Your privacy & trust matter to us.
ZINAL’S HOMOEOPATHY - Solo Homoeopathic Practice — India
Patient Privacy & Data Protection Policy
Effective Date: June 2025 | Version 2.0
This policy has been drafted to comply with the IT Act 2000, SPDI Rules 2011, Digital Personal Data Protection Act 2023, Indian Medical Council Act 1956, Consumer Protection Act 2019, Telemedicine Practice Guidelines 2020, and ASCI Healthcare Advertising Guidelines.
1. Introduction & Scope Zinal’s Homoeopathy (“we”, “us”, or “our”) is a solo homoeopathic medical practice operated by Dr. Jinal, a qualified Homoeopathic practitioner registered under the applicable State Homoeopathic Medical Council. We are committed to safeguarding the privacy, confidentiality, and security of all personal and sensitive health information entrusted to us by our patients.
This Privacy Policy governs all interactions with our practice including in-clinic consultations, website visits, testimonials and case studies published on our website, teleconsultations, WhatsApp communications, and engagement with our Instagram account. It applies to all patients, website visitors, and followers of our social media channels.
Applicable laws and regulations include: • The Information Technology Act, 2000 and IT (SPDI) Rules, 2011
• The Digital Personal Data Protection Act, 2023 (“DPDP Act”)
• The Indian Medical Council Act, 1956 and applicable State Homoeopathic Medical Council Acts
• The Consumer Protection Act, 2019
• The Telemedicine Practice Guidelines, 2020
• ASCI (Advertising Standards Council of India) Guidelines for Healthcare Advertising
2. Identity of the Data Fiduciary The Data Fiduciary under the DPDP Act, 2023 and controller of your personal data is:
Practice Name: Zinal’s Homoeopathy
Practitioner: Dr. Jinalben Chavda
Registration No.: G-23980
Clinic Address: 308, Shreemad Business Point, Near Star Paradise, 200 ft Naroda Dehegam Road, Ahmedabad - 382330, Gujarat
Email: zinalshomoeopathy@gmail.com
Phone: +91-6354262639
Website: www.zinalshomoeopathy.com
Instagram: @zinals_homoeopathy
For privacy grievances, queries, or data requests, contact us directly at the details above. As a solo practitioner, Dr. Jinal serves as the Grievance Officer for this practice.
3. Personal & Sensitive Personal Data We Collect
3.1 Personal Identification Data
• Full name, age, date of birth, and gender
• Residential address, city, and PIN code
• Contact information: mobile number and email address
• Emergency contact details
3.2 Sensitive Personal Data or Information (SPDI)
• Medical history: past illnesses, surgical history, and family medical history
• Current and past medications, treatments, and prescriptions
• Homoeopathic case-taking records including physical, mental, and emotional symptoms
• Diagnosis notes, clinical observations, and follow-up records
• Clinical photographs of skin conditions, lesions, or other visible features — only when clinically necessary and with explicit written consent specifying the permitted use
• Diagnostic reports, investigation results, and pathology records shared by the patient
• Lifestyle information such as diet, sleep, stress, and occupation relevant to homoeopathic case analysis
3.3 Data We Do NOT Collect
• Payment card details — payments are processed through third-party POS or UPI systems only
• Government identity documents (Aadhaar, PAN) unless specifically required by law
• Biometric data of any kind
4. Purpose of Collection and Use of Data Your personal and health data is used solely for the following lawful purposes:
• Providing homoeopathic consultations, diagnosis, and treatment
• Maintaining accurate medical case records as required under applicable professional guidelines
• Issuing prescriptions, certificates, and referral letters
• Communicating regarding appointments, follow-ups, and test results
• Publishing patient testimonials or case studies on our website or Instagram, only with separate explicit written consent as described in Section 7A
• Sharing general health awareness content on Instagram (no patient-identifiable data)
• Compliance with legal obligations, court orders, or regulatory requirements
We will not use your data for marketing, advertising, or any commercial purpose without your express written consent. We will never sell, rent, or trade your personal data to any third party.
5. Legal Basis for Processing
• Consent: Explicit consent obtained at registration and, separately, for specific uses such as photography and publication.
• Contractual Necessity: Processing is necessary to provide the medical services you have sought.
• Legal Obligation: We may be required to retain or disclose records under applicable Indian law or by order of a competent authority.
• Legitimate Interest: Maintaining accurate health records to ensure continuity of care.
