Legal — CARE

Privacy Policy

This Privacy Policy explains how ClinAlly collects, uses, and protects your personal information when you use the CARE application — your AI-powered companion for tobacco cessation.

Last updated: September 24, 2026  ·  Effective: September 24, 2026

1. Overview

Cardiometcare Plus Health Solutions Pvt Ltd, operating under the brand name ClinAlly ("we", "us", or "our"), is committed to protecting your privacy. This Privacy Policy applies to the CARE mobile application and explains what information we collect, how we use it, and your rights in relation to it.

By downloading, installing, or using CARE, you agree to the collection and use of your information as described in this policy. If you do not agree, please do not use the application.

Note: CARE handles sensitive personal and health-related data including tobacco-use history and health assessment information. We are committed to handling this data with care, confidentiality, and in compliance with India's Digital Personal Data Protection Act, 2023.

2. About CARE

CARE — Comprehensive AI-powered ConveRsational IntErface to Quit Tobacco — is a mobile application designed to provide tobacco users with accessible, interactive, personalised, and ongoing support throughout their tobacco cessation journey.

CARE is an educational and tobacco-cessation support application. It is not a medical or clinical treatment service. Counselling and clinical care are facilitated through Tobacco Cessation Centres (TCCs).

The application provides the following features and services:

3. Information We Collect

The following information is collected when you register and use CARE. All fields marked as required are necessary to provide you with personalised cessation support.

3.1 Registration and Identity

3.2 Tobacco-Use Profile

3.3 Health Assessment Information

Information entered voluntarily into CARE's built-in health assessment calculators, which may include:

3.4 AI Chatbot Interaction Data

Conversation history and interaction data with the CARE AI chatbot, used to personalise cessation support and maintain continuity across sessions.

Note on data sync: The CARE intake form includes a provision to sync information already collected by a clinician or counsellor at a Tobacco Cessation Centre, avoiding the need for you to re-enter the same information.

Data Category Collected Purpose
Name & mobile number Yes Account creation, OTP login, communication
Age, gender, area of residence Yes Personalised support, population-level insights
Tobacco-use profile Yes Tailored cessation guidance and AI responses
Health assessment inputs Yes (voluntary) Health risk awareness, personalised content
AI chatbot conversation history Yes Continuity of support, personalisation

4. Device Permissions

CARE requests the following device permissions. We request only what is necessary for specific features of the application.

Permission Required Purpose
Camera Yes To allow you to photograph documents or images for use within CARE — for example, when sharing health-related content with your TCC counsellor or setting a profile photo for your account
Microphone Yes To allow you to speak your messages aloud to the CARE AI chatbot, enabling hands-free, voice-based conversations during your tobacco-cessation support sessions
Photos / Gallery Yes To allow you to select images from your device's photo library for use within CARE — for example, when uploading a profile photo or sharing health-related images with your TCC counsellor
Location No Not collected or requested
Contacts No Not collected or requested

You can manage these permissions at any time through your device's Settings. Denying a permission may limit certain features of the application.

5. How We Use Your Information

The information collected through CARE is used exclusively for the following purposes:

CARE does not use your data for advertising, marketing profiling, or any commercial purpose beyond the delivery of cessation support services.

6. Data Sharing

We do not share your personal information with any external organisations or third parties, except as specifically described below. This includes limited sharing with OpenAI, the AI service that powers the CARE chatbot (see Section 6.4).

6.1 TCC Counsellors (With Your Knowledge)

If you are enrolled at or referred to a Tobacco Cessation Centre, relevant intake and assessment information may be accessible to your assigned TCC counsellor through the TCC application, to support your care and continuity of counselling.

6.2 Legal Requirements

We may disclose information if required by law, court order, or a competent governmental authority, or where necessary to protect the safety of users or the public.

6.3 No Commercial Data Sharing

We do not sell, rent, trade, or otherwise share your personal or health-related data with advertisers, data brokers, research organisations, or any other commercial third parties.

