Personal data protection policy
Last Updated: 15 November 2018
1. YOUR INFORMATION
2. INFORMATION WE COLLECT
Depending on the nature of your interaction with us, the types of personal data that we collect when you provide to us include: (a) name; (b) NRIC, passport, visa or other government-issued identification data; (c) address; (d) telephone number; (e) email address; (f) profession, occupation or job title; (g) photograph, for example, for your account profile; and (h) health, medical and clinical information that you provide to us through the Services, including our mobile apps, web apps and internet enabled devices that integrate with the Online Services. This information includes your age, date of birth, gender, height, weight, nationality, race or ethnicity, medical history (including hereditary illnesses or diseases, allergies, past and/or present medical treatments sought), living lifestyles (including alcohol consumption, smoking habits, sleep patterns, exercise regimes), activity and fitness data (including perfusion index, pulse, oxygen saturation, blood pressure, heart rate, aerobic steps/strokes taken, blood glucose levels, body fat percentage, BMI, calories burnt, metabolism rate); (i) details of products and/or services that you have purchased from us or which you have enquired about, together with any additional information necessary to process your purchase order and deliver those products and services (including payment data such as debit and credit card number), or to respond to your enquiries; (j) any additional information relating to you that you provide to us directly through the Services or indirectly through use of the Services or through our representatives; (k) information you provide to us through our customer support centre, customer surveys or visits by our representatives from time to time; and (l) any information that is provided to us by, or that we have collected on behalf of, customers that have outsourced a business process function to us including healthcare providers, institutions, organisations, specialists, clinics and doctors.
We may also collect information that is not personal data because it does not identify you or anyone else. These non-personal data include for example, browser and device data; app usage data; data collected through cookies, pixel tags and other technologies; demographic data, anonymous answers to surveys and other data provided by you; or aggregated information about how users use the Site. To the extent these non-personal data should reveal your specific identity or relate to an individual, we will treat these data as Personal Data.
3. HOW WE COLLECT PERSONAL DATA
We collect your personal data directly from you unless it is unreasonable or impracticable to do so. We may collect personal data in a number of ways, including: (a) through your access and use of the Online Services (for example, when you download/install our apps or create an online account with us, or when data from your health or fitness monitoring devices is transmitted or stored on the our apps); (b) during communication or conversations between you or your organisation and our representatives (for example, when you contact our customer support centres or communicate with us via online chat services); and (c) when you submit to us a document containing personal data (for example, emails, contact forms, subscription forms, event or promotional participation forms, proof of identification, etc.)
We may also collect personal data from third parties including: (a) from credit reporting agencies; (b) from law enforcement agencies and other government entities; (c) from agents, dealers and subcontractors that form part of our sales, business and/or service network; (d) from our customers that have outsourced a business process function to us; and (e) from our service providers that collect information on our behalf.
4. COOKIES, WEB BEACONS AND SIMILAR TECHNOLOGIES
A “cookie” is a small summary file containing a unique ID number which is sent to your internet enabled device, such as your computer. A web beacon is an electronic image which (whether alone or in conjunction with a cookie) is used to compile information about your website usage and your interaction with email. We use the term "cookies" to cover cookies, web beacons and similar technologies generally used in the market.
If you do not wish to receive cookies, you can set your browser so that your internet enabled device does not accept them. However, if these cookies are rejected, this may interfere or impair your use of some features of the Online Services.
5. CONSEQUENCES IF WE CANNOT COLLECT PERSONAL DATA
If you do not provide us with the personal data described above, some or all of the following may happen: (a) we may not be able to provide the requested products or services to you, either to the same standard or at all; (b) we may not be able to provide you with information about products and services that you may want, including information about discounts, sales or special promotions; or (c) we may be unable to tailor the content of the Online Services to your preferences and your experience of the Online Services may be impacted and not be as enjoyable or useful.
6. PURPOSES FOR WHICH WE COLLECT, USE AND DISCLOSE PERSONAL DATA
We collect personal data about you so that we can perform our business activities and functions and to provide best possible quality of customer service. These data are held in either electronic and/or hardcopy form.