6. Disclosure and Sharing of Your Data
6.1 Permitted Disclosures
• With your explicit written consent — e.g., referral to a specialist or hospital
• To diagnostic laboratories or imaging centres to whom referrals are made, limited to what is necessary
• To other treating doctors involved in your care, with your consent
• As required by law, court order, or government or regulatory authority
• In public health emergencies as required under the Epidemic Diseases Act or similar legislation
6.2 Strictly Prohibited Disclosures
• Your data will never be shared with insurance companies without your specific written consent
• Your data will never be disclosed to your employer or family members without your consent, except in medical emergencies involving risk to life
• Your data will never be sold, rented, or shared with marketing firms, data brokers, or advertisers
7. Website Usage & Data
7.1 Nature of the Website Our website is informational only. It does not host a patient portal, online consultation form, or e-commerce functionality. Patients are requested not to share sensitive health information through any contact form or email link on the website.
7.2 Automatically Collected Data
• IP address, browser type, operating system, and referring URLs
• Pages visited, time spent, and navigation behaviour
• This data is collected through cookies and analytics tools such as Google Analytics
7.3 Third-Party Tools & Data Processors Our website uses third-party tools including Google Analytics and our hosting service provider. These parties may receive limited non-identifiable data such as IP addresses and browsing behaviour. They operate under their own privacy policies. We ensure that no sensitive personal health data is transmitted to any third-party tool. Patients are encouraged to review Google’s Privacy Policy and our hosting provider’s terms independently.
7.4 Cookies Our website may use cookies to track usage patterns and improve content. You may configure your browser to refuse cookies; however, some parts of the website may not function correctly. We do not use cookies to collect personal health information.
7.5 Third-Party Links Our website may contain links to external websites. We are not responsible for the privacy practices of those sites and encourage you to review their respective policies.
7A. Patient Testimonials & Case Studies
7A.1 Consent Requirements for Publication Zinal’s Homoeopathy may publish patient testimonials and case studies on its website and/or Instagram account solely for genuine health information and patient experience purposes. The following conditions apply without exception:
• A separate, specific written consent form is obtained before any testimonial or case study is published. This consent is entirely independent of the general treatment consent signed at registration.
• The patient is shown the exact content — text, images, or both — before publication and given full opportunity to review, edit, or reject it.
• The consent form explicitly states the platform(s) on which the content will appear (website, Instagram, or both). Consent for one platform does not imply consent for another.
• The patient retains the right to withdraw consent and request removal at any time. Upon receiving such a request, the content will be removed within
7 working days.
• No testimonial or case study will include a full name, address, contact details, or any other directly identifying information unless the patient explicitly consents to such inclusion in writing.
7A.2 ASCI Compliance All testimonials and case studies published by Zinal’s Homoeopathy comply with the Advertising Standards Council of India (ASCI) Guidelines for Healthcare Advertising. Specifically:
• No testimonial will make unsubstantiated claims about cure rates, guaranteed outcomes, or comparative superiority over other treatments
• Before-and-after photographs will not be used in a manner that creates false or misleading impressions about treatment outcomes
• All published content will include a disclosure that individual results may vary
7A.3 Anonymised Case Studies Where case studies are published in anonymised format, we ensure that the combination of information published cannot reasonably identify the individual. Even for anonymised content, patient awareness and written approval is obtained before publication.
7B. Social Media & Instagram
7B.1 Nature of Social Media Content Dr. Jinal maintains an Instagram account for general health awareness, homoeopathic education, and wellness content. The following must be clearly understood by all followers and patients:
• All content on Instagram is for general informational and educational purposes only and does not constitute medical advice, diagnosis, or treatment.
• Following or engaging with the Instagram account does not create a doctor-patient relationship.
• Followers should not act on any content published on social media without first consulting a qualified medical professional in person.
7B.2 Prohibition on Individualised Advice via Social Media To protect both patients and the practice, Dr. Jinal will not provide specific medical advice, diagnosis, or treatment recommendations through Instagram comments, direct messages, or any other social media interaction. Any follower seeking medical guidance will be directed to book a formal in-clinic or teleconsultation. This policy is strictly observed without exception.
7B.3 Patient Data on Social Media
• No identifiable patient information — including name, photograph, diagnosis, prescription, or case details — will be published on any social media platform without explicit separate written consent as described in Section 7A.
• If a patient’s case is referenced in an educational post, it will be fully anonymised and the patient will be informed prior to publication.
• Any patient who identifies themselves in anonymised content and requests its removal will have the content removed within 7 working days.
