Privacy Policy

RF Health is a cloud-based practice management platform for doctors working across multiple hospitals. It processes personal data and sensitive health data on behalf of doctors, hospitals, and their patients.

Data fiduciary: RAPDFLY PRIVATE LIMITED determines the purpose and means of processing personal data collected through RF Health.

This policy applies to all users of RF Health: doctors, hospital administrators, front-desk and billing staff, and, indirectly, to patients whose records are managed within the platform.

By accessing or using RF Health, you confirm that you have read and agree to this policy. If you are a hospital or practice onboarding staff, you are responsible for informing those staff members of this policy.

Patient data

When a patient is registered or a visit is recorded, the platform stores:

• Full name, date of birth, gender, contact number, and address
• Unique patient identifier assigned by the platform
• Clinical history: chief complaints, symptoms, examination findings, vitals
• Diagnoses, differential diagnoses, and clinical notes
• Prescriptions: medication name, dose, duration, refill status
• Investigation orders and results (lab and imaging)
• Surgery records: pre-operative diagnosis, procedure name, anaesthesia type, operative findings, post-operative instructions, surgeon name
• Follow-up appointments and referral notes
• Scanned documents attached to a patient record; text is extracted from scans and indexed to make the record searchable
• Billing records: invoices, payment status, insurance claim details

Doctor and staff data

• Full name, email address, and contact number used for account registration
• Role assignment (Doctor, Hospital Admin, Front Desk, Billing, or other configured role)
• Hospital affiliations and consulting schedules
• Login activity, session timestamps, and IP address
• Two-factor authentication device or method (no authentication secrets are stored in plaintext)

Appointment and scheduling data

• Appointment date, time, type, status, and assigned hospital
• OPD queue position and consultation duration
• Cancellations, reschedules, and no-show records

Audit and operational data

• An immutable audit log recording every view of, and edit to, a patient record, including the user, timestamp, and action type
• System-level event logs for security and operational monitoring

ABHA (Ayushman Bharat Health Account)

RF Health does not currently collect or store ABHA numbers as part of the patient registration process. Patient records are identified by an internal platform identifier. If ABHA linkage is introduced in a future version of the platform, this policy will be updated before that feature is made available, and patients or their healthcare providers will be notified of the change and its data implications.

Data we do not collect

We do not collect payment card numbers directly. Any payment processing is handled by third-party payment providers under their own terms. We do not collect biometric data, genetic data, or social media profiles.

We use the data we collect solely to provide and improve the RF Health service:

• Creating and maintaining patient records accessible across a doctor's registered hospitals
• Scheduling and managing appointments and operating-theatre slots
• Generating prescriptions, consultation summaries, dispense summaries, and operative reports in PDF format
• Producing analytics and operational reports (appointment volumes, completion rates, revenue summaries) from the records already entered by staff
• Sending in-platform notifications about appointments and outstanding investigations
• Enforcing role-based access to ensure each staff member sees only the data their role requires
• Maintaining the audit log so access to records is always attributable and reviewable
• Diagnosing platform errors and improving system performance

We do not sell patient data or staff data to any third party. We do not use patient health records for advertising, profiling outside the platform, or any purpose beyond the delivery of the RF Health service.

Data minimization

We collect only the personal and health data necessary to provide the RF Health service. We do not require doctors, administrators, or patients to provide information beyond what is needed for the specific function being used. Optional fields within the platform are not required to use core features.

Purpose limitation

Health data entered into RF Health is used only for the purposes described in this policy at the time of collection. We will not use patient health records for a new or materially different purpose without providing prior notice and, where required, obtaining fresh consent. Analytics and operational reporting produced within the platform are derived from data already entered by healthcare providers and are used only within the platform to support the delivery of care, not for profiling, research, or commercial purposes beyond the RF Health service.

Access to data within RF Health is controlled by roles. Each account is assigned a role at the hospital level, and each role restricts what data that account can view, create, or edit. The platform enforces these restrictions on every request.

