1.1 This Policy statement provides information on the obligations and policies of The Pill in respect of a user’s Personal Data, whereby the user may be browsing the The Pill website without registering for an account, as a registered user, or as a health care provider. The Pill undertakes to use reasonable efforts in applying, where practicable, those principles and the processes set out herein to its operations.
1.2 The Pill’s officers, management, and members of staff shall use reasonable endeavours to respect the confidentiality of and keep safe any and all Personal Data collected and/or stored and/or disclosed and/or used for, or on behalf of, The Pill. The Pill shall use reasonable endeavours to ensure that all collection and/or storage and/or disclosure and/or usage of Personal Data by The Pill shall be done in an appropriate manner and in accordance with the Act and this Policy.
1.3 By interacting with us, submitting information to us, or signing up for any products or services offered by us, you agree and consent to The Pill as well as to its respective representatives and/or agents (“Representatives“) (collectively referred to herein as “The Pill“, “us“, “we” or “our“) collecting, using, disclosing and sharing amongst themselves your Personal Data, and disclosing such Personal Data to The Pill’s authorised service providers and relevant third parties in the manner set forth in this Policy.
1.4 This Policy supplements but does not supersede nor replace any other consents you may have previously provided to us in respect of your Personal Data, and your consents herein are additional to any rights which we may have at law to collect, use or disclose your Personal Data.
1.5 For the purposes of this Policy, in line with the provisions under the Singapore Personal Data Protection Act 2012 (No. 26 of 2012) (the “Act”), “Personal Data” shall mean data, whether true or not, about an individual customer who can be identified — from that data; or from that data and other information which an organisation has or is likely to have access. Such Personal Data shall also refer to that which is already in the possession of The Pill or that which shall be collected by The Pill in future.
2. Contacting the Data Protection Officer
2.1 Where you legitimately request access to and/or correction of Personal Data relating to you, such Personal Data which is in the possession and control of The Pill, The Pill shall provide and/or correct that data within thirty (30) days and in a manner in accordance with its standard procedures as stated hereinafter.
2.2 In accordance with the Act, The Pill has established a process for receiving and responding to any query or complaint that may arise with respect to the application of this Act. To ensure that The Pill receives your complaints and enquiries, please send the same via email to the Data Protection Officer (the “DPO”) of The Pill at the following email address: email@example.com
2.3 Please note that if your Personal Data has been provided to us by a third party (e.g. a member via a referral process), you should contact that individual to make such queries, complaints, and access and correction requests to The Pill on your behalf.
2.4 Should you not wish The Pill to use your Personal Data for any of the purposes listed in Clauses 3.2 to 3.4, or not to receive promotional materials from The Pill, you may opt out by sending a clearly worded email to the DPO via the email address provided in Clause 2.2. Your request shall be processed within thirty (30) days. Please note however that this may affect our ability to attend to your needs in the event where there is already an existing business relationship.
3. Statement of Practices
Types of Personal Data Collected
3.1 As part of its day-to-day activity, The Pill may collect from you, through various means, including via our websites, smart phone applications and any other forms used by The Pill from time to time, some or all of the following Personal Data:-
- First and last name;
- Postal Address;
- Phone number (mobile and/or home number);
- Office number;
- Fax number;
- Email address;
- Bank account/credit card details;
- Personal Data of your emergency contacts;
- Previous and present employment;
- IP addresses; and
- Photographs and images;
Purpose of Collection of Personal Data
3.2 The above Personal Data mentioned in Clause 3.1 is collected for the purposes of:-
- Tracking and monitoring the usage of our website;
- Generating user information which will help to improve the features and functionality of our website, or creating new features, functionalities and services available on our website;
- Providing customer support for you;
- Providing notices and/or contacting you via email or your user account in relation to your user account, regarding updates to our Terms and Conditions, this Policy, changes to your user account, or for other customer service purposes;
- Informing you of new developments and services of other third parties which we are associated with;
- Connecting you to other users and/or health care providers on our website which may be of relevance and/or interest to you;
- Generating user information which will help to improve the design and quality of our website;
- Investigating illegal activities, if any, being carried out on our website that violates our Terms and Conditions;
- Detecting, addressing and/or preventing technical issues which may arise on our website;
- Customising advertising which you may see when using our website and/or third party websites;
- Identification purposes;
- Conducting market research and client surveys to enhance the provision of our services; and
- Measuring the performance of marketing campaigns carried out by us and providing you with marketing from third parties, if any.
Disclosure of Personal Data
3.3In order to carry out the functions described above, The Pill may, from time to time, disclose your Personal Data between The Pill’s companies.
3.4 Without derogating from any of the above, The Pill may also disclose your Personal Data to the following third parties:-
- Regulators and law enforcement officials;
- Third party service providers and consultants;
- Credit, debit and charge card companies, banks and other entities processing payment;
- Potential buyers or investors of The Pill or any of The Pill’s companies; and
- Any agent or sub-contractor acting on The Pill’s behalf for the provision of The Pill’s services.
3.5 The Pill may disclose your Personal Data to the abovementioned parties also in the occurrence of any of the following events:-
- To the extent that The Pill is required to do so by the law;
- In connection with any legal proceedings or prospective legal proceedings;
- To establish, exercise or defend The Pill’s legal rights;
- To the purchaser (or prospective purchaser) of any business or asset which The Pill is (or is contemplating) selling;
- To any person and/or entity for the purpose of processing such information on The Pill’s behalf;
- To third parties who provide services to The Pill or on its behalf;
- To third parties who The Pill provides services to;
- To any third party that purchases The Pill or The Pill’s business or any part of The Pill or The Pill’s business;
- With your consent; and
- For the purposes of disaster recovery.
