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

1. 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.

2. 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.

3. 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.

4. 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.

5. 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.

6. 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.

7. 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.

8. 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.

9. Third party analytics

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

10. 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.

11. 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

12. 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.

Getui Privacy Policy

This policy is only applicable to the Getui Push Service of Zhejiang Merit Interactive Network Technology Co., Ltd. (hereinafter referred to as “Getui”). Last updated: September 30, 2019.

If you have any questions, comments or suggestions, please contact us using the contact details below:

  • Email: support@getui.com
  • Phone: 4006-808-606
  • Fax: 0571-86473223

This policy will help you understand the following:

  • How do we collect and use your personal information?
  • How do we share, transfer, and publicly disclose your personal information?
  • How do we protect your personal information?
  • Your rights
  • Children’s personal information protection
  • How to update this policy

Please read, understand and agree to accept this privacy policy before using the Getui push service. If you do not agree to this policy, please stop using the Getui push service immediately.

1. How do we collect and use your personal information?

(a) Getui will only collect and use your personal information for the functions described in this policy:

1. Create the user ID required for the push service
In order to create the user ID, we may need to collect the following information: device identifier (such as IMEI, Android ID, device serial number, MAC, Android Advertisement ID, IMSI and other device related information). This information will be used to generate unique push target id, id est, the CID.

2. Optimize message push capability
We may need to collect the following information, which will help us to provide you with better push services and experiences, such as the use of vendor system push capabilities: device manufacturer, device brand, device model, Android version, Rom information, etc. However, if this information cannot be collected, it will not affect the basic functions of this push service.

3. Smart push function
In order to implement the smart push function, based on the user portraits for refined push operation, we may need to collect the following information: installed packages, and active packages information. We analyze your interests by using above information, and can recommend push content that better suits you, which will reduce unnecessary bothering push message to you.

4. Location-based push function
In order to implement message push based on the user’s offline scene, we may need to collect the following information: network identity information (including IP address, MAC address) and location based information (WIFI list, latitude and longitude, base station information, MAC). It helps you to provide a refined push based on offline scenes, and recommend push content that better suits you, which will reduce unnecessary bothering push message to you.

The above information provided by you will continue to be authorized for use during your use of the push service. When you stop using the push service, we will stop using and delete the above information.

The above information will be stored on servers in the People’s Republic of China. For cross-border transmission, we will ask for your authorization.

When we want to use the information for other purposes not covered by this policy, we will ask for your consent in advance.

When we want to use information collected for a specific purpose for other purposes, we will ask for your consent in advance.

(b) Exceptions for obtaining authorization:

Please understand that in accordance with laws, regulations and relevant national standards, we collect and use your information without the consent of your authorization:
1. Directly related to national security and national defense security;
2. Directly related to public safety, public health, and major public interests;
3. Directly related to criminal investigation, prosecution, trial and judgment execution;
4. When it is difficult to obtain the consent of the person for the protection of the life and property of you or other individuals;
5. The collected information about you is disclosed to the public by yourself;
6. Your personal information collected from legally publicly disclosed information, such as legitimate news reports, government information disclosure, etc.;
7. When it is necessary to maintain the safe and stable operation of software and related services, such as faults in discovering and disposing of software and related services;
8. When an academic research institution conducts statistical or academic research based on public interest and provides academic research or description results, the personal information contained in the results is anonymized;
9. Other circumstances as stipulated by laws and regulations.

2. How do we share, transfer, and publicly disclose your personal information?

(a) Sharing

We do not share your personal information with any company, organization or individual other than Getui, except in the following cases:

  • Share with explicit consent: We will share it with other parties under your explicit consent.
  • We may share it in accordance with laws and regulations or in accordance with the mandatory requirements of the competent government authorities.
  • Sharing with our affiliates, we will only share the necessary information and will be bound by the purposes stated in this Privacy Policy. If the subsidiary wants to change the purpose of processing the information, we will ask for your authorization again.
  • Sharing with Authorized Partners: For the purposes stated in this policy, we may share certain of your personal information with our partners. We only share information for legitimate, necessary, and specific purposes, and we only share the information necessary to provide the service, and our partners do not have the right to use the shared information for any other purpose. Our authorized partners include the following types: advertisers, media and other partners. We will use the desensitized data processed and processed by the Getui data platform for commercial use including optimizing advertising and improving marketing effects. For companies and organizations with which we share information, we will enter into a strict confidentiality agreement with them to process personal information in accordance with our instructions, this Privacy Policy, and any other relevant confidentiality and security measures.

