This Policy applies to websites and apps owned and operated by us along with the information and services made available to you through our websites and apps, as the “Services.”
This Policy applies to personal data in our possession or under our control, including personal data in the possession of organisations in which we have engaged to collect, use, disclose, or process personal data for our purposes. Collection, use, disclosure, or otherwise processing of the personal data of our users on behalf of government ministries or statutory boards will be in accordance with guidelines set out in the government’s data management policy. We will comply with the relevant requirements under the government’s data management policy.
II. What data do we process
As used in this Policy, “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.
Depending on the nature of your interaction with us and the services we provide to you, some examples of personal data which we may collect from you include name, identification numbers such as NRIC, fin, work permit and birth certificate, contact information such as residential address, email address or telephone number, nationality, ages, gender, date of birth, marital status, medical history, photographs and other audio-visual information, employment information and financial information such as credit card numbers, debit card numbers or bank account information, app/browser and device information.
We may also acquire information from external sources such as partners, vendors, and third parties. We require such external parties to have the right to collect, use and share your information before giving it to us.
III. How do we collect and use 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 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 (please find the mentioned purposes as below), and (ii) you (or your authorised representative) have provided proper 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 applicable data privacy laws. We shall seek your consent before collecting any additional personal data.
We may use your personal data for any or all of the following purposes:
- to provide, improve and create our current and new Services;
- to provide personalised experiences to you, including ads display, to make sure everything you see is interesting and useful to you;
- to respond, handle, and process queries, requests, applications, complaints, and feedback from you and to send you administrative communications about our websites and Services;
- to send you secured electronic messages and personalized emails pertaining to your interests as inferred from your use of the Services, including news, announcements, reminders and opportunities from us;
- to statistically analyze trends and user behavior and activity including how frequently areas of the websites are visited, how the Services are being used and how many emails are received and opened;
- to provide you and people with similar demographic characteristics and interests with more relevant content including advertising both on and off the websites and apps;
- to offer lead generation services;
- to detect and defend against fraud and other threats to the Services and our users;
- to identify issues with the Services;
- to conduct research and measurement activities, including those described below;
- to administer and verify your account and your identity;
- to transmit to any unaffiliated third parties including our partners, service providers, agents, other third parties, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes;
- to send you promotional information (including by direct mail, email, telephone, and text message) or otherwise contact you about products, services, programs or other topics that we think may interest you upon your consents in accordance with the appliable laws;
- to ask you to participate in research based on things such as how you use our Services;
- 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;
- any other purposes for which you have provided the information;
- any other incidental purposes related to or in connection with the above; and
- any other purpose which has not been mentioned above (except where permitted or authorised by laws), we will seek your consent before using your personal data.
The purposes listed in the above clauses may continue to apply even in situations where your relationship with us) 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), except you have explicitly informed us that you withdraw your consent for the aforementioned purposes.
We may combine your personal information and other information collected about your use of the Services, and also supplement with information from external sources for the purposes described in this Policy. For example, information that we collect about you may be combined by us with other information available to us through third parties for research and measurement purposes, including measuring the effectiveness of content, advertising or programs. We may report aggregate information, which is not able to be identified back to an individual user of our websites, to our current or prospective advertisers and other business partners.
See some examples on how we collect and use your personal data
While you may use most of the services without registering, certain services do require that you register for them to function properly. If you choose to register or update an existing account or access certain services, you may be required to provide certain personal information, such as your name, address, telephone number, gender, email address and date of birth, and a username and password to access your account. You are responsible for ensuring the accuracy of the personal information that you submit.
Some of our services, such as Hello Doctor Symptom Checker, are interactive and may request that you submit health-related information, along with other information such as your age and gender. You may be required to register with us to use Hello Doctor Symptom Checker and if you are registered with us, we may associate the information that you submit to the Symptom Checker with the registration information that you have previously provided.
