Privacy Policy

Last Updated: 17 June 2021 – V1

Personal Data Protection Policy

We take our responsibility under Singapore’s Personal Data Protection Act 2012 (“PDPA”) seriously. We also recognize the importance of your personal data which you have entrusted to us and believe that it is our responsibility to properly manage, protect and process your personal data within our means.

Your personal data may be used and/or processed by us for the following purposes:

(a) to give you access to the Services;

(b) to maintain medical records detailing historical and current health and/or treatments, medications prescribed to patients, and other administrative purposes;

(d) complying with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities;

(e) purposes which are reasonably related to the aforesaid;

(f) any other purposes which we notify you of at the time of obtaining your consent.

We will not disclose your personal information to third parties without first obtaining your consent permitting us to do so except where:

(i) to enable Healthcare Professionals to deliver their Services to you;

(ii) the disclosure is required or authorised based on applicable laws and regulations;

(iii) the disclosure is necessary to respond to an emergency that threatens your or your child’s life, health or safety;

(iv) the disclosure is required pursuant to any order of court or tribunal of competent jurisdiction or governmental authority; and

(v) where such disclosure without your consent is permitted by the PDPA or any other written law.

Notwithstanding anything to the contrary, you agree and acknowledge that Biorithm shall in no event be liable to you or any third party for any information (including Confidential Information) transmitted or disclosed to third parties with your consent or at your direction, and that you shall take full responsibility for such transmission or disclosure.

Biorithm may, at our sole discretion, revise this Privacy Policy from time to time. The most current version of the Privacy Policy will be made available to you within the Application. If we make material changes to this Privacy Policy, we will notify you within the Application by pushing a notification to you or posting a conspicuous notice prior to the effective date of the changes. You may be required to review and opt-in to the revised terms to continue to access the features of the Application. By continuing to access or use the Application after those changes become effective, you agree to be bound by the revised Privacy Policy. If you do not agree to the revised Privacy Policy, you must uninstall the Application.

Data Protection Notice

This Data Protection Notice (“Notice”) sets out the basis which [name of organization (“we”, “us”, or “our”) may collect, use, disclose, or otherwise process personal data of our customers 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 organizations which we have engaged to collect, use, disclose or process personal data for our purposes.

Personal Data

As used in this Notice: “customer” means an individual 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 data, whether true or not, about a customer 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 with us, some examples of personal data which we may collect from you include your name and identification information such as your NRIC number, contact information such as your address, email address or telephone number, nationality, gender, date of birth, marital status, photographs and other audio-visual information, employment information and financial information such as credit card numbers, debit card numbers or bank account information.

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

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 authorized 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. We shall 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 law).

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 goods and/or services requested by you;

(b)verifying your identity; (c)responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;

Withdrawing Your Consent

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.

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. 10.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 8 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.

Access To And Correction Of Personal Data

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.

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. 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).

Protection Of Personal Data

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. 16.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.

Accuracy Of Personal Data

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.

Retention Of Personal Data

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.

Protection Of Personal Data:

To safeguard your personal data from unauthorized 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. 16.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.

Data Security

Biorithm cares about the integrity and security of your personal information. However, we cannot guarantee that unauthorized third parties will never be able to defeat our security measures or use your personal information for improper purposes. You acknowledge that you provide your personal information at your own risk.”

We will endeavour to maintain commercially reasonable administrative, physical and technical safeguards to protect the security, confidentiality and integrity of your personal data.

You agree that we and the service providers that we utilize to assist in providing our services to you shall have the right to access your Account and your personal data to the extent necessary to provide our services, including, without limitation, in response to your support requests. Any third-party service providers we utilize will only be given access to your Account and your personal data as is reasonably necessary to provide our services and will be subject to confidentiality obligations which are commercially reasonable and substantially consistent with the standards described in these Terms of Use.

Permission

Once you download and install the Application, you may be prompted to grant certain permissions to allow the Application to perform certain actions on your device. These actions include permission to:

(a) read/write/modify/delete data in relation to the Application on your device’s storage

(b) view/access information relating to networks/access networks, including permission to send and receive data through such networks/access networks

(c) view/access information related to Bluetooth access and connection, including permission to connect with Bluetooth connected devices as part of the Service.

Aggregated Data and Processed Data

Notwithstanding anything to the contrary, we may generate aggregated and statistical data derived from your use of the App and/or from your information, including, without limitation, aggregated or anonymized data, the number of records, the number and types of transactions, configurations, and reports processed (“Aggregated Data”). By using the App and storing data on the App, you agree that we may have access to your data for the purpose of generating anonymised aggregated data. Aggregate data may be used for research, reporting, marketing and enhance the products and services we offer. Such aggregated data shall not include any personally identifiable information.

You acknowledge and agree that we own:

(a) the Aggregated Data; and

(b) the processed data that results from any data analysis and processing by us or our affiliates (“Processed Data”).

Nothing herein shall be construed as prohibiting us from utilizing or disclosing the Aggregated Data and/or Processed Data for purposes of operating our business, provided that our use of Aggregated Data and/or Processed Data will not reveal the identity, whether directly or indirectly, of any individual. In no event shall the Aggregated Data and/or Processed Data include any personally identifiable information.

You further acknowledge and agree that, as part of our services, we may from time to time provide on the App with product or service advertisements from us or our affiliates or partners based on the Aggregated Data and/or Processed Data collected or processed by us.

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.

Transfers Of Personal Data Outside Of Singapore

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

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: [insert DPO’s contact details including, where applicable, address, email address and telephone number].

Effect Of Notice And Changes To Notice

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. 23.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 : 17 June 2021

Last updated : 17 June 2021

Acknowledgement And Consent

I acknowledge that I have read and understood the [above Data Protection Notice], and consent to the collection, use and disclosure of my personal data by [name of organisation for the purposes set out in the Notice.