Cookie Policy | GoClinica

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Overview

HealthChip Technologies Private Limited (hereinafter referred to as the “Company,” “we,” “us,” or “our”), acting for itself and its affiliates/group entities operating under the trade name “GoClinica,” is the proprietary owner and operator of the internet resource located at www.goclinica.com and the mobile application branded as “GoClinica” (collectively, the “Website”).

This Cookie Policy explains how GoClinica uses cookies and similar tracking technologies when you visit or use the Website, and the choices available to you in relation to such technologies. This Cookie Policy supplements, and should be read together with, our Privacy Policy and our Terms of Use. Capitalized terms not defined in this Cookie Policy carry the meanings assigned to them in our Privacy Policy and Terms of Use.

By continuing to browse or use the Website, subject to the consent mechanisms described in Clause 6 (Managing Your Cookie Preferences) below, you acknowledge that you have read and understood this Cookie Policy.

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1. WHY THIS COOKIE POLICY?

This Cookie Policy is published in compliance with applicable Indian law, including:

•the Information Technology Act, 2000, and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (“SPDI Rules”);

•the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021; and

•the Digital Personal Data Protection Act, 2023, and the Digital Personal Data Protection Rules, 2025, as the same come into force in a phased manner.

GoClinica acknowledges that certain of the enactments referred to above are being brought into force in a phased manner, and that GoClinica’s obligations in respect of consent and disclosure for cookies shall apply prospectively and be updated as and when the corresponding provisions come into effect.

1.1Territorial Scope. In accordance with Clause 1.7 (Territorial Restriction) of our Terms of Use, the Website and the Services are intended solely for individuals located in India, and this Cookie Policy is drafted accordingly, by reference to Indian law. GoClinica does not direct, target, or market the Website toward individuals located outside India. Users located in the European Union, the European Economic Area, or the United Kingdom who nonetheless access the Website should refer to Annex A (GDPR Supplementary Addendum) below, which applies solely by virtue of such access and not because GoClinica offers or directs the Website or Services toward those jurisdictions.

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2. WHAT ARE COOKIES?

2.1Cookies are small text files that are placed on your computer, mobile phone, or other device when you visit a website or use an application. Cookies are widely used to make websites and applications function efficiently, to remember your preferences, and to provide information to the owners of the site regarding how it is used.

2.2In addition to cookies, GoClinica may use other similar tracking technologies, including web beacons, pixel tags, embedded scripts, local storage, and software development kit (“SDK”) identifiers within the GoClinica mobile application. References to “cookies” in this Policy include such similar technologies, unless the context requires otherwise.

2.3Session and Persistent Cookies.

•Session Cookies: temporary cookies that remain on your device only until you close your browser or the application. These are used to maintain your session while you navigate the Website (for example, to keep you logged in while booking an appointment).

•Persistent Cookies: cookies that remain on your device for a set period, or until you delete them, even after you close your browser. These are used to remember your preferences and recognize you as a returning User.

2.4First-Party and Third-Party Cookies.

•First-Party Cookies: cookies set directly by GoClinica.

•Third-Party Cookies: cookies set by a domain other than the Website, typically by our analytics, advertising, or service-provider partners, as described in Clause 4 below.

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3. CATEGORIES OF COOKIES WE USE

3.1Strictly Necessary Cookies. These cookies are essential for the Website and the GoClinica mobile application to function and cannot be switched off in our systems. They are usually set only in response to actions made by you which amount to a request for services, such as logging into your account, setting your privacy preferences, filling in appointment booking forms, or maintaining the security of your session. You may set your browser to block these cookies, but some parts of the Website may not then function.

Examples of purposes served by strictly necessary cookies include:

•maintaining your logged-in session across pages;

•remembering items in an active booking or checkout flow;

•load-balancing and distributing traffic across our servers; and

•detecting and preventing fraudulent activity and abuse, including in connection with GoClinica’s Fraud Detection Policy.

3.2Functional Cookies. These cookies enable the Website to provide enhanced functionality and personalization, such as remembering your city or clinic preferences, language settings, or previously searched Practitioners. If you do not allow these cookies, some or all of these services may not function properly.

3.3Analytics and Performance Cookies. These cookies allow us to count visits and traffic sources so that we can measure and improve the performance and usability of the Website. They help us understand which pages are most and least popular, how Users navigate the Website, and where errors may occur. All information collected by these cookies is aggregated and, unless you are logged into your account, is not used to identify you individually.

