Account Deletion and Data Retention Policy

Effective Date: March 15, 2026
Version: 1.0
Entity: DOCWO SERVICES PRIVATE LIMITED
Registered Office: Building No. 5/257A8, Suite No. 162 B, Heiley Offices, Basement Floor, Pallath Square, Kalamassery, Ernakulam, Kanayannur, Kerala, India, 683104
Contact: privacy@docwo.com | support@docwo.com

1. Purpose and Philosophy

At Docwo, we believe you should have complete autonomy and control over your personal data. This Account Deletion and Data Retention Policy ("Policy") forms an integral part of our Terms and Conditions of Service and Privacy Policy, and delineates:

The exact technical and procedural steps to request the permanent deletion of your Docwo account;
What data is destroyed immediately, what occurs during the 30-day recovery grace period, and what data is permanently wiped;
The essential legal carve-outs where statutory healthcare regulations (National Medical Commission rules, Indian Medical Council regulations) and financial laws (Income Tax Act, GST Act) legally compel the preservation of clinical and transaction records.

2. End-to-End Deletion Lifecycle

The account deletion process follows a structured, secure lifecycle:

You request deletion via your Profile Settings or by contacting our Privacy Office.
We verify your identity by sending a high-security OTP to your registered phone number.
Immediate deactivation — your account is soft-deleted, all sessions are terminated, and your profile is hidden.
30-day grace period — your account remains recoverable in case of accidental deletion or pending disputes.
Permanent hard deletion — after 30 days, an automated process permanently destroys all recoverable account data.
Statutory archive — encrypted clinical and financial records are transferred to restricted cold storage for the legally mandated retention period.

3. Step-by-Step Deletion Process

Step 1: User Request and High-Security OTP Verification

To protect your account from malicious, unauthorized, or accidental deletion, deletion cannot be executed with a single click.

Navigate to Account Settings > Security & Privacy > Delete Account within the Docwo mobile app or web portal.
The system dispatches a high-security One-Time Password (OTP) to your registered, verified mobile phone number.
You must review the statutory data retention warnings and enter the correct OTP to authenticate your intention.

Step 2: Immediate Effects upon Verification (Deactivation Phase)

Upon successful verification of the OTP:

Instant Revocation of Access: All active web sessions, refresh tokens, and mobile access tokens are immediately invalidated. You are logged out across all devices.
Push Notification Suppression: All push notification device tokens associated with your user ID are immediately deleted.
Marketing Halt: Your communication preferences are wiped. Contact details are moved to internal suppression lists to ensure you never receive promotional emails, SMS, or campaign messages again.
Media Destruction: Your profile photos, avatar images, and associated uploaded thumbnails are permanently and irrevocably deleted from our cloud object storage.
Profile Anonymization: Patient profiles associated solely with your account that have no active clinical engagements are immediately stripped of personal identifiers (names, emails, and phone numbers are overwritten with cryptographic hashes).

Step 3: The 30-Day Recovery & Dispute Grace Period

Following deactivation, your account enters a mandatory 30-day soft-delete grace period:

Accidental Deletion Recovery: If you initiated the deletion by error or experienced account hijacking, you may contact Docwo Support (support@docwo.com) within thirty (30) days from your registered email address with identity verification to restore your account.
Pending Dispute Resolution: The 30-day buffer permits the settlement of pending financial transactions, open refund reconciliations, or ongoing clinic dispute investigations.
During this period, your profile is hidden from all public searches, doctor directories, and clinic booking flows.

Step 4: Automated Permanent Hard Deletion

Upon the expiration of the 30-day grace period, an automated scheduled background task executes permanent deletion:

Your user credentials, hashed passwords, session logs, clinic staff assignments, export logs, and marketing audience entries are permanently purged from the active database.
All cached data and in-memory entries are completely deleted.
After this point, your account is permanently destroyed and cannot be restored under any circumstances.

4. Statutory Exceptions: Why Certain Records Must Be Retained

Reconciliation of Right to Erasure with Statutory Legal Obligations

Both Section 12 of the Digital Personal Data Protection Act, 2023 (DPDPA) and Article 17(3)(b) of the General Data Protection Regulation (GDPR) recognize that the Right to Erasure is not absolute. It does not apply where data retention is mandatory under statutory law or necessary for the establishment, exercise, or defence of legal claims.

