Diligio
Legal & ComplianceIndia DPDP

Data Privacy Policy: India DPDP

How Diligio collects, uses, and protects personal data across Diligio Respond and Diligio Medical ERP, your rights under India's Digital Personal Data Protection Act 2023, and how to contact us about them.

Effective 06 August 2026 · Revised 01 November 2026

1. Data Fiduciary & Framework

Who we are: Diligio is operated by Diligio Ventures Private Limited (Corporate Identity Number: U62010RJ2026PTC117054), a private limited company incorporated in India, trading as Diligio ("Diligio", "we", "us"). For personal data about website visitors, account holders and enquirers, Diligio is the Data Fiduciary. For content our customers upload to the platform, Diligio acts as Data Processor on the customer's behalf, under our Data Processing Agreement.

Governance: We process personal data in accordance with the Digital Personal Data Protection Act 2023 (the “DPDP Act”) and the rules made under it. Where the DPDP Act uses different terminology, references in this policy to a data subject, controller and processor should be read as references to the corresponding concepts under that Act (Data Principal, Data Fiduciary and Data Processor).

Contact: For any data-protection enquiry, access request, or deletion request, email our data protection contact at dpo@diligio.co.

Complaints: You have the right to lodge a complaint with the Data Protection Board of India, although we would welcome the chance to resolve any concern first.

2. Data Collection & Lawful Basis for Processing

Account & enquiry data (we are Data Fiduciary): We collect names, work email addresses and basic account details to provide the service, respond to demo requests, and manage the customer relationship. The lawful bases are performance of a contract and our legitimate uses in operating and marketing the service to business users.

Customer content (we are Data Processor): Documents, knowledge-base entries and questionnaire content that customers upload to Diligio Respond are processed only to provide the platform's features (ingestion, AI-assisted drafting, verification, collaboration and export), on the customer's instructions. The customer is the Data Fiduciary for this content; Diligio is the Data Processor under our Data Processing Agreement.

Patient & clinic data in Diligio Medical ERP (we are Data Processor): In Diligio Medical ERP the customer (the clinic, pharmacy or hospital) is the Data Fiduciary for the data it records, including patient demographics and contact details, appointments and queue entries, vitals and clinical notes, prescriptions, pharmacy stock, batch and billing records, laboratory orders and results, and inpatient records. Where the clinic enables optional ABHA verification and the patient consents, ABHA identifiers and demographics flow through the product. Where Diligio hosts Medical ERP, Diligio acts as Data Processor and processes this data only to provide the Medical ERP features (registration, consultations, pharmacy, billing, laboratory and IPD operations, audit logging, backups and export), on the customer's instructions. Where Medical ERP is installed locally, the clinic hosts the data on its own infrastructure and Diligio does not process patient or clinical data, except for support, update or optional sync functions the clinic enables. Medical ERP has no generative-AI features and sends no clinical data to an AI model. The customer is responsible for obtaining the patient consents and notices required by applicable law, including the DPDP Act and applicable Indian medical-records rules; the product supports this with consent capture (such as the optional ABHA consent flow) and audit logging.

Children's data: Diligio Medical ERP may hold paediatric records. The clinic is responsible for any parental or guardian consent or notice required by applicable law, and Diligio processes that data only on the clinic's instructions.

No AI training: Customer content is never used to train AI foundational models, and we do not sell personal data. This applies equally to Medical ERP data, which is never sent to an AI model at all.

3. Cookies & Analytics

Our public website uses cookieless, privacy-friendly analytics with no advertising cookies and no cross-site tracking. Because we set no non-essential cookies on the website, no cookie-consent banner is required.

The application itself uses only the strictly necessary cookies needed to keep you signed in and to secure your session. We do not sell analytics or personal data.

4. Data Sovereignty & Security Guardrails

Tenant isolation: Each organisation's documents and knowledge-base content are isolated at the database layer using PostgreSQL Row-Level Security, so users can only access their own organisation's data.

Encryption at rest: All records and database volumes are encrypted at rest with AES-256 across our AWS and Supabase infrastructure.

Encryption in transit: All data in transit is encrypted using TLS 1.2 or higher over HTTPS.

Local Medical ERP deployments: In a locally installed Medical ERP deployment, the clinic is responsible for encryption, access control, backups and disaster recovery on its own equipment. Diligio does not host or access that data unless the clinic enables support access.

5. Cross-Border Transfers & Sub-processors

Sub-processors: We use a small set of vetted sub-processors to run the service, some located outside India (for example, AI inference and email delivery). The current list, with each provider's purpose and location, is published on our Sub-processors page.

Data residency: Primary hosting for our cloud services, including cloud-hosted Diligio Medical ERP, is in the EU (AWS Paris and Supabase EU); some sub-processors process data outside the EU as listed on our Sub-processors page. We do not currently offer an India hosting region. In a locally installed Medical ERP deployment, patient and clinical data stays on the clinic's own equipment.

Transfer safeguards: Where personal data is transferred outside India, we rely on the safeguards required by the DPDP Act, as described in our Data Processing Agreement.

6. Data Retention & Deletion

Diligio retains customer data for the duration of the active contract. Upon closure of the account by the client, for Diligio Respond, all related organisational data, raw documents and vector embeddings are deleted within 30 days, unless the client has specifically requested that we retain the data or we are legally required to keep it. Backups for Diligio Respond follow their ordinary rotation cycle and are purged within the same 30-day period. For Diligio Medical ERP, patient and clinical records are retained or deleted according to the clinic's own retention policy and applicable local regulations. Diligio will follow the clinic's documented instructions for export and deletion, subject to any legal retention requirement. Account and enquiry data we hold as Data Fiduciary is kept only for as long as needed for the relationship and to meet our legal obligations.

Local backups: Local backups apply only to the locally installed edition of Diligio Medical ERP. In that edition, the clinic creates and stores backups on its own infrastructure and controls their retention and deletion. This does not apply to Diligio Respond or to the cloud-hosted edition of Diligio Medical ERP, whose backups are managed by Diligio.

7. Breach Notification

If a personal data breach affects customer content for which Diligio acts as Data Processor, we will notify the affected customer (the Data Fiduciary) without undue delay after becoming aware of it, so they can meet their own intimation obligations to affected Data Principals and the Data Protection Board of India under the DPDP Act. If a personal data breach affects data for which Diligio is the Data Fiduciary (such as website visitor or account data), we will notify the Data Protection Board of India and affected Data Principals as required by the DPDP Act.

8. Rights of Data Subjects

Your rights: Under the DPDP Act, Data Principals have the right to access information, correction and erasure, grievance redressal, and nomination of another person to exercise their rights in the event of death or incapacity, together with the right to give, manage, review and withdraw consent.

How to exercise them: Email dpo@diligio.co and we will respond within the statutory time limit (normally one month). Where Diligio processes content on a customer's behalf, we will refer requests to that customer (the Data Fiduciary) and assist them in responding.