Doctor

Can view and edit the full clinical record (EMR, prescriptions, investigation orders, surgery notes, and the patient timeline) for patients under their care. Can view their own appointment schedule and analytics across their hospitals.

Hospital Administrator

Can manage staff accounts, role assignments, and hospital-level settings. Can access operational reports and the audit log for that hospital. Does not have clinical editing access unless also assigned a Doctor role.

Front Desk

Can book, cancel, and reschedule appointments. Can register new patients and view basic patient demographics for appointment purposes. Cannot view or edit clinical notes, prescriptions, or investigation results.

Billing

Can access invoices, payment records, and insurance claim details. Cannot view clinical notes or prescriptions beyond what is required for billing.

RF Health includes an optional feature called the Clinical Copilot. It is a decision-support tool, not a diagnostic tool.

What the Clinical Copilot does

• Reads the patient record you are currently viewing and produces a concise summary of the clinical history, medications, investigations, and visit timeline
• Answers questions you ask about that patient's record, for example, when a medication was started, or what changed since the last visit
• Drafts a consultation note based on the current visit data, returned as a draft for your review

What the Clinical Copilot does not do

• It does not write anything to the patient record without the doctor reviewing and explicitly saving it
• It does not make diagnoses, prescribe treatments, or replace clinical judgement
• It does not share patient data with any AI service beyond the scope of generating the requested output

Opt-in and control

The Clinical Copilot is off by default for every account, including hospital administrators. A doctor enables it deliberately for their own account. Even after enabling, the Copilot reads only the record currently open; it does not run across the full patient database in the background.

Patient data sent to the AI processing layer for Copilot requests is used only to generate the response for that request. It is not used to train models or retained beyond the scope of completing the request.

No automated clinical decisions

The Clinical Copilot produces outputs (summaries, drafts, answers) that are always presented to the treating doctor for review before any action is taken. No clinical decision affecting a patient is made automatically by the platform. The doctor retains full clinical responsibility and must explicitly save or act on any AI-generated content. The platform does not issue prescriptions, diagnoses, referrals, or instructions to patients through automated means.

RF Health uses third-party infrastructure providers to operate the platform. These providers act as data processors under our instructions and are bound by data processing agreements that prohibit them from using your data for their own purposes.

Infrastructure categories

• Cloud database hosting: patient records, appointment data, and all structured data are stored in a managed PostgreSQL database hosted on a cloud provider with encryption at rest and automated daily backups.
• Application hosting: the RF Health web application is deployed on a cloud application platform. Servers are located in a region selected for latency and compliance relevance.
• Email delivery: transactional emails (account setup, password reset, notifications) are delivered through a third-party email service. No patient health data is included in these emails.
• AI inference: when the Clinical Copilot is active for a request, relevant portions of the open patient record are sent to a third-party AI inference API to generate the requested output. This processing is governed by a data processing agreement that prohibits the provider from using the data for model training or any purpose other than generating the requested response. The identity of the AI inference provider is available on request by contacting support@ppmsai.com. This is described further in the Clinical AI Processing section.

We do not share patient data with health insurance aggregators, pharmaceutical companies, data brokers, or any party not listed above without explicit consent or a legal obligation to do so.

We implement technical and organisational measures designed to protect personal data against unauthorised access, alteration, disclosure, or destruction.

Technical controls

• All data in transit is encrypted using TLS. All data at rest is encrypted by the database and storage providers.
• Two-factor authentication is available for all accounts and is encouraged for doctor and administrator accounts.
• Session tokens are rotated on authentication events and expire after inactivity.
• Every access to and edit of a patient record is written to an immutable audit log. The log records the user account, the action, the patient identifier, and the timestamp. It cannot be edited or deleted by any user within the platform, including administrators.
• Role-based access control is enforced at the server level on every API request, not only in the user interface.
• The database is backed up automatically every day. Backups are stored separately from the primary database and are tested periodically.

