Privacy Policy
Steward Healthcare India Pvt. Ltd. ("Steward", "we", "us", "our") operates the Steward Learning Cloud platform (the "Platform"). This Privacy Policy explains how we collect, use, disclose and safeguard your personal data in compliance with:
- The Digital Personal Data Protection Act, 2023 (DPDPA) of India
- The Information Technology Act, 2000 and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 ("IT Rules")
- Applicable rules of the Ministry of Electronics and Information Technology (MeitY)
1. Data We Collect
We collect only the personal data necessary to deliver our services:
- Identity data — name, email, mobile, employee/staff ID, designation.
- Employment data — organization, department, role, joining date.
- Learning data — course enrolments, progress, exam scores, certificates.
- Payment data — billing name, GSTIN (where applicable), payment status. Card / UPI details are processed by our payment partner (Razorpay) and never stored on our servers.
- Technical data — IP address, browser fingerprint, device type, session timestamps, audit trail entries.
2. Purpose & Lawful Basis
We process your data on the following lawful grounds under Section 6 of the DPDPA:
- Delivery of the Platform services you signed up for (contract);
- Compliance with statutory obligations (accreditation reports, tax invoices);
- Legitimate interests (fraud prevention, security);
- Your verifiable consent for optional communications and marketing.
3. Data Sharing
We share personal data only with:
- Your employer / institution (they are the Data Fiduciary for staff data);
- Payment processors, email/SMS providers, cloud hosting vendors (bound by contractual data-protection obligations);
- Regulatory / accreditation bodies (NABH, JCI, NABL) upon written request from your organization;
- Law-enforcement authorities pursuant to a lawful order.
We do not sell personal data to any third party.
4. Data Storage & Security
- Data is stored on servers located in India.
- We use TLS 1.2+ encryption in transit and encryption-at-rest for sensitive fields (passwords are bcrypt-hashed).
- Role-based access control, audit logs, brute-force lockouts and periodic penetration testing are in place.
5. Retention
- Active-account data is retained for the duration of your enrolment.
- Certificate records are retained for 7 years (statutory audit trail).
- Marketing consents are retained until withdrawn.
- After the retention period, data is anonymised or securely deleted.
6. Your Rights (DPDPA §11-15)
You have the right to:
- Access the personal data we hold about you;
- Correct inaccurate or incomplete data;
- Erase data where no lawful ground for retention exists;
- Grievance redressal — see Section 9 below;
- Nominate another individual to exercise your rights in case of death or incapacity;
- Withdraw consent at any time (without prejudice to prior processing).
To exercise any right, write to admin@stewardindia.com from your registered email. We will respond within 30 days as required by law.
7. Cookies
Please refer to our separate Cookies Policy.
8. Children
The Platform is intended for adult healthcare professionals and students aged 18 and above. We do not knowingly collect personal data of children. If parental consent is required (educational programmes), we obtain it in compliance with DPDPA §9.
9. Grievance Officer
Under Rule 5(9) of the IT Rules, our Grievance Officer is:
- Name: Data Protection Officer
- Email: admin@stewardindia.com
- Address: 2nd Floor, SCO 23, Hi Street, Eldeco Estate One, Panipat-132103, Haryana, India
- Phone: +91 96162-98162
Complaints are acknowledged within 24 hours and resolved within 15 days.
10. Changes to this Policy
We may update this Privacy Policy from time to time. Material changes will be notified via email to the address on file. The "Last Updated" date at the top of this page reflects the most recent revision.
11. Governing Law
This Policy is governed by the laws of India. Disputes are subject to the exclusive jurisdiction of the courts at Panipat, Haryana.
