Privacy Policy

1. Introduction

SpeechThrive is a technology platform that connects Patients with independent Speech-Language Pathologists (SLPs). We provide tools for patient management, assessments, therapy planning, scheduling, and practice recording.

This Privacy Policy describes how we handle your personal data when you use our Platform, whether you are a Patient, Guardian of a Patient, or an SLP.

2. Data Controller Information

3. What Data We Collect

3.1. Data Collected from Patients & Guardians

• • Personal Identifiers: Name, age, date of birth, gender, contact number, email address, and address.
• • Health Data (Sensitive Personal Data): Speech assessment results, therapy plans, medical history, oral mechanism findings, articulation errors, phonological processes, and clinical notes created by your SLP.
• • Biometric/Audio Data: Voice recordings and video recordings of practice sessions uploaded for SLP review.
• • Guardian Information: If the Patient is a minor, we collect the Guardian's name, relationship to the Patient, contact details, and consent records.
• • Usage Data: Platform interactions, session history, login activity, and device information.

3.2. Data Collected from SLPs

• • Professional Information: Name, qualifications, license/registration number, years of experience, areas of specialization.
• • Contact & Billing Data: Email address, phone number, address, GSTIN (if applicable), and payment details for platform fees.
• • Verification Documents: Copies of degrees, licenses, and identity documents for onboarding verification.

4. How We Use Your Data

We process your personal data for the following purposes:

• ✅ Platform Operation: To enable SLPs to manage Patients, conduct assessments, create therapy plans, schedule sessions, and review practice recordings.
• ✅ Telemedicine Services: To facilitate remote consultations between Patients and SLPs in compliance with the Telemedicine Practice Guidelines, 2020.
• ✅ Speech Analysis: To provide speech analysis features (via Azure Speech API) as a reference tool for SLPs.
• ✅ Compliance: To comply with legal and regulatory obligations, including record-keeping requirements.
• ✅ Platform Improvement: To analyze usage patterns and improve our services (in an anonymized manner).
• ✅ Billing & Payments: To process platform fees from SLPs.

5. Legal Basis for Processing

Under the Digital Personal Data Protection Act, 2023, we process your data based on the following legal grounds:

• 📝 Consent: For Patients and Guardians, we rely on your explicit consent to collect and process your personal data, including sensitive health data.
• 📋 Contractual Obligation: For SLPs, we process data to perform our obligations under the SLP Service Agreement.
• ⚖️ Legal Obligation: We process data as necessary to comply with legal requirements, including record-keeping under the Telemedicine Practice Guidelines.

6. Data Sharing

We share your data only as necessary to provide the Platform services:

6.1. With Your SLP (for Patients)

• • Your SLP has access to your assessment data, therapy plans, practice recordings, and communication history for the purpose of providing therapy.

6.2. Third-Party Service Providers

• • Cloud Hosting: We use third-party cloud service providers to store and process data securely. These providers are bound by strict data protection obligations.
• • Azure Speech API: We use Microsoft Azure Speech API for speech analysis. Audio data is transmitted to Azure for processing and is subject to Azure's data protection practices.
• • Payment Processors: For processing SLP platform fees, we use third-party payment gateways. We do not store payment card details on our servers.

6.3. Legal and Regulatory Disclosures

• • We may disclose your data if required by law, court order, or government authority, or to protect the rights, safety, or property of SpeechThrive, our users, or others.

7. Data Retention

We retain your personal data for as long as necessary to provide the Platform services and to comply with legal obligations:

• • Patient Data: Retained for the duration of the therapy relationship and for a minimum of 3 years after the last interaction, or 10 years if the records are part of a medico-legal case, as required by the Telemedicine Practice Guidelines.
• • SLP Data: Retained for the duration of the SLP's active relationship with SpeechThrive and for a reasonable period thereafter for record-keeping and legal compliance.
• • Practice Recordings: Retained as part of the Patient's medical record. You may request deletion of recordings by contacting your SLP or us.

8. Your Rights Under the DPDP Act, 2023

The Digital Personal Data Protection Act, 2023 provides you with the following rights:

• ✅ Right to Access: You have the right to obtain confirmation from us on whether we are processing your personal data and to access a copy of such data.
• ✅ Right to Correction: You have the right to correct, update, or complete inaccurate or incomplete personal data.
• ✅ Right to Erasure: You have the right to request the erasure of your personal data when it is no longer necessary for the purpose for which it was collected, subject to legal retention obligations.
• ✅ Right to Withdraw Consent: You have the right to withdraw your consent at any time. Withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal.
• ✅ Right to Grieve: You have the right to lodge a complaint with the Data Protection Board of India if you believe your rights have been violated.

9. Consent for Minors (Children)

SpeechThrive serves Patients starting from 4 years of age up to adults. For Patients who are minors (under 18 years of age):

• • We collect personal data of minors only with the verifiable consent of their parent or legal guardian.
• • The Guardian has the right to access, correct, and request deletion of the minor's data on their behalf.
• • We do not knowingly collect data from minors without parental consent. If we discover such data has been collected without consent, we will delete it promptly.

10. Data Security

We implement reasonable security safeguards to protect your personal data from unauthorized access, disclosure, alteration, or destruction, including:

• 🔒 Encryption: Data in transit is encrypted using TLS/SSL. Data at rest is encrypted using industry-standard encryption.
• 🔒 Access Control: Role-based access control ensures that only authorized personnel (and your SLP) can access your data.
• 🔒 Secure Infrastructure: We use secure, ISO-certified cloud infrastructure with regular security audits.
• 🔒 Incident Response: We have an incident response plan to handle data breaches. We will notify affected users and the Data Protection Board of India within 72 hours of becoming aware of a breach, as required by law.

11. Data Localization

The DPDP Act, 2023 requires that certain categories of personal data be stored within India. We store all personal data on servers located in India. Any transfer of data outside India will be done in compliance with applicable laws and only with your consent where required.

12. Cookies & Tracking

We use cookies and similar tracking technologies to:

• • Maintain your session and authentication status
• • Remember your preferences
• • Analyze platform usage (in an anonymized manner)

You can manage cookie preferences through your browser settings. However, disabling certain cookies may affect the functionality of the Platform.

13. Grievance Officer

In accordance with the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021 and the DPDP Act, we have designated a Grievance Officer to address data protection and platform-related concerns:

14. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. When we do, we will revise the "Last Updated" date at the top of this page. We encourage you to review this policy periodically.

If we make material changes, we will notify you through the Platform or via email.

15. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or your personal data, please contact us:

By using SpeechThrive, you acknowledge that you have read, understood, and agreed to this Privacy Policy.

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