We collect, use and disclose your personal data for the following purposes: (a) to provide products and services to you and to send communications requested by you; (b) to answer enquiries and provide information or advice about existing and new products or services; (c) to provide you with access to protected areas of the Online Services; (d) to assess and improve the performance, operation and relevance of the Online Services; (e) to perform business processing functions including providing personal data to our related corporations, contractors, service providers or other third parties; (f) to service your account with us, including but not limited to processing and responding to any application or complaint made by you, investigating problems, resolving disputes and enforcing agreements with us; (g) for advertising, promotional and marketing activities (including direct marketing), administration, planning, product or service improvement and development, quality control, data analytics and research purposes. We may also use your personal data to plan and host corporate events, host online forums and social networks in which event you may participate, and to populate your online profiles on our Online Services; (h) to update our records and keep your contact details up to date; and (i) if we determine that it is reasonably necessary to: (1) comply with any law, rule, regulation, binding determination, decision or direction of a regulator or in co–operation with any governmental authority of any country; (2) protect any person from death or injury, and includes any response to an emergency that threatens the life, health or safety of an individual; or (3) protect our rights, property or safety and those of our users or the public as required or permitted by law.
7. DISCLOSURE OF PERSONAL DATA BY US
These third-party organisations include: (a) your nominated or authorised healthcare provider, institution, organisation, specialist, clinic and doctor; (b) any organisation involved in our sales and support network, for example: our authorised sales agents, dealers, service providers and subcontractors (for example, delivery services providers); (c) any organisation involved in our business processing functions, for example: payment processors, credit reporting bodies, debt collection providers; (d) any organisation involved in the operation, hosting and management of our information technology infrastructure (including our website), for example: web hosting providers, IT systems administrators, electronic network administrators; (e) professional advisors, for example, accountants, solicitors, business advisors and consultants; (f) organisations that perform advertising or marketing related services on our behalf, for example, advertising agencies and our authorised agents and dealers; (g) any supplier or other third parties with whom we have commercial relationships for business related purposes; (h) any organisation if we determine that it is reasonably necessary to: (1) comply with any law, rule, regulation, binding determination, decision or direction of a regulator or in co–operation with any governmental authority of any country; (2) protect any person from death or injury, and includes any response to an emergency that threatens the life, health or safety of an individual; or (3) protect our rights, property or safety and those of our users or the public as required or permitted by law; and (i) in addition to the above examples, any other third-party organisations expressly authorised by you.
We may combine or share any personal data that we collect from you with personal data collected by any of our related corporations or by any organisations within our authorised sales and support network.
8. SHARING OF INFORMATION AND PERSONAL DATA BY YOU
Your personal data (including account details such as user names, PIN codes, passwords and security authentications) are private and confidential to you (hereinafter referred to as the “Confidential Data”). If you choose to disclose or share any of such Confidential Information with a third party (including your healthcare provider, specialist, doctor, Guardian, spouse and relative): (i) you do so solely at your own risk; and (ii) you expressly acknowledge and agree that we will not be responsible or liable in any way whatsoever for: (1) any loss of confidentiality due to disclosure or sharing of such Confidential Data by you; or (2) the use and/or processing of such Confidential Data by the third party, including any and all losses, damages, liabilities and harm arising therefrom, including any act or omission of medical prevention, intervention, diagnosis, advice, treatment or care.
Public Forums, Refer A Contact And Testimonials. We may provide bulletin boards, blogs, or chat rooms on the Online Services. Any personal data that you choose to disclose, share or submit in such a forum may be read, collected, or used by others who visit these forums, and may be used to send you unsolicited messages. You are disclosing, sharing and submitting those personal data at your own risk and we will not be responsible or liable in any way for such disclosure, sharing or submission of data. You may elect to use our referral program to inform your contacts about our Services and products. When using the referral program, we may request the contact’s name and email address. We may post a list of customers and testimonials on the Online Services that contains information such as customer names and titles. Where you have given us a testimonial, you hereby consent to our posting of such information and testimonials on our Online Services.
From time to time we may seek your consent to a specific proposed collection, use and/or disclosure of your personal data. If we decide to bundle multiple requests for your consent, you may withhold your consent to any or all such requests. If you have consented to a specific purpose for our use and disclosure of your personal data, then we may rely on your consent until you withdraw your consent.
10. DIRECT MARKETING MATERIALS
We may collect, hold, use and/or disclose your personal data to send you direct marketing communications and information which offers, advertises or promotes our products and services and which we consider may be of interest to you. These communications may be sent in various forms, including voice calls, mail, SMS, fax and email.
