Introduction

The State Health Agency (SHA) Kerala‘s mobile application - “KASP Health App” enables the public to view the details about their Health insurance scheme - Karunya Arogya Suraksha Padhathi (KASP).

KARUNYA AROGYA SURAKSHA PADHATHI (KASP) is the Government health care scheme which aims at providing a health cover of Rs. 5 lakhs per family per year for secondary and tertiary care hospitalization to over 42 Lakhs poor and vulnerable families that form the bottom 40% of the Kerala population. State of Kerala decided to converge all the Government sponsored health care schemes namely RSBY (Central and State Government combined scheme, where the premium is shared in the ratio 60:40), Comprehensive Health Insurance Scheme-CHIS (Kerala government fully sponsored scheme i.e. full premium paid by the State) etc along with Ayushman Bharat – Pradhan Mantri Jan Arogya Yojana (PMJAY) and formulated Karunya Arogya Suraksha Padhathi (KASP).

“KASP Health App” is a user-friendly Mobile Application introduced by the State Health Agency (SHA) with the help of Kerala Development and Innovation Strategic Council (K-DISC) to provide details about health-related information and details on KASP.

This document describes the Privacy Policy along with terms and conditions associated with the usage and data collection of the “KASP Health App” mobile Application.

“KASP Health” Mobile Application is developed by Qkopy Online Services Pvt Ltd with its registered office at "UL Cyberpark KSUM 2nd floor,NelliKode, Kerala 673016". This Policy describes how ' KASP Health App' and its Entities/Partners (herein after referred to as the “Platform”) provide its services to public users. By downloading and using the ' KASP Health App ' through the Google Play Store, you expressly agree to be bound by this Privacy Policy and the applicable terms and conditions. We value the trust you place in us and honor your privacy, holding the highest accepted standards for secure transactions and protection of your personal information.

This Privacy Policy is published and shall be construed in accordance with the provisions of Indian laws and regulations, including the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, under the Information Technology Act, 2000, the Aadhaar Act, 2016 and its Amendments, including the Aadhaar Regulations; that require publishing of the privacy policy for the collection, use, storage, transfer, disclosure of Personal Information.

Personal Information means and includes all information that can be linked to a specific individual and also includes Sensitive Personal Information (all Personal Information that requires heightened data protection measures due to its sensitive and personal nature), both, herein after referred to as “Personal Information,” excluding any information that is freely available or accessible in the public domain.

If you disagree with this Privacy Policy, please do not use or access our Platform.

Information Collection

We may collect your Personal Information when you use our Platform during the course of our relationship. We collect Personal Information which is relevant and absolutely necessary for providing the services in the form of KASP card details.

Personal and Sensitive Personal Information collected includes but is not limited to:

• Mobile number, ration card details
• Your device details, such as device identifier, device model, Brand

Information may be collected at various stages of your usage of the Platform, such as:

Registration
Registering on the Platform as a “user,” which may be governed by terms and conditions listed on the Platform.

We and our service providers or partners may also collect your Personal Information from third parties or information made publicly available.

Purpose and Use of Information

The platform may process your Personal Information for the following purposes:

• Registration of your account and verification of your identity and access privileges
• Provide you access to the KASP card details and wallet balance
• To monitor and review services from time to time, customize the services to make your experience safer and easier, and conduct audits
• To resolve disputes; troubleshoot problems; provide technical support and fix bugs; help promote a safe service
• To identify security breaches and attacks; investigate, prevent, and take action on illegal or suspected fraud or money laundering activities; and conduct forensic audits as part of an internal or external audit or investigation by government agencies in India.

Information Sharing and Disclosures

Your Personal Information is shared as allowed under applicable laws, after following due diligence and in line with the purposes set out in this Policy.

We may share your Personal Information in the course of your transaction with different categories of recipients such as business partners, service providers, merchants, affiliates, associates, subsidiaries, legally recognized authorities, regulatory bodies, governmental authorities, financial institutions, internal teams such as marketing, security, investigation team, etc.

