1. General Principles
As a matter of principle, we try to minimise the amount of personal data we collect from you. We endeavour not to ask for more than that which is required to service your account, provide you access to our Websites and provide the Services you select.
2. Collection of Data
- Personal Data
- your name, age, date of birth, gender, email address;
- billing information that you provide us, for example credit card or online payment system account information.
We use the aforementioned information to open an account for you, verify that you are a unique visitor, and enable you to use our Websites and/or Services.
- Personal Data
- How We Collect Your Data
- How We Collect Your Data
3. Purposes for the Collection, Use and Disclosure of Data
Generally, we collect, use and/or disclose your personal data for the following purposes:
- opening and maintaining your account with us;
- verifying that you are a unique user of our Websites;
- providing you with information or Services you have requested;
- providing you with our Services, and customising our Services to you;
- processing fees for any transactions relating to any other Services purchased or used by you;
- notifying you about changes to our Services;
- improving our Websites and ensuring that the content on our Websites is presented in the most effective manner for you and your device;
- administering our Websites, including internal operations such as trouble shooting, data analysis, testing, research, statistical and survey purposes;
- keeping our Websites safe and secure;
- responding to your queries, requests or feedback;
- enforcing our terms, conditions and policies;
- completing our customer screening and identity verification process including checks in relation to fraud detection and prevention, anti-money laundering, know-your-client and the countering of the financing of terrorism;
- detecting, investigating and preventing fraudulent transactions or illegal activities;
- aggregating data into anonymised statistical data, which we will use for statistical analysis so that we can improve our Websites and/or Services to serve you better;
- with your consent, contacting you and sending you marketing and promotional materials in relation to our Websites and/or Services, as well as the products and services that our subsidiaries and/or affiliates offer, whether they are of interest to you or otherwise. In this regard, if you have provided an incorrect email address (or any other contact detail) (collectively, “Contact Addresses”), you may not receive these communications. We will not be responsible for any breach of personal data protection obligations due to correspondence going to an incorrect Contact Address;
- any other purposes relating to the aforesaid; and
- any other purposes that we may notify you from time to time.
We will take reasonable steps to protect your personal data against unauthorised disclosure. Subject to the provisions of any applicable law, we may disclose your personal data in the following circumstances:
- when we obtain your permission;
- when we find it necessary to disclose your personal data to our subsidiaries and/or affiliates in order to respond to your queries, requests or feedback;
- when we find it necessary to disclose your personal data to third-party service provider(s) who have confidentiality agreement(s) with us, in order to provide the Services indicated to you. The services performed by the third-party service provider(s) may include, without limitation, performing statistical analysis, sending you emails or postal mails, providing user support, arranging for deliveries, or any other service which we deem necessary in order to provide theServices indicated to you;
- when you choose to integrate our Websites with any third-party’s mobile application(s) (for example the Health application provided and maintained by Apple Inc. and/or its subsidiaries and affiliates), whereupon we may disclose your personal data to said third-party in response to requests made by such third-party;
- when we find it necessary to disclose information to a buyer or other successor in the event of a merger or acquisition, restructuring, reorganisation, or other sale or transfer of some or all of Hidoc’s assets, in which your personal data maintained by our Websites is among the assets transferred; and
- when we find it necessary to disclose information to our legal advisors or other professional advisors, or as otherwise authorised or required by law.
For the purposes of disclosure of your personal data under paragraph (4) above, Hidoc shall not integrate our Websites with the third-party’s mobile application(s) unless you grant Hidoc access to said third-party’s mobile application(s). If you grant Hidoc access to the third-party’s mobile application(s), you are deemed to have consented to the disclosure or transfer of your personal data collected by Hidoc and stored on your device to the database which stores your personal data collected by the third-party, in response to requests made by such third-party. You are also deemed to have consented to Hidoc accessing your personal data collected by and stored in the third-party’s database. Hidoc shall not disclose or transfer your personal data collected from the third-party’s database to any other third-party unless Hidoc has obtained your prior consent. For the avoidance of doubt, Hidoc is in no way responsible for the protection of your personal data that is stored in the third-party’s database. You and the third-party are solely responsible for the protection of such personal data. Please therefore review the applicable data protection policies and procedures before integrating our Websites with the third-party’s mobile application(s).
We also reserve the right to disclose your personal data as is necessary to prevent a threat to the life, health or security of an individual or corporate entity. Further, we reserve the right to disclose your personal data, as is necessary, to law enforcement, governmental agencies, or authorised third-parties, in response to a verified request relating to a criminal investigation or alleged illegal activity or any other activity that may expose us to legal liability.
