Privacy Policy

1. Who We Are

JivaKosh, operated by JivaKosh Health Technologies Pvt. Ltd., is a health data management platform that enables individuals and families to securely store, organise, and manage personal health records.

We are a Data Fiduciary as defined under the Digital Personal Data Protection Act, 2023 (DPDP Act). This means we determine the purpose and means of processing your personal data and are responsible for ensuring that such processing is lawful, fair, and transparent.

2. Scope of This Notice

This Privacy Notice applies to:

• The JivaKosh mobile application (iOS and Android)
• The JivaKosh web application at jivakosh.com
• All related services, APIs, and communications operated by JivaKosh Health Technologies Pvt. Ltd.

This notice is issued in compliance with Section 5 of the Digital Personal Data Protection Act, 2023 and describes the personal data we collect, why we collect it, how we use and protect it, and the rights you hold as a Data Principal.

3. What Personal Data We Collect

We collect personal data only to the extent necessary for the purposes described in this notice.

We do not collect personal data from third-party data brokers, social media platforms, or government registries.

4. Why We Process Your Data — Purposes and Legal Basis

Under the DPDP Act, we process personal data only on the basis of your freely given, specific, informed, and unambiguous consent. The table below sets out each processing purpose and its consent basis.

You may withdraw any optional consent at any time from Settings → Privacy & Consent in the app. Withdrawal of mandatory consents will result in account closure.

5. Who We Share Your Data With

We do not sell, rent, or trade your personal data. We share data only with trusted Data Processors who process data strictly on our instructions and are contractually bound to protect it.

All processors are engaged under Data Processing Agreements that require them to process data only as instructed, implement appropriate security measures, and delete or return data upon termination.

We may also disclose personal data to government or regulatory authorities when required by law, or to our legal and financial advisors under confidentiality obligations. In the event of a merger or acquisition, you will be notified of any change in Data Fiduciary.

6. Health & Fitness Data from Connected Devices (Google Health Connect & Apple HealthKit)

JivaKosh offers an optional Vital Sync feature that reads health and fitness data from your device's health platform — Google Health Connect on Android and Apple HealthKit on iOS — so your wearable, scale, BP cuff, and glucose meter readings appear in your JivaKosh vitals dashboard alongside the medical documents you upload.

This feature is strictly opt-in. We do not read any data from Health Connect or HealthKit until you tap Connect in Settings → Vital Sync and grant each individual data type in the system permission screen. You can revoke any permission at any time from the system Health Connect / Health settings, or disconnect the feature entirely from inside JivaKosh.

6.1 Health Data Types We Access

The table below lists every Health Data type JivaKosh requests, the exact Health Connect permission, what we do with it, and our commitments around handling.

On iOS, the equivalent Apple HealthKit data types are read under the NSHealthShareUsageDescription entitlement. The categories and usage purposes are identical to the Health Connect table above.

6.2 How Health Connect / HealthKit Data Is Stored and Protected

• Aggregated daily summaries (e.g. min/avg/max heart-rate, step total, sleep duration) are uploaded to your encrypted JivaKosh vault on Microsoft Azure (India region).
• Storage uses AES-256 encryption at rest and TLS 1.3 in transit.
• Health Connect / HealthKit data is associated only with your JivaKosh account and is accessible only to you and the family members you explicitly grant access to.

6.3 What We Do Not Do With Health Connect / HealthKit Data

• We do not sell, rent, trade, or transfer this data to any third party for advertising, marketing, or any other commercial purpose.
• We do not share this data with insurers, employers, data brokers, or any other party without your explicit per-share consent.
• We do not send Health Connect / HealthKit data to OpenAI or any other AI provider.
• We do not use Health Connect / HealthKit data to train or fine-tune any machine-learning or AI model.
• We do not derive a credit score, insurance score, or any other financial scoring from your health data.
• We do not read any Health Connect data type beyond the ten listed in Section 6.1.

6.4 Retention and Deletion

• Health Connect / HealthKit summaries are retained for the lifetime of your active account so you can see long-term trends.
• When you disconnect Vital Sync, all further reads stop immediately. Previously synced summaries remain in your vault and you can delete them individually from the Vitals screen.
• When you delete your JivaKosh account, all Health Connect / HealthKit data in your vault is permanently deleted within 30 days from live systems and within 90 days from backups, as described in Section 9.
• JivaKosh does not modify, delete, or write back to Health Connect or HealthKit (we use read-only access on Android; on iOS, write access is only used when you manually log a vital inside JivaKosh).

