Privacy Policy

Oraly Healthcare Solutions  |  Effective Date: 1 January 2025  |  Last Updated: 2 June 2025

1. Who We Are

Oraly Healthcare Solutions is a dental technology company based in Gwalior, Madhya Pradesh, India. We operate the Oraly Patient consultation service and the Oraly Clinic practice-management platform. For privacy enquiries, contact us at: privacy@oraly.in or via WhatsApp at +91 62675 05080.

2. Information We Collect

When you use our WhatsApp consultation service, we may collect:

• Contact information: Your name, WhatsApp phone number, and profile name.
• Health information: Dental concerns, symptoms, photos of teeth or oral conditions, and voice notes you voluntarily share.
• Communication data: Messages, images, and audio you send through our WhatsApp channel.
• Usage data: Timestamps, message types, and interaction logs (no browsing behaviour is tracked on WhatsApp).
• Device information: Basic technical metadata provided by the WhatsApp Business API (device type, OS version).

We do not collect payment card details, government IDs, or biometric data through this service.

3. How We Use Your Information

We use your data to:

• Provide dental guidance, triage advice, and referrals from our licensed dentists.
• Follow up on your consultation and send appointment reminders (if applicable).
• Improve our AI-assisted triage models and service quality (in anonymised, aggregated form only).
• Comply with Indian health regulations and legal obligations under the Digital Personal Data Protection Act 2023 (DPDP Act).
• Respond to your enquiries and provide customer support.

We do not use your health data for advertising, profiling, or sale to third parties.

4. WhatsApp & Meta Platform Disclosure

Our patient consultation service is delivered through WhatsApp Business, a product of Meta Platforms, Inc. By messaging us on WhatsApp, you acknowledge that:

• Your messages are transmitted through Meta's infrastructure and are subject to WhatsApp's Privacy Policy.
• Oraly uses the WhatsApp Business API (provided by a Meta Business Solution Provider) to receive, read, and respond to messages.
• Meta may process metadata (e.g. message timestamps, delivery receipts) in accordance with its own privacy practices.
• Oraly does not share your health information with Meta beyond what is technically required for message delivery.

This service is built on top of the Meta / WhatsApp Business platform. Our use of the platform complies with Meta's Platform Terms and WhatsApp Business Policy.

5. Sharing of Information

We share your data only in these limited circumstances:

• Dentists on our platform: Licensed dentists who provide your consultation receive your messages and photos solely to answer your dental query.
• Technology providers: Our WhatsApp Business API provider and cloud hosting provider (data stored on India-based servers) may process your data as data processors acting on our instructions.
• Legal obligations: We may disclose data if required by Indian law, court order, or regulatory authority.
• With your consent: We will ask your permission before sharing your data for any other purpose.

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

6. Data Retention

Consultation messages and associated health data are retained for up to 3 years from the date of your last interaction to allow continuity of care and comply with medical record obligations under Indian law. You may request deletion at any time (see Section 9); we will delete your data within 30 days except where retention is legally required.

7. Security

We implement appropriate technical and organisational measures to protect your data, including:

• End-to-end encryption on WhatsApp (provided by Meta).
• Access controls limiting data access to authorised personnel only.
• Encrypted storage on Indian cloud servers.
• Regular security reviews.

No method of electronic transmission or storage is 100% secure. We take reasonable precautions but cannot guarantee absolute security.

8. Children's Privacy

Our service is not directed at children under 13. We do not knowingly collect personal data from children under 13 without verifiable parental consent. If a parent or guardian believes their child has sent us a message, please contact us at privacy@oraly.in and we will promptly delete the information.

9. Your Rights (DPDP Act 2023)

Under the Digital Personal Data Protection Act 2023, you have the right to:

• Access a copy of your personal data held by us.
• Correct inaccurate or incomplete personal data.
• Erase your personal data (subject to legal retention obligations).
• Withdraw consent at any time (this will not affect processing done before withdrawal).
• Nominate another person to exercise these rights on your behalf.
• Grievance redressal by contacting our Data Protection Officer.

To exercise any right, message us on WhatsApp at +91 62675 05080 or email privacy@oraly.in. We will respond within 30 days.

10. Cookies & Website Tracking

Our website (oraly.in) may use essential cookies for site functionality. We do not use third-party advertising cookies. Analytics data, if collected, is anonymised and used only to improve the website.

11. Changes to This Policy

We may update this policy from time to time. We will notify you of significant changes via WhatsApp message or a notice on our website. Continued use of our service after changes constitutes acceptance of the updated policy.

12. Contact Us

For any privacy-related questions or to exercise your rights:

• Email: privacy@oraly.in
• WhatsApp: +91 62675 05080
• Address: Oraly Healthcare Solutions, Gwalior, Madhya Pradesh, India