This Data Protection Notice (“Notice”) sets out the basis which Assurance Technology Pte Ltd (“we”, “us”, or “our”) may collect, use, disclose or otherwise process personal data of persons in accordance with the Personal Data Protection Act (“PDPA”). This Notice applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose or process personal data for our purposes.

PERSONAL DATA

  1. As used in this Notice:
    • “Clinic Assist Software” (CAS) means the clinic management software we provide to our customer; and
    • “Services” means CAS and the support services provided by us; and
    • “Customer” means an individual or clinic who (a) has contacted us through any means to find out more about the Services we provide, or (b) may, or has, entered into a contract with us for the supply of the Services by us; and
    • “App user” means an individual who has installed and uses mobile app (“App”) services provided by us (“eHealthAssist”); 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; and
    • “Data Controller” means our role with personal data for App users; and
    • “Data Intermediary” means our role with personal data for our Customers.
  2. Other terms used in this Notice shall have the meanings given to them in the PDPA (where the context so permits).

COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA

  1. We generally collect personal data from our customers, business partners, contractors and other individuals such as mobile apps users. We would only collect data that have been provided to us voluntarily by you or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”).
  2. These personal data would be furnished to us in forms filled out by you, face to face meetings, email messages, telephone conversations or through our website(s). We may also keep a record of any contact you have with us. These data would be collected only for business purposes or for the purpose stated by us when we gather the information from you.
  3. The personal data collected may be used for any or all of the following purposes:Clinic Assist Software and App users
    • identify verification
    • to provide services and support any incidental business purposes
    • for follow-up action regarding any complaints, feedback, queries or requests received via our website or any other communication channels
    1. We provide Clinical Assist Software (“CAS”) to customers who enter into a Service Agreement (“Customers”) with us. CAS is a clinic management software which computerize clinic processes and store clinic data digitally. Clinical Assist users include physicians, physician assistants, practitioners and non-physician staff members (“Authorized Users”). As a software provider, we are data intermediary and do not own the clinic data. Customers and Authorized Users are responsible for determining uses and disclosures of patient medical information maintained in the Clinical Assist, in accordance with their legal and professional responsibilities as health care professionals and PDPA guidelines. To the extent that we receive or maintain patient medical information in the course of providing the Clinical Assist, that information is secured, used and disclosed only in accordance with our legal obligations as a service provider.
    2. We collect personal data from our App users through the forms filled out by you during App registration. The mandatory information require in the account registration page includes your name, phone number, identity type, identity number, Data of Birth, Gender, Nationality and postal code which we used to validate your identity with clinical assist in order to retrieve medical data accurately. Other information like address, email address, demographic data (such as your gender, marital status, age), medical data (such as your height, weight, medical conditions) are optional and dependent on your willingness to share with us. We would only collect data that have been provided to us voluntarily by you or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative” such as your family members). You may choose not to provide us with any personal information but features that require personal information will not be accessible to you.

    We provide mobile payment for credit card, PayNow and GrabPay via our App. The transactions are processed by OCBC Bank, PayNow and GrabPay payment gateways respectively. To facilitate credit card payment, we may collect details of your credit card (name, credit card number, expiry date, cvv). You may find the data protection policy for OCBC (credit card and PayNow) at https://www.ocbc.com/business-banking/policies.html and GrabPay at https://www.grab.com/sg/terms-policies/privacy-policy/

    Your name, phone number, date of birth, identity number, identity type, email and last 4 digits of your credit card will be stored by us with SHA 256 encryption. Information such as gender, nationality, marital status, language spoken, relationship, home contact no, address, allergy, the credit card name, number, expiry date, cvv and first 12 digits and other information shall be stored in database within your mobile phone. Your registered account is the main profile of the App. Our App allows you to create sub-profiles for your parents or children. The profile data is stored in the same manner as the main profile.

    We may ask you for the following app access permission during App installation:

        • Camera – enable taking of pictures of wounds or physical objects such as lab results or medical reports or medicines for recording purposes or to show to doctors.
        • Contact – enable you to setup Emergency Contact list
        • Location – enable you to find clinics near you.
        • Telephone – enable you to use the telemedicine function
      • Storage – store your health records in the phone (medicine details, invoices, MC, & etc)
      • Bluetooth – enable compatible devices to send data into the apps (e.g. glucose meter readings)

    You may choose to deny the app access permission but features that require it will not be accessible to you.

