Privacy Policy

Effective 12 October 2026. Version 3.0.

1. Introduction

This Privacy Policy governs the MediMan Patient Application and the MediMan Doctor Application (together, the “Services”), available on the Web, the Google Play Store and the Apple App Store. We build MediMan with privacy-by-design and security-by-default principles, so that patients and doctors can use telehealth and personal health tools with confidence.

In short: you decide what health information you add, adding it is always optional, and we never sell your data or use it for advertising. The rest of this Policy explains the details.

2. Our Platform Role (Intermediary)

MediMan is an intermediary technology platform that connects patients with independent doctors through our app. We do not practice medicine or make clinical decisions. Doctors provide care directly and may manage clinic bookings within the MediMan Doctor Application. Clinical responsibilities and decisions rest with the doctor and patient.

The personal health tools in the Patient Application (such as My Vitals, BMI, the Period Tracker, Medicine Reminders, the Health Check-in and the Child Health tracker) help you keep track of your own health. They do not diagnose any condition, they are not a medical device, and they do not replace advice from a doctor. Reading ranges follow published health guidelines and are shown for general information only. MediMan is not an emergency service. In an emergency, please contact your local emergency number or your nearest hospital, clinic or doctor.

3. Data Controller, Representative & Contacts

Controller: Mediman Life (PVT) Ltd., #95 KKS Road, Jaffna, Sri Lanka. (Company Registration PV 00319083)
Data Protection Officer (DPO) & EU/UK Representative: itsupport@mediman.life – +94 70 167 7488
Support & Data Requests: itsupport@mediman.life

Last Updated: October 13, 2026 | Effective Date: October 13, 2026 | Version: 3.1

4. Scope & Audience

This Policy covers how we handle data across our Services, including identity and account management, appointment scheduling, secure video consultations, notifications, file uploads, payments, analytics and general platform operations on both apps. It also covers the personal health tools in the Patient Application: the Health Passport, Medicine Reminders, My Vitals, BMI, blood group, the Period Tracker, the Emergency Profile, the Blood Donor profile, the Daily Health Dashboard, the Health Check-in, the Health Timeline, Family Health and the Child Health & Vaccination tracker.

It applies to patients using the MediMan Patient Application and to authorized doctors and licensed healthcare professionals using the MediMan Doctor Application.

5. Information We Collect

We collect the following types of information to provide and improve our Services:

Patient Identity: Personal details such as name, date of birth, gender, nationality, email, phone number and profile photo.
Health Data from Care: Medical history and conditions, diagnoses, treatment plans, prescriptions, allergies, lab results, imaging, vaccination records, consultation notes and clinical observations created through consultations. (Any mental health data is processed only with explicit consent and with heightened safeguards.)
Health Tracking Data (optional, entered by you): Information you choose to add in the health tools, such as vital signs (blood pressure, blood sugar, heart rate, oxygen level, temperature and weight), height, BMI and blood group; medicines, doses and reminder times; period and menstrual cycle details, symptoms and reminder choices; the details in your Emergency Profile (such as allergies, conditions, current medicines and an emergency contact you choose to add); your blood donor status, last donation date and district; your answers in the Health Check-in; and health documents you upload to the Health Passport.
Family Members’ Information (optional, entered by you): If you add family members, we store the details you provide about them, such as name, relationship, date of birth and gender, and the health information you choose to keep for them, including a child’s growth measurements, developmental milestones and vaccination records.
Content You Create: Ratings and reviews of doctors, notes you add, and the reason you give when you book a consultation.
Doctor Profile: Professional information for doctors, including name, title, specialties, license numbers and verification documents, education and certifications, professional affiliations, tax identifiers (if required), payout/banking details, clinic locations and schedules, and consultation fees.
Operational & Device Data: Technical information such as device model, operating system, app version, IP address, the country or region inferred from your IP address, push notification tokens, session and authentication metadata, crash reports and performance diagnostics, and app usage information (see Section 19).
Financial & Billing: Payment references and transaction details, wallet credits and refunds, and records of payouts to providers. We do not store raw payment card numbers. Card details are entered in and processed by our payment gateway (see Section 13).

What we do not collect: The Patient Application does not collect your device location, contacts, call logs, browsing history or the advertising identifier, and it does not read your text messages or your calendar. It does not connect to Apple HealthKit, Google Health Connect or health devices.