Organisational controls

• Access to production infrastructure is restricted to a small number of authorised personnel.
• We review access grants periodically and revoke access that is no longer needed.

Active accounts

Patient records, appointment history, prescriptions, and all clinical data are retained for as long as the doctor or hospital account that holds them is active. Medical records may be required to be retained for specified periods under applicable Indian law (including the Clinical Establishments Act and state-level regulations), and we will retain data in compliance with those obligations even if an account is closed.

Account closure

When a doctor or hospital account is closed, the account holder may request export of the patient data before closure. We will provide a structured export in a machine-readable format on request. After the applicable legal retention period has elapsed, personal data that is no longer required will be deleted or anonymised.

Audit logs

Audit logs are retained for the duration of the account and for a period thereafter as required by law or as necessary to resolve disputes or investigate security incidents.

Requesting deletion

Individual data principals may request erasure of their personal data by contacting us at the address in the Grievance & Contact section. We will process the request subject to any legal retention obligation that prevents deletion, for example, retention requirements that apply to medical records under Indian law.

Under the Digital Personal Data Protection Act, 2023 and other applicable law, you have the following rights with respect to your personal data:

Right to access

You may request a summary of the personal data we hold about you, the purposes for which it is processed, and the categories of third parties with whom it has been shared.

Because patient records in RF Health are managed by your treating doctor or hospital (not by you directly), the most effective way to access your health record is to request it from the doctor or hospital that entered and manages it. They can view and export your record within the platform. If you are unable to obtain access through your healthcare provider, or if your request concerns data that RAPDFLY PRIVATE LIMITED holds directly, contact us at support@ppmsai.com and we will facilitate access or provide a response within 30 days.

Right to correction

You may request correction of personal data that is inaccurate or incomplete. For patient clinical records, corrections should be requested through the treating doctor or the hospital that holds the record, who can update the record within the platform.

Right to erasure

You may request deletion of personal data that is no longer necessary for the purpose it was collected, subject to legal retention obligations described above.

Right to withdraw consent

Where processing is based on consent, for example, use of the Clinical Copilot feature, you may withdraw consent at any time. To withdraw consent for an optional feature, disable it in your account settings. To withdraw consent for the processing of your patient record by the underlying healthcare provider, contact that provider directly; they are responsible for acting on your withdrawal within their practice.

Where a withdrawal request is directed to RAPDFLY PRIVATE LIMITED and relates to data we process directly, we will cease the relevant processing within 7 business days of receiving a verified withdrawal request. Withdrawal does not affect the lawfulness of processing carried out before withdrawal, and does not override legal obligations to retain medical records under Indian law.

Right to grievance redressal

You may raise a grievance about how your data is handled. We will acknowledge your grievance and respond within 30 days. Details are in the Grievance & Contact section.

Right to nominate

Under the DPDP Act, you may nominate another individual to exercise your data rights on your behalf in the event of your death or incapacity.

To exercise any of these rights, contact us at support@ppmsai.com. We may ask you to verify your identity before acting on a request.

RF Health uses cookies and similar technologies to maintain user sessions and ensure the platform functions correctly.

Session cookies

When you sign in, a session token is set in a secure, HTTP-only cookie. This token identifies your session and is required for the platform to function. It expires when you sign out or after a period of inactivity. No session cookie contains health data.

What we do not use

We do not place third-party advertising cookies, analytics tracking cookies from advertising networks, or any cookie designed to track you across other websites. We do not use fingerprinting or other non-cookie tracking techniques.

Managing cookies

The session cookie is essential for the platform to work. Blocking it will prevent sign-in. You can sign out at any time to invalidate your session cookie.

Your cookie preferences

On your first visit we ask which optional categories you allow: functional (remembered preferences such as layout settings), analytics and marketing. All are off unless you turn them on. Necessary cookies, including the session cookie and the cookie that stores your choice, are always active. Your choice is kept in a first-party cookie named rf_consent for up to 12 months, after which, or when this policy changes, we ask again. It holds only your choices and the date. You can change them at any time from Cookie Settings in the footer.