5. Safeguards of Data
As part of our commitment to keeping your personal data in our possession or control secured, we have taken reasonable steps to protect the personal data we collect from you in order to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar
risks. Such measures include, but are not limited to, setup of processes, equipment and software to avoid unauthorised access or disclosure of your personal data. We limit access to your personal data only to Hidoc employees who are reasonably required to come in contact with that information in order to provide Services to you or in order to do their jobs.
While we commit to take reasonable steps to protect the security of the information communicated through our Websites, the Internet is not a secure method of transmitting information. Accordingly we do not assume any responsibility for the information we collect from and disclose to you through the Internet or for any unauthorised access or use of that information. We also cannot and do not guarantee that information we collect from and disclose to you will be received or that it will not be altered before or after its transmission to us or to you, as the case may be. In any event, you agree to not hold us, our subsidiaries or affiliates, our past, present and future employees, officers, directors, contractors, consultants, suppliers, vendors, service providers, agents, representatives, predecessors, successors and assigns liable for any loss or damage of any sort incurred as a result of any misappropriation, interception, modification, deletion, destruction or use of the information provided through our Websites and/or Services.
The security of your personal data also relies on your protection of your personal data. In this regard, we kindly ask that you protect the password given or created by you for your use of our Websites and/or Services without sharing the same with anyone. You agree to inform us as soon as reasonably practicable if you know or suspect that someone else knows your password or believe that the confidentiality of your password has been lost, stolen or compounded in any way or that actual or possible unauthorised transactions have taken place. We are not liable for any damages resulting from any unauthorised and/or fraudulent use of your password.
6. Retention and Transfer of Data
We shall not retain your personal data if it is no longer required to meet the purposes for which they were collected and/or no longer serves a legal and/or business purpose.
Some of the recipients of your personal data (for example, our third-party service providers) may be based in countries outside of Singapore. We are committed to adequately protecting your personal data regardless of where the data resides and to providing appropriate protection for your personal data where such personal data is transferred outside of Singapore. We will make our best effort to ensure that the third-party service providers engaged by us to provide our Services to you will not transfer your personal data to a place outside Singapore without our prior written consent. In the event that we provide such consent, we will make our best effort to procure that the relevant third-party service provider provides a written undertaking to us that your personal data which is transferred outside of Singapore will be protected at a standard that is at least comparable to that under the PDPA. If the relevant third-party service provider transfers your personal data to any person overseas, we will make our best effort to procure that such third-party service provider procures the same written undertaking from such person
If you have provided personal data to Hidoc, you have the right to access, at any time, personal data we hold about you and information about the ways in which your personal data has been or may have been used or disclosed by Hidoc within one (1) year before the date of your request. Where permitted by law, we reserve the right to charge a reasonable administrative fee for services provided to you to enable us to respond to your request for access to personal data. Should an administrative fee be charged, we will provide you with a written estimate of the administrative fee that we will be charging. In exceptional circumstances and where permitted by the applicable laws, we reserve the right to deny you access to your personal data and may provide an explanation as required by applicable laws.
You have the right to correct any personal data held about you that is inaccurate. If you would like to inquire, make any corrections or request deletion of your personal data, please contact our Data Protection Officer at the address stated under Section 13 below.
- Our Response
We will strive to respond to each request for access or correction as soon as reasonably possible or as soon as practicable. We strive to respond to each request within thirty (30) days. If more than thirty (30) days are required for our response, we will inform you in writing before the lapse of thirty (30) days from the date of your request, of the time by which we will respond to your request.
We require your assistance to ensure that your personal data is accurate and complete. As such, please inform us of any changes to your personal data by contacting our Data Protection Officer at the address stated under Section 13 below.
9. Refusal and Withdrawal of Consent
If you prefer not to provide your personal data to us, you may opt not to do so. In addition, you have the right to withdraw your consent for us to collect, use or disclose your personal data at any time by contacting our Data Protection Officer at the address stated under Section 13 below).
However, please note that by denying the provision and/or withdrawal of your personal data, you may not be able to fully use and/or benefit from our Websites and/or Services which may require such personal data.
10. Social Sharing Feature and links to other websites
Our Websites may offer social sharing features, links to social media and other integrated tools owned and/or operated by third-parties who are not related or affiliated to Hidoc. Depending on the settings you use with the entity that provides the social sharing feature or social media, your use of such social sharing feature or social media may enable the sharing of your personal data with your contacts or the public. You are advised to visit the privacy policies of the entities that provide these social sharing features or social media to obtain information about the way they collect, use and/or disclose your personal data.
Should you wish to disable cookies, you may at any time adjust the settings on your browser to do so. However, if you choose to disable cookies, many of the features on our Websites and/or Services will not operate properly.
13. Contact Us
Hidoc Pte. Ltd.
1004 Toa Payoh North