6. Your Choice: Health Information Is Optional

We collect health tracking information only when you choose to give it to us, and only to provide the feature you are using.

Every health tool is optional. You can use MediMan for consultations without ever using the health tools, and you can skip any field you do not want to fill in.
You decide what to add. If you do not want to record something, simply leave it out. Features that need a detail (for example, a medicine reminder needs a medicine and a time) only ask for it when you choose to use that feature.
You stay in control. You can edit or delete any reading, medicine, period entry, document, family member or child record at any time, and you can turn reminders off.
Period data is private. The Period Tracker is available only to the account holder, is never included in a family member’s profile, and is not shared with anyone unless you choose to share it. Discreet reminders that do not mention a period are available.
Sharing is your decision. Health cards (for example a vitals, blood donor or vaccination card) are created on your phone and shared only when you choose to share them through your phone’s share options. You see the exact picture before you share it.
Information about family members: when you add a family member or child, please make sure you have their permission or the authority to do so as their parent or guardian.

7. We Do Not Sell Your Data or Use It for Advertising

We do not sell, rent or trade your personal data or health data to anyone.
We do not use your personal data or health data for advertising, and we do not show advertisements in our apps.
We do not use the advertising identifier on Android or iOS, and we do not track you across other companies’ apps or websites.
We do not share your data with data brokers, advertisers or insurers, and we do not use your health data for marketing or profiling.
We share data only with the doctors you choose to consult and with the service providers listed in Section 13, who work for us under contract and may use it only to provide their service to MediMan.

8. Controller / Processor Roles

Our role under data protection law can vary depending on the data and context:

MediMan as a Data Processor: When you engage in a consultation, the clinical data generated (medical records, consultation notes, prescriptions, etc.) is processed by MediMan on behalf of the treating doctor. The doctor is responsible for that clinical data, and we act only as a processor handling it per the doctor’s instructions (aside from necessary security and compliance logging).
MediMan as a Data Controller: MediMan is the controller for the other data needed to run the platform, such as account information, appointment details (metadata like dates and doctor IDs), payment facilitation records, security and fraud logs, analytics, and the health tracking information you add in the health tools.
Doctors as Independent Controllers: Each doctor using our platform remains an independent controller for the clinical information they generate or use within the app. Doctors retain responsibility for maintaining their own clinical records, notes and prescriptions, and for complying with any regulatory requirements related to their practice.

9. Android Permissions

We request only the permissions our features need. You can manage these permissions in your device settings at any time (turning some off may stop the related feature from working). The MediMan Patient Application uses:

Core connectivity & stability: INTERNET, ACCESS_NETWORK_STATE, ACCESS_WIFI_STATE, WAKE_LOCK, FOREGROUND_SERVICE – Needed to connect to our servers, check network status and keep a consultation running.
Telehealth media: CAMERA, RECORD_AUDIO, MODIFY_AUDIO_SETTINGS – Needed for video and audio consultations, and the camera lets you photograph a document to upload.
Notifications: POST_NOTIFICATIONS, VIBRATE – Needed for appointment updates, reminders and alerts.
Medicine reminders: SCHEDULE_EXACT_ALARM, RECEIVE_BOOT_COMPLETED, USE_FULL_SCREEN_INTENT – Needed to ring medicine reminders on time, set them again after your phone restarts, and show a reminder or an incoming consultation call over the lock screen.

To upload photos and documents, the Patient Application uses Android’s photo picker and file picker, so it does not need access to all your photos or files. When you log in, the app can fill in the one-time code from our SMS only after Android asks for your permission to share that one message; the app cannot read your other messages. The Patient Application does not request location, contacts, SMS, call log, phone state, calendar, Bluetooth or battery optimization permissions. Screens that show health information are protected from screenshots and screen recording.

The MediMan Doctor Application additionally uses location (ACCESS_COARSE_LOCATION, ACCESS_FINE_LOCATION) only while the app is in use, so a doctor can set a clinic’s location on a map, and READ_PHONE_STATE to pause a consultation when a phone call comes in. It does not use background location.

If we ever need a new permission, we will update this Policy before we use it.