    1. We may disclose your personal data:
      1. Customer
        1. where such disclosure is required for performing obligations in the course of or in connection with our provision of the Services requested by you; or
        2. assisting in law enforcement and investigations conducted by any governmental and/or regulatory authority; or
        3. to third party service providers, agents and other organisations we have engaged to perform any of the functions listed in clause 7 above for us. The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) 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 any contract with you).
          1. Apps User
            1. assisting in law enforcement and investigations conducted by any governmental and/or regulatory authority; or
            2. to third party service providers, agents and other organisations we have engaged to perform any of the functions listed in clause 7 above for us. The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) 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 any contract with you).
        1. The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) 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 any contract with you).
        2. We may collect, use and disclose individual personal data pursuant to an exception under the PDPA law such as assisting in law enforcement and investigations conducted by any governmental and/or regulatory authority.

        WITHDRAWING YOUR CONSENT

        1. As a Data Intermediary to our Customer, we do not deal with their clients directly and have no rights to handle personal data requests from their clients. Such requests shall be managed by Customer. Request for withdrawal of personal data for App users will be assessed on the nature and scope of request. We reserve the rights to reject requests on valid grounds. The following section will not be applicable to our Customer and is only applicable for App users as Data Controller.
        2. Individuals have choices regarding our collection, use or disclosure of your personal data. If you choose not to provide us with the personal data described in this notice, we may not be able to perform our obligations as stated in this notice. You have the right to object to the processing of your personal data and withdraw your consent in the manner described in this section.
        3. 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 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.
        4. 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 ten (10) business days of receiving it.
        5. 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.
        6. 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.

        ACCESS TO AND CORRECTION OF PERSONAL DATA

        1. As a Data Intermediary to our Customer, we do not deal with their clients directly and have no rights to handle personal data requests from their clients. Such requests shall be managed by Customer. The following section will not be applicable to our Customer and is only applicable for App users as Data Controller.
        2. 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, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.
        3. 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, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.
        4. 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.
        5. We will respond to your access request as soon as reasonably possible. Should we not be able to respond to your access request within thirty (30) days after receiving your access 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).
        6. We allow update of identity number (e.g. FIN No) for App users. Within 48 hours, we will contact you for verification and ask for evidence. Upon validating the information with the evidence, we will proceed to update your particular accordingly.

        PROTECTION OF PERSONAL DATA

        1.  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 the use of privacy filters to secure all storage and transmission of personal data by us, and disclosing personal data both internally and to our authorised third party service providers and agents only on a need-to-know basis.
        2. 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
        3. The personal data you submitted shall be stored locally by us or any third-party we engaged to safe guard the personal data. We do not allow personal data transfer to, and collect, use and disclose to any third-party oversea.

        ACCURACY OF PERSONAL DATA

        1. As a Data Intermediary of our Customer, we are not authorized to manage their client data beyond contracture obligation in providing the Services. The Customer shall be responsible for the accuracy of their client personal data.
        2. As a Data Controller for App users, 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, you should update the information in the App. For update of identity number, please inform our Data Protection Officer in writing or via email at the contact details provided below. Our DPO will contact you within 24 hours to follow up on the request.
        3. For Apps users, mobile number will be verified through OTP code during registration. Your NRIC number, date of birth and identity type will be validated by our system during data matching process.

        RETENTION OF PERSONAL DATA

        1. 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.
        2. 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.
        3. Customer data in CAS shall be removed within 24 hours from the last day of Services.
        4. Personal data for App users shall be removed within 24 hours upon receiving and confirmation of identity. User record inactive for 1 year or more shall also be removed.

        TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE

        1. 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.

        DATA PROTECTION OFFICER

        1.  You may contact our Data Protection Officer if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, in the following manner:
            • Attention to Data Protection Officer
            • Email to DPO@eclinic.com.sg or contact +65 65632435.
            • Content of your queries, feedback or request

        EFFECT OF NOTICE AND CHANGES TO NOTICE

        1.  This Notice applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.
        2.  We may revise this Notice from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Notice was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.

         

        Effective Date: 12/05/2020

        Last Updated: 12/05/2020