Personal Information will be shared, as applicable, on a need-to-know basis, for the following purposes:

• For enabling the provision of the Rewards availed by you and facilitating the services between you and the Platform Entities, as requested
• For services related to communication, marketing, data and information storage, transmission, security, analytics, fraud detection, risk assessment, and research
• Enforce our Terms or Privacy Policy; respond to claims that an advertisement, posting, or other content violates the rights of a third party; or protect the rights, property, or personal safety of our users or the general public
• If required to do so by law or in good faith, we believe that such disclosure is reasonably necessary to respond to subpoenas, court orders, or other legal processes.
• If requested by government authorities for government initiatives and benefits
• For grievance redressal and resolution of disputes

The platform ensures stricter or no less stringent privacy protection obligations are cast on these third parties, wherever applicable and to the extent possible. However, the Platform may share Personal Information with third parties such as legally recognized authorities, regulatory bodies, governmental authorities, and financial institutions as per purposes set out in this Policy or as per applicable laws. We do not accept any responsibility or liability for the usage of your Personal Information by these third parties or their policies.

Storage and Retention

To the extent applicable, we store Personal Information within India and retain it in accordance with applicable laws and for a period no longer than required for the purpose it was collected. However, we may retain Personal Information related to you if we believe it may be necessary to prevent fraud or future abuse or if required by law, such as in the event of the dependency on any legal/regulatory proceeding or receipt of any legal and/or regulatory direction to that effect or for other legitimate purposes.

Once the Personal Information has reached its retention period, it shall be deleted in compliance with applicable laws.

Reasonable Security Practices

The platform has deployed technical and physical security measures to safeguard users’ Personal Information and Sensitive Personal Information. We understand that as effective as our security measures are, no security system is impenetrable. Hence, as part of our reasonable security practices, we undergo strict internal and external reviews to ensure appropriate information security encryption or controls are placed for both data in motion and data at rest within our network and servers, respectively.

The database is stored on servers secured behind a firewall; access to the servers is password-protected and strictly limited.

Further, you are responsible for maintaining the confidentiality and security of One Time Password (OTP) and Mobile Number. Please do not share your OTP details with anybody. It shall be your responsibility to inform us in case of any actual or suspected compromise of your Personal Information.

Third-Party Products, Services, or Websites

When you are availing information from ' KASP Health App ' Platform, Your Personal Information may be collected by respective Partners/subsidizers, and such Personal Information shall be governed by their privacy policy. You may refer to their privacy policy and terms of service to understand how your Personal Information will be handled by such service providers.

Our services may include links to other websites or applications when you visit our Platform. Such websites or applications are governed by their respective privacy policies, which are beyond our control.

Your Consent

We process your Personal Information with consent. By using the ' KASP Health App ' Platform or services and/or by providing your Personal Information, you consent to the processing of your Personal Information by the Platform in accordance with this Privacy Policy.

If you disclose to us any Personal Information relating to other people, you represent that you have the authority to do so and permit us to use the information in accordance with this Privacy Policy.

Opt-out

We provide all users with the right to opt-out/quit our services after setting up an account. If you want to remove your contact information from all our lists or discontinue any of our services, please click on the De-Register button on the application.

Personal Information Access/Rectification and Consent

If you wish to delete your account or Personal Information, please use the ‘Feedback’ section of the ' KASP Health App ' Platform. However, retention of your Personal Information will be subject to applicable laws.

For the above requests, Team ' KASP Health App ' may need to request specific information from you to confirm your identity and ensure authentication. This is a security measure to ensure that Personal Information is not disclosed to any person who does not have a right to receive it or is not incorrectly modified or deleted.

Children Information

We do not knowingly solicit or collect Personal Information from children under the age of 18, and use of our Platform is available only to persons who can form a legally binding contract under the Indian Contract Act 1872. If you are under the age of 18 years, then you must use the Platform or services under the supervision of your parent, legal guardian, or any responsible adult.

Changes to Policy

We reserve the right, at our sole discretion, to change, modify, add, or remove portions of this Privacy Policy at any time without any prior written notice to you. We may, however, reasonably endeavor to notify you of the changes; it is your responsibility to review the Privacy Policy periodically for updates/changes. Your continued use of our services/Platform following the posting of changes will mean that you accept and agree to the revisions. We will never make changes to policies in order to make them less protective of Personal Information already shared by you.

Contact Us

In case you have any questions, concerns, or complaints regarding the processing of your Personal Information or this Privacy Policy, you may write to ' KASP Health App ' Privacy Officer using the feedback form provided in the ' KASP Health App '. We are committed to answering your questions within a reasonable time limit. Any delay in the resolution time shall be proactively communicated to you.