7B.4 Standard Social Media Disclaimer All posts on our Instagram account are subject to the following disclaimer, which is displayed prominently in the account bio and referenced in educational posts:
“Content shared on this account is for general health awareness only and does not constitute medical advice. Please consult your doctor before making any health decisions. Engaging with this account does not establish a doctor-patient relationship. Individual results may vary.”
7B.5 Third-Party Review Platforms Patients may leave reviews on third-party platforms such as Google, Practo, or Justdial. When responding to reviews — including negative reviews — no clinical information, diagnosis, treatment details, or any patient-identifiable data will ever be disclosed by the practice, even in self-defence. All responses will be generic and professional in nature. Breach of this protocol constitutes a direct violation of medical confidentiality.
8. Telemedicine & Digital Consultations
8.1 Compliance with Telemedicine Guidelines Where Dr. Jinal conducts consultations via video call, phone, or other digital means, such consultations are conducted in compliance with the Telemedicine Practice Guidelines, 2020 issued by the Board of Governors in supersession of the Medical Council of India, as applicable to Homoeopathic practitioners under the respective State Council guidelines.
8.2 Patient Identification For every teleconsultation, the patient’s identity is verified through their registered name and mobile number before the consultation commences. First-time teleconsultation patients are required to provide their location and a self-declaration of their identity.
8.3 Record-Keeping for Teleconsultations A record of every teleconsultation is maintained including the date, mode of consultation, patient identity, symptoms discussed, and any advice or prescription issued. These records are retained in the same manner as in-clinic records and subject to the same retention periods described in Section 10.
8.4 Prescription Restrictions Prescriptions issued via teleconsultation comply with the restrictions prescribed under applicable telemedicine guidelines. No prescription for prohibited or Schedule X drugs will be issued via teleconsultation. WhatsApp messages, voice notes, or informal digital communications do not constitute a formal consultation or prescription unless documented in the patient’s case record.
8.5 WhatsApp Communications WhatsApp is used for appointment scheduling, follow-up reminders, and general correspondence only. Where a patient initiates sharing of clinical photographs, prescriptions, or sensitive health information via WhatsApp:
• The patient is informed that WhatsApp, while end-to-end encrypted in transit, may not be fully secure at the device or backup level (e.g., cloud backups on Google Drive or iCloud).
• Patients are advised not to store sensitive clinical images in unprotected cloud backups.
• For highly sensitive clinical documentation, patients are encouraged to share records in person.
• Any clinical information shared via WhatsApp that forms part of the patient’s treatment is documented in the formal case record.
• Patients who choose to communicate via WhatsApp do so with awareness of these limitations, and their choice constitutes informed acceptance of the associated risks.
9. Patient Consent Framework
9.1 General Treatment Consent A signed patient registration and consent form is obtained at the time of the first consultation. This form covers the collection and use of personal and health data for treatment purposes as described in Section 4. For minor patients (below 18 years), consent is obtained from a parent or legal guardian.
9.2 Photographic Consent — Three-Track System A separate, explicit written consent is obtained before any clinical photographs are taken. This consent specifies one or more of the following permitted uses, and the patient independently consents to each:
• Track A — Internal Records Only: Photographs used solely for clinical record-keeping and treatment monitoring. Never published or shared externally.
• Track B — Website Publication: Photographs used as part of a case study or testimonial on the practice website.
• Track C — Social Media Publication: Photographs used in educational content on Instagram or other social media platforms.
Consent for Track A does not imply consent for Track B or Track C. Each track requires independent, affirmative written consent. Consent for any track may be withdrawn at any time.
9.3 Testimonial & Case Study Consent As described in Section 7A, a separate written consent is obtained before any patient testimonial or case study is published. The patient reviews and approves the final content before publication and retains the right to request its removal at any time.
9.4 Withdrawal of Consent You may withdraw any consent given under this Policy at any time. Withdrawal of general treatment consent may affect our ability to continue providing care. Withdrawal of publication consent will result in removal of the relevant content within 7 working days. Withdrawal does not affect the lawfulness of processing carried out prior to withdrawal.
10. Data Retention
• Patient medical records: Minimum 3 years from the date of last consultation, or as required by applicable State regulations
• Minor patients: Records retained until the patient attains 18 years of age plus 3 years
• Teleconsultation records: Retained for the same period as in-clinic records
• Consent forms (general, photographic, and publication): Retained for the duration of the clinical relationship plus 5 years
• Records subject to ongoing legal proceedings: Retained until final resolution
• Published testimonials or case studies: Subject to the patient’s right to request removal at any time regardless of the retention period
• Website analytics data: As per the settings of the analytics provider (typically 26 months for Google Analytics)
10.1 Minor Patients Turning 18 When a patient who was treated as a minor attains 18 years of age, they acquire full rights over their personal data. If any content featuring them (testimonials, case studies, photographs) was published with parental consent, they have the right to review that content and request its removal or modification. We will proactively inform such patients of this right where practicable.