10. iOS Privacy

Our iOS apps request permissions through the standard iOS prompts, each with a short explanation of why it is needed. You can allow or deny each one, and change your choice later in iOS Settings. The MediMan Patient Application uses:

Camera (NSCameraUsageDescription): For video consultations and to photograph a document to upload.
Microphone (NSMicrophoneUsageDescription): For audio during consultations.
Photos (NSPhotoLibraryUsageDescription and NSPhotoLibraryAddUsageDescription): To choose medical images to upload, and to save a health card to your photos when you choose Save Image.
Alarms (NSAlarmKitUsageDescription, iOS 26 and later): So medicine reminders can ring like an alarm, even in Silent mode or Focus.
Calendar (NSCalendarsUsageDescription): To add an appointment to your calendar when you choose to. MediMan does not read your other calendar events.
Notifications: For appointment updates, reminders and alerts.

The Patient Application does not request location access on iOS. App screens are hidden while the screen is being recorded and in the app switcher. The MediMan Doctor Application additionally asks for location while the app is in use, to set a clinic’s location on a map.

11. Lawful Bases for Processing

Depending on the situation, we rely on different legal grounds to process personal data under applicable data protection laws, including Sri Lanka’s Personal Data Protection Act No. 9 of 2022 and, where they apply, the EU/UK GDPR and similar laws:

Consent: Health information is sensitive data. We process the health tracking information you add (including period and reproductive health details, and the health records you keep for family members and children as their parent or guardian) on the basis of your explicit consent, which you give by choosing to enter it. You can withdraw your consent at any time by deleting that information or deleting your account. We also rely on consent where the law requires it for telehealth, and before sharing information with third parties for care coordination beyond our platform.
Contract: Much of our processing is necessary to provide the Services you ask for: consulting with doctors, managing your account, scheduling appointments, processing payments, delivering reminders you set and enabling secure communication with your healthcare provider.
Legal Obligation: We may need to process data to comply with the law. For example, healthcare regulations may require us (or your doctor) to keep medical records for a certain period, financial laws require us to keep payment records, and we must respond to valid and binding requests from authorities.
Vital Interests: In rare cases we might process personal data to protect someone’s life, for instance by sharing relevant information with emergency responders when a person cannot give consent, to the extent allowed by law.
Legitimate Interests: We process limited data to keep the Services secure, prevent fraud and abuse, fix problems and improve the app, in a way that does not override your rights. We never rely on legitimate interests to use health data for advertising or marketing.

12. How We Use Data

We use the information we collect only to provide, maintain and improve our Services, and to keep them safe and compliant:

Care Delivery: To schedule appointments and send reminders, connect doctors and patients through secure video and audio consultations, maintain the record of consultations (notes, prescriptions, treatment plans), issue e-prescriptions, and provide referral letters or medical certificates when needed.
Health Tools: To show your readings, trends and BMI, your Daily Health Dashboard and Health Timeline; to plan your medicine, period and vaccine reminders (these reminders are scheduled on your phone, and we keep your medicines and settings so they stay the same on any phone you use); to show your Emergency Profile; to suggest the kind of doctor that may help with a concern you describe in the Health Check-in (it does not diagnose, and danger signs show your local emergency number); to show your child’s vaccination schedule, growth and milestones; and to let you share a health card when you choose.
Blood Donation: If you register as a blood donor, we use your blood group, availability, last donation date and district to show when you can donate next, and to notify you of urgent blood requests in your district. We do not share your donor details with the person who needs blood; you decide whether to respond.
Operations: To verify doctors’ identities and credentials, manage accounts and login sessions, prevent unauthorized access, process payments and refunds, and provide customer support.
Quality & Improvement: To find and fix crashes and problems, measure app performance, and improve the design and usability of the app (see Section 19). Where we analyse data beyond fixing problems, we use aggregated or anonymized data that does not identify you.
Communications: To send you service messages by SMS, email or push notification, such as login codes, booking confirmations, appointment and health reminders you have set, important service updates and changes to our terms or this Policy. We do not send advertising.

