1.1. Antara Integrated Wellness Clinic ("AIWC", "we", "us" or "our") is a brand and service vertical of Antara Assisted Care Services Limited, a company incorporated under the Companies Act, 1956 (and continued under the Companies Act, 2013), having its registered office at Max House, 1 Dr. Jha Marg, Okhla, New Delhi – 110020, and a corporate/clinical office at Plot No. 65, Plus Office, Landmark House, 2nd Floor, Sector 44, Gurugram, Haryana – 122003 ("Antara", "Company").

1.2. This Privacy Policy ("Policy") describes how Antara collects, uses, discloses, stores, transfers, retains and protects personal data of individuals who visit or use the AIWC website, mobile site, mobile application, WhatsApp channel or any other digital interface (collectively, the "Platform"), or who book, enquire about, or avail any consultation, therapy, diagnostic, wellness programme or other service offered by AIWC, whether through the Platform, over the telephone, or in person at an AIWC facility (collectively, the "Services").

1.3. This Policy is issued in accordance with the Digital Personal Data Protection Act, 2023 ("DPDP Act"), the rules notified thereunder from time to time ("DPDP Rules"), the Information Technology Act, 2000, the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 to the extent still applicable, and other applicable law governing the processing of personal data in India. In the event of any conflict between this Policy and the Terms & Conditions of the Platform on a matter of data protection, this Policy shall prevail, save that all disclaimers, limitations of liability and indemnities contained in the Terms & Conditions shall continue to apply in Antara's favour to the fullest extent permitted by law.

1.4. By accessing the Platform, registering an account, booking an appointment, submitting any form, or otherwise providing personal data to AIWC, you ("you", "User", "Data Principal") acknowledge that you have read and understood this Policy. Where processing is based on your consent, this Policy, together with the specific consent notice presented to you at the point of collection, forms the basis of that consent. If you do not agree with this Policy, you must not use the Platform or avail the Services, save that you may still contact us using the details in Clause 15 to raise a query before doing so.

2.1. "Personal Data" means any data about an individual who is identifiable by or in relation to such data.

2.2. "Data Principal" means the individual to whom the personal data relates, and where such individual is a child, includes the parent or lawful guardian of such child, and where such individual is a person with disability, includes their lawful guardian, acting on their behalf.

2.3. "Data Fiduciary" means the person who alone or in conjunction with other persons determines the purpose and means of processing of personal data, being Antara in respect of personal data processed in connection with the Platform and the Services.

2.4. "Data Processor" means any person who processes personal data on behalf of a Data Fiduciary, such as a technology vendor, cloud host, payment gateway or courier partner engaged by Antara.

2.5. "Processing" means an operation performed on personal data, including collection, recording, organisation, storage, adaptation, retrieval, use, alignment, disclosure, dissemination, restriction, erasure or destruction.

2.6. "Consent Manager" means an entity registered with the Data Protection Board of India that enables a Data Principal to give, manage, review and withdraw consent through an accessible, transparent and interoperable platform, where Antara elects to make use of such a mechanism.

2.7. "Sensitive Health Information" means personal data relating to the physical, mental or behavioural health of a Data Principal, including medical history, diagnosis, treatment, medication, allergies, disability and genetic information, and is treated by Antara with the highest standard of care described in this Policy.

3.1. This Policy applies to personal data collected by AIWC through: (a) the Platform, including registration forms, booking flows, chat and WhatsApp interactions, and cookies; (b) in-clinic interactions, including consultation, therapy, diagnostic and residential programme records; (c) customer support and grievance communications, whether by phone, email or in person; and (d) any other lawful source, including publicly available data and data received from a healthcare partner, referring physician, diagnostic laboratory or corporate wellness client with your consent or as otherwise permitted by law.

3.2. This Policy does not apply to anonymised or aggregated data from which you cannot reasonably be identified, or to personal data that any third party collects independently through its own website, application or service, even where accessed via a link on the Platform. Please refer to Clause 12 (Third-Party Links and Services) in this regard.

4.1. For the purposes of the DPDP Act, the Data Fiduciary in respect of personal data described in this Policy is Antara Assisted Care Services Limited, acting through its AIWC vertical, at the registered and corporate office addresses set out in Clause 1. Questions concerning this Policy or the processing of your personal data may be directed to the Grievance Officer/Data Protection contact named in Clause 15.

The categories of personal data collected depend on your interaction with the Platform and the

Services availed. These may include:

5.1. Identity and Contact Data

5.1.1. Full name, gender, date of birth or age, photograph (where voluntarily shared, such as for identity verification).

5.1.2. Residential or communication address, phone number, email address.

5.1.3. Government-issued identification details, where required for verification, admission to a residential programme, or as mandated by law.