3.4Advertising and Targeting Cookies. These cookies may be set through the Website by GoClinica or by our advertising partners. They may be used to build a profile of your interests and to show you relevant advertisements (including for Sponsored ads, as described in our Terms of Use) on the Website or on other websites and applications. These cookies do not directly store personal information but are based on uniquely identifying your browser and device. If you do not allow these cookies, you will experience less targeted advertising.

3.5Social Media Cookies. These cookies may be set by third-party social media services that GoClinica has added to the Website (for example, to enable content sharing). These services may set cookies that may also be used to track your activity on other websites, and GoClinica does not control the operation of such cookies. Please refer to the respective privacy policies of these third-party services for further information.

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4. THIRD-PARTY COOKIES

4.1Certain third parties, including analytics providers, payment gateway providers, advertising networks, and social media platforms, may set cookies on your device when you use the Website. These third parties may include:

•Analytics providers, to help us understand Website usage and performance;

•Payment gateway providers, to facilitate secure processing of appointment fees and other payments;

•Advertising and marketing partners, to measure the effectiveness of promotional campaigns and Sponsored ads; and

•Communication service providers, to facilitate SMS, email, or push notification delivery in connection with appointment reminders and updates.

4.2GoClinica does not control the cookies set by these third parties, and their use of cookies is governed by their respective privacy and cookie policies. GoClinica encourages you to review the policies of these third parties for further information regarding their data practices.

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5. PURPOSES FOR WHICH WE USE COOKIES

GoClinica uses cookies for the following purposes:

•to authenticate Users and maintain secure login sessions;

•to facilitate appointment booking, cancellation, and payment workflows;

•to remember your preferences (such as location, language, and previously viewed Practitioners or specialties);

•to measure and analyze traffic, usage patterns, and Website performance;

•to detect, investigate, and prevent fraudulent or abusive activity, in accordance with GoClinica’s Fraud Detection Policy;

•to personalize content, search results, and Practitioner recommendations; and

•to deliver and measure the effectiveness of advertisements, including Sponsored ads.

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6. MANAGING YOUR COOKIE PREFERENCES

6.1Cookie Banner and Consent. On your first visit to the Website, you will be presented with a cookie banner or similar notice allowing you to accept, reject, or customize your cookie preferences in respect of cookies other than Strictly Necessary Cookies. Strictly Necessary Cookies do not require your consent, as they are essential to the functioning of the Website.

6.2Browser Controls. Most web browsers allow you to control cookies through their settings, including to block cookies entirely, delete existing cookies, or be notified when a cookie is set. Please note that if you choose to block or delete cookies, certain features of the Website may not function correctly, and you may be unable to access some Services, including appointment booking.

6.3Mobile Application Controls. If you use the GoClinica mobile application, you may manage similar tracking preferences, including advertising identifiers, through your device’s operating system settings (for example, “Limit Ad Tracking” or “Opt out of Ads Personalization,” as applicable to your device).

6.4Do Not Track Signals. Some browsers offer a “Do Not Track” (“DNT”) setting. As there is currently no uniform industry standard for recognizing or honoring DNT signals, GoClinica does not, at this time, respond differently to DNT signals from your browser. GoClinica will update this Clause 6.4 if a common industry standard for DNT is adopted in the future.

6.5Withdrawal of Consent. You may withdraw your consent to non-essential cookies at any time by adjusting your cookie preferences through the cookie banner (where available), your browser settings, or your device settings, or by writing to privacy@goclinica.com. Withdrawing consent will not affect the lawfulness of any processing carried out based on your consent before its withdrawal.

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7. RETENTION OF COOKIE DATA

Different cookies have different lifespans: some (session cookies) expire when you close your browser, while others (persistent cookies) remain for a defined period, which varies depending on the specific cookie and its purpose, generally not exceeding [24 months / such period as GoClinica may specify in its cookie management tool]. Data collected through analytics and advertising cookies is retained only for as long as reasonably necessary for the purposes described in Clause 5, or as otherwise required under applicable law, including the record-retention requirements under the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021.

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8. CHILDREN’S DATA

Consistent with Clause 13 (Children’s and Minors’ Privacy) of our Privacy Policy, GoClinica does not knowingly use cookies to conduct behavioural monitoring or targeted advertising directed at children. Where a User registers a child as a dependent on their account in accordance with our Terms of Use, cookies associated with that dependent’s use of the Services (if any) will be limited to Strictly Necessary Cookies required to deliver the relevant healthcare Services.