13. Data Sharing & Processors (Named Only)

We share data only when it is needed to deliver our Services. We never sell it. The recipients are:

Doctors you consult: your profile details, booking details, the reason for your consultation, and any records or documents you choose to share with that doctor.
Our service providers, who process data on our behalf under contract and only for the service they provide to us:
Amazon Web Services (AWS): hosting of our servers and encrypted storage of files and backups.
MongoDB Atlas: our managed, encrypted database.
Cloudflare: protects and speeds up the connection between the apps and our servers.
Google Firebase: delivery of push notifications (Firebase Cloud Messaging, together with Apple’s push service on iPhone), app usage analytics (Google Analytics for Firebase) and crash reporting (Firebase Crashlytics).
Microsoft Clarity: app usage analytics, including recordings of how app screens are used (see Section 19).
Twilio: sends the one-time login codes to your phone by SMS.
ZEGOCLOUD: real-time video and audio for consultations. Calls are encrypted in transit and are not recorded by MediMan.
Payment gateways (PayHere, and our bank’s card payment gateway where used): process card payments. Card details go directly to the gateway, which is PCI-DSS compliant; we keep only payment references.
Our email delivery provider: sends transactional emails such as booking confirmations. These emails do not include health details.
Google Maps Platform (Doctor Application only): shows maps and turns a chosen point into a clinic address.

We may also disclose information when the law requires it, or to protect the safety of a person in an emergency, as described in Section 11. If we add a new service provider or change how data is shared in a significant way, we will update this Policy and, where required, ask for your consent first.

14. International Data Transfers

MediMan is based in Sri Lanka and serves patients and doctors in many countries. Our main servers run on Amazon Web Services in the United States, and some of the service providers listed in Section 13 process data in other countries. When personal data is transferred across borders, we protect it:

We use recognized legal safeguards for the transfer, such as Standard Contractual Clauses or similar contractual frameworks, as required by the law that applies to you, including Sri Lanka’s Personal Data Protection Act.
We assess the risks of each transfer and apply technical and organizational measures, such as encryption and access controls, to protect the data.
Wherever your data is processed, we handle it in line with this Privacy Policy and applicable law.

15. Security Posture

We protect your personal data with strong security practices:

Encryption: All data between the apps and our servers is encrypted using HTTPS/TLS. Files and database records stored with our providers are encrypted at rest, and login sessions use secure, expiring tokens.
Access Controls: Access to personal data is limited to people who need it for their work, with role-based permissions. Administrative access requires strong authentication and is logged.
App Protections: Screens that show health information are protected from screenshots and screen recording, content is hidden in the app switcher, and reminders can be set to discreet wording.
Secure Development: We follow secure coding practices, review code for security and privacy, keep dependencies up to date, and keep secrets such as API keys out of the apps.
Monitoring & Response: We monitor our systems for unusual activity and keep an incident response plan. If a data breach occurs, we will investigate, contain it and notify affected people and regulators as the law requires.
Resilience: We keep encrypted backups and plans to restore the Services and data after an outage.
Organizational Measures: Our staff are trained in privacy and security, and people with access to personal data are bound by confidentiality obligations.

Please help us keep your account safe: never share your login code with anyone, and tell us at once if you suspect unauthorized access to your account.

16. Data Retention

We keep personal data only as long as it is needed for the purposes in this Policy, or as long as the law requires:

Health tracking data: Kept while your account is active, until you delete the entry, remove the family member it belongs to, or delete your account.
Medical records: Records created through consultations (consultation notes, prescriptions, etc.) are generally kept for 7 to 10 years, depending on local healthcare regulations, for continuity of care and legal compliance.
Booking records: Information about appointments (such as appointment dates and times, the doctor you saw, the type of visit and payment references) is kept permanently to meet medical audit and healthcare regulatory requirements.
Account profile data: Kept for the lifetime of your account. If you delete your account, we remove or anonymize your profile data, but we may keep limited information for up to 3 years where the law requires it or to protect our legal rights.
Communications logs: Support tickets and technical logs of notifications sent are kept for up to 2 years.
Payments and payout records: Kept for about 7 years, as accounting and tax laws require.
Analytics data: Usage and performance data are kept for up to 14 months, and screen recordings are kept for a limited period set by Microsoft Clarity. Where possible we aggregate or anonymize this data.

When data is no longer needed, we delete or anonymize it securely. We may keep certain information longer if the law requires it (for example, under a legal hold or court order).

