Privacy Policy

Effective Date: [01 January 2020]
Last Updated: [31 December 2019]

Mednefits Privacy Policy for Customers

This Mednefits Privacy Policy (“Privacy Policy”) sets out the basis which Medicloud Pte. Ltd. (UEN 201415681W) and our related corporations (“Mednefits”, “we”, “us” or “our”) may collect, use, disclose or otherwise process personal data of our customers (“you” or “your”) in accordance with the Personal Data Protection Act 2012 of Singapore (“PDPA”). 

This Privacy Policy 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. 

1. DEFINITIONS 

1.1. As used in this Privacy Policy: 

customer” means any person who (a) has contacted us through any means to find out more about any goods or services we provide; 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 any data which can be used to identify a natural person. 

Services” means our products, services, content, features, technologies or functions offered on websites, applications and services operated by us or our third party service providers. 

1.2. Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include name, residential address, email address, telephone number, biography, nationality, gender, date of birth, marital status, employment information and financial information. 

1.3. Other terms used in this Privacy Policy shall have the meanings as given to them in the PDPA (where the context so permits). 

2. YOUR CONSENT 

2.1. This Privacy Policy applies to any individual’s personal data which is in our possession or under our control (including personal data in possession of organisations which we have engaged to collect, use, disclose or process personal data for our purposes), and shall govern your use of the Services. This Privacy Policy is in addition to the other terms and conditions which may apply in respect of your use of the Services. 

2.2. You are deemed to have accepted this Privacy Policy when you provide us with personal data or otherwise sign up for, access or use any of our Services. 

2.3. Notwithstanding the foregoing, you may withdraw your consent for us to collect, use or disclose your personal data, but this may affect our ability to provide you with the Services. We will not be liable for any failure to provide any Services if such failure is due to your consent hereunder being withdrawn. 

3. COLLECTION AND USE OF PERSONAL DATA 

3.1. We generally do not collect your personal data unless: 

(a) it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”) after (i) you (or your authorised representative) have been notified of the purposes for which the data is collected; and (ii) you (or your authorised representative) have provided written consent to the collection and usage of your personal data for those purposes; or 

(b) collection and use of personal data without consent is permitted or required by the PDPA or other laws. 

3.2. We will seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorised by the PDPA or other laws). 

3.3. We may collect and use your personal data for any or all of the following purposes: 

(a) performing obligations in the course of or in connection with our provision of the Services requested by you; to measure the performance of the Services; to monitor the Services provided by or made available through us; to personalise and improve the provision of the Services; to develop new products and services; 

(b) to verify your identity, conduct due diligence checks and identify you as a user in our system; 

(c) to facilitate the creation of, administration, access, use and security of your account in connection with our provision of the Services requested by you; 

(d) to verify and determine your geographic location, provide localised versions of the Services, provide you with customised or personalised recommendations or content, determine your Internet service provider; to optimise our selection and recommendation algorithm and delivery; 

(e) to process payment or credit transactions; 

(f) to prevent, detect and investigate fraud or other potentially prohibited, unauthorised or illegal activities; to detect, prevent and remediate any violations of our policies or terms and conditions; 

(g) to respond to, handle, and process queries, requests, applications, complaints, and feedback from you; to address or investigate any complaints, claims or disputes; 

(h) to send administrative communications relating to our Services; 

(i) to communicate with you to assist you with operational requests (such as, password reset requests); 

(j) to handle requests for data access or correct; 

(k) to analyse and understand our users; to improve our Services (including, but not limited to, our user interface experiences); to participate in industry exercises and studies; to conduct research and measurement activities; 

(l) to train our employees and third party service providers; to monitor for quality assurances; 

(m) to manage your relationship with us; 

(n) to enforce any obligation owed to us; to protect our rights and the rights of other users, vendors, customers, partners and/or third parties; 

(o) to seek professional advice (such as, legal advice); 

(p) to prepare and maintain financial reporting, regulatory reporting, management reporting, risk management, audit and record keeping purposes; 

(q) to negotiate a business transaction (including, but not limited to, any financing, merger, acquisition or liquidation involving Mednefits); to enable any actual or proposed assignee, transferee, participant or sub-participant of our rights, business or obligations to evaluate any proposed transaction; 

(r) to negotiate and/or enter into any transaction relating to our acquisition by, or merger with, another entity or the sale or transfer of all or part of our business or assets; 

(s) to manage our infrastructure and business operations (including, but not limited to, our technology infrastructure) and to comply with our internal policies and procedures; 

(t) to conduct due diligence enquiries and comply with the enforcement of tax, sanctions or prevention or detection of money laundering, terrorism financing or other unlawful activities; 

(u) to comply with all applicable laws, regulations, rules, code of practice, guidelines, directions, orders, instructions and requests from any authorities (whether local or foreign), including any regulatory, governmental, tax and law enforcement authorities or other authorities; to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority; 

(v) any other incidental business purposes related to or in connection with the above; 

(w) any other purpose specifically (i) provided for in the Services; (ii) provided for in any particular product or service offered or provided by us; (iii) described in notices we provide to you from time to time; or (iv) permitted or required by law or the relevant authorities; and 

(x) 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. 