As a healthcare technology platform operating in India, Docwo and its participating medical practitioners are legally compelled to preserve specific records under the following statutes:

4.1 Medical Records, Prescriptions, and Consultation Notes (10-Year Retention)

Statutory Mandate: Regulation 1.3 of the Indian Medical Council (Professional Conduct, Etiquette and Ethics) Regulations, 2002 mandates that medical practitioners and healthcare institutions must maintain clinical records for a minimum period of three (3) years from the date of commencement of treatment.
Legal Defense & Limitation Period: Under the Limitation Act, 1963, claims for medical negligence, consumer disputes, or latent bodily injury may be filed within extended timeframes from when an injury is discovered. Destroying medical notes or e-prescriptions deprives doctors and clinics of their constitutional right to defend against clinical malpractice allegations.
Docwo Policy: In-clinic consultation histories, symptoms, clinical notes, and digital e-prescriptions are retained for a total period of ten (10) years from the date of the clinical encounter. These records are completely decoupled from active user profiles, encrypted with AES-256-GCM, and stored in an immutable, restricted-access cold archive accessible only under lawful court subpoenas, statutory medical council inquiries, or for clinical defense.

4.2 Financial, Billing, and Tax Invoices (7-Year Retention)

Statutory Mandate: Section 44AA of the Income Tax Act, 1961, Rule 6F of the Income Tax Rules, 1962, and Section 36 of the Central Goods and Services Tax (CGST) Act, 2017 mandate that all invoices, payment vouchers, credit notes, and books of account must be retained for at least six (6) to seven (7) years.
Docwo Policy: All clinic invoices, payment receipts, platform fee itemizations, and transaction logs are archived for seven (7) years following the close of the financial year to satisfy statutory tax and financial audits.

4.3 Security & Deletion Compliance Proof Logs (7-Year Retention)

Pursuant to Rule 3(1)(h) of the IT Intermediary Rules, 2021 and Section 8 of DPDPA 2023, Docwo preserves an immutable, encrypted audit log recording the fact, timestamp, and technical fulfillment of your deletion request as evidentiary proof of regulatory compliance.

5. Summary of Data Retention and Deletion Timelines

Category of Data	Retention Period	Post-Retention Action	Statutory Basis
Account Credentials & Profiles	30 Days (Grace Period)	Permanent cryptographic destruction	DPDPA 2023 §12 / GDPR Art 17
Avatar & Profile Media	Immediate (0 Days)	Permanently deleted from cloud storage	Right to Erasure
Active Push & Device Tokens	Immediate (0 Days)	Hard deleted from active DB	Right to Erasure
Marketing Preferences	Immediate (0 Days)	Cleared; hashes added to suppression	DPDPA 2023 §6 / TRAI DLT
Temporary Session & Exports	7 Days	Automated daily purge	Purpose Limitation
Invoices & Payment Records	7 Years	Secure electronic shredding	Income Tax Act / CGST Act
Medical Notes & E-Prescriptions	10 Years	Encrypted cold archive disposal	IMC Regulations 2002 / NMC TPG
Deletion Audit Certificate	7 Years	Automated purge	IT Rules 2021 / DPDPA §8

6. How to Request Account Deletion

You may initiate account deletion through any of the following channels:

Self-Service In-App: Go to Settings > Privacy & Security > Delete Account and complete the mobile OTP authentication.
Email Request to Privacy Office: If you cannot access your mobile device, transmit a formal deletion request from your registered email address to privacy@docwo.com or support@docwo.com. Our compliance team will verify your identity via secondary verification procedures and execute the deletion within forty-eight (48) hours of successful verification.

For inquiries regarding our retention schedules or archival practices, contact:

Grievance Redressal & Privacy Officer: DOCWO SERVICES PRIVATE LIMITED
Address: Building No. 5/257A8, Suite No. 162 B, Heiley Offices, Basement Floor, Pallath Square, Kalamassery, Ernakulam, Kerala, India, 683104
Email: grievance@docwo.com | Phone: +91 99614 53665