5.2. Account and Authentication Data

5.2.1. User ID, password (stored in encrypted/hashed form), OTP records, login history and device identifiers.

5.2.2. Information received when you log in using a third-party account, such as Google or Facebook, limited to the profile fields you authorise that platform to share.

5.3. Sensitive Health Information

5.3.1. Medical history, presenting complaints, existing conditions, current medications, allergies, pregnancy status, prior surgeries, implanted devices, infectious disease status, and cardiac, neurological or psychiatric conditions.

5.3.2. Clinical notes, consultation records, therapy and treatment records, diagnostic and investigation reports, prescriptions, and follow-up communication.

5.3.3. Information generated during residential wellness programmes, including dietary, sleep, vital-sign and activity records maintained for clinical purposes.

5.4. Financial Data

5.4.1. Payment instrument details (collected and processed directly by regulated third-party payment gateways and not stored by Antara in unencrypted or complete form, save to the limited extent necessary for refund processing).

5.4.2. Billing address, transaction history, invoices and refund records.

5.5. Usage and Technical Data

5.5.1. Booking history, service preferences, feedback and survey responses.

5.5.2. Device, browser, IP address, approximate location, and log data generated through your use of the Platform, and cookie identifiers described in Clause 13.

5.5.3. You are not obliged to provide any personal data, but where certain data, including Sensitive Health Information, is necessary to safely deliver a Service, AIWC may be unable to provide that Service, in whole or in part, if such data is not furnished, and Antara shall bear no liability for any consequence arising from your decision not to furnish such data.

6.1. Directly from you, when you register on the Platform, book an appointment, complete a health intake or consent form, make a payment, contact customer support, or otherwise communicate with AIWC.

6.2. Automatically, through cookies, SDKs and similar technologies when you use the Platform, as described in Clause 13.

6.3. From a referring physician, diagnostic laboratory, corporate wellness client, insurer/TPA, or other healthcare partner, where you have consented to such sharing or where such sharing is otherwise permitted by applicable law.

6.4. From your parent or lawful guardian, where the Service is availed on your behalf as a minor or as a person with disability requiring a lawful guardian.

7.1. Antara processes personal data only for specified and lawful purposes for which you have given consent, or as otherwise permitted under Section 7 of the DPDP Act, including the following purposes:

7.1.1. Registering and authenticating your account and verifying your identity and eligibility.

7.1.2. Scheduling, delivering, supervising and following up on consultations, therapies, diagnostics and wellness programmes, including clinical assessment and treatment planning.

7.1.3. Processing payments, issuing invoices, and processing refunds in accordance with the Terms & Conditions.

7.1.4. Communicating with you regarding bookings, appointment reminders, service updates, and, where you have consented, promotional or informational communications.

7.1.5. Complying with applicable law, including healthcare, pharmacy, drugs, consumer protection, tax and medical record-keeping obligations, and responding to lawful requests from regulators, courts or law enforcement.

7.1.6. Maintaining the safety, security and integrity of the Platform and AIWC facilities, including fraud prevention, incident investigation, and enforcement of the Terms & Conditions.

7.1.7. Internal quality assurance, service improvement, research on an aggregated/anonymised basis, staff training, and audits.

7.1.8. Establishing, exercising or defending legal claims, including in connection with a medical emergency or a dispute concerning the Services.

7.2. Antara does not use Sensitive Health Information for any purpose unrelated to the delivery of the Services, applicable legal compliance, or the specific purpose for which it was collected, without obtaining your separate, specific consent, save where processing without consent is expressly permitted under the DPDP Act, such as in a medical emergency threatening life or health.

8.1. Antara relies on one or more of the following legal bases to process your personal data: (a) your free, specific, informed, unconditional and unambiguous consent given through a clear affirmative action; (b) processing that is necessary for the performance of a contract to which you are a party, such as delivering a Service you have booked; (c) compliance with a legal obligation to which Antara is subject; (d) processing necessary to respond to a medical emergency involving a threat to life or immediate injury to you or any other individual; and (e) other specified legitimate uses recognised under Section 7 of the DPDP Act, applied narrowly and only to the extent necessary.

9.1. Where Antara relies on consent, it will present an itemised notice describing the personal data to be collected and the purpose of processing, in a clear and plain manner, and will seek your consent through an affirmative action such as ticking a box, clicking to proceed, or signing a physical or electronic consent form. Consent obtained in this manner is treated by Antara as the operative basis of processing for the purpose stated, and Antara does not process your personal data for a materially different purpose without seeking fresh consent, save where an exception under the DPDP Act applies.

