“user” means an individual who (a) has contacted us through any means (such as through any of the Platforms) in relation to the goods or services available on the Platforms, or (b) may, or has, entered into a contract with us for the supply of any goods or services by us; and
“personal data” means data, whether true or not, about a user who can be identified: (a) from that data; or (b) from that data and other information to which we have or are likely to have access.
- Depending on the nature of your interaction, some examples of personal data which we may collect from you include:
- Your name, identification numbers like Passport Number, NRIC, FIN, home address, email address, telephone number, nationality, gender and date of birth;
- Personally-identifiable medical and health-related information which you provide to us during tele-medicine (which information or records relating to your medical or health history, health status, laboratory testing results, diagnostic images);
- Billing information that you provide us (e.g. credit card or online payment system account information);
- Information about the computer or mobile device you are using;
- Geo location or address; or
- Other information which you may input into the MyCLNQ platform or related services.
- We may collect and use your personal data for any or all of the following purposes:
- performing obligations in the course of or in connection with our provision of the goods and/or services requested by you (including the provision of any medical or healthcare services, the delivery of products purchased by you);
- verifying your identity;
- responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
- managing your relationship with us;
- processing or facilitating the processing of your claims;
- processing payment or credit transactions;
- improving the quality of medical or healthcare services through the performance of quality reviews and similar activities;
- creating de-identified information which is information which is not used or intended to be used to personally identify an individual (e.g. aggregate statistics relating to the use of the services on the Platforms);
- marketing and promoting the Platforms, and the services and products offered on the Platforms to you;
- complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;
- converting the personal data to anonymised data for the purposes of analytics and market research;
- any other purposes for which you have provided the information;
- transmitting to any unaffiliated third parties including our third party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes; and
- any other incidental business purposes related to or in connection with the above.
- As you use the Platforms, services, or purchase or arrange for the delivery of products, certain information may be passively collected:
- Access Device and Browser Information: When you access the Website from a computer or other device, we may collect anonymous information from that device, such as your Internet protocol address, browser type, connection speed and access times;
- Cookies (i.e. small pieces of information that a site sends to your browser while you are viewing a website): We may use both session Cookies (which expire once you close your web browser) and persistent Cookies to make the Platforms and services easier to use, to make our advertising better, and to protect both you and Ssivix Lab. You can instruct your browser, by changing its options, to stop accepting Cookies or to prompt you before accepting a Cookie from the websites you visit. If you do not accept Cookies, however, you will not be able to stay logged in to the Platforms. We presently do not honour “Do Not Track” requests across all parts of our Platforms.
- Real-Time Location: Certain features of the Platforms use GPS technology to collect real-time information about the location of your device so that the Platforms can connect you to a healthcare professional/treatment provider near your location.
- Device information: We may also collect non-personal information from your mobile device or computer. This information is generally used to help us deliver the most relevant information to you. Examples of information that may be collected and used include how you use the application(s) and information about the type of device or computer you use. In addition, in the event our application(s) crashes on your mobile device we will receive information about your mobile device model software version and device carrier, which allows us to identify and fix bugs and otherwise improve the performance of our application(s).
- We may disclose your personal data where such disclosure is required for performing obligations in the course of or in connection with our provision of the goods and services requested by you:
- To our subsidiaries, related companies, affiliates, or partners;
- To the relevant parties who may process your claims for your medical care. For the avoidance of doubt, we will not disclose any confidential medical diagnoses to such parties unless your consent is provided to us separately in writing;
- To our contractors, service providers and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them (including logistics service providers, data service providers);
- As required by law, which can include providing information as required by a court order;
- When we believe in good faith that disclosure is necessary to protect your safety or the safety of others, to protect our rights, to investigate fraud, or to respond to a government request;
- To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all Ssivix Lab assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal data maintained on the Platforms is among the assets transferred;
- The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to your employment contract should you be hired) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under a contract with you).
- The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop collecting, using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.
- Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within fifteen (15) business days of receiving it.
- Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our goods or services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in clause 11 above.
- Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.
- If you wish to make (a) an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, or (b) a correction request to correct or update any of your personal data which we hold about you, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below. Such request shall include the details of the requestor, description of the personal data being requested, and the date and time range the personal data was believed to be collected.
- Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.
- We will respond to your request as soon as reasonably possible. In general, our response will be within fifteen (15) business days. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).
- To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as up-to-date antivirus protection, encryption, and disclosing personal data both internally and to our authorised third party service providers and agents only on a need-to-know basis.
- You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.
- We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided below.
- We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.
- We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes. The retention of data policy would be mainly based on local country data regulation policy.
- We generally do not transfer your personal data to countries outside of Singapore. However, if we do so, we will obtain your consent for the transfer to be made and we will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.
QUESTIONS, COMPLAINTS, AND CONTACTS
If you have any questions about this Privacy Statement, our policies and practices, your rights under this statement, your dealings with Ssivix Lab, or require access or corrections to your Personal Data, send an email to firstname.lastname@example.org or by mail to the address below:
Personal Data Protection Officer
Ssivix Lab Pte Ltd
#27-15, 10 Anson Road, International Plaza,
+65 8189 3129
Dated: 17th July 2020