This Privacy Policy outlines how “PLURO”(“Company”, “we”, “our”, “us”) collect, use, store, and protect your personal information when you visit our website, use our applications, book appointments, undergo treatment at our centres, interact with us for availing any of the Services, or for any other business transactions via digital and offline channels in India.

We process your data in compliance with the Section 43A of the Information Technology Act, 2000; and applicable Indian healthcare laws including the Assisted Reproductive Technology (Regulation) Act, 2021, Regulation 3(1) of the Information Technology (Intermediaries Guidelines) Rules, 2011, the Surrogacy (Regulation) Act, 2021, and the Telemedicine Practice Guidelines, 2020.

Who We Are & Scope

• Entity: Esperanza Medical Platform Private Limited, having its registered office at 501 Phase-III, Parekh Mkt, Ghatkopar East, Rajawadi, Mumbai, Mumbai, Mumbai, Maharashtra, India, 400077, operating fertility clinics and digital properties under the PLURO brand in India.
• Scope: This policy governs our websites, mobile/telemedicine platforms, electronic health record systems, clinic services, partner networks, and customer support channels.

What Data We Collect

We may receive various types of information from you when you avail any of the Services or interact with us for business purpose. Such information includes the kinds of information as shown below (collectively, “Information”).

• Identity & contact Information: Name, age/date of birth, gender, address, phone number, email.
• Medical & Reproductive Health Data: Health history, fertility investigations, lab results, imaging, prescriptions, vitals, ART/IVF case files, gamete/embryology notes (where applicable), genetic testing (if applicable), treating clinician details.
• Appointment & Billing: Booking details, payment method tokens (processed via RBI‑regulated gateways), invoices, GST details where applicable.
• Device & Usage Information: Cookies, IP address, pages viewed, approximate location, device identifiers (for security, analytics, fraud prevention), location data (where consented).
• Communication Records: Messages, forms, call recordings (where permitted by applicable law and with prior disclosure/consent as required under Indian law, including the Indian Telegraph Act, 1885 and relevant judicial pronouncements), emails, teleconsultation notes.

Some of the Information may be classified as Personal Information (as defined above), and we may receive, retain, process, use, transfer or disclose such Personal Information for the purposes set out in this Privacy Policy. Some of the Information may be classified as Sensitive Personal Data or Information (“SPDI”) under the SPDI Rules and is treated as such under this Privacy Policy.

Purpose of Processing

We and/or our affiliates may receive, collect, use, process, disclose, transfer, or store your Information, including for the following purposes (collectively, the “Purposes”):

• Provide care, counselling, and ART/IVF services
• Schedule and manage appointments
• Maintain clinical records as required by law.
• Run teleconsultations compliantly (identifying patient and RMP, documenting consent, issuing e-prescriptions as permitted).
• Processing payments, invoices, refunds; prevent fraud; meet tax/legal obligations.
• Maintain and secure our systems; analytics to improve services and patient experience.
• Send service notifications (bookings, reports) and relevant treatment updates.
• To assess and improve the quality and effectiveness of our services, to develop and enhance new services, and to conduct surveys or market analysis for service improvement purposes.
• For any other lawful purpose.
• We will only send marketing communications with your explicit consent, which you may withdraw at any time.

Legal Basis & Consent under Indian law

We rely on your consent (which you may withdraw at any time), performance of a service/contract (e.g., appointment you requested), and legal obligations (medical record keeping, responding to authorities, to defend or assert legal rights of us or others). You may review or request deletion of your Information that qualifies as SPDI or may also request correction, updating, or change such Information where possible. We will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable. Access to, or correction, updating, or deletion of your Information may be denied or limited by us if it would render the Information inaccurate or incomplete, violate another person’s rights and/or is not otherwise permitted by applicable law.

Patients Under 18 & sensitive contexts

We do not collect, process, or store personal data of individuals under the age of 18 years without the verifiable consent of a parent or legal guardian and the oversight of the treating clinician, in compliance with the ART Act, applicable Indian laws, and established medical ethics. Fertility and ART-related data is classified as Sensitive Personal Data and is handled in accordance with industry-standard security practices to ensure maximum confidentiality.

Health/ART record retention

Clinical and ART records are retained as mandated by law. Under the ART Act/Rules, ART clinics/banks must preserve records (e.g., donor, procedure, outcome data) and, in case of closure before the mandated period, transfer records to the National Registry. Current guidance indicates preservation for up to 10 years for ART/clinic records, with periodic updating of the National Registry or such longer period as may be prescribed by law or required for ongoing legal proceedings. Non-clinical website/analytics data may be retained for shorter periods consistent with business needs and law.

Note: Where the Surrogacy Act applies to your case, additional record-keeping and retention obligations may apply.