Despite the controls described in the Security section, no system can guarantee complete protection against all threats. In the event that we become aware of a personal data breach:

• We will assess the breach promptly to determine its scope and risk.
• Where the breach is likely to result in harm to affected data principals, we will notify the Data Protection Board of India (or the relevant regulatory authority under applicable law) within 72 hours of becoming aware of the breach, or as soon as practicable if a complete assessment is not yet possible within that period.
• We will notify affected individuals without undue delay where the breach is likely to result in a high risk to their rights or interests. The notification will describe: what data was affected, the likely consequences of the breach, and the steps individuals can take to protect themselves.
• We will document every breach, regardless of whether notification is required, including the facts, effects, and remedial action taken.
• We will take steps to contain the breach, assess the root cause, and implement measures to prevent recurrence.

If you believe your account has been compromised, contact us immediately at support@ppmsai.com.

RF Health is operated in India and processes data of persons in India. The Digital Personal Data Protection Act, 2023 ("DPDP Act") applies to the personal data we process.

Data fiduciary

RAPDFLY PRIVATE LIMITED is the Data Fiduciary for the personal data processed through RF Health. We determine the purpose and means of processing and are responsible for compliance with the DPDP Act.

Lawful basis for processing

We process personal data on the following bases:

• Consent: for the processing of patient data entered by the treating doctor or healthcare facility, and for optional features such as the Clinical Copilot.
• Legitimate uses: for security and fraud prevention, compliance with legal obligations, and operation of the platform that the user has contracted for.

How patient consent is obtained

RF Health operates as a platform used by licensed healthcare providers. Patients do not register on RF Health directly. When a doctor or hospital administrator enters a patient's data into the platform, the healthcare provider is responsible for obtaining the patient's prior consent for the collection and use of their health data as part of the treatment relationship, in accordance with applicable professional and legal obligations.

RAPDFLY PRIVATE LIMITED, as Data Fiduciary, relies on the healthcare provider's confirmation that such consent has been obtained. Healthcare providers using RF Health agree, as part of their subscription terms, that they have obtained and will maintain all necessary patient consents for the health data they enter into the platform.

For optional features that RF Health controls directly, such as the Clinical Copilot, consent is obtained at the account level from the treating doctor, who enables the feature for their account. Patient health data is used within that feature only to respond to the specific query the doctor raises; it is not used beyond that purpose.

Data localisation

All patient health data processed through RF Health is stored on infrastructure located within India. We do not transfer patient health records to servers outside India. If this changes, we will update this policy with at least 30 days' prior notice to active account holders and will ensure any cross-border transfer complies with applicable law.

Consent notices

Where we rely on consent as the lawful basis for processing, we provide clear notice of the data being collected and the purpose. You may withdraw consent at any time without affecting the lawfulness of prior processing.

Grievance officer

As required by the DPDP Act, we have designated a point of contact for data principal grievances. Details are in the Grievance & Contact section below.

RF Health may process medical records of minor patients where a treating doctor or hospital registers and manages the child's record as part of clinical care. In such cases, the data is entered by the healthcare provider and is subject to the same protections as all other patient data.

RF Health does not offer direct accounts to persons under 18. If we become aware that a minor has independently registered an account, we will delete that account promptly.

We may update this Privacy Policy from time to time to reflect changes in the platform, applicable law, or our practices. When we make material changes, we will notify active account holders by email or through an in-platform notice at least 14 days before the change takes effect, where practicable.

The "Last updated" date at the top of this page shows when the policy was last revised. Continued use of RF Health after the effective date of a change constitutes acceptance of the updated policy.

If you have a question, concern, or complaint about how we handle your personal data, or if you wish to exercise any of your rights under the DPDP Act, contact us:

We will acknowledge your grievance within 7 business days and aim to resolve it within 30 days. If your grievance is not resolved to your satisfaction, you may escalate it to the Data Protection Board of India once it is established under the DPDP Act, 2023.