9.2. You may withdraw your consent at any time with prospective effect, by writing to the contact in Clause 15 or using any withdrawal mechanism made available on the Platform. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal. You acknowledge and agree that withdrawing consent in respect of Sensitive Health Information necessary for a Service already booked or in progress may result in AIWC being unable to safely continue or complete that Service, and Antara shall bear no liability for any consequence of ceasing a Service on this account, including any inability to obtain a refund under the Terms & Conditions.

9.3. Where Antara makes available the option to manage consent through a registered Consent Manager, you may use such mechanism to give, review, manage and withdraw your consent across purposes in an interoperable manner.

10.1. Antara does not sell personal data. Antara may share personal data, including on a need-to- know basis, with the following categories of recipients, solely for the purposes described in Clause 7 and subject to contractual and technical safeguards intended to protect such data:

10.1.1. Treating physicians, therapists, practitioners and other clinical or wellness staff engaged by or affiliated with AIWC, to the extent necessary to deliver the Service booked.

10.1.2. Diagnostic laboratories, pharmacies, equipment or device manufacturers, and other healthcare partners involved in delivering a specific Service.

10.1.3. Payment gateways, banks and financial institutions, solely to process payments and refunds.

10.1.4. Information technology, cloud hosting, data analytics, customer support, and communication service providers (Data Processors) engaged by Antara to operate the Platform, acting on Antara's instructions and under contractual confidentiality and security obligations.

10.1.5. Group companies and affiliates of Antara, for internal administration, consolidated record-keeping, and coordinated delivery of Antara's broader assisted-care and wellness services, where relevant to you.

10.1.6. Regulators, courts, law enforcement agencies, the Data Protection Board of India, or other governmental authorities, where required or permitted under applicable law, including in response to a valid legal process, or to protect the rights, property or safety of Antara, its Users, staff or the public.

10.1.7. A successor entity or acquirer, in connection with a merger, acquisition, restructuring, or sale of all or substantially all of Antara's business or assets, subject to that entity assuming obligations no less protective than this Policy.

10.2. Any disclosure of Sensitive Health Information to a party outside AIWC's direct care team is made strictly on a need-to-know basis and, save where the disclosure is necessary for emergency medical care or required by law, only with your consent.

11.1. Personal data may be stored, hosted or processed on servers located outside India, including by cloud service providers or Data Processors engaged for hosting, analytics, or customer support, except where the Central Government restricts transfer of personal data to any specific country or territory by notification under the DPDP Act. Any such cross-border processing shall be subject to contractual, technical and organisational safeguards intended to ensure a standard of protection consistent with the DPDP Act and this Policy.

12.1. The Platform may contain links to third-party websites, applications or services, including payment gateways, social media login providers, and healthcare partners, that are not owned or controlled by Antara. This Policy does not apply to such third parties, and Antara is not responsible for their privacy practices. You are encouraged to review the privacy policy of any third-party service before providing personal data to it. Antara shall not be liable for any loss or damage arising from your interaction with any third-party website or service.

13.1. The Platform uses cookies, web beacons, SDKs and similar technologies (collectively, "Cookies") to operate the Platform, remember your preferences, authenticate sessions, measure Platform performance, and, where you consent, to personalise content and measure the effectiveness of marketing, including through third-party analytics and advertising providers such as Google.

13.1.1. Strictly necessary Cookies, required for core functionality such as login and security, which cannot be disabled without affecting the Platform's operation.

13.1.2. Performance and analytics Cookies, used to understand how the Platform is used and to improve it.

13.1.3. Functional Cookies, used to remember your preferences and settings.

13.1.4. Advertising Cookies, including third-party cookies, used to deliver more relevant advertising and measure campaign performance, which you may opt out of through your browser settings or the relevant third party's opt-out mechanism, such as the Network Advertising Initiative.

13.2. You may control or disable Cookies through your browser or device settings; however, disabling certain Cookies may affect the availability or functionality of parts of the Platform, and Antara shall not be liable for any resulting degradation in your experience.

14.1. Antara retains personal data, including Sensitive Health Information, only for as long as is necessary for the purpose for which it was collected, or as required under applicable law, including medical record-keeping regulations, tax and accounting law, and limitation periods for legal claims, whichever is longer. Where retention is no longer necessary and no legal obligation requires continued storage, Antara will erase or anonymise the personal data concerned, including upon a valid erasure request under Clause 16, subject to the exceptions described therein.

15.1. Antara implements reasonable technical and organisational security safeguards designed to protect personal data against unauthorised access, use, alteration, disclosure or destruction, including access controls and role-based permissions, encryption of data in transit and, where appropriate, at rest, secure storage of health and payment records, staff confidentiality undertakings, and periodic review of security practices.

