1Introduction
TruCover Wellness, operated by Rosetta Elliptic Partners Pvt Ltd ("TruCover", "we", "our", "us"), is committed to protecting the privacy and confidentiality of personal data belonging to employees, HR professionals, insurance intermediaries, and agents who use our platform. This Privacy Policy explains what data we collect, why we collect it, how we use it, and your rights in relation to it.
By accessing or using the TruCover Wellness platform ("Platform"), you agree to the terms of this Privacy Policy. If you do not agree, please discontinue use of the Platform immediately.
2Who This Policy Applies To
- Employees enrolled in a corporate wellness or group health insurance plan via TruCover
- HR professionals and administrators managing corporate accounts
- IRDAI-licensed intermediaries (Composite Brokers, Direct Brokers, Corporate Agents)
- Individual insurance agents registered under the TruCover agent network
- Visitors to our website at www.trucover365.com
3Information We Collect
3.1 Personal Identification Data
- Full name, date of birth, gender, photograph
- Government-issued ID numbers (Aadhaar, PAN) where required for KYC
- Contact information: email address, mobile number, residential address
3.2 Health & Medical Data
- Health risk assessment responses and wellness scores
- Medical consultation records (doctor notes, prescriptions) — stored with your consent
- Annual health check results scheduled through the platform
- Vitals tracked voluntarily: steps, sleep, hydration, blood pressure, blood glucose
- Mental wellness assessment responses
3.3 Insurance & Financial Data
- Group health insurance policy details, sum insured, coverage dates
- Claims history, claim documents submitted through the platform
- Bank account details for claim reimbursements (encrypted)
- Commission-related financial data for intermediaries and agents
3.4 Professional & Organisational Data
- Employer name, employee ID, department, designation
- IRDAI licence number and category (for intermediaries)
- Agent registration details, client portfolio data
3.5 Technical & Usage Data
- Device type, operating system, browser, IP address
- Login timestamps, session duration, features accessed
- App usage analytics (anonymised where possible)
4How We Use Your Data
| Purpose | Legal Basis |
|---|
| Provide wellness platform services, doctor consultations, health tracking | Contract performance |
| Process and support insurance claims 24/7 | Contract performance / Legal obligation |
| Enable HR dashboards — aggregate wellness & absenteeism data | Legitimate interest (anonymised) |
| KYC verification for agents and intermediaries (IRDAI compliance) | Legal obligation |
| Send wellness tips, health alerts, appointment reminders | Consent |
| Commission calculations and payouts for agents and intermediaries | Contract performance |
| Platform security, fraud detection, audit trails | Legitimate interest |
| Product improvement via anonymised analytics | Legitimate interest |
5Data Sharing & Third Parties
We do not sell your personal data. We share data only in the following circumstances:
- Insurance companies (insurers) — for policy issuance, endorsements, and claims settlement
- Third Party Administrators (TPAs) — for cashless claims processing
- IRDAI-licensed intermediaries — limited to policy data relevant to their clients
- Diagnostic labs and pharmacy networks — for health check scheduling and fulfilment
- Cloud hosting providers — SOC2-aligned, data processed in India
- Regulatory authorities — IRDAI, SEBI, Income Tax authorities, courts — when legally required
6Data Security
TruCover implements security practices aligned with SOC2 Type II principles:
- End-to-end encryption for health and financial data (AES-256 at rest, TLS 1.3 in transit)
- Role-based access controls — employees cannot view other employees' health data
- Multi-factor authentication for HR admins and intermediary accounts
- Regular penetration testing and vulnerability assessments
- Incident response plan with 72-hour breach notification to affected parties
7Data Retention
| Data Category | Retention Period |
|---|
| Employee health & wellness data | Duration of employment + 3 years |
| Insurance policy & claims data | 7 years (IRDAI regulatory requirement) |
| Agent / intermediary KYC data | 5 years post relationship end (PMLA) |
| Consultation records | 5 years (Medical Records Rules) |
| Usage logs & analytics | 2 years (anonymised after 6 months) |
8Your Rights
- Right to Access — request a copy of your personal data held by us
- Right to Correction — update inaccurate or incomplete data
- Right to Erasure — request deletion (subject to regulatory retention requirements)
- Right to Withdraw Consent — for marketing communications and voluntary health tracking
- Right to Grievance Redressal — raise complaints via bd@trucover365.com
We will respond to data requests within 30 days. For health data, you may access your records at any time via the TruCover app.
9Cookies & Website Tracking
Our website uses essential cookies for session management and analytics cookies (with consent) to improve user experience. You may manage cookie preferences via the settings panel on our website. We do not use third-party advertising cookies.
10Children's Privacy
The TruCover Wellness platform is not intended for persons below the age of 18. We do not knowingly collect data from minors. Health data of minor dependants covered under a family floater policy is collected only with the consent of the primary insured adult.
11Changes to This Policy
We may update this Privacy Policy periodically. Material changes will be communicated via email or in-app notification at least 14 days before they take effect. Continued use of the Platform after the effective date constitutes acceptance of the revised policy.
12Contact & Grievance Officer