Terms used and not otherwise defined in this privacy policy (the “Privacy Policy”) have the meaning given in the Terms of Use.

 

Raffles Medical Group Ltd (“RMG”) has the Raffles Connect App (the “App”), and recognizes its obligations under the Singapore Personal Data Protection Act 2012 (the “PDPA”) which sets out our obligations in respect of the collection, use and disclosure of personal data. Your privacy is one of our top priorities. We have created this Privacy Policy to help you understand how we collect, use, communicate, disclose and make use of the personal information we collect. We collect personal information solely for the objective of fulfilling those purposes specified by us (now or in the future), or as required by law.

 

We are committed to conducting our business in accordance with these principles in order to ensure that the confidentiality of personal information is protected and maintained. Please note that RMG is not responsible for the privacy statements or other content on websites outside of the App. You should review the privacy statements of websites you choose to link to from the App, so that you understand how those websites collect, use and share your information. If you have any doubts about the security of the information you are providing on another site, RMG recommends that you contact that website directly for more information. RMG shall not be responsible for the actions of third parties in any manner whatsoever, including but not limited to any violation of such privacy policies or otherwise.

 

This policy sets out:

  • Your consent to this Privacy Policy
  • What Personal Data we collect
  • What we use Personal Data for
  • How long we keep Personal Data
  • Changes to this Privacy Policy
  • Public Information
  • Personal Information Security
  • Children under eighteen
  • Third Party Analytics
  • Transfer of Personal Data
  • Contact Information

 

Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to: pdpa@rafflesmedical.com

 

Your consent to this policy

By agreeing to the Terms of Use you are accepting and consenting to the practices described in this policy.

 

You agree that your Personal Data that is collected by RMG or posted on the App or processed through the Services from time to time may be used for the purposes described in this Privacy Policy or the Terms of Use.

 

Through the Services and content on the App, you may be introduced to a variety of third parties such as medical practitioners and wellness experts (“Providers”) and other websites. The privacy policies of these third parties are not under RMG’s control and you should read the respective privacy policies carefully. The use of any information that you may provide to any third party, or the use of “cookie” technology by any third party, will be governed by the privacy policy of the operator of the website that you are visiting.

 

You may refuse or withdraw your consent for us to collect, use or disclose your Personal Data by giving us reasonable notice. This can be done at any time by emailing pdpa@rafflesmedical.com (as long as there are no legal or operational restrictions preventing you from doing so). It is important to note that in the event you do withdraw consent, we will be unable to collect, use, or disclose your Personal Data meaning that you will no longer be able to use the Services.

 

What personal data are collected

We will store data we collect from you through the account registration process, such as name, age, ethnicity, occupation, gender, height, weight, address and lifestyle habits (and any other data you or others post on the App through the use of the Services) (the “Personal Data”). We may also collect your Personal Data if you report a problem with the App or if you contact us for any reason.

 

RMG does not use, disclose or collect sensitive personal information (such as religion, political affiliations or medical information) without your consent. RMG keeps track of the App and pages our users visit within the App, in order to determine what Services are the most popular. This data may be used to deliver customized content and advertising within the App to users whose behavior indicates that they are interested in a particular subject area.

 

If you have provided Personal Data to RMG, you can request access to it at any time, as well as request to know how it is being used and disclosed for the last 12 months. In order to facilitate this access, you may be charged an administrative fee. You also have the right to request correction to your Personal Data.

 

What we use your data for

The primary reason we collect Personal Data is to enable users and Providers to conduct Consultations through the Services and to enable the content-related functions of the App. In order to facilitate this service we will need to share your personal data with the healthcare provider who you have chosen or connected with. Your data will only be shared with that individual and only for the purposes of providing the service that you have requested.

 

We may use your Personal Data for account and the App’s maintenance, marketing, billing purposes and user profiling. We use and disclose Personal Data relating to payment methods and details to the extent required to process fees for completed Consultations, monthly subscriptions and other transactions.

 

We may use your Personal Data to contact you in respect of the Services. We will send emails to the email addresses provided by you and we will be making calls on the phone numbers provided by you if required. If you have provided an incorrect email address or phone number (or if these details have been changed without notice to us), then you may not receive these communications. RMG will not be responsible for any breach of privacy due to correspondence going to an incorrect address or phone number. We may also use your Personal Data to contact you to perform surveys about your opinion of RMG or the Services, or of potential new Services that may be offered. By using the App on RMG’s platform, you consent to your Personal Data being used by RMG for such communications. Should you no longer wish to be contacted, you may opt out of receiving these communications on your profile.