At registration and at various times as you use the websites, you will be given the option of providing us with personal information in order to receive informational/promotional newsletters – such as a newsletter relating to a specific health condition – via email from us and/or directly from third parties. From time to time, we may offer users of third-party websites the opportunity to subscribe to our newsletters through those websites. If you elect to subscribe to one of our newsletters on a third-party website, the operator of that website will provide us with the personal information you have provided in connection with the subscription request, which we may use in accordance with this Policy as though you had provided it directly to us. In the Message Boards, if you turn on the email notification for posts you have created or participated in, you’ll receive an email when there has been any activity on those posts. If you later decide you no longer want to receive email updates, you can turn it off by navigating to the Email Alerts section in your Profile settings.
From time to time, we may conduct online research surveys on behalf of ourselves and third parties through email invitations, pop-up surveys, and online focus groups. When participating in a survey, we may require you to provide your location, age, and if there’s a sweepstake associated with the market research survey, your name, and contact information for purposes of sweepstakes administration. The information you submit in a survey may be used by us for research and measurement purposes, as described below, including to measure the effectiveness of content, advertising, or programs. The personal information you provide in connection with a sweepstake entry will be used for the sole purpose of administering the sweepstakes and as required by applicable laws. Market research surveys conducted by or on behalf of ourselves will contain a link to this Policy.
User Reviews, Message Boards, and Other Public Forums
We also feature several message board areas and other public forums where users can post reviews, share information, and support one another or where users can post questions for experts to answer. We also offer online discussions moderated by healthcare experts. Our reviews feature in the bookings system and our message boards are open to the public and should not be considered private.
Any information (including personal information) you share in any review, online message board, or other forum is by design open to the public and is not private. You should think carefully before posting any personal information in any public forum. What you post can be seen, disclosed to or collected by third parties and may be used by others in ways we cannot control or predict, including to contact you for unauthorized purposes. As with any public forum on any site, the information you post may also show up in third-party search engines.
If you mistakenly post personal information in our message board areas and would like it removed, you can send us an email to request that we remove it by using the Contact Us link on every page of our websites.
Services and Device Information
When you access and use the services, we automatically collect and stores in our server logs information from your browser or mobile devices such as your IP address or unique device identifier, browser information (including referring URL), your preferences and settings, cookies and information about the content you have viewed and actions taken (e.g., search queries, ad engagement, clicks and the associated dates and times). We may also collect device-specific information when you install and use an App including your device model, operating system information, advertising ID (which is a unique, user-resettable identification number for advertising associated with a mobile device) and App version and usage information. When enabled by you, we collect precise location information provided by your mobile device, which you may disable through the device settings.
Cookies and Other Tracking Technologies
We also work with third-party ad networks to display advertising on our websites and on third-party websites. Our ad network vendors use technologies to collect information about your activities on our websites and apps to provide you with cookie-based targeted advertising on our websites and on third-party websites based on your browsing activity and your interests.
IV. How are the personal data shared
We may share and disclose your personal data:
- where such disclosure is required for, or in connection with, the provision of the services requested by you;
- to our partners, clients, third-party service providers, agents, vendors and other organisations we have engaged to perform any of the purposes listed in Section III above for us;
- any other party to whom you authorised us to disclose your personal data to, or where necessary to undertake any action requested by you;
- to our partners, clients and third-parties in order for them to provide more helpful services and promotional information to you (including ads displayed on our websites and/or third-party websites;
- to third parties which you choose to connect with on our websites or who use our products and services; and
- to our subsidiaries and corporate affiliates within Hello Health Groups which will continue to comply with this Policy.
The purposes listed in the above clauses may continue to apply even in situations where your relationship with us) 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), except you have explicitly inform us that you withdraw your consent for the aforementioned purposes.
See some examples on how we share your personal data:
Hello Health Group’s Subsidiaries and Corporate Affiliates
We may share your information with our subsidiaries, affiliates and companies acquired by or merged with us and our affiliates. In the event of a corporate change in control resulting from, for example, a sale to, or a merger with, another entity, or in the event of a sale of assets or a bankruptcy, we may share your personal information with the new party in control or the party acquiring assets. In the event of such a change, your personal information will continue to be treated in accordance with this Policy. Our sharing is to ensure remote safety, security and integrity and comply with applicable laws, to personalize offers, ads and other sponsored or commercial content; to develop and provide features and integrations and to understand how people use and interact with our products and services.