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9. CHANGES TO THIS COOKIE POLICY

GoClinica reserves the right to update or modify this Cookie Policy at any time, to reflect changes in the cookies and similar technologies we use, or for legal, regulatory, or operational reasons. Material changes will be notified to you via the Website, the cookie banner, or email, as appropriate. The “last updated” date at the top of this Policy (once published) will indicate when this Cookie Policy was last revised. We encourage you to review this Cookie Policy periodically.

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10. CONTACT US

If you have any questions about this Cookie Policy or GoClinica’s use of cookies, please contact us at:

•Email: privacy@goclinica.com

•Grievance Officer: As named in our Terms of Use, contactable through the “Contact Us” page at www.goclinica.com/contact.

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ANNEX A: GDPR SUPPLEMENTARY ADDENDUM (FOR USERS IN THE EUROPEAN UNION / UNITED KINGDOM)

A.1 Applicability

A.1.1GoClinica’s Website and Services are intended solely for individuals located in India, as described in Clause 1.7 of our Terms of Use and Clause 1.1 of this Cookie Policy. GoClinica does not direct, target, market, or offer the Website or the Services toward individuals located in the European Union, the European Economic Area, or the United Kingdom, and does not intend to monitor the behaviour of such individuals for the purposes of Regulation (EU) 2016/679 (the “GDPR”) or the UK GDPR.

A.1.2Notwithstanding Clause A.1.1, this Annex applies, in addition to and not in substitution of Clauses 1 to 10 above, to any User who nonetheless accesses the Website from within the European Union, the European Economic Area, or the United Kingdom, solely by virtue of such access, and not on the basis that GoClinica offers or directs the Website or Services toward those jurisdictions (each, a “European User”). This Annex is provided by GoClinica on a good-faith basis to afford European Users a materially equivalent standard of protection in the event the GDPR or the UK GDPR is nonetheless found to apply to such access.

A.1.3Where this Annex conflicts with Clauses 1 to 10 in respect of a European User, this Annex shall prevail solely as regards that European User.

A.2 Legal Basis for Cookies

A.2.1In addition to the DPDP Act-based consent framework described in Clause 6, the placement of any cookie other than a Strictly Necessary Cookie on a European User’s device requires prior, informed, freely given, and specific consent, in accordance with Article 5(3) of the ePrivacy Directive (as implemented in the relevant EU member state or the UK Privacy and Electronic Communications Regulations) and Article 6 of the GDPR.

A.2.2GoClinica shall present European Users with a consent mechanism that allows consent to be given, refused, or withdrawn separately for each cookie category described in Clause 3 (i.e., granular, purpose-by-purpose consent), rather than a single accept-all/reject-all toggle. Continued browsing shall not, by itself, be treated as consent for European Users.

A.2.3Where GoClinica processes a European User’s personal data on a legal basis other than consent (for example, to perform a contract for booking a Practitioner appointment, or on the basis of GoClinica’s legitimate interests in securing the Website and preventing fraud), GoClinica shall identify the applicable legal basis in its privacy notice to European Users.

A.3 Special Category Data

Where cookies or related technologies result in the processing of health-related information capable of identifying a European User (a “special category” of data under Article 9 of the GDPR), GoClinica shall only process such data on the basis of explicit consent or another condition permitted under Article 9(2) of the GDPR, notwithstanding that the DPDP Act does not itself maintain a distinct “sensitive personal data” category.

A.4 Automated Decision-Making and Profiling

A.4.1GoClinica’s Practitioner search and ranking algorithm (described in Clause 3.3 of the Terms of Use) and its use of Advertising and Targeting Cookies (Clause 3.4 of this Policy) may involve profiling of European Users based on their browsing behaviour and preferences.

A.4.2European Users have the right, under Article 22 of the GDPR, not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning them or similarly significantly affects them. GoClinica confirms that its Practitioner ranking and ad-targeting processes do not produce legal or similarly significant effects of this nature, but European Users may nonetheless object to profiling for direct marketing purposes at any time, free of charge, by contacting GoClinica as set out in Clause A.8 below.

