Introduction:
Thank you for your interest, in enrolling with us in the GlucoControl program, which uses WhatsApp Business and is designed to provide support and information to individuals with Diabetes. The program will be delivered by Wellthy Therapeutics Pvt. Ltd. (Data Processor), who will be responsible for collection and processing of your personal information, on behalf of the program sponsor Dr. Reddy’s and Nestle Health Science Limited (Data Controller).

Purpose:
The purpose of this support program is to provide you with information and support related to effectively manage your blood sugar levels. This data will be used to improve the products and service offerings that are intended to support your Diabetes journey and to better understand your needs related to manage your day to day blood sugar levels.

Collection of Personal Information:

Your participation in the GlucoControl Program is voluntary and if you are interested and consent to participate in the GlucoControl program, you will be asked to provide your Personal Information, including your basic identifying information such as the user’s name, age, gender, and contact details (e.g., email address, phone number), your health information such as medical history, symptoms, diagnoses, medications, allergies, and treatment plans and activity data about your lifestyle, exercise routines, diet, and sleep patterns. Where you are required to share your family history, it will be assumed that you have the consent of your family members to share their Personal Information. It’s important to note that the collection and processing of personal data is always done in compliance with applicable data protection laws and regulations in India. Please note that this program shall also be governed by the privacy policy mentioned at https://www.drreddys.com/privacy-policy

Purpose and Use of personal information:
Personal Information is collected to understand the history of the individual having Diabetes and any underlying health conditions, in order to offer appropriate support. The data shall be also used for monitoring the progress and effectiveness of this support program.

Access & sharing of personal information:
Authorized Personnel: Within the organization, access to personal data is limited to authorized personnel or specific vendors of the Data Processor, who require it for specific roles or services, such as customer support representatives, technical staff, or data administrators and health coaches or data hosting services.

While, the processing of personal data will always align with the principles of data protection, privacy, and confidentiality, the data may also be anonymized and aggregated and shared with the Data Controller and/or any other third parties as the Data Controller may so direct from time to time.

Procedure:
As a participant in the GlucoControl program, you will receive information about Diabetes along with diet and lifestyle tips for effectively managing your blood sugar levels. The content that is delivered to you is based on the responses provided by you and no duty or obligation is assumed for or in respect of any of the information or services made accessible to you under this program. You will also get access to a health coach appointed by the Data Processor, who will interact with you over calls and chats. These health coaches are not medical professionals and none of our services and/or content in this support program include the provision of medical advice or treatment. All telephonic and chat conversations will be recorded for training and quality purposes. Should you have any queries on medication or any other health related query, you must reach out to your doctor. Your participation shall not be construed as an invitation or encouragement to use or buy any product or services or as a substitute of medical advice. For any medical advice, please reach out to your doctor

Confidentiality:
All information collected as part of the GlucoControl program will be kept confidential. We agree not to disclose the details except on a need-to-know basis and shall take all reasonable measures to protect any information in relation to this support program. Your Personal Information will not be shared with any third parties without your explicit consent, except for carrying out services under this support program and information required by law or regulation to disclose to any regulatory agencies or any other person or body entitled by law to such disclosure or for the purposes of any audit conducted either by Data controller and/or any third party appointed by Data Controller.

Data Security:
We maintain reasonable electronic and procedural safeguards to protect your information as per applicable laws, regulations and standards in India.

Data Retention:

We retain your Personal Information in accordance with applicable laws, for a period no longer than is required for the purpose for which it was collected or as required under any applicable law. However, we may retain data related to you if there is legal obligation to retain the data; if required to comply with any statutory or regulatory retention requirement by law.

Data Subject rights:
We take every reasonable step to ensure that your Personal Information is accurately processed and, where necessary, kept up to date, and if you inform us that any of your personal data processed by us is inaccurate (having regard to the purposes for which they are processed), we shall erase or rectify the same. You may write to us at the contact information provided below to assist you with the request to add, modify and delete your personal information.

You can also withdraw your consent that you have already provided by writing to us at the contact information provided below. Please mention “for withdrawal of consent” in the subject line of your communication. We will verify such requests before acting upon your request. Please note that withdrawal of consent will not be retroactive and will be in accordance with the terms of this consent form and applicable laws. In the event you withdraw consent given to us, such withdrawal may hamper your access to the patient support or restrict provision of our services to you.

Please note that your Personal Information will also be processed by WhatsApp Business, in line with their Terms of Service. For more details, visit: https://business.whatsapp.com/terms-and-conditions

You can also nominate another individual to exercise your privacy rights on your behalf in case of your death or inability to do so.

Changes to Patient Consent:
We will keep you informed about any changes in Patient Consent form by sending you an email/alerts. Also the date will reflect the latest version of this Consent document. You continuing to use our services post the release date of the updated terms of consent shall be considered as your deemed consent of such updated terms. Should you have any concerns with the updated terms you shall cease to use our services and may choose to withdraw your consent as per the process mentioned above.

 Customer Care Support
For any query or complaint, or for exercising your rights, you are requested to contact our customer care by sending an Email at helpdesk@wellthy.care and you can expect to receive a response within a reasonable time frame but within timelines prescribed under applicable laws in India. If you have any concerns related to how your personal information is being processed, you can also write to our Data Privacy Officer at  dataprivacy@drreddys.com.

Participation in the GlucoControl program is voluntary, and you may choose to stop participating at any time. If you choose to stop participating, you can reach out to us and we shall off-board you from this program.

By pressing ‘Yes’ on your WhatsApp Business chat screen, you acknowledge that you have read and understood the information provided in this consent form, and you agree to participate in the GlucoControl program on the terms as stated in this consent form.