Optional Provision of Personal Data
3.6 In some instances, you may also be requested to provide certain Personal Data that may be used to further improve The Pill’s services and/or better tailor the type of information presented to you. In most cases, this type of data is optional although, where the requested service is a personalised service dependent on your providing all requested data, failure to provide the requested data may prevent The Pill from providing the service to you. This type of data includes, but is not limited to:-
- Your first and last name;
- Your age;
- Your gender;
- Your race;
- Your geographic location;
- Your telephone number;
- Your email address;
- Particulars of next of kin;
- Employment details;
- Present/ past employment history;
- Hobbies and leisure activities; and
- Other related products and services subscribed to.
3.7 Under certain circumstances, telephone calls made to any of The Pill’s companies to order and/or service hotlines and/or inquiry telephone numbers are recorded for the purposes of quality control, appraisal, as well as staff management and development. In such an event, by agreeing to this Policy, you hereby give your consent for the collection, use and disclosure of such Personal Data for the purposes of our records, following up with your enquiry and/or transaction, and for quality control and training purposes.
4. Transfer of Personal Data Overseas
Your Personal Data may be processed by The Pill, its affiliates, agents and third parties providing services to The Pill, in jurisdictions outside of Singapore. In this event, The Pill will comply with the terms of the Act.
5. Accuracy of Personal Data
Where possible, The Pill will validate data provided using generally accepted practices and guidelines. This includes the use of check sum verification on some numeric fields such as account numbers or credit card numbers. In some instances, The Pill is able to validate the data provided against pre-existing data held by The Pill. In some cases, The Pill is required to see original documentation before we may use the Personal Data such as with Personal Identifiers and/or proof of address. To assist in ensuring the accuracy of your Personal Data in the possession of The Pill, please inform us of any updates of any parts of your Personal Data by sending a clearly worded email to the DPO at the email address provided at Section 2.2.
6. Protection of Personal Data
The Pill uses commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of your Personal Data and will not knowingly allow access to this data to anyone outside The Pill, other than to you or as described in this Policy. However, The Pill cannot ensure or warrant the security of any information you transmit to The Pill and you do so entirely at your own risk. In particular, The Pill does not warrant that such information may not be accessed, altered, collected, copied, destroyed, disposed of, disclosed or modified by breach of any of The Pill’s physical, technical, or managerial safeguards.
7. Access and Correction of Personal Data
7.1 In accordance with Clause 2.1 of this Policy, you have the right to:-
a. check whether The Pill holds any Personal Data relating to you and, if so, obtain copies of such data; and
b. require The Pill to correct any Personal Data relating to you which is inaccurate for the purpose for which it is being used.
7.2 The Pill reserves the right to charge a reasonable administrative fee in order to meet your requests under Clause 7.1(a). Upon payment of the requisite fee under Clause 7.1(a) and/or receipt of your request under Clause 7.1(b), your request shall be processed within thirty (30) days.
7.3 If you wish to verify the details you have submitted to The Pill or if you wish to check on the manner in which The Pill uses and processes your data, The Pill’s security procedures means that The Pill may request for proof of identity before we reveal information. This proof of identity will take the form of full details of your name, the last 4 characters of your NRIC or Passport or FIN number. You must therefore keep this information safe as you will be responsible for any action which The Pill takes in response to a request from someone using the aforementioned details.
8. Storage and Retention of Personal Data
The Pill will delete, as reasonably possible, or otherwise anonymise any Personal Data in the event that the Personal Data is not required for any reasonable business or legal purposes of The Pill and where the Personal Data is deleted from The Pill’s electronic, manual, and other filing systems in accordance with The Pill’s internal procedures and/or other agreements.
9. Contacting you
To the extent that any of the communication means which you have provided The Pill with (which may include, your telephone number and fax number) is/will be listed on the Do Not Call Registry (the “DNC”), by checking the applicable box, or by any other means of indication, you hereby grant The Pill your clear and unambiguous consent to contact you using all of your communication means you have provided to The Pill including using via voice calls, SMS, WhatsApp, MMS, fax or other similar communications applications or methods, for the purposes as stated above in Paragraph 3.2. This will ensure your continued enjoyment of The Pill’s services.
10. Change Policy
The Pill reserves the right to alter any of the clauses contained herein in compliance with local legislation, and for any other purpose deemed reasonably necessary by The Pill. You should look at these terms regularly. If you do not agree to the modified terms, you should inform us as soon as possible of the terms to which you do not consent. Pending such notice, if there is any inconsistency between these terms and the additional terms, the additional terms will prevail to the extent of the inconsistency.
11. Governing Law
This Policy is governed by and shall be construed in accordance with the laws of Singapore. You hereby submit to the non-exclusive jurisdiction of the Singapore courts.
12.1 This Policy only applies to the collection and use of Personal Data by The Pill. It does not cover third party sites to which we provide links, even if such sites are co-branded with our logo. The Pill does not share your Personal Data with third party websites. The Pill is not responsible for the privacy and conduct practices of these third party websites, so you should read their own privacy policies before disclosure of any Personal Data to these websites.
12.2 The Pill will not sell your personal information to any third party without your permission, but we cannot be responsible or held liable for the actions of third party sites which you may have linked or been directed to The Pill’s website.
12.3 The Pill’s websites do not target and are not intended to attract children under the age of 18 years old. The Pill does not knowingly solicit, collect or maintain personal information from children under the age of 18 years old or send them requests for personal data. If you are under the age of 18 years old, please cease your access and usage of our website at any time or manner.