(b) Transfer

We will not transfer your personal information to any company, organization or individual except in the following cases:

  • Transfer with explicit consent: After obtaining your explicit consent, we will transfer it to other parties;
  • When it comes to enterprise mergers, acquisitions or bankruptcy liquidation, if it involves the transfer of your personal information, we will ask the new company and organization to continue to be bound by this privacy policy, otherwise we will ask the company and organization to ask for your consent again.

(c) Public disclosure

We will only publicly disclose your personal information in the following cases:

  • After obtaining your explicit consent
  • Disclosure based on law: We may disclose it publicly in the case of laws, legal procedures, litigation or mandatory requirements of the competent government authorities.

(d) Exceptions for prior authorization of consent when sharing, transferring, and publicly disclosing information

Please understand that in accordance with laws and regulations and relevant national standards, we share, transfer, and publicly disclose your information without the consent of your authorization:

  • Directly related to national security and national defense security;
  • Directly related to public safety, public health, and major public interests;
  • Directly related to criminal investigation, prosecution, trial and judgment execution;
  • When it is difficult to obtain the consent of the person for the protection of the life and property of you or other individuals;
  • Information that you disclose to the public by yourself;
  • Information collected from legally publicly disclosed information, such as legal news reports and government information disclosure.

3. How do we protect and store your personal information?

  • (a) We have used industry-standard security measures to protect your personal information from unauthorized access, public disclosure, use, modification, damage or loss. We will take all reasonable and practicable steps to protect your personal information. For example, we deploy access control mechanisms to ensure that only authorized person have access to personal information; and we conduct security and privacy protection training courses to enhance employee awareness of the importance of protecting personal information.
  • (b) We have obtained the following certifications: Information System Security Level Protection Level 3 certificate, and ISO9001 certification.
  • (c) Our data security capabilities: We will establish a data classification system, a data security management specification, and a data security development specification to manage the storage and use of standardized information.
  • (d) We will take all reasonable and feasible measures to ensure that irrelevant information is not collected. We will only retain your personal information for the period of time required to achieve the purposes described in this policy, unless we need to extend the retention period or be permitted by law.
  • (e) The Internet is not an absolutely secure environment, and email, instant messaging, and communication with other users are not encrypted. We strongly recommend that you do not send information in this way. Please use complex passwords to help us keep your account secure.
  • (f) The Internet environment is not 100% secure and we will do our best to ensure or guarantee the security of any information you provide to us. If our physical, technical, or administrative protective equipment is destroyed, resulting in unauthorized access, public disclosure, alteration, or destruction of information, resulting in damage to your legal rights, we will bear the corresponding legal responsibility.
  • (g) After we take necessary and reasonable security measures, we still unfortunately have security incidents such as information disclosure. We will promptly inform you according to the requirements of laws and regulations: the basic situation and possible impact of security incidents, we have taken or disposal measures to be taken, suggestions for your own prevention and risk reduction, remedial measures for you, etc. At the same time, we will also report the handling of information security incidents in accordance with the requirements of the regulatory authorities.

4. Your rights

In accordance with relevant laws, regulations, standards in China and other countries and regions, we guarantee that you exercise the following rights to your personal information:

(a) Access information

You have access to your personal information, except as provided by laws and regulations. If you want to exercise data access, you can do the following:

Personal Information Protection Email: support@getui.com

Address: Floor 4, Bldg. 1, Fudi Park 2.0, Xidoumen Road No.9, Xihu District, Hangzhou, Zhejiang, China

You can also contact us at any time by visiting https://www.getui.com/ online customer service or by calling one of our customer service numbers.

We will respond to your request within 30 days.

For other personal information that you generate during the use of our products or services, we will provide you with as far as we could. If you would like to exercise data access, please send an email to support@getui.com.