17. Account Deletion & Data Rights

You can delete your account and data, and you have other rights over how your data is used:

Account Deletion: You can delete your MediMan account in the app (Delete Account in your profile) or on our website: https://mediman.life/delete-account/. We confirm your identity first, to protect you, and ask you to acknowledge what deletion means. Once confirmed, we delete your data from our active systems, including the health tracking information and the family members you added. Backup copies are removed in our normal backup cycle, except for information we must keep by law (as described below).

Deletion Acknowledgment (shown during account deletion): “Important: In accordance with healthcare regulations and legal requirements, we will retain your booking records (appointment dates, doctor information, visit types, and payment references) for medical audit and legal compliance purposes. All other personal profile data and system data will be permanently deleted or anonymized. I understand the data retention policy stated above and confirm my request to permanently delete my MediMan account. I acknowledge that this action cannot be undone and that booking records will be retained as described for legal compliance.”

This acknowledgment makes sure you know that while most of your data is deleted, certain minimal information must be kept for regulatory reasons.

Your Data Protection Rights: Depending on the laws that apply to you (for example, Sri Lanka’s Personal Data Protection Act, the GDPR in the EU/UK, or the CCPA in California), you may have some or all of the following rights:

Right of Access: Request a copy of the personal data we hold about you and how we process it.
Right of Rectification: Ask us to correct information that is wrong or incomplete. You can also edit most of your information directly in the app.
Right to Erasure: Ask us to delete your personal data. We delete the data we are not legally required to keep.
Right to Data Portability: Request your personal data in a structured, commonly used and machine-readable format.
Right to Restrict Processing: Ask us to limit how we use your data in certain circumstances, for example while we review a question about its accuracy.
Right to Object: Object to processing based on our legitimate interests.
Right to Withdraw Consent: Withdraw your consent at any time, for example by deleting the health information you added. This does not affect processing that happened before you withdrew it.

California Residents (CCPA/CPRA): If you are a California resident, you have the right to know what personal information is collected, used and disclosed, and to access it; to delete it (with certain exceptions, such as information needed to complete a transaction or for legal compliance); to correct inaccurate information; to opt out of the sale or sharing of personal information (MediMan does not sell personal information and does not share it for cross-context behavioral advertising); and not to be treated differently for exercising these rights.

To exercise any of your rights, contact us at itsupport@mediman.life. We may need to verify your identity (and your authority, if you ask on behalf of someone else) first. We aim to respond within the time the law requires, generally within 30 days. There is no fee, unless a request is clearly unfounded or excessive.

18. Children’s Privacy

Protecting children’s privacy is extremely important to us. The MediMan Patient Application is for adults. Children under 18 (or the minimum age of digital consent in your region) may not create their own account.

A parent or legal guardian may add a child as a family member in their own account, to book consultations for the child and to keep the child’s health records, such as growth measurements, developmental milestones and vaccination records. The child does not use the app. These records are entered by the parent or guardian, are treated as health data with heightened safeguards, and can be edited or deleted by the parent or guardian at any time. We never use children’s data for marketing.

The MediMan Doctor Application is only for licensed medical professionals aged 24 or older; we do not allow minors to register as doctors on our platform.

If we learn that we have collected personal data from a child without the required consent, we will delete it. Parents or guardians who believe we hold such information can contact us to have it deleted.

19. Cookies, SDKs & Tracking

Our Services use a small set of technologies to run the apps and improve them:

Session tokens: keep you logged in securely.
Data on your phone: the app keeps some information on your phone so screens open quickly and reminders ring even without internet, such as your reminder schedule and recently viewed health information. Uninstalling the app removes it.
Google Analytics for Firebase: counts which screens and features are used, so we know what to improve. It does not use the advertising identifier.
Firebase Crashlytics: sends crash and error reports with technical details (such as device model and error logs) so we can fix problems quickly.
Microsoft Clarity: records how app screens are used (for example taps, scrolls and the screens you visit) to help us find and fix usability problems. These recordings can include what is shown on your screen, including health information you have entered. They are linked to your account ID, viewed only by our team to improve the app, never used for advertising, and kept for a limited period set by Microsoft.
Website (mediman.life): before you choose, the site stores only your cookie choice. If you select Accept all, or turn on Analytics in Cookie settings, we load Google Tag Manager, which runs Google Analytics (cookies _ga and _ga_<id>) to count visits and pages, and Microsoft Clarity (cookies _clck and _clsk) to see how pages are used. If you select Reject all, none of these load. You can change your choice at any time with Cookie settings at the bottom of every page; turning analytics off removes these cookies. Third-party services embedded in our website (such as a payment gateway) may set their own cookies, governed by their own policies.