Upon expiry of the retention period, records are securely destroyed or anonymised to prevent unauthorised access or reconstruction.
11. Data Security We implement reasonable security practices and procedures as mandated under Rule 8 of the SPDI Rules, 2011:
• Physical records stored in locked cabinets with restricted access limited to Dr. Jinal and authorised support staff
• Electronic records protected with password access and device-level encryption where applicable
• Clinical photographs stored in a dedicated, access-controlled location and not in general phone camera rolls or publicly accessible cloud folders
• Access to patient data strictly limited to persons bound by professional confidentiality obligations
• No patient data shared via personal social media accounts, personal email, or any unencrypted public channel
• Periodic review of security practices to ensure continued adequacy
While we take all reasonable precautions, no method of data storage or transmission is completely secure. In the event of a data breach that is likely to result in harm to patients, we will notify affected patients and the appropriate authority in accordance with the DPDP Act, 2023.
12. Your Rights as a Data Principal
12.1 Right to Access You may request a copy of the personal data we hold about you. We will respond within a reasonable time and in a practicable format.
12.2 Right to Correction You may request correction of inaccurate or incomplete data. Medical records may be amended with an appropriate notation while preserving the original entry for clinical integrity.
12.3 Right to Erasure You may request deletion of your personal data, subject to our legal obligations to retain medical records and any overriding public interest or legal requirement.
12.4 Right to Withdraw Consent You may withdraw any consent at any time as described in Section 9.4.
12.5 Right to Grievance Redressal You may raise a grievance with us regarding processing of your personal data. See Section 14 for contact details.
12.6 Right of Nomination Under the DPDP Act, 2023, you may nominate another individual to exercise your data rights in the event of your death or incapacity.
12.7 Rights of Minor Patients Upon Attaining Majority As described in Section 10.1, patients who were treated as minors have independent rights over their data and any published content upon turning 18, regardless of consents previously given by their guardians.
13. Limitation of Liability Zinal’s Homoeopathy and Dr. Jinal shall not be held liable for:
• Any harm arising from a patient acting on general health information published on social media or the website without seeking a formal consultation
• Unauthorised access to data resulting from circumstances beyond our reasonable control, including but not limited to cyberattacks, device theft, or force majeure events, provided that we have implemented the reasonable security measures described in Section 11
• The privacy practices of third-party platforms including Instagram, Google Analytics, or payment processors, which operate under their own terms
Nothing in this section limits our liability for gross negligence, wilful misconduct, or any liability that cannot be excluded under applicable Indian law, including liability under the Consumer Protection Act, 2019.
14. Grievance Redressal For privacy-related complaints, queries, or data requests:
Grievance Officer: Dr. Jinal, Zinal’s Homoeopathy Address: 308, Shreemad Business Point, Near Star Paradise, 200 ft Naroda Dehegam Road, Ahmedabad - 382330, Gujarat
Email: zinalshomoeopathy@gmail.com
Phone: +91-6354262639
Response Time: Acknowledgement within 72 hours; resolution within 30 days
If you are not satisfied with our response, you may escalate your complaint to:
• The Data Protection Board of India, once constituted under the DPDP Act, 2023
• The relevant State Homoeopathic Medical Council for professional conduct matters
• The appropriate Consumer Disputes Redressal Forum under the Consumer Protection Act, 2019
• A court of competent jurisdiction in Ahmedabad, Gujarat
15. Special Provisions – Minor Patients For patients below 18 years, all personal and health data is collected with the consent of a parent or legal guardian. We take additional care to protect health information of minors. No photograph, testimonial, or case study involving a minor patient will be published on any platform. Upon the minor patient attaining 18 years of age, they are entitled to exercise all rights described in Section 12 independently.
16. Amendments to This Policy We reserve the right to update this Policy at any time to reflect changes in applicable law, our practice, or data handling processes. The most current version will be displayed at our clinic and on our website. Continued engagement with our practice after any changes constitutes acceptance of the revised Policy.
17. Governing Law & Jurisdiction This Policy is governed by the laws of India. Any disputes arising under this Policy shall be subject to the exclusive jurisdiction of the courts in Ahmedabad, Gujarat.
© 2025 Zinal’s Homoeopathy. All rights reserved. | Version 2.0