Privacy Policy

AREN is a clinical software platform operated by Anmol Pandey, an individual carrying on business as Aren Node (“AREN”, “we”, “us”, “our”). This Privacy Policy describes the categories of information we process in connection with the Service, the purposes for which we process it, the parties with whom it may be shared, the periods for which it may be retained, and the rights available in respect of it.

This Policy applies to the AREN website, the Clinic registration process, and the AREN applications, including AREN Front Desk, AREN Consult, AREN Cortex and the Synapse functionality within them. It forms part of, and shall be read together with, the Terms of Service. Capitalised terms not defined in this Policy have the meanings given to them in the Terms of Service.

This Policy does not govern the practices of any Clinic in respect of its own patients. A Clinic's handling of patient information outside the Service is a matter between that Clinic and its patients.

In this Policy, the following expressions shall have the meanings set out below.

The allocation of responsibility under applicable data-protection law differs according to the category of information concerned, and the distinction determines which party a given obligation falls upon.

The Clinic shall be responsible for the lawfulness of the Patient Data it processes through the Service, including for obtaining and maintaining any consent, authorisation or notice required under applicable law, and for its accuracy. The warranties given by the Clinic in this respect are set out in the Terms of Service.

AREN shall not be responsible for determining whether a Clinic's own processing of patient information complies with the professional, statutory or regulatory obligations applicable to that Clinic.

We process the following categories of information. Where a category is supplied by the Clinic, we process only such information as the Clinic elects to enter into the Service.

We process the information described in section 4 for the purposes set out below, in each case to the extent applicable to the Subscription in force and the functionality the Clinic uses.

The following restrictions apply to identifiable personal information and identifiable Patient Data, and are not qualified by any other provision of this Policy.

We do not use identifiable Patient Data for advertising, for the marketing of third-party products or services, or for any independent commercial exploitation unrelated to the provision and improvement of the Service. We do not undertake profiling of patients for commercial purposes.

We do not sell, licence, rent, trade or otherwise transfer identifiable Patient Data, identifiable practitioner information or identifiable Clinic information to advertisers, data brokers, insurers, pharmaceutical undertakings, medical device undertakings or other third parties for their own independent purposes.

Identifiable information may be disclosed only in the following circumstances:

The Service includes Synapse, a clinical suggestion and ranking function which presents ranked options drawn from clinical and medicine-related information available to it. Synapse does not independently make clinical decisions and does not replace clinical judgment. The treating clinician remains responsible for the review of patient information, the interpretation of findings, the determination of diagnosis and treatment, and the assessment of whether any suggestion is appropriate.

Synapse may personalise the ordering and relevance of the options it presents, based on usage patterns and preferences observed within the Service. Personalisation operates at two levels:

Personalisation of this kind is confined to the Authorised User or Clinic to which it relates. It is not used to influence the suggestions presented to any other Clinic, and it is distinct from the improvement of Synapse at a general level, which is addressed in section 8.

Personalisation does not restrict the options available. An Authorised User may select any clinically appropriate option, including one not presented among the higher-ranked suggestions, and may disregard the suggestions entirely.

We may create De-identified Information and Aggregated Information from information processed through the Service, applying measures intended to ensure that the resulting information no longer identifies, and cannot reasonably be used to identify, an individual, an Authorised User or a Clinic. Whether information has been effectively de-identified is assessed having regard to the means reasonably likely to be used to re-identify it, and to applicable law.

Subject to applicable law, we may retain and use De-identified Information and Aggregated Information for the following purposes:

De-identification is applied before information is used for the purposes set out in this section. We shall not attempt to re-identify De-identified Information, nor permit or assist any other person to do so, except where re-identification is required by law or is necessary to investigate a suspected failure of the de-identification process itself.

No report, publication or disclosure made under this section shall contain information from which a Clinic, an Authorised User or a patient may be identified, whether from that information alone or in combination with other information reasonably available.

Information which has been effectively de-identified does not identify any individual, and our rights to retain and use it, together with the rights of any person to whom it has lawfully been provided, shall survive the expiry or termination of a Subscription and of the Terms of Service. We state this expressly rather than leave it to be inferred: findings, models and clinical rules derived from such information cannot be withdrawn on a per-Clinic basis without degrading the Service for Clinics which continue to rely upon it.

A Clinic may, by written request to anmol@arenode.com, require that information originating from its use of the Service be excluded from the research, publication, benchmarking and model-development purposes described in this section. Such exclusion shall take effect prospectively, shall be given without charge, and shall not affect the Clinic's access to the Service or to any functionality within it. Exclusion does not extend to processing necessary for the operation, security, support, maintenance and repair of the Service itself.

The Service is an online service which maintains certain information locally on Authorised Devices in order to support continuity of operation and responsiveness. Information so maintained is routinely synchronised with our infrastructure.

Personalisation Data may likewise be associated with an Authorised User's use of the Service on an Authorised Device, for the purposes described in section 7.

Information held locally on an Authorised Device is within the physical control of the Clinic. The Clinic shall be responsible for the physical and logical security of its devices, including access control, device encryption where appropriate, and the secure disposal or reset of devices which cease to be used for the Service.