Sharing & Disclosure

We may share data with:

• Treating clinicians, labs, radiology partners, healthcare agencies, affiliates and accredited ART banks involved in your care;
• Our agents, contractors, and third-party service providers who process your information on our behalf, including providers of administrative, professional, and support services such as legal advisors, accountants, mailing and courier services.
• Third party administrators of insurance companies/insurance companies, government sponsors, or other third parties who may make payments on your behalf for the Services availed by you;
• Technology & cloud providers, appointment and EMR systems, communication tools, and security vendors under contracts with confidentiality safeguards;
• Payment gateways and RBI-regulated providers for transactions;
• Regulators/authorities where required by law (e.g., National Registry updates).
• A third party that acquires, or proposes to acquire, any of our business units or assets, whether by merger, divestiture, consolidation, or purchase of all or a substantial portion of our assets and that, as a result, is entitled to continue using the information you have provided to us.

We do not sell, rent, or trade patient information. Any cross-border storage or transfer of personal data is conducted in compliance with applicable Indian laws and using contractual and legal safeguards to ensure the security and confidentiality of personal data.

Retention of Information

We will retain Information in the formats and for the duration prescribed under applicable law or our Privacy Policy. We will retain your Information for as long as needed to provide you the Services or any other Purposes for which you have provided your consent to us. We will not retain such Information for longer than is required for the purposes for which the Information may lawfully be used or is otherwise required under any other law for the time being in force. We will put in place measures to ensure that your Information in our possession or under our control is destroyed and/or anonymized as soon as it is reasonable, practicable after: (a) the Purposes for which that Information were received is no longer being served by the retention of such Information; and (b) retention is no longer necessary under any applicable law. Your data may be anonymized, de-identified and/or aggregated, and the resulting data may be held by us, our affiliates, associates, agents, representatives, and other authorized third parties, for as long as necessary for us to provide the Services effectively or for other Purposes.

Security of Your Information

We endeavour to maintain physical, operational, managerial, technical and procedural safeguards that are appropriate to protect your Information against loss, misuse, copying, damage, modification, unauthorized access or disclosure. We will not be responsible for any breach of security or for any actions of any third parties or events that are beyond our reasonable control, including acts of Government, computer hacking, unauthorised access to computer data and storage device, computer crashes, breach of security and encryption, etc.

Disclaimer and Limitation of Liability

You are to ensure that Information provided to us is accurate, true and up to date at all times. We will not be liable for any loss, damage or prejudice suffered by you due to your failure to provide accurate, true or up to date Information or due to your provision of false, inaccurate or misleading Information. None of us, our affiliates, franchisees, our employees, consultants, directors, will be liable or obligated for any indirect, incidental, special or consequential damages with respect to collection and processing of your Information under any tort, contract, negligence, strict liability or other legal or equitable theory, even if you have been advised of the possibility of such damages. Your information may be disclosed in ways not foreseeable pursuant to the description in this Privacy Policy due to legal and/or regulatory requirement or for reasons beyond our control. Therefore, although we are committed to protecting your privacy, we do not promise, that your Information or private communications will always remain private.

Cookies & Tracking

We use necessary cookies for functionality and, with your explicit consent, analytics and advertising cookies for improving services. You can control cookies via your browser settings and our cookie banner preferences.

Your Rights & Choices

Subject to applicable law, you have the right to:

• Access a summary of your data we process,
• Request correction, completion, updating, or erasure of data given on consent,
• Withdraw consent for processing and marketing at any time,
• Nominate another individual to exercise your rights in the event of death or incapacity.
• Raise a grievance through our mechanism below.

Telemedicine Disclaimer & medical information

All teleconsultations are provided by Registered Medical Practitioners (RMPs) in line with the Telemedicine Practice Guidelines. Online resources and self‑assessment tools are informational only and not a substitute for in-person clinical diagnosis or emergency care. In emergencies, call local emergency services or visit the nearest hospital immediately.

Grievance Redressal

As required by Indian law for digital and e-commerce services, we provide a dedicated grievance channel. if you wish to withdraw your consents, please contact at contact@pluro.in You may object and/or withdraw your consent at any time and your request will be processed subject to the requirement of applicable law. However, if you choose to withdraw your consent, we may not be able to continue to provide the Services to you.

Email: contact@pluro.in

Postal: 1^st Floor, One45 Business Bay, Vallabh Baug Ext Lane, Pant Nagar, Ghatkopar East, Mumbai 400075

Consent to this Policy

You acknowledge that this Privacy Policy is a part of the Website and the other Services, and you unconditionally agree that becoming a User of the Website, and Services signifies your assent to this Privacy Policy. Your visit to the Website, and use of the Services is subject to this Privacy Policy.

Changes to the Privacy Policy

We reserve our right to change, modify, add, or update portions of this Privacy Policy, at our sole discretion subject to the applicable laws. We may update this Privacy Policy from time to time, with or without advance notice, and as required by latest regulations.