(b) Correcting information

You have the right to ask us to make corrections when you find that we have processed an error about your personal information. It can be done in the following ways:

Personal Information Protection Email: support@getui.com

Address: Floor 4, Bldg. 1, Fudi Park 2.0, Xidoumen Road No.9, Xihu District, Hangzhou, Zhejiang, China

You can also contact us at any time by visiting https://www.getui.com/ online customer service or by calling one of our customer service numbers.

We will respond to your request within 30 days.

For other personal information that you generate during the use of our products or services, we will provide you with as long as we do not need to invest too much. If you would like to exercise data access, please send an email to support@getui.com.

(c) Deleting information

In the following situations, you can ask us for a request to delete information:

  • If we deal with information in violation of laws and regulations;
  • If we collect and use your personal information without your consent;
  • If we deal with information, which violates the agreement with you;
  • If you no longer use our products or services, or you delete your account;
  • If we no longer provide products or services for you.

If we decide to respond to your removal request, we will also notify the entity from which we obtained your personal information and request that it be removed in a timely manner, unless otherwise required by laws and regulations, or if these entities obtain your independent authorization.

When you delete information from our services, we may not immediately delete the corresponding information in the backup system, but will delete it when the backup is updated.

(d) Change the scope of your authorization

Each business function requires some basic personal information to be completed (see “Part 1” of this policy). You may give or withdraw your authorization consent at any time for the collection and use of additional collected personal information.

You can do it yourself in the following ways:

Personal Information Protection Email: support@getui.com

Address: Floor 4, Bldg. 1, Fudi Park 2.0, Xidoumen Road No.9, Xihu District, Hangzhou, Zhejiang, China

You can also contact us at any time by visiting https://www.getui.com/ online customer service or by calling one of our customer service numbers.

We will respond to your request within 30 days.

(e) Cancellation of accounts

You can cancel your previously registered account at any time, you can do it yourself:

Personal Information Protection Email: support@getui.com

Address: Floor 4, Bldg. 1, Fudi Park 2.0, Xidoumen Road No.9, Xihu District, Hangzhou, Zhejiang, China

You can also contact us at any time by visiting https://www.getui.com/ online customer service or by calling one of our customer service numbers.

We will respond to your request within 30 days.

After canceling the account, we will stop providing you with products or services, and delete your personal information according to your requirements, except as otherwise provided by laws and regulations.

Respond to your request above

To be safe, you may need to provide a written request or otherwise prove your identity. We may ask you to verify your identity before processing your request.

We will respond within thirty days. If you are not satisfied, you can also complain through the following channels:

Personal Information Protection Email: support@getui.com

Address: Floor 4, Bldg. 1, Fudi Park 2.0, Xidoumen Road No.9, Xihu District, Hangzhou, Zhejiang, China

You can also contact us at any time by visiting https://www.getui.com/ online customer service or by calling one of our customer service numbers.

We will respond to your request within 30 days.

In principle, we do not charge a fee for your reasonable request, but we will charge a certain fee for the repeated requests that exceed the reasonable limit. For those who are unreasonably repetitive, need too much technical methods (for example, need to develop new systems or fundamentally change existing practices), pose risks to the legal rights of others, or are very impractical request(for example, involving information stored on backup tapes), we may refuse.

5. Children’s personal information protection

Our push service is for adults and does not accept children using push services.

For the collection of children’s personal information with or without parental consent, we will only retain, use or publicly disclose this information if it is permitted by law, with the explicit consent of the parent or guardian or the protection of the child, otherwise we will try to delete the relevant data as soon as possible.

6. How to update this policy

Our Privacy Policy may be changed, and we will have the right to make timely adjustments and re-release of this Privacy Policy based on actual operations and performance. If you do not agree to the changes made to the terms of this policy, please stop using the push service. If you choose to continue using the push service, you are deemed to have accepted the adjustments to the terms of this policy.

We will not reduce your rights under this Privacy Policy without your explicit consent. We will post any changes to this policy on this page.

For major changes, we also provide more noticeable notices (including for certain services, we will send a notification via email stating the specific changes to the privacy policy).