Companies and Contractors that Work with us
We work with third-party companies and contractors that help us provide the services and otherwise assist in the operation of our websites and apps, including those that provide services relating to technology, data analysis, research, email management and deployment, sweepstakes and contest administration, advertising and marketing and/or content. Our contractors sometimes have limited access to your information in the course of providing products or services to us. We contractually require that our contractors not use or disclose your information for any purpose other than providing the limited service or function for us.
Third-Party Advertisers and Third-Party Websites
We may share information that we have about you, such as a cookie ID or IP address, with third-party advertising service providers who may use this information to deliver ads on our websites and on third-party websites which are most relevant to your interests.
We may also include social widgets on our websites which enable you to interact with the associated social media services, e.g., to share an article. These widgets may collect browsing data which may be received by the third-party that provided the widget, and are controlled by these third parties. You may be able to manage your privacy preferences directly with the applicable social network platform.
Partners who offer goods or services on our products and commerce services platforms
When you choose to make a transaction, or otherwise choose to share information with a seller, creator, fundraiser, charity, payment services provider or commerce services platform, we share information with them and with any providers acting on their behalf.
Depending on how you interact with them, they receive:
- Information to complete your transaction, such as order, payment, contact and delivery information
- Information to help ensure the security of the transaction, such as information about your device or connection
- Any information required by applicable regulation
- Other information that you choose to share with them
We share information about you with companies that help market our companies, services and products, measure the effectiveness of our own marketing campaigns and perform advertising research. For example, we share your device identifier or other identifiers with advertising vendors to help us serve you ads most relevant to your interests.
Compliance with Law, Regulation, and Law Enforcement Requests
To cooperate with government and law enforcement officials and private parties to enforce and comply with law, we may release personal information to third parties: (1) to comply with legal requirements such as a law, regulation, search warrant, subpoena or court order; (2) when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request; or (3) in special cases, such as in response to a physical threat to you or others, to protect the property or defend or assert legal rights.
V. Deemed Consent By Notification
We may collect or use your personal data, or disclose existing personal data for secondary purposes that differ from the primary purpose which it had originally collected for pursuant to this Policy. If we intend to rely on deemed consent by notification for such secondary purposes, we will notify you of the proposed collection, use or disclosure of your personal data through appropriate mode(s) of communication.
You will be given a reasonable period to inform us if you wish to opt out of the collection, use and disclosure of your personal data for such purposes.
After the lapse of the opt out period, you may notify us that you no longer wish to consent to the purposes for which your consent was deemed by notification by withdrawing your consent for the collection, use or disclosure of your personal data in relation to those purposes.
VI. Reliance On The Legitimate Interests Exception
In compliance with the applicable personal data privacy laws, we may collect, use or disclose your personal data without your consent for the legitimate interests of ourselves or another person. In relying on the legitimate interests exception of the applicable, we will assess the likely adverse effects on the individual and determine that the legitimate interests outweigh any adverse effect.
In line with the legitimate interests’ exception, we will collect, use or disclose your personal data for the following purposes:
- Fraud detection and prevention;
- Detection and prevention of misuse of services;
- Network analysis to prevent fraud and financial crime, and perform credit analysis; and
- Collection and use of personal data on company-issued devices to prevent data loss.
The purposes listed in the above clause may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter.
VII. How to withdraw 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 or your authorised representative in writing. You or your authorised representative 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 via email or otherwise in writing to our Data Protection Officer at the contact details provided below. If you are unable to submit your request in writing or if you require any assistance with the submission of your request, you can ask to speak to or meet with our Data Protection Officer.
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 thirty (30) days of receiving it.
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 the manner described above.
Please note that withdrawing consent does not affect our right to continue to collect, use and disclosure personal data where such collection, use and disclose without consent is permitted or required under applicable laws.