 

Generally, RMG does not sell, rent or lease its user lists to third parties. RMG may, from time to time, contact you on behalf of external business partners about a particular offering that may be of interest to you. In addition, RMG may share data with trusted partners to help us perform statistical analysis, send you email or postal mail, provide user support, or arrange for deliveries. All such third parties are prohibited from using your personal information except to provide these services to RMG, and they are required to maintain the confidentiality of your information.

 

We may disclose your personal information if we are under a duty to disclose or share such data in order to comply with any legal obligation, or to protect the rights, property, or safety of RMG, our users, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

 

We may aggregate personal and other data captured through the App and the Services so that the data is no longer capable of identifying any individual. Aggregated data may cover patterns of usage relating to the App and its Services and RMG reserves the right to use this aggregated information for the purposes of improving and enhancing its Services, developing and selling data and information to third parties, generating and commercializing insights and otherwise for the purposes of our business.

 

You may opt to integrate RMG with Apple’s Health App Database. If you grant RMG access to Apple’s Health App Database, RMG may transfer data that you store locally on your device to the Health App Database. RMG cannot integrate with the Health App Database unless you grant access. Data accessed from the Health App Database will never be shared with third parties, such as third party service providers and/or advertisers, without your permission.

 

RMG is in no way responsible for the protection of your Personal Data that is stored within Apple’s Health App Database. You and Apple are solely responsible for the protection of such information in the Health App Database. Please review Apple’s applicable policies and procedures before syncing and backing up your Personal Data and/or other information with the Health App Database.

 

How long we keep your personal data for

We reserve the right to retain any Personal Data collected until your account is terminated or for a period of ten (10) years after you last long logged into your account (whichever is the longer period). By following the “profile” link provided on the App, you may view, edit and delete Personal Data you have already given us. You may also elect to receive or discontinue receiving any email newsletters we may choose to distribute periodically.

 

Changes to this policy

Any changes we may make to this Privacy Policy in the future will be posted on the App. Changes will take effect immediately and be binding on you from the time of posting.

 

Public information

Keep in mind that any reviews, personal information, or comments that you voluntarily disclose on public pages (e.g. the questions and answers page) of the App may be viewed by the general public. Your account and user name may be displayed to other users when you send and/or post messages on public pages. Please note that any comment or other content you post or send on public pages becomes published content and is not considered personally identifiable information (so is not protected by the PDPA or subject to this Privacy Policy). Your messages and other information you make available in public pages of the App will be seen by people and organizations not related to or controlled by RMG and may be used by others to contact you.

 

The data that you submit or write on the App may be seen by other service providers such as doctors or operations and maintenance team repairing and maintaining our technical systems. RMG does not have Non-Disclosure Agreements with these parties who may be able to access your information.

 

Personal information security

RMG secures the Personal Data you provide on computer servers in a secure environment. Your information is always protected from unauthorized access.

 

Children under eighteen

The App is not directed to children under the age of eighteen, and RMG will never knowingly collect personally identifiable information from children under the age of eighteen. If you are under the age of eighteen, you must ask your parent or guardian for permission to visit the App.

 

Third party analytics

We use third party analytics services to collect information for system administration, to create reports, and to improve the App.

 

Transfer of personal data

In the event that RMG enters a business transaction, such as a merger or acquisition with/by another company, your Personal Data may be among the assets transferred. You will be notified via email of any such change in ownership or control of your Personal Data.

 

Marketing materials

If you have elected to receive marketing materials, at any time subsequently you can ask not to receive marketing materials. You can exercise this right by contacting pdpa@rafflesmedical.com

 

Contact information

RMG welcomes your comments regarding this Privacy Policy and its adherence to its obligations under the PDPA. If you believe that RMG has not adhered to the PDPA and would like to make a complaint, or have a query, please contact us at pdpa@rafflesmedical.com In order to process your request, please ensure you state your:

  • Full Name
  • Contact Number
  • Email Address
  • Details of the nature of your complaint and/or query

 

You will then be contacted within 30 days by the relevant data protection officer. Please note that you may be charged an administrative fee depending upon the nature of your request.