We do not use any tracking for advertising, we do not use the advertising identifier, and we do not allow third-party advertisers to track you through our Services. To ask questions about analytics or to object to it, contact us at itsupport@mediman.life. You can change your website choice with Cookie settings, and control cookies through your browser settings.

20. Platform & App Store Compliance

We follow the privacy rules of the app stores we publish on:

Google Play (Android): We keep our Data safety section and Health apps declaration accurate and up to date, and we follow Google Play’s Developer Policies, including the User Data, Permissions and Health policies.
Apple App Store (iOS): Our App Privacy details describe what data is collected and why. We do not track users across other companies’ apps or websites, so no App Tracking Transparency prompt is needed. Health information is never used for advertising, marketing or data mining, in line with App Store Review Guideline 5.1.3.
We do not integrate with Apple HealthKit, CareKit or Google Health Connect. If we ever do, we will ask for your explicit permission first and follow the platform rules for that data.

We keep these disclosures up to date as our apps change.

21. Third-Party Links

The MediMan platform and communications may occasionally contain links to external websites or services that we do not operate. For example, a doctor might share a link to an external resource, or our website might link to a medical article or a regulatory authority’s site for information. Once you leave our platform, this Privacy Policy no longer applies.

Information you give to third-party sites is governed by their own privacy policies. Please read them before providing your personal data. MediMan is not responsible for the content, privacy practices or handling of information by third parties that are not under our control.

22. Accessibility

We want this Privacy Policy to be accessible and understandable to all users:

We can provide this Privacy Policy in other languages on request, including Tamil and Sinhala.
If you need it in an alternative format (such as large print or audio), please contact us at itsupport@mediman.life and we will do our best to help.
We write in plain language, and we may publish short summaries when we make significant updates.

If anything in this Policy is unclear, please contact us with your questions.

23. Changes to This Policy

We may update this Privacy Policy to reflect changes in our practices, technologies, legal requirements or other factors. When we do, we change the “Last Updated” date at the top of this Policy.

If there are material changes (for example, new types of data or new uses), we will give you prominent notice, such as a notification in the MediMan apps, an email, a notice on our website, or a note in the app store release notes. Where the law requires it, we will ask for your consent.

Please review this Privacy Policy from time to time. If you do not agree with a change, you can stop using the Services and delete your account as described in Section 17.

24. Dispute Resolution & Regulatory Recourse

If you have questions, concerns or complaints about how we handle your personal data, we are here to help:

Contact Us First: Please contact our Data Protection Officer or support team at itsupport@mediman.life so we can address your concern directly. We aim to respond within 30 days or sooner, in line with applicable law.
Data Protection Authorities: You have the right to complain to a data protection authority, such as the Data Protection Authority of Sri Lanka, the Information Commissioner’s Office in the UK, or the data protection authority in the country where you live or work. We will cooperate with any official inquiry.
Legal Dispute Resolution: Disputes that cannot be resolved amicably may be subject to the dispute resolution procedures in our Terms of Service, to the extent they are enforceable and do not limit rights the law gives you.

Your trust is of utmost importance to us. We will do our best to resolve any privacy concern fairly and transparently.

25. Technology & Hosting Statement

Our servers run on Amazon Web Services (AWS), our database runs on MongoDB Atlas, and Cloudflare protects the connection between the apps and our servers. Files and backups are stored in Amazon S3. All of them are leading providers with strong security certifications and compliance with international standards.

Data stored with these providers is encrypted at rest, and all connections are encrypted in transit. We monitor our cloud environment and apply security updates promptly, following cloud security best practices.

If you have specific questions about our technology or hosting, please contact us at itsupport@mediman.life.

Acknowledgment

By using the MediMan Services, the Patient Application or the MediMan Doctor Application, you confirm that you have read and understood this Privacy Policy. If you do not agree with any part of this Policy, please do not use our Services, or contact us to discuss your concerns.