If you do not wish to receive marketing communications, you may opt–out of receiving these communications from us at any time by using the opt–out feature/facilities specified in our direct marketing communications or by contacting us at email@example.com, or +65 6957 4800. We will then ensure that your details are removed from the relevant marketing contact list you have elected to opt–out of.
11. ACCESS TO, CORRECTION, DELETION OR ERASURE OF, YOUR PERSONAL DATA
When providing any personal data to us, you should take care to only provide us with accurate, complete and up-to-date data.
To the extent the Online Services allows you to update certain information on your own (including correction and/or deletion of your personal data in your Online Services account), you can always choose to do so personally. When you update such information, we usually keep a copy of the prior version for our records.
Otherwise or alternatively, if you wish to apply for a copy of the personal data we hold about you; or request for your personal data to be updated or corrected or deleted by us; or if you would like to receive an electronic copy of your personal data for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by law), please contact our data protection officer at firstname.lastname@example.org, and we will take all reasonable steps to comply with such requests, as soon as reasonably possible.
To enable us to review and respond to your requests in a timely manner, please include the following details (as a minimum) in your requests: (a) your full legal name and telephone contact number; (b) a description of the personal data you are requesting to access, correct and/or delete; (c) a date range of when you believe the personal data was supplied to us; (d) any details of how the personal data was supplied to us originally (for example, when you completed an online subscription form); and (e) where correction/deletion is required, details of the correction/deletion requested. We may contact you for additional information if required (for example, to clarify your request, to confirm your identity etc).
Please note that when you unsubscribe and close your account with us, we will have the right to remove and delete all your data, whereupon you will no longer be able to access your data.
Fees. We will not charge you any fee when you make a request for access, correction and/or deletion. However, and where legally permissible, we may charge you for our reasonably incurred costs in complying with your request, including: (a) costs of producing a copy of the personal data requested (for example, photocopying/printing and portable storage device costs); and (b) expenses we have incurred in giving access or delivering the personal data (for example, postage costs). To the extent practicable, we will advise you in advance prior to charging you in these circumstances and give you an indication of the likely amount.
12. TRANSFER OF PERSONAL DATA
Your data, including personal data, may be disclosed or transferred to or accessed by our related corporations and third-party organisations (for example, IT or cloud storage service providers) located outside of your country where the data protection standards may differ from those in your jurisdiction. By using and accessing the Services, you expressly agree and consent to the transfer to and processing of data by such entities located outside your jurisdiction.
You may revoke your consent to this at any time, in which case: (i) you must inform us of this consent revocation immediately; and thereafter, (ii) your data will be deleted, and you will then no longer have access to our Services.
13. INTERNET SECURITY AND THIRD-PARTY WEBSITES
We will take reasonable steps to protect your personal data from unauthorised access, improper use or disclosure, unauthorised modification, unlawful destruction or accidental loss.
However, as the Online Services are linked to the internet, and the internet is inherently insecure, we cannot provide any guarantee, warranty or assurance regarding, nor be held liable or responsible for any liability arising out of or in connection with any breach of, the security of transmission of information communicated online. In particular, we cannot guarantee that information transmitted or communicated will not be intercepted while being transmitted over the internet or that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our administrative, physical or technical safeguards. It is your sole responsibility to protect the security of your login and password information. Please note that emails and other communications you send through the Online Services are not be encrypted, we therefore strongly advise you not to communicate or disclose any confidential information through these means.
The Online Services may contain links to other websites or services operated by third parties that are not owned or controlled by us. These third-party websites and services are governed by their own separate data privacy, security and other practices and policies (including any “cookies” or similar technology practices), and we make no representation or warranty in relation to, and will not be responsible or liable in any way for, the data privacy, security or other practices and policies or content of such third-party websites and services. These third-party websites and services are responsible for informing you about their own data privacy, security and other practices and policies.
14. PERSONAL DATA RETENTION PERIOD
We may retain your personal data for a period of time consistent with the original purpose of collection. For instance, we may retain your personal data during the time in which you have an account to use our Online Services and for a reasonable period of time afterward. We also may retain your personal data during the period of time needed for legal or other legitimate business purposes.
15. HOW TO CONTACT US
17. APPLICABLE LAW