Expiry, suspension or termination of a Subscription does not of itself cause the removal of information already held locally on an Authorised Device. We do not remotely erase a Clinic's devices by reason only of a Subscription having ended. Any deletion shall be effected in accordance with section 18, applicable law, and the instructions of the Clinic.

Certain functionality within the Service requires connectivity to our infrastructure and is not available while an Authorised Device is disconnected from it. Continued operational use of the Service accordingly requires periodic connectivity.

Where an Authorised Device remains without successful connectivity for a continuous period exceeding seventy-two (72) hours, the Service may enter a restricted state on that device, in which functions dependent upon our infrastructure become unavailable. Such functions may include the creation of new patient records, the creation of new consultations, the generation of prescriptions, and Synapse.

A restricted state of this kind is a limitation upon operational use. It does not constitute deletion of Clinic Data. Records already available locally remain accessible, may be viewed and searched, may be printed, and may be exported, in each case to the extent technically supported.

Upon successful reconnection, connectivity status is restored and normal functionality resumes, subject to the Clinic's Subscription status and to any other condition applicable at that time. Information created locally during a period without connectivity may be synchronised upon reconnection.

We engage third parties to provide infrastructure and services necessary to operate the Service. Such providers may include providers of cloud infrastructure, hosting, database and storage services, authentication services, communication and messaging services, and analytics and monitoring services.

Each such provider is engaged under contractual terms requiring it to process information only as necessary to provide its service to us, to apply appropriate security measures, and to assist us in meeting our obligations. We remain responsible to the Clinic for the performance of our obligations under this Policy.

Certain of these providers operate infrastructure which we do not own or control, and their services are subject to their own operational and security arrangements. Where a communication is transmitted to a patient over a third-party messaging platform, that transmission is subject to the terms and practices of the platform concerned, over which we have no control, and the Clinic determines whether to use that channel.

We may add to or change our providers as the Service develops. Where such a change is material we shall update this Policy, and where applicable law requires prior notice, such notice shall be given.

Clinic Data, including Patient Data, is stored on infrastructure located in India.

Certain third-party providers engaged in accordance with section 11 may process limited categories of information outside India in the course of providing support, monitoring, message transmission or comparable services. Such processing is confined to what is necessary for the relevant provider to perform its function, is subject to contractual safeguards, and does not involve the storage of Patient Data outside India.

We shall not commence the storage of Patient Data outside India without amending this Policy and, where applicable law so requires, obtaining consent.

Access to Clinic Data is restricted to the Authorised Users of the Clinic to which that data belongs, and is governed by role-based access controls enforced at the level of the underlying system rather than by presentation alone.

Different roles carry different permissions. By way of illustration, an Authorised User assigned an administrative or front-desk role may create and amend demographic and administrative information while not being permitted to amend protected clinical information, and access to a system function does not of itself confer clinical editing rights.

The Clinic determines which individuals hold Authorised User accounts and the role assigned to each. The Clinic shall maintain that allocation accurately and shall procure the disabling of an account upon the departure of the individual holding it.

Our personnel do not access identifiable Patient Data except to the extent strictly necessary to operate, secure, support, maintain or repair the Service, and then only for so long as the relevant task requires. Such access is limited to personnel requiring it and is subject to confidentiality obligations which survive the termination of their engagement.

Where multiple Authorised Devices operate concurrently, clinical information shall not be silently overwritten by reason only of concurrent or intermittently disconnected operation. Where a conflict cannot safely be reconciled, the Service preserves the affected information or requires resolution rather than discarding it.

We implement reasonable technical and organisational safeguards appropriate to the nature and sensitivity of the information processed, including encryption of information in transit, encryption at rest, role-based access control, authentication controls, restriction of internal access on a need-to-know basis, logging of administrative access, and monitoring for anomalous activity.

No electronic system, method of transmission or method of storage can be guaranteed to be absolutely secure, and we do not represent that ours is. We do not represent that our personnel are technically incapable of accessing information; access is restricted by controls, contractual obligation and audit rather than by impossibility.

The Clinic is responsible for the security of its credentials, devices and premises, for maintaining distinct credentials for each Authorised User, for refraining from sharing credentials, and for notifying us promptly upon suspecting that an account or device has been compromised.

Where we become aware of a personal data breach affecting information processed under this Policy, we shall notify the affected Clinic without undue delay, and shall make such notification to the Data Protection Board of India and to any other competent authority as applicable law requires and within the period it prescribes.

Our notification shall describe, to the extent then known, the nature of the breach, the categories and approximate volume of information affected, the likely consequences, and the measures taken or proposed to address it. We shall provide the Clinic with reasonable assistance in the discharge of its own notification obligations.

Notification under this section shall not constitute and shall not be construed as an admission of fault or liability.

We retain Clinic Data for so long as the Clinic maintains an active Subscription, the Service being incapable of operation otherwise.

Expiry of a Subscription is followed by the grace period provided for in the Terms of Service, and thereafter by a restricted state in which operational functionality is limited while Clinic Data remains accessible and exportable to the extent technically supported. Neither the grace period nor the restricted state constitutes deletion of Clinic Data.