3.4. We may also use your personal data to send you newsletters, surveys, offers and promotional materials relating to our Services, via various modes of communication such as email, short message service and push notifications. If you do not wish to receive marketing communications from us, please let us know in writing. 

4. DISCLOSURE AND TRANSFER OF PERSONAL DATA 

4.1. We may disclose your personal data: 

(a) 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 

(b) to our employees, third party service providers, agents and other organisations, located anywhere in the world, whom we have engaged to perform any of the functions with reference to the above mentioned purposes. 

4.2. In the event that Mednefits is or may be acquired by or merged with another company or involved in any other business deal (or negotiation of a business deal) involving the sale or transfer of all or part of our business or assets, we may transfer or assign your personal data as part of or in connection with the transaction. In the event of insolvency, bankruptcy, or receivership, personal data may be transferred or disclosed as a business asset. 

4.3. We may transfer, store, process and/or deal with your personal data outside of Singapore, in compliance with applicable data protection or privacy laws. 

4.4. The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to the terms of use) 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). 

5. WITHDRAWING YOUR CONSENT 

5.1. 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. 

5.2. 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 fourteen (14) business days of receiving it. 

5.3. 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 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 5.1 above. 

5.4. 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. 

6. ACCESS TO AND CORRECTION OF PERSONAL DATA 

6.1. 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. 

6.2. 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. 

6.3. We will respond to your request as soon as reasonably possible. In general, our response will be within fourteen (14) 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). 

7. PROTECTION OF PERSONAL DATA 

7.1. To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, organisational, physical and technical measures (such as up-to-date antivirus protection, encryption, use of privacy filters), and disclosing personal data both internally and to our authorised third party service providers and agents only on a need-to-know basis. 

7.2. 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. 

8. ACCURACY OF PERSONAL DATA 

8.1. We generally rely on the personal data provided by you (or your authorised representative). 

8.2. In order to ensure that your personal data is current, complete and accurate, please update us if there are any changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided below. You are responsible for the completeness and accuracy of all personal data provided to us. 

9. RETENTION OF PERSONAL DATA 

9.1. Your personal data is retained for so long as the purpose for which it was collected remains and until it is no longer necessary for any other legal or business purposes. This period is generally 7 years from the date of termination or expiry of the last of your contract or relationship with us, but may possibly be for a longer period if, for example, an investigation or legal proceedings should commence within that period. 

9.2. 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. 

10. DATA PROTECTION OFFICER 

10.1. 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:

Contact No.: (+65) 6254 7889 
Email: dpo@mednefits.com 

11. OUR SERVICES 

11.1. Our Services may contain links to sites operated by third parties. Such links are not an endorsement of the third party sites nor of the third parties operating them. These third party sites may also have different data protection practices. We have no control over and do not take responsibility for these third party sites. 

11.2. When using our Services, your Internet Protocol (IP) address may be automatically recorded and 

logged by our equipment and/or any equipment operated by third parties. 

11.3. When using our Services, certain components may be retrieved from servers operated by third parties. For example, we may use servers operated by third parties to provide our Services. Accordingly, data relating to your use of our Services may be collected by such third parties. 

11.4. Google Analytics is used on our Services to collect traffic data. You can find out more about how 

Google collects and processes data here: https://policies.google.com/technologies/partner-sites 

11.5. When using our Services, we may store some data on your device using technologies such as cookies or other local storage provided by your browser, application, operating system or device. Such data is stored on your device to enable us to: 

(a) provide you with our Services; 

(b) recognise, identify, authenticate and authorise you; 

(c) customise our Services for you and provide you with a more personal and interactive experience; 

(d) collect traffic data and perform measurements for business reporting purposes; and 

(e) any other purposes set out herein. 

11.6. You are free to decline or block such data from being stored (insofar as your browser, application, operating system or device permits), but this may interfere with your use of our Services and you may not be able to use all or any part of our Services. 

11.7. We may also use other technologies (such as a pixel tag or web beacon) for the purposes set out herein, such as when we send you emails to determine whether you have opened or acted on our emails. 

12. CHANGES TO THIS PRIVACY POLICY 

12.1. We may revise this Privacy Policy 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 Privacy Policy was last updated. Your continued use of our Services constitutes your acknowledgement and acceptance of such changes.