A.5 European User Rights

In addition to the rights described in Clause 10 (Your Rights) above, European Users have the following rights under the GDPR in respect of personal data processed via cookies and related technologies:

•Right of access: to obtain confirmation of, and access to, personal data being processed;

•Right to rectification: to correct inaccurate or incomplete personal data;

•Right to erasure: to request deletion of personal data, subject to applicable exceptions;

•Right to restrict processing: to request that GoClinica limit the processing of personal data in certain circumstances;

•Right to data portability: to receive personal data provided to GoClinica in a structured, commonly used, machine-readable format, and to have it transmitted to another controller, where technically feasible;

•Right to object: to object to processing based on legitimate interests or carried out for direct marketing purposes, including profiling related to such marketing; and

•Right to withdraw consent: to withdraw consent to cookie-based processing at any time, without affecting the lawfulness of processing carried out before such withdrawal.

GoClinica shall respond to requests from European Users within one (1) month of receipt, extendable by a further two (2) months where necessary, taking into account the complexity and number of requests, in accordance with Article 12 of the GDPR.

A.6 International Data Transfers

Where cookie or related data of a European User is transferred outside the European Economic Area or the United Kingdom, including to GoClinica’s servers or service providers located in India, GoClinica shall ensure that such transfer is carried out on the basis of the European Commission’s (or, as applicable, the UK’s) Standard Contractual Clauses, an applicable adequacy decision, or such other transfer mechanism as is recognized under Chapter V of the GDPR from time to time.

A.7 EU/UK Representative

A.7.1As set out in Clause A.1, GoClinica does not offer, direct, or market the Website or the Services toward individuals located in the European Union, the European Economic Area, or the United Kingdom, and does not systematically monitor the behaviour of individuals in those jurisdictions. Accordingly, any processing of a European User’s personal data by GoClinica is occasional in nature, does not involve large-scale processing of special category data (including health data) or criminal-records data relating to individuals in those jurisdictions, and, having regard to the nature, context, scope, and purpose of such processing, is unlikely to result in a risk to the rights and freedoms of the individuals concerned.

A.7.2On this basis, GoClinica relies on the exemption available under Article 27(2)(a) of the GDPR and the corresponding provision of the UK GDPR, and does not, at this time, designate a representative established in the European Union or the United Kingdom for data protection matters. GoClinica shall keep this position under periodic review and shall designate such a representative if, and to the extent that, its processing of European Users’ personal data ceases to qualify for this exemption.

A.7.3Notwithstanding Clause A.7.2, European Users may direct any queries regarding this Annex, or regarding GoClinica’s processing of their personal data, to GoClinica at the contact details in Clause A.8 below, and GoClinica will endeavour to respond in accordance with this Annex.

A.8 Contact and Supervisory Authority

A.8.1European Users may contact GoClinica regarding this Annex, or to exercise any of the rights described in Clause A.5, at privacy@goclinica.com.

A.8.2European Users also have the right to lodge a complaint with their local data protection supervisory authority, or, in the case of the United Kingdom, the Information Commissioner’s Office (ICO), if they consider that GoClinica’s processing of their personal data infringes the GDPR or the UK GDPR.

A.9 Relationship with the DPDP Act

For the avoidance of doubt, this Annex operates independently of, and in addition to, GoClinica’s obligations under the DPDP Act and the SPDI Rules described in Clauses 1 to 10 of this Policy. A European User located in India, or an Indian User located in the European Union or United Kingdom, may be entitled to rights under both frameworks concurrently, and GoClinica shall apply whichever framework affords the User the higher standard of protection in case of conflict.

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SCHEDULE: INDICATIVE LIST OF COOKIES

The table below is indicative only and may be updated from time to time as GoClinica’s use of cookies evolves. The current, authoritative list of cookies in use, including their names, providers, and expiry periods, is available through the cookie management tool accessible via the cookie banner on the Website.

Cookie Classification Schedule

Cookie Category	Illustrative Purpose	Illustrative Duration	Consent Required
Strictly Necessary	Session authentication, load balancing, fraud prevention	Session to a few hours	No
Functional	Remembering location, language, and search preferences	Up to 12 months	Yes
Analytics and Performance	Measuring traffic and Website usage patterns	Up to 24 months	Yes
Advertising and Targeting	Personalizing and measuring Sponsored ads	Up to 12 months	Yes
Social Media	Enabling content sharing via third-party platforms	Set by third party	Yes