Privacy Policy

Important: This is a structured, India-aligned privacy policy template (DPDP Act 2023, IT Rules, MDR 2017). Before going live, please have it reviewed by a privacy / data protection lawyer in India. Replace placeholders in [square brackets].

Last updated: [Insert date of publication]

1. Who we are

This Privacy Policy explains how Cosma ("Cosma", "we", "us", "our") collects, uses, shares, retains and protects your personal data when you visit www.cosmafertility.com, use our applications, or interact with our products and services (together, the "Services").

2. Scope

This Policy applies to all individuals who access our Services, including visitors, users of FertiLens, customers who purchase Fertigen, individuals who book diagnostic tests through us, healthcare professionals who interact with our platforms, and corporate / institutional partners.

3. The data we collect

3.1 Information you provide

• Identity & contact data: name, email, mobile number, date of birth, gender, address, PIN code
• Account data: login credentials, profile information, preferences
• Health & fertility data: cycle information, fertility goals, medical history you choose to share, test results when uploaded, FertiLens responses
• Transaction data: orders, subscriptions, billing address, payment confirmation (we do not store full card details — see Section 6)
• Communications: emails, WhatsApp messages, support tickets, call recordings (where permitted and disclosed at the start of the call)

3.2 Information collected automatically

• Device & usage data: IP address, browser type, device identifiers, pages visited, time spent, referral source
• Cookies and similar technologies (see Section 9)

3.3 Information from third parties

• Diagnostic lab partners (your test reports, with your consent)
• Payment gateway partners (transaction confirmation only)
• Logistics partners (delivery status)
• Healthcare professionals you have authorised to share information with us

4. Sensitive personal data

Health and fertility information you share with us is treated as sensitive personal data under Indian law. We collect it only with your informed consent, use it only for the purposes you have agreed to, and apply heightened safeguards when processing or storing it.

5. How we use your data

• To deliver our Services — process orders, ship Fertigen, schedule tests, deliver reports, run FertiLens, manage your doctor consultation
• To provide clinical guidance through our fertility specialists, where you have requested it
• To communicate with you about your orders, tests, and account
• To improve and develop our products, content and services (using aggregated and de-identified data wherever possible)
• To comply with legal, tax, regulatory and quality / pharmacovigilance obligations
• To detect, prevent and address fraud, abuse, security incidents and unauthorized access
• With your separate consent, to send you marketing communications — which you can opt out of at any time