15.2. In the event of a personal data breach, Antara shall intimate the Data Protection Board of India and the affected Data Principals in the form and manner, and within the timelines, prescribed under the DPDP Act and DPDP Rules. Notwithstanding the foregoing, no method of transmission or storage is entirely secure, and Antara does not warrant or guarantee absolute security of any personal data, and shall not be liable for unauthorised access, disclosure or loss arising from causes beyond its reasonable control, including cyber-attacks, acts of third parties, or a User's failure to safeguard their own credentials.

16.1. Subject to the DPDP Act, the DPDP Rules, and reasonable verification of your identity, you may exercise the following rights by writing to the contact in Clause 18:

16.1.1. Right to Access: to obtain a summary of the personal data being processed by Antara and the processing activities undertaken in relation to such data, and identities of Data Processors with whom your personal data has been shared, along with the categories of personal data shared.

16.1.2. Right to Correction and Updating: to request correction of inaccurate or misleading personal data, and completion of incomplete personal data.

16.1.3. Right to Erasure: to request erasure of personal data that is no longer necessary for the purpose for which it was processed, unless retention is required by law.

16.1.4. Right to Grievance Redressal: to have your grievance concerning processing of your personal data addressed by Antara in a reasonable time, and, if unsatisfied, to escalate the matter to the Data Protection Board of India.

16.1.5. Right to Nominate: to nominate another individual to exercise these rights on your behalf in the event of your death or incapacity, by notifying Antara in the manner prescribed.

16.2. Antara will endeavour to respond to a verified request within the timelines prescribed under applicable law. Antara may decline a request, in whole or part, where permitted under the DPDP Act, including where retention or continued processing is necessary for compliance with law, for the establishment or defence of a legal claim, or for other legitimate uses recognised under the DPDP Act, and will communicate the reason for such refusal where required to do so.

16.3. The details of Data Protection Officer are as below:

Name: Krishna Kant Srivastava

Contact number: +91-7895199464

Email ID: krishan.kant@antaraseniorcare.com

17.1. Where a Service is availed on behalf of a child (an individual below 18 years of age) or a person with disability who has a lawful guardian, Antara processes the relevant personal data only with the verifiable consent of the parent or lawful guardian, obtained in a manner consistent with the DPDP Act. Antara does not undertake tracking, behavioural monitoring, or targeted advertising directed at children, and does not process children's personal data in a manner likely to cause any detrimental effect on their wellbeing, save to the extent processing is necessary for healthcare purposes recognised under the DPDP Act, such as tracking a child's health or education.

18.1. In accordance with the Information Technology Act, 2000, the rules made thereunder, and the DPDP Act, Antara has designated a Grievance Officer / Data Protection contact to address queries, complaints and requests concerning this Policy and the processing of personal data. The name, designation, address and contact particulars of the Grievance Officer shall be published and kept updated on the Platform. Where you remain dissatisfied with the resolution provided, you may approach the Data Protection Board of India in accordance with the DPDP Act, without prejudice to any other remedy available to you under law.

18.2. For all other queries relating to this Policy, you may write to Antara at the registered office address set out in Clause 1, or through the contact channels published on the Platform.

18.3. The Grievance Officer's details are as follows:
Name: Prateek Sood
Designation: Grievance Officer
Contact Number: +91-8800001320
Email: Grievance@antaraseniorcare.com

19.1. Antara reserves the right to amend, revise or update this Policy at any time, at its sole discretion, to reflect changes in law, our data practices, or the Services offered. The revised Policy shall take effect upon publication on the Platform, and, where required by law, Antara will provide additional notice of material changes and, where necessary, seek fresh consent. Your continued use of the Platform or the Services after such publication constitutes your acknowledgment of the revised Policy. You are encouraged to review this Policy periodically.

20.1. This Policy shall be governed by and construed in accordance with the laws of India, including the DPDP Act. Any dispute arising out of or in connection with this Policy shall be subject to the governing law and jurisdiction provisions set out in the Terms & Conditions of the Platform.

21.1. THIS POLICY IS A SUMMARY OF ANTARA'S DATA PRACTICES AND DOES NOT CREATE ANY RIGHT, WARRANTY OR OBLIGATION BEYOND WHAT IS MANDATORILY REQUIRED UNDER APPLICABLE LAW. ALL DISCLAIMERS, LIMITATIONS OF LIABILITY AND INDEMNITIES SET OUT IN THE TERMS & CONDITIONS OF THE PLATFORM APPLY EQUALLY TO ANY CLAIM ARISING OUT OF OR IN CONNECTION WITH THIS POLICY OR THE PROCESSING OF PERSONAL DATA DESCRIBED HEREIN, TO THE FULLEST EXTENT PERMITTED BY LAW.