POLICY
HealthAI is operated by SMARTnCODE Technologies Private Limited ("SMARTnCODE", "we", "us", "our"). We are committed to protecting your personal health information and ensuring complete confidentiality, data sovereignty, and security.
Last updated: September 3, 2026 · Version v1.0.2
PART A — COMPANY-WISE TERMS & COMMITMENTS
A.1 Identity of the Data Fiduciary/Controller and Named DPO
SMARTnCODE Technologies, Jain Sadguru Capital Park, Hyderabad, Telangana, India, is the Data Fiduciary/Controller responsible for your personal data.
For questions regarding this Privacy Policy, the processing of your personal data, or to exercise your applicable privacy and data protection rights, you may contact our Privacy & Grievance Support Team at support@smartncode.com.
Our Support Team will receive and route privacy-related requests to the appropriate personnel within SMARTnCODE Technologies for review and resolution.
A.2 Security Measures We Maintain
We encrypt personal data in transit and at rest and maintain session management controls that allow you to view and control your active sessions yourself through Profile → Linked Accounts and Devices → Active Sessions.
A.3 Sub-Processors and Data We Share
We may share your personal data with service providers, including cloud, AI/ML, calendar/health-platform, payment, and communications providers, as necessary to provide the Service, or with authorities where legally required or permitted. We require appropriate contractual, confidentiality, and security safeguards for providers processing data on our behalf. We do not sell your personal data or permit third parties to use your health data for their own advertising. We will provide applicable information about material sub-processors, their purposes, processing locations, and any AI model-training use, including required choices or opt-outs.
A.4 Breach Notification Commitment
If we experience a data breach affecting your personal data, we will notify you and the relevant regulator within the timeline required by the law applicable to you.
A.5 No Sale of Data, No Health-Data Advertising
We do not sell your personal data. We do not use health data collected through the Service for third-party advertising.
A.6 Changes to This Policy
We will notify you in-app of changes to this Policy. Where a change materially affects a purpose you previously consented to, we will seek your renewed, affirmative consent before relying on the new purpose.
PART B — USER-WISE RIGHTS & CHOICES
B.1 Granular Consent, By Purpose
When you create your account, you separately confirm: Health Data Processing (required for core functionality), AI Analysis of Uploaded Reports (required for report insights), Anonymized Research and Product Improvement (optional, off by default), and Health Tips & Updates (optional, off by default). You can change any optional preference at any time in Account Settings.
B.2 Family Member Data — Consent Before Activation
If you add a family member to your account, we collect the information you provide about them (name, mobile number, relationship, date of birth, gender, blood group, and any health records you upload on their behalf). Health-data processing for that profile does not begin until either (a) the added person accepts an invitation and confirms their own consent, or (b) where the profile belongs to a minor, we have verified your identity and your relationship or guardianship status.
B.3 Your Rights
Subject to the law applicable to you, you may have the right to: access a copy of your data; correct inaccurate data; request deletion or erasure; withdraw consent at any time (without affecting the lawfulness of past processing); object to certain processing; and request data portability. Most of these rights can be exercised directly in-app (Profile → Account Information, Health Preferences, Linked Accounts, Delete Account) or by contacting us at support@smartncode.com.
B.4 Marketing and Health Tips
"Health Tips & Updates" is opt-in, off by default, and can be withdrawn at any time without affecting your access to core Service features.
B.5 If a Minor's Data Is Found Without Verified Consent
If we identify that a profile belongs to a minor without completed guardian verification, we will suspend processing of that profile's health data (rather than delete it outright) until verification is completed or the profile is removed by the account holder.
PART C — LEGAL PERSPECTIVE & JURISDICTIONS
C.1 Legal Basis for Processing, By Purpose
Account operation relies on the necessity of processing to perform our contract with you. AI health analysis relies on your explicit consent. Anonymized research and marketing communications each rely on separate opt-in consent. No purpose involving your health data relies on a general "legitimate interest" basis.
C.2 International Data Transfers
Your data may be processed in India. Where data is transferred outside India, we rely on the framework in Section 16 of the DPDP Act, 2023, which permits transfers to any country by default unless the Central Government has specifically restricted that country by notification (no such restriction is currently in force). Where other jurisdictions' residents' data is transferred internationally, we apply the safeguard appropriate to that jurisdiction — for example, a documented privacy-impact assessment for Quebec residents under Law 25, or an approved safeguard/adequacy finding for Saudi residents under the PDPL.
C.3 Retention and Deletion
We retain your personal data while your account remains active. When you delete your account, your personal data is permanently deleted from our systems within seconds and cannot be retrieved or recovered. We do not retain your data after account deletion.
C.4 Jurisdiction-Specific Provisions
India (DPDP Act 2023 & Rules 2025)
We process your data as a Data Fiduciary under the DPDP Act, 2023 and DPDP Rules, 2025. Our Grievance Officer's contact details are in Part A. Unresolved grievances may be escalated to the Data Protection Board of India.