6.5 Revoking Access

• Android: Open the Health Connect app → App permissions → JivaKosh, and toggle off any data type, or tap Remove all permissions.
• iOS: Open the Settings app → Privacy & Security → Health → JivaKosh, and toggle off any data category.
• Inside JivaKosh: Open Settings → Vital Sync → Disconnect. This stops the sync orchestrator from making any further reads.

7. Third-Party Account Connections (Google Gmail)

JivaKosh offers an optional Gmail connector that lets you import medical documents (lab reports, prescriptions, discharge summaries, and similar records) that have been emailed to you as attachments. You may connect your Google account from Account Settings → Connect Gmail in the JivaKosh mobile app at any time, and you may disconnect at any time.

Google API scopes we request

When you connect Gmail, we request the following scopes via Google OAuth:

What we do with your Gmail data

• We scan the last 90 days of your inbox for PDF, JPG, and PNG attachments that appear to be medical documents
• Matching attachments are presented to you in a dedicated review screen inside the JivaKosh app
• Only attachments you explicitly select and confirm are imported into your JivaKosh health vault
• Imported attachments are then processed by the same document pipeline as any other upload (with AI extraction applied only if you have separately consented to AI processing — see Section 4)

What we do not do

• We do not read non-medical emails or email bodies
• We do not send, modify, delete, or label any messages in your inbox
• We do not access your Google contacts
• We do not display your email inbox inside the JivaKosh app
• We do not share Gmail data with any third party for purposes other than the specific import you requested
• We do not use Gmail data to train or fine-tune machine-learning or AI models

How we store and protect Gmail credentials

Google OAuth refresh tokens are encrypted at rest using AES-256-GCM with an encryption key stored in Microsoft Azure Key Vault. Access tokens are short-lived and are also encrypted. Tokens are never logged, never included in client-side bundles, and never shared with any party outside JivaKosh.

Revoking access

You can disconnect Gmail at any time from Account Settings → Gmail in the JivaKosh mobile app. Disconnection:

• Immediately revokes JivaKosh's OAuth token at Google
• Deletes the encrypted refresh token and access token from our servers
• Does not delete medical documents you previously chose to import — those remain in your health vault and can be removed individually at any time

You can also revoke access directly from your Google account at myaccount.google.com/permissions.

Google API Services User Data Policy — Limited Use

8. Cross-Border Data Transfers

Some of our Data Processors, notably OpenAI (AI processing), are located in the United States. TrustSignal (SMS/WhatsApp) processes data within India. When you consent to AI document processing or SMS/email communications, your data is transferred to these processors outside India.

We ensure that all cross-border transfers are made only to processors with adequate contractual protections in place, are subject to the conditions of the DPDP Act, and are limited to the minimum data necessary for the stated purpose.

If you do not consent to AI processing, your documents will not be transferred to OpenAI and will be stored without automated data extraction. Health Connect / HealthKit data is never transferred outside India — it is stored in our Microsoft Azure India region.

9. How Long We Keep Your Data

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law.

After account deletion, personal data is purged from live systems within 30 days and from backups within 90 days, except where retention is required by law.

10. Your Rights as a Data Principal

Under the DPDP Act, you have the following rights. To exercise any right, contact dpo@jivakosh.com or use the in-app settings.

11. Children's Data

JivaKosh allows account holders to create family health profiles for minor dependants (persons below 18 years of age). When you add a minor to your family profile, you represent that:

• You are the parent or legal guardian of that minor
• You are providing consent on behalf of the minor for the storage and management of their health data
• You will remove the minor's profile if you are no longer their guardian

We do not knowingly allow minors to create independent accounts without parental consent. All rights described in Section 10 may be exercised by a parent or guardian on behalf of a minor.

12. Data Security

We implement appropriate technical and organisational measures to protect personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• End-to-end TLS encryption for all data in transit
• AES-256 encryption for documents and sensitive data at rest
• Role-based access controls limiting staff access to personal data
• Multi-factor authentication for administrative access
• Regular security assessments and vulnerability scanning
• Secure deletion procedures for data no longer required

In the event of a data breach that poses a risk to your rights, we will notify you and the Data Protection Board of India as required by the DPDP Act.

13. Changes to This Privacy Notice

We may update this Privacy Notice from time to time. When we make material changes, we will post the revised notice at jivakosh.com/privacy with the updated date, and notify you by email or in-app notification at least 7 days before the changes take effect. Where changes require fresh consent, we will prompt you to provide that consent before the changes apply to you.

14. Contact and Grievances