Where an account remains inactive or unrenewed over an extended period, we may retain identifiable Clinic Data for a period of up to approximately eighteen (18) months from the commencement of that inactivity, subject always to applicable law and to any retention or deletion obligation imposed by it. Before taking further action at the expiry of that period we may contact the Clinic in respect of renewal, continued use, export of its data, or other disposition of the account.

Following the expiry of the applicable retention period, and where legally permissible and technically appropriate, we may de-identify or aggregate eligible information and retain the resulting De-identified Information or Aggregated Information for the purposes described in section 8.

The eighteen-month period stated above is our intended contractual retention policy. It is not asserted as a statutory entitlement, and it yields to any longer or shorter period which applicable law requires.

We maintain backups of information processed through the Service in order to support service continuity, disaster recovery, restoration and data integrity.

Backups are retained on a defined cycle and are protected by the access controls described in section 13. Where information has been deleted from the active Service, copies may persist within backup systems until the relevant backup lifecycle expires, after which they are overwritten in the ordinary course. We do not undertake to extract individual records from historic backups, and we do not represent that every copy of deleted information is destroyed immediately upon deletion.

Where a backup is restored, any deletion previously given effect to is reapplied.

Where an authorised representative of a Clinic requests the deletion of eligible Clinic Data or Patient Data, we shall give effect to that request within a reasonable period, subject to:

Where information has been deleted at the request of a Clinic, we shall not thereafter retain an identifiable copy of it for the purpose of model development or training.

We may retain a minimal audit record evidencing that a deletion was requested and effected, together with the date and the requesting party, without retaining the deleted clinical content itself. Records of consent, including the timestamp and the policy version accepted, are likewise retained following deletion, their purpose being to evidence what was agreed and when.

A Clinic may obtain an export of its Clinic Data in a standard machine-readable format. Standard export is provided without separate charge, subject to reasonable operational conditions as to frequency, volume and verification of the requesting party's authority.

Where a Clinic requires its data to be transformed into the specific schema of another provider, or requires field mapping, validation, custom engineering or migration assistance, such work constitutes a service additional to standard export and may be subject to a reasonable fee. No fee is charged for a Clinic to obtain its own data in standard form.

Subject to applicable law, an individual may request a summary of the personal data we process concerning them and the processing undertaken, request the correction or completion of inaccurate or incomplete data, request erasure, or withdraw a consent previously given. Where applicable law permits the nomination of another person to exercise such rights in the event of death or incapacity, such nomination may be made.

The withdrawal of consent operates prospectively. It does not affect the lawfulness of processing carried out before withdrawal, and it may prevent the continued provision of the Service or of particular functionality.

A request concerning Patient Data should ordinarily be directed to the Clinic which maintains the record, that Clinic being the party which determines the purposes and means of its processing. Where a patient approaches us directly, we shall refer them to the relevant Clinic and shall provide that Clinic with such assistance as applicable law or our contractual arrangements require. We do not make determinations concerning a patient's clinical record on a Clinic's behalf.

Requests should be addressed to anmol@arenode.com. We may require verification of identity and of authority before acting upon a request, and shall say so where we do.

A person dissatisfied with our handling of information or of a request made under section 20 may address a grievance to our Grievance Officer:

Anmol Pandey, Grievance Officer, Aren Node. anmol@arenode.com

Receipt of a grievance shall be acknowledged, and a substantive response shall be provided within 30 days. A person who remains dissatisfied may make a complaint to the Data Protection Board of India.

Accounts on the Service are intended for authorised adult users. We do not knowingly establish an Authorised User account for a child.

This is to be distinguished from the clinical records of child patients. Paediatrics is among the specialties the Service supports, and paediatric records are processed in the ordinary course as Patient Data. The Clinic shall be responsible for obtaining any consent required from a parent or lawful guardian in respect of such records.

The public website and the Service use cookies and equivalent browser storage which are strictly necessary to maintain an authenticated session, to retain user preferences, and to preserve the security and integrity of the Service. These cannot be disabled without preventing the Service from functioning.

We may use analytics and performance-measurement technologies, whether our own or those of a provider engaged under section 11, in order to understand how the website and the Service are used and to improve them. Such technologies are used for those purposes and are not used to deliver advertising.

We do not use cookies or similar technologies to serve advertising, and we do not permit third-party advertising networks to place tracking technologies through the website or the Service.

We may amend this Policy from time to time as the Service develops or as applicable law changes. Each version bears an effective date and a version identifier, and the version in force at the time of a Clinic's registration is recorded against that Clinic's account.

Where an amendment materially diminishes the rights of a Clinic or materially expands the purposes for which information is processed, we shall give notice through appropriate channels before it takes effect, and where applicable law requires a fresh consent, notice or other action, we shall comply with that requirement. Amendments which do not have such an effect take effect upon publication.

This Policy shall be governed by and construed in accordance with the laws of India. Disputes arising out of or in connection with it shall be subject to the exclusive jurisdiction of the courts at Lucknow, Uttar Pradesh.

Enquiries concerning this Policy, requests under section 20 and grievances under section 21 may be addressed to anmol@arenode.com.