Eden PMS

Privacy Policy

Last updated: 6 September 2026 · Applies to Eden PMS (iOS and Android)

1. Who we are

Eden Skin and Wellness Clinic ("we", "us", "the Clinic") operates Eden PMS, an internal application used solely by our authorised staff.

Address: SCO 34-35, D Block, Ranjit Avenue, Amritsar, Punjab 143001, India
Contact: privacy@edenskin.clinic | +91 77107 79393

Under the Digital Personal Data Protection Act, 2023 ("DPDP Act"), the Clinic is the Data Fiduciary in respect of all patient personal data described in this policy.

2. Who this policy is for

This policy covers two distinct groups:

Staff users — employed or contracted personnel of the Clinic who are issued credentials by the Clinic administrator and who use the app on the Clinic's behalf.

Patients — individuals whose records are entered into the app by staff. Patients do not use, install, or log in to this application. Patients are nevertheless Data Principals under the DPDP Act and hold the rights set out in Section 9 below.

There is no public registration. No member of the public can create an account.

3. What data we process

3.1 Patient data (entered by staff)

Name, age, sex, contact number, and address
Visit records: date of visit, attending clinician, consultation notes
Services and procedures availed
Payment records: amount, mode of payment, invoice reference
Clinical photographs captured through the app or uploaded from the device
Documents uploaded and attached to a visit, including lab reports, prescriptions, consent forms, and invoices

Clinical photographs and medical documents constitute health data. We treat this category with heightened safeguards as described in Section 7.

3.2 Staff account data

Staff name, role, and work email address
Authentication credentials (passwords are stored only as salted cryptographic hashes)
Audit logs recording which staff account accessed or modified which record, and when

3.3 Technical data

Device model and operating system version
App version
Error and crash diagnostics

We do not collect location data, contacts, advertising identifiers, or any data for behavioural profiling.

4. Why we process it

Purpose	Category
Maintaining accurate clinical records of patient visits	Patient data
Recording services rendered and payments received	Patient data
Attaching clinical images and documents to the correct patient file	Patient data
Continuity of care across visits and clinicians	Patient data
Statutory and regulatory record-keeping obligations applicable to a medical establishment in India	Patient data
Controlling and auditing staff access to patient records	Staff data
Diagnosing faults and maintaining app stability	Technical data

We do not use patient data for marketing. We do not use it to train machine learning models. We do not sell it under any circumstances.

5. Lawful basis

Patient data is processed on the basis of consent obtained at the point of care, and where applicable for the performance of legitimate uses permitted under the DPDP Act in connection with the provision of medical treatment and health services. Consent for clinical photography is obtained separately at the time the photograph is taken.

Staff data is processed on the basis of the employment or engagement relationship.

6. Device permissions

Permission	Why
Camera	To capture clinical photographs and attach them directly to a patient record, so images do not remain in a staff member's personal camera roll
Photos / Files	To attach an existing document or image, such as a scanned lab report or PDF prescription, to a patient record
Network access	To synchronise records with the Clinic's patient management system

Permissions are requested at the point of first use and can be revoked at any time in device settings. Revoking camera or file access disables the corresponding attachment feature but does not otherwise affect the app.

7. Storage and security

Data is stored on servers controlled by the Clinic and located in Mumbai, India.
All data in transit is encrypted using TLS 1.2 or higher.
Data at rest is encrypted on the server.
Access is role-based. Each staff member sees only what their role permits.
Credentials are issued and revoked by the Clinic administrator. Access is withdrawn on the same day a staff member's engagement ends.
All record access and modification is logged and attributable to an individual account.
The app does not store patient records in unencrypted form on the device beyond what is required for an active session.

No system is entirely immune from risk. In the event of a personal data breach, we will notify the affected Data Principals and the Data Protection Board of India within the timelines prescribed under the DPDP Rules, 2025.

8. Sharing and disclosure

We do not sell, rent, or trade personal data.

We disclose personal data only:

To service providers acting as Data Processors under contract, strictly for hosting, storage, and technical maintenance, and bound to equivalent confidentiality and security obligations. Our current hosting provider is Hostinger International Ltd.
To the patient concerned, on request
Where required by law, court order, or a lawful direction from a regulatory or statutory authority

All personal data is stored on infrastructure located in Mumbai, India. We do not transfer personal data outside India.

9. Patient rights

As a Data Principal under the DPDP Act, a patient may:

Obtain a summary of the personal data we hold about them and how it is processed
Request correction of inaccurate or incomplete data, or completion of data
Request erasure of personal data, subject to our obligation to retain medical records for the periods prescribed by law
Nominate another individual to exercise these rights in the event of death or incapacity
Raise a grievance and, if unresolved, escalate to the Data Protection Board of India

To exercise any of these rights, contact our Grievance Officer at the address in Section 12. We respond within 30 days.

Requests for erasure of clinical records may be declined or partially fulfilled where retention is required under applicable medical record-keeping obligations. Where we decline, we explain why.

10. Children's data

Where the patient is under 18 years of age, records are created only after obtaining verifiable consent from a parent or lawful guardian, in accordance with the DPDP Act. We do not undertake behavioural monitoring or targeted advertising directed at children.

11. Retention

Patient records, including clinical images and attached documents, are retained for 8 years from the date of the patient's last consultation, after which they are deleted or irreversibly anonymised. This period exceeds the minimum prescribed under applicable Indian medical record-keeping obligations and is applied uniformly across consultation notes, service records, clinical photographs, uploaded documents, and payment records.

Two circumstances extend this period:

Patients who were minors at the time of treatment. Records are retained until the patient attains 21 years of age, or for 8 years from the last consultation, whichever is later. This reflects that a claim may be brought by the patient after attaining majority.
Records subject to a complaint, legal notice, regulatory inquiry, or proceeding. Retention continues until final disposal of the matter and for 3 years thereafter.

Where a patient exercises the right to erasure under Section 9, we delete personal data that we are not obliged to retain. Financial and tax records associated with a visit may be retained for the full period even where the associated clinical record is erased, as these are held under separate statutory obligations.

Staff account data and audit logs are retained for 8 years following the end of the staff member's engagement.

12. Grievance Officer

Questions, requests, and complaints regarding personal data should be addressed to:

Tajjanpreet Kaur
Grievance Officer, Eden Skin and Wellness Clinic
privacy@edenskin.clinic
SCO 34-35, D Block, Ranjit Avenue, Amritsar, Punjab 143001, India
+91 77107 79393

If you are not satisfied with our response, you may lodge a complaint with the Data Protection Board of India.

13. Changes to this policy

We may update this policy. The "Last updated" date at the top reflects the most recent revision. Material changes will be communicated to staff users through the app and, where they affect patient rights, notified at the point of care.

14. Contact

Eden Skin and Wellness Clinic
SCO 34-35, D Block, Ranjit Avenue, Amritsar, Punjab 143001, India
privacy@edenskin.clinic | +91 77107 79393