Contents 13 sections
- 1. Purpose
- 2. Controller details
- 3. Register of processing activities
- 4. Special categories and children
- 5. Processors and recipients
- 6. Requests from individuals
- 7. Security measures in summary
- 8. Purpose limitation and data minimisation
- 9. Roles and accountability
- 10. Link to retention and deletion
- 11. Review log
- 12. Summary of individuals' rights
- 13. Review
1. Purpose
This record lists each way in which Zebrold Private Limited, as operator of Consult Your Doctor, handles personal data. It supports the company's duties under the General Data Protection Regulation and India's Digital Personal Data Protection Act, 2023, and is kept up to date by the data protection lead. Where the company acts for another controller, such as a hospital, that is noted in the last column.
2. Controller details
| Item | Detail |
|---|---|
| Controller | Zebrold Private Limited (CIN U26109TS2026PTC210471), operating Consult Your Doctor |
| Operational office | Bockenheimer Landstraße 17-19, Frankfurt am Main, 60325, Germany |
| Registered office | Plot N.13 Survey P64/2, Software Units Layout, Madhapur, Hyderabad, 500081, Telangana, India |
| Directors | Hemendrah Kumar Sadamsetty; Indu Reddy Morthala |
| Data protection lead / DPO | Name and contact: (blank) |
| Grievance officer (India) | Name and contact: (blank) |
3. Register of processing activities
| Activity | Data and people | Purpose and legal basis | Recipients | Retention |
|---|---|---|---|---|
| Patient registration | Name, date of birth, sex, mobile number, email; patients and guardians | Create account and identify patient. Contract; consent | Support staff; platform vendors | While account is active, then per CYD-DP-04 |
| Teleconsultation | Symptoms, history, allergies, medicines, vital signs, notes; patients | Provide medical care. Health care provision; consent | Treating doctor | Medical record period |
| Prescription issue and AI checking | Prescription details, doctor details; patients and doctors | Issue prescription; check for errors. Health care provision; consent | Doctor; pharmacy chosen by patient; AI vendor as processor | Medical record period |
| Diagnostic tests and reports | Sample details, results, reports; patients | Perform and deliver tests. Health care provision; consent | Diagnostic centre; referring doctor | Medical record period |
| 12-day follow-up | Replies, symptom reports, alerts; patients | Support recovery. Consent; health care provision | Doctor; messaging vendor as processor | Medical record period |
| Payments | Payment status and reference (not full card details); patients | Collect fees. Contract; legal obligation | Payment partner | Per tax and company law |
| Doctor and centre onboarding | Identity, qualifications, registrations; doctors and centre staff | Verify credentials. Legitimate interest; legal obligation | Credentialing staff; regulators on request | While active plus period in CYD-DP-04 |
| Complaints and incidents | Complaint details, event reports; patients, staff | Investigate and improve. Legal obligation; legitimate interest | Medical lead; authorities where required | Per CYD-DP-04 |
| Website and app analytics | Device data, cookies; visitors | Keep the service working. Consent for non-essential cookies | Analytics vendor as processor | As in cookie notice |
| Staff administration | Contract, payroll, attendance; employees | Employment. Contract; legal obligation | HR, payroll, authorities | Per CYD-DP-04 |
4. Special categories and children
Most of the data handled by the platform is health data, which the General Data Protection Regulation treats as a special category and which India's law treats as sensitive in practice. It is processed only for health care and the related purposes in the register, under the safeguards in the Information Security and Access Control Policy (CYD-SEC-01). Data about children is processed only with the consent of a parent or guardian, which is verified, and no child's data is used for advertising or tracking.
5. Processors and recipients
| Recipient | Role | Data shared | Safeguard |
|---|---|---|---|
| Payment partner | Processor | Payment status and reference | Data processing agreement |
| Cloud hosting provider | Processor | All platform data, encrypted | Data processing agreement; transfer safeguards |
| Messaging and video provider | Processor | Contact details, messages, consultation sessions | Data processing agreement |
| AI service provider | Processor | Prescription data for checking | Data processing agreement; no use for the vendor's own purposes |
| Diagnostic centres, hospitals, doctors | Independent controllers for their own care duties | Referral and results data | Agreement; professional confidentiality |
6. Requests from individuals
| Date received | Person | Request | Decision | Date answered |
|---|---|---|---|---|
| (blank) | (blank) | (blank) | (blank) | (blank) |
| (blank) | (blank) | (blank) | (blank) | (blank) |
| (blank) | (blank) | (blank) | (blank) | (blank) |
Requests to see, correct, erase or restrict data, to object, to move data or to withdraw consent are logged here and answered within the time that the law allows, normally within one month under the General Data Protection Regulation.
7. Security measures in summary
The technical and organisational measures that protect this data, including role-based access, multi-factor authentication, encryption, logging, backups, staff training and vendor review, are set out in CYD-SEC-01. This record must be updated if any of those measures changes in a way that affects the risk to individuals.
8. Purpose limitation and data minimisation
Each activity in the register has a stated purpose, and data may be used only for that purpose or for a purpose that is compatible with it and that the patient could expect. Before a new use is introduced, the data protection lead checks whether it is compatible and whether new consent or a new notice is needed. Only the data needed for the purpose is collected, and optional fields are clearly marked.
9. Roles and accountability
The directors are accountable for compliance. The data protection lead maintains this register, advises on assessments, trains staff and acts as the contact for regulators and individuals. Each department head is responsible for the accuracy of the entries in the register for his or her area and for telling the data protection lead of any new use of data.
10. Link to retention and deletion
The retention periods in the register are those in the Data Retention and Deletion Policy (CYD-DP-04). When data reaches the end of its period it is deleted or made anonymous, and the date and method are recorded in the quarterly deletion log.
11. Review log
| Date | Reviewer | Changes made |
|---|---|---|
| (blank) | (blank) | (blank) |
| (blank) | (blank) | (blank) |
| (blank) | (blank) | (blank) |
12. Summary of individuals' rights
| Right | How it is handled |
|---|---|
| To be informed | Privacy notice (CYD-DP-03) given at registration and available at all times |
| Access and copy | Provided on request within the legal time |
| Correction | Doctor or data protection lead corrects the record; the original is kept as a version |
| Erasure and restriction | Applied unless the law requires the record to be kept; the person is told why |
| Objection and withdrawal of consent | Processing based on consent stops; earlier processing remains lawful |
| Complaint | To the grievance officer or to the data protection authority |
13. Review
The data protection lead reviews this record every six months and whenever a new use of personal data, a new vendor or a new country is introduced. The record is made available to a data protection authority on request.
Approval
This document is approved by the directors of Zebrold Private Limited, the operator of Consult Your Doctor.
Hemendrah Kumar Sadamsetty
Electronically signed | November 5, 2026
Hemendrah Kumar Sadamsetty
Director, Zebrold Private Limited
Date: November 5, 2026
Indu Reddy Morthala
Electronically signed | November 5, 2026
Indu Reddy Morthala
Director, Zebrold Private Limited
Date: November 5, 2026
Zebrold Private Limited
CIN: U26109TS2026PTC210471
Operational office: Bockenheimer Landstraße 17-19, Frankfurt am Main, 60325, Germany
Registered office: Plot N.13 Survey P64/2, Software Units Layout, Madhapur, Hyderabad, 500081, Telangana, India
Document No.: CYD-DP-01 | Version 1.0 | Effective date: November 5, 2026 | Owner: Zebrold Private Limited | Status: Approved