6.4 AI Service Provider — OpenAI (Third-Party AI Data Processing)

Third-Party AI Service: The CARE AI chatbot is powered by OpenAI. When you use the chatbot, your messages and limited profile context are transmitted to OpenAI to generate responses. This section explains exactly what is shared, with whom, and how your consent is obtained.

What data is sent to OpenAI:

What is not sent to OpenAI: Your name, registered mobile number, OTP/PIN credentials, and health assessment inputs (BMI, Cardiovascular Health, Alcohol Audit, and Diabetes Risk Score) are not transmitted to OpenAI.

Your consent: Before your first interaction with the CARE AI chatbot, the application will display a clear in-app notice informing you that your conversation data will be sent to OpenAI, and will ask for your explicit permission. You may decline this sharing; however, the AI chatbot feature will then be unavailable. All other CARE features — health calculators, craving tools, TCC information, and educational content — remain fully accessible without consenting to AI data sharing.

OpenAI's data protections: OpenAI processes your data solely to generate chatbot responses on ClinAlly's behalf. Your data is not used to train OpenAI's AI models and is not shared with any other party. OpenAI's data protection standards are consistent with or exceed those described in this Privacy Policy. For full details, see OpenAI's Privacy Policy and their API Data Usage Policies.

7. Data Security

We apply appropriate technical and organisational measures to protect your information from unauthorised access, loss, alteration, or disclosure:

If you believe your account has been compromised, please contact us immediately at info@clinally.com.

8. Data Retention and Account Deletion

We retain your information for as long as your account remains active and for a reasonable period thereafter, as required to fulfil the purposes described in this policy or as required by applicable law.

8.1 How to Request Deletion

To request deletion of your account and personal data, email us at info@clinally.com with the subject line "Account Deletion Request" and include the mobile number registered to your account. An in-app account deletion option is not currently available — all such requests must be submitted by email. We will confirm and process your request within 30 days of receipt.

8.2 What Is Deleted

Upon a confirmed deletion request, the following data will be permanently deleted from our systems:

8.3 What Is Retained

Certain data may be retained after deletion in the following limited circumstances:

Deleted data cannot be recovered. If you re-register after deletion, you will be treated as a new user with no prior history.

9. Your Rights

Under India's Digital Personal Data Protection Act, 2023, you have the following rights in relation to your personal data:

To exercise any of these rights, email us at info@clinally.com. We will respond within 30 days of receipt.

10. Children's Privacy

CARE is not intended for use by individuals under the age of 18. We do not knowingly collect personal data from minors. If you believe a minor has used the application and provided personal information without appropriate consent, please contact us at info@clinally.com and we will promptly address the matter.

11. Third-Party AI Service — OpenAI

11.1 OpenAI — AI Chatbot Infrastructure

The CARE AI chatbot is powered by OpenAI, L.L.C. (San Francisco, California, USA). When you use the chatbot, your messages and limited tobacco-use profile context are transmitted to OpenAI's API to generate personalised cessation-support responses.

OpenAI acts as a data processor on ClinAlly's behalf. It does not use your data to train its AI models and does not share your data with any third party. A full description of what data is shared and your consent options is set out in Section 6.4 of this policy.

OpenAI Privacy Policy: openai.com/privacy

OpenAI API Data Usage Policies: openai.com/policies/api-data-usage-policies

11.2 No Other Third-Party Integrations

No analytics platforms, advertising networks, social media SDKs, payment processors, or other third-party services are integrated into CARE. There are no payments, subscriptions, in-app purchases, or advertisements within the application.

12. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable legal requirements. When material changes are made, we will update the "Last updated" date at the top of this page and notify registered users where appropriate.

Continued use of CARE after the effective date of any changes constitutes your acceptance of the revised policy.

13. Contact Us

For any questions, concerns, or requests related to this Privacy Policy or your personal data, please contact us:

Grievance Officer / Data Protection Contact

Organisation: Cardiometcare Plus Health Solutions Pvt Ltd (ClinAlly)

Email: info@clinally.com

Address: Gurugram, Haryana, India — 110038

We will acknowledge your query within 48 hours and respond fully within 30 days of receipt.