This Data Protection Policy (“Policy”) sets out the basis which illumia Medical Pte Ltd and its affiliates (“we”, “us”, or “our”) may collect, use, disclose or otherwise process your personal data in accordance with the Personal Data Protection Act 2012 (“PDPA”). This Policy supplements the Terms and Conditions of our Service (“T&C”).
This Policy 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, through your use of our mobile application[, website] and services (collectively, “Services”).
1. PERSONAL DATA
1.1 “Personal data” means data, whether true or not, about an individual 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. Other terms used in this Policy shall have the meanings given to them in the PDPA (where the context so permits).
1.2 Depending on the nature of your interaction with us, some examples of personal data or other information which we may collect from you include:
(a) Profile information such as name, identity no., residential address, email address, photo, gender, contact number, date of birth and medical histories.
(b) Any other information disclosed by you in any of the above-mentioned methods and/or through the use our Services.
(c) Aggregate data collected through the use of our Services.
(d) Any communications between you and other user(s) of our Services.
2. COLLECTION OF PERSONAL DATA
2.1 We only collect your personal data (a) if it is provided to us voluntarily by you directly or after (i) you have been notified of the purposes for which the data is collected, and (ii) you have provided consent to the collection and use 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).
2.2 We may collect and receive personal data from you in the following situations:
(a) When you register for an account with us.
(b) When you use the features and functions available on our Service.
(c) If you contact us, for example, with a query or to report a problem or provide feedback.
(d) When you register for a survey, campaign, contest and/or lucky draw with us.
(e) When you interact with us using our Services, offline or through an external third party.
2.3 You are under no obligation to provide your personal data to us. However, if you choose to withhold your personal data or to revoke permission for us to receive your personal data, we may be unable to provide certain aspects of our Services to you.
2.4 By providing us with any personal data relating to a third party (including but not limited to information of your spouse, children, parents, and/or employees), you represent to us that you have validly obtained the consent of the third party to provide us with their personal data for the respective purposes.
3. USE OF PERSONAL DATA
3.1 We may use your personal data for any or all of the following purposes:
(a) To provide our Services and customise the content shown to you.
(b) To develop, operate, improve, deliver and maintain our Services.
(c) To verify your identity, update our records and generally maintain your user account with us.
(d) To respond to, handle, and process queries, requests, applications, complaints, and feedback from you.
(e) To process or resolve any dispute arising from or in connection with any interaction between users, in accordance with our T&C.
(f) To manage your relationship with us.
(g) To detect or monitor any frauds, other prohibited content, businesses or activities, or possible violations of our T&C.
(h) To carry out polls, surveys, analysis and research on how our Services are being utilised and how we can improve them.
(i) To update you on matters related to our Services.
(j) To send you marketing and/or promotional materials related to our Services and selected third parties.
(k) To comply with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority.
(l) [To provide a tailored online advertising experience by delivering relevant advertisements based on your interests].
(m) Any other purposes for which you have provided the information.
(n) To transmit 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.
(o) Any other incidental business purposes related to or in connection with the above.
4. DISCLOSURE OF PERSONAL DATA
4.1 We may disclose your personal data in the following ways:
(a) To our potential partners, investors and other parties with a view to a potential business partnership, collaboration, joint venture or otherwise in furtherance of our business.
(b) To any competent law enforcement body, regulatory, government agency, court or other third party if required to do so by law or if we believe that such action is necessary to prevent fraud or crime or to protect our Services or the rights, property or personal safety of any person.
(c) To any other person with your consent to the disclosure.
4.2 We will never sell your personal information to any third party.
5. USE OF OUR SERVICES
5.1 Common sense and good judgement on your part must be used when sharing of information in groups or otherwise during the use of our Services. Our Service offers features which allow users to share information in a one-on-one or group basis. You are responsible for such information shared with other users.
6. WITHDRAWING YOUR CONSENT FOR US TO USE, COLLECT OR DISCLOSE YOUR PERSONAL DATA
6.1 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.
6.2 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 [ten (10)] business days of receiving it.
6.3 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 6.1.
6.4 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.
7. ACCESS TO AND CORRECTION OF PERSONAL DATA
7.1 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.
7.2 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.
7.3 We will respond to your request as soon as reasonably possible. In general, our response will be within [ten (10)] 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).
8. PROTECTION OF PERSONAL DATA
8.1 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 [encryption, and disclosing personal data both internally and to our authorised third party service providers and agents only on a need-to-know basis].
8.2 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.
8.3 You should also protect unauthorised access of your user account and information by choosing a sufficiently strong password, and keeping your password and account secure such as by signing out after using our Services.
9. ACCURACY OF PERSONAL DATA
9.1 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.
10. RETENTION OF PERSONAL DATA
10.1 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.
10.2 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.
11. TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE
11.1 [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.
12. DATA PROTECTION OFFICER
12.1 You may contact our Data Protection Officer if you have any enquiries or feedback on our personal data protection policies and procedures.
13. CONTACT US
13.1 Should you have any further queries, concerns or comments unrelated to our Data Protection Policy, please send an email to illumiatherapeutics@gmail.com, detailing a clear question/comment on the subject header and succinct details of any content you wish to communicate to us.
14. EFFECT OF POLICY AND CHANGES TO POLICY
14.1 This 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.
14.2 We may revise this 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 Policy was last updated. Your continued use of our Services constitutes your acknowledgement and acceptance of such changes.