VIII. How to access and correct 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 via email or otherwise in writing, to our Data Protection Officer at the contact details provided below. If you require assistance with the submission of your request, you can ask to speak to or meet with our Data Protection Officer.
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. In general, our response will be within two (2) 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 applicable laws).
Furthermore, you can correct, update or review the personal information you have previously submitted by going back to the specific service, logging in, and making the desired change. You can also update any personal information you have submitted by contacting us using the contact information listed below or through the Contact Us link provided at the bottom of every page of our websites.
When you sign up to receive email communications for any of our services, including our email newsletters, or at any time, you can choose to opt out of receiving additional newsletters or other email communications from us or our advertisers or sponsors.
You can unsubscribe from an email newsletter by:
- Following the directions included at the bottom of the newsletter and using the “Unsubscribe” link found in the emails.
- Logging in to our websites and unchecking the newsletters you no longer wish to receive under the “My Profile” section.
All promotional emails that we send with opportunities from us or with offers or informational materials from us on behalf of our sponsors will contain an opportunity to unsubscribe from getting additional emails of that type in the future from us unless you re-subscribe.
You may also control interest-based advertising on your mobile device by enabling the “Limit Ad Tracking” setting in your iOS device’s settings or “Opt out of Ads Personalization” in your Android device’s settings. This will not prevent you from seeing advertisements, but will limit the use of device advertising identifiers to personalize ads based on your interests. If you have questions about how to reject cookies on your specific device please check with the device manufacturer.
IX. How are personal data protected
To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate and reasonable administrative, physical and technical measures such as minimised collection of personal data, authentication and access controls (such as good password practices, need-to-basis for data disclosure, etc.), encryption of data, data anonymisation, up-to-date antivirus protection, regular patching of operating system and other software, securely erase storage media in devices before disposal, web security measures against risks, usage of one time password(otp)/2 factor authentication (2fa)/multi-factor authentication (mfa) to secure access, and security review and testing performed regularly. When you enter personal information (including personal health information in various Services), we encrypt the transmission of that information or use SSL connections (Secure Socket Layer) technology.
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. Despite our efforts to protect your personal information, there is always some risk that an unauthorized third-party may find a way around our security systems or that transmissions of your information over the Internet may be intercepted. Please note that you should notify us as soon as possible if you are losing control of your account or knowing or aware that your device is breached and please take responsibility to the safety of your password and account information.
X. 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 at the contact details provided below.
XI. How are personal data retained
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.
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.
XII. TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE
Our technical infrastructure is located in Vietnam. The personal information that you provide to us is stored on servers located in Singapore. If you are located in another jurisdiction, you should be aware that in order to provide the services to you, we must transfer your personal information to Singapore where it will be stored and processed in accordance with this Policy. We may transfer your information outside to service providers with operations in other countries. You hereto consent to such collection, storage and processing in Singapore and other jurisdictions where Hello Health Group maintains a presence in. If we transfer your personal data to countries outside of the above-mentioned scopes, we will obtain your further consent for the transfer to be made
We will take reasonable steps to ensure your personal information is protected with a standard of protection that is at least comparable to the protection of your home jurisdiction or provided under the applicable laws, whichever is stricter.
XIII. How to contact our 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:
- Contact No. : +84 32612 6496
- Email Address : [email protected]
We will endeavor to respond to your request within a reasonable timeframe and may request additional information from you to provide a comprehensive response. Further information may be sought from you in order to provide you with a comprehensive response. You may also contact local Customer Service for any other inquiries.
XIV. EFFECT OF POLICY AND CHANGES TO POLICY
This Policy applies in conjunction with any other Policies, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.
We may revise this Policy from time to time without any prior Policy. You may determine if any such revision has taken place by referring to the date on which this Policy was last updated. If we make any material changes to this Policy, we will notify you by means of a notice on our website and/or by email to our registered users (sent to the email address specified when you register) prior to the change becoming effective. Your continued use of our services and our websites constitutes your acknowledgment and acceptance of such changes.