United States (CCPA/CPRA, Washington MHMDA & COPPA)
If you are a California resident, see our CCPA/CPRA Notice at Collection for your "Do Not Sell/Share" rights, even though we do not sell data, because sharing for advertising purposes must be separately disclosed and opted out of if it occurs. If you are a Washington resident, see our standalone Consumer Health Data Privacy Policy, required under the My Health My Data Act, including a functioning opt-out of any location-based health-data tracking. If you are under 13, our processing of your data is governed by COPPA and requires your parent's or guardian's verified consent.
United Kingdom & European Union (UK GDPR & EU GDPR Article 9)
We process special-category health data relying on the explicit-consent condition under UK GDPR Article 9(2)(a). Where we use automated processing to generate a Health Score or AI summary, your rights under Articles 22A–22D (introduced by the Data (Use and Access) Act 2025) — including the right to a human-reviewed explanation and to contest the output — are described in Part D. The Information Commissioner's Office (ICO) is your supervisory authority.
Canada (PIPEDA & Quebec Law 25)
We process your data consistent with PIPEDA's ten fair-information principles. If you are a Quebec resident, Law 25 additionally applies, including your right to have a privacy officer designated (see Part A) and to receive consent requests presented separately from other terms.
Australia (Privacy Act 1988 & APPs 3 and 6)
We handle your health information consistent with Australian Privacy Principles 3 and 6, which apply to all private health-service-adjacent providers regardless of size. Since June 2025, you may also have access to the statutory tort for serious invasions of privacy introduced by the Privacy and Other Legislation Amendment Act 2024.
GCC States (UAE Law No. 2/2019, Decree 26/2025 & Saudi PDPL)
If you are a UAE resident, your health data is governed by Federal Law No. 2/2019 (confidentiality of patient information) rather than the federal PDPL, and, where relevant, by Federal Decree-Law No. 26/2025 on Child Digital Safety. If you are a Saudi Arabia resident, our processing is governed by the PDPL and its Implementing Regulations, including the mandatory DPO named in Part A. If you are a Qatar, Bahrain, or Oman resident, we process your sensitive/special-nature data under the safeguards required by the applicable local law.
Singapore (PDPA 2012 & 2024 Advisory Guidelines)
We process your data consistent with the Personal Data Protection Act 2012. If you are under 18, our processing is additionally guided by the Personal Data Protection Commission's 2024 Advisory Guidelines on Children's Personal Data in the Digital Environment.
PART D — HEALTH AI-WISE DISCLOSURES
D.1 What Health Data We Collect and Why
We collect the following categories of health data, each for the specific purpose stated:
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Blood group, height, weight: To power your profile and Health Score calculation.
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Uploaded medical reports and scans: To generate the AI report summary you request.
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Prescriptions: To extract medicines, set reminders, and generate summaries.
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Vitals (blood pressure, glucose, SpO2, HbA1c): To power vitals tracking and trend charts.
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Medicines and dosages: To power interaction checking and reminders.
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Appointment records and vaccination status: To power the Appointments and Vaccination features.
D.2 AI/LLM Processing Disclosure
Our enterprise AI processing models include Google Cloud Gemini, OpenAI, and Anthropic. We use these providers to generate the Health Score, 'Needs Attention' flags, and report summaries you see in the app. We do NOT use your uploaded medical reports, documents, or data to train these providers' general-purpose foundation models.
D.3 Automated Decision-Making and Your Right to Contest
Health Scores, 'Needs Attention' flags, and AI summaries are generated by automated analysis of the data you upload. These outputs are informational only and are not a medical diagnosis. You have the right to request a human-reviewed explanation of, and to contest, any such output by contacting us at no cost, and you are never required to treat an automated output as final.
D.4 Sensitive and Special Category Data — Extra Safeguards
Health data, biometric App-Lock data, and any family member's health data receive access controls and encryption beyond the baseline applied to account and identity data, and are never used for behavioural advertising. Face ID/fingerprint data used for App Lock is processed and stored only locally on your device via your device manufacturer's secure hardware enclave and is never transmitted to or stored on our servers.
D.5 Location Data for Nearby and Emergency Features
We use your location only to power the Nearby hospitals/pharmacies search and the SOS emergency-call feature. We do not retain your location beyond the session unless you save a location, and we do not share it with advertisers.
D.6 Emergency/SOS Data Handling and Limitation
When you use the SOS feature, we use your device's location, where available, to attempt to display or dial a locally-appropriate emergency number. The SOS feature is not a monitored emergency-response service and does not transmit your location to any emergency dispatcher on our behalf. You remain responsible for contacting your local emergency services directly in a genuine emergency.
D.7 Algorithmic Bias Disclosure
The AI models underlying your Health Score and report summaries are trained on datasets that may not equally represent all demographic groups, geographies, or rare medical conditions. We encourage you to interpret AI outputs with this limitation in mind and to treat them as a starting point for a conversation with your healthcare provider, not a final assessment.
D.8 Data Minimization in AI Processing
The AI-generated Health Score and summary for any given report are derived only from the specific report(s) you upload for that analysis. They are not cross-referenced against other users' data to produce your score.
CONTACT & GRIEVANCE
SMARTnCODE Technologies Private Limited
Jain Sadguru Capital Park, Hyderabad, Telangana, India
Privacy & Support: support@smartncode.com
Website: www.smartncode.com
© 2026 SMARTnCODE Technologies Private Limited. All rights reserved.