1 Personal information we collect
1.1 When you visit the Site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically-collected information as “Device Information”.
1.2 We collect Device Information using the following technologies:
1.2.2 “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
1.2.3 “Web beacons”, “tags”, and “pixels” are electronic files used to record information about how you browse the Site.
1.3 We collect User Information when you submit information including but not limited to chatbot messages, Ask a Doctor and patient experience surveys through the Site, as well as from partners, public agencies and other third parties. User Information includes but is not limited to:
1.3.1 your name;
1.3.2 your medical history and condition (including photos);
1.3.3 payment information (including credit card numbers);
1.3.4 email address; and
1.3.5 phone number.
1.5 If you provide us with any Personal Information relating to a third party (e.g. information of spouse, children, parents, employees and/or authorised persons), by submitting such information to us, you represent to us that you have obtained the consent of the third party to provide us with their Personal Information for the respective purposes. You should ensure that all Personal Information submitted to us is complete, accurate, true and correct. Failure to do so on your part may result in our inability to provide you with the services which you have requested.
2 Use of your Personal Information
2.1 We use User Information generally to fulfil any queries and submissions through the Site (including but not limited to processing your Ask-a-Doctor and patient experience survey submissions).
2.2 We use Device Information to help screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimise our Site (for example, by generating analytics about how our customers browse and interact with the Site, and to assess the success of our marketing and advertising campaigns).
2.3 Additionally, we use your Personal Information to:
2.3.1 communicate with you regarding your complaints, queries, requests, feedback and suggestions;
2.3.2 manage our administrative and business operations and comply with our internal policies and procedures;
2.3.3 conduct audits, reviews and analysis of our internal processes, action planning and manage commercial risks;
2.3.4 legal purposes (including but not limited to obtaining legal advice, drafting legal documents and contracts and facilitating dispute resolution);
2.3.5 comply with any applicable rules, laws, regulations, codes of practice or guidelines issued by any legal or regulatory bodies which are binding on us (including but not limited to disclosures to regulatory bodies or conducting audit checks, surveillance, investigation, or due diligence);
2.3.6 in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services;
2.3.7 conduct market research, understand and analyse customer behaviour, location, preferences and demographics for us to develop special offers and marketing programmes; and
2.3.8 any other purpose relating to any of the above.
2.4 As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at https://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.
2.5 You can opt out of targeted advertising by using the links below: – Facebook: https://www.facebook.com/settings/?tab=ads – Google: https://www.google.com/settings/ads/anonymous – Bing: https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: https://optout.aboutads.info/.
2.6 If you prefer not to receive any direct marketing communications from us, you can opt out at any time by sending us an email at email@example.com with sufficient information to identify you (e.g. account username) and which direct marketing channels you would like to object to.
3 Do not track
3.1 Please note that we do not alter our Site’s data collection and use practices when we see a Do Not Track signal from your browser.
4 Disclosure of Personal Information
4.1 We will take reasonable steps to protect your Personal Information against unauthorised disclosure. Subject to the provisions of any applicable law, your Personal Information may be provided, for the purposes listed above (where applicable), to the following entities or parties, whether they are located overseas or in Singapore:
4.1.1 our partners;
4.1.2 companies or brokers providing us services relating to insurance and/or reinsurance;
4.1.3 agents, contractors or third party service providers who provide operational services to us, such as courier services, telecommunications, information technology, advertising, payment, payroll, processing, training, market research, storage, archival, customer support investigation services or other services;
4.1.4 vendors or other third party service providers in connection with promotions and services offered by us;
4.1.5 external banks, credit card companies and their respective service providers;
4.1.6 third party referrals;
4.1.7 our professional advisers such as our consultants, auditors and lawyers;
4.1.8 relevant government regulators, government ministries, statutory boards or authorities and/or law enforcement agencies, whether local or overseas, to comply with any directions, laws, rules, guidelines, regulations or schemes issued or administered by any of them;
4.1.9 external business and charity partners in relation to corporate promotional events; and/or
4.1.10 any other party to whom you authorise us to disclose your Personal Information to.
5 Your rights
5.1 You have the right to access Personal Information we hold about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise this right, please contact us through the contact information below.
5.2 Please note that if your Personal Information has been provided to us by a third party, you should contact such party directly to make any queries, feedback, and access and correction requests to us on your behalf.
5.3 If you withdraw your consent to any or all use of your Personal Information, depending on the nature of your request, we may not be in a position to continue to provide our services to you, administer any contractual relationship in place, may also result in the termination of any agreements with you, and your being in breach of your contractual obligations or undertakings, and our legal rights and remedies in such event are expressly reserved.
5.4 Additionally, please note that your Personal Information may be transferred outside of Singapore as part of our use of third party cloud services to store our data and operate the Site. Such transfers are subject to security measures of a comparable standard to the Personal Data Protection Act 2012 to safeguard your Personal Information.
6 Data retention
6.1 When you make a submission through the Site, we will maintain your User Information for our records unless and until you ask us to delete this information.
6.2 We will implement commercially reasonable security measures in the storage of your User Information.
7 Contact us
7.1 For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by email at firstname.lastname@example.org or by postal mail using the details provided below:
Asia MD Pte Ltd
1 Magazine Road
#04-11 Central Mall
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