Privacy and Data Protection Policy
This privacy and data protection policy (“Policy”) outlines how we manage your personal data in compliance with the Personal Data Protection Act in Singapore (the “PDPA”). This Policy applies to Tucker Medical and its affiliates, subsidiaries, and associated entities (collectively, “we,” “us,” or “our”).
1. As used in this Policy:
“customer(s)” means an individual (“you”, “your” or your “authorized representative”) who (a) has contacted us through any means to find out more about any goods or services we provide, or (b) may, or has, entered into a contract with us for the supply of any goods or services by us; and “personal data” means data, whether true or not, about a customer who can be identified: (a) from that data; or (b) from that data and other information to which we have access.
2. Depending on the nature of your interaction with us, personal data which we may collect from you includes:
b. identification numbers, including NRIC, FIN, passport number, work permit, and birth certificate
c. residential address
d. email address
e. telephone numbers
g. gender, race, religion
h. date of birth
i. marital status
j. employment information
k. financial information
l. insurance information
m. emergency contact
n. medical information, including genetic data
COLLECTION, USE, AND DISCLOSURE OF PERSONAL DATA
3. We generally do not collect your personal data unless (a) it is provided to us voluntarily by you directly or via a third party which you have duly authorized to disclose your personal data to us after (i) you (or your authorized representative) have been notified of the purposes for which the data is collected, or (ii) you (or your authorized representative) have provided written 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 PDPA or authorized by law. We shall seek your consent before collecting any additional personal data for a purpose that has not been notified to you (except where permitted or required by the PDPA or authorized by law).
4. We may collect and use your personal data for any or all of the following purposes, and we may disclose your personal data to third parties where necessary for the following purposes:
a. verifying your identity;
b. performing obligations during or in connection with our provision of the goods and services requested by you, including medical and allied services;
c. providing customer service (e.g., responding to queries and requests; informing you about service status and product updates; sending you alerts and newsletters);
d. processing payment or credit transactions;
e. complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or assisting in law enforcement and investigations conducted by any governmental and/or regulatory authority;
f. any other purposes for which you (or your authorized representative) have provided the information;
g. verifying insurance authorizations and payments;
h. maintaining customer relations with notification of new developments about us or events featuring our practitioners or consultants; and/or
i. transmitting to any unaffiliated third parties, including our third party service providers and agents, and relevant governmental and/or regulatory authorities, for the aforementioned purposes.
5. We may disclose your personal data to:
a. our service providers and specialist advisers/institutions that have been engaged to provide administrative, financial, legal, accounting, information technology, marketing, research, or other services;
b. other insurers, credit providers, courts, tribunals, law enforcement agencies, regulatory authorities, and other governmental agencies as agreed or authorized by law;
c. where such disclosure is in the course of or in connection with our provision of the goods and services requested by you (or your authorized representative); and/or
d. as permitted or required by the PDPA or authorized by law.
6. 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). This Policy does not limit or replace the purposes for which you provide us with your personal data, which may be expressly stated in any form for submission of personal data to us.
WITHDRAWING YOUR CONSENT
7. The consent that you provide for the collection, use, and disclosure of your personal data will remain valid until it is withdrawn by you (and acknowledged by us) 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.
8. 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.
9. While 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.
10. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use, and disclosure without consent is permitted or required under applicable laws.
ACCESS TO AND CORRECTION OF PERSONAL DATA
11. If you wish to make (a) an access request for a copy of the personal data which we hold about you or information about how we use or disclose your personal data; or (b) a correction request to correct or update any of your personal data which we hold, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.
12. Please note that a reasonable fee may be charged for an access request. We will inform you of the fee before processing your request.
13. We will respond to your request as soon as reasonably possible. In general, our response will be within ten (10) business days. If we are unable to respond to your access request within thirty (30) days after receiving your access 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 or other applicable law).
14. Please note that depending on the request, we will only need to provide you with access to the personal data contained in the documents requested and not to the documents themselves. In those cases, it may be appropriate for us to provide you with confirmation of the personal data that our organization has on record if the record of your personal data forms a negligible part of the document.
PROTECTION OF PERSONAL DATA
15. To safeguard your personal data from unauthorized access, collection, use, disclosure, copying, modification, disposal, or similar risks, we have introduced appropriate administrative, physical, and technical measures, including firewall, endpoint/ antivirus protection, data encryption, backup, and by disclosing personal data both internally and to our authorized third-party service providers only on a need-to-know basis.
16. You should be aware, however, that no method of transmission over the Internet or method of electronic storage is entirely secure. While security cannot be guaranteed, we strive to protect the security of your information and review and enhance our information security measures regularly.
ACCURACY OF PERSONAL DATA
17. We generally rely on personal data provided by you (or your authorized 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 at the contact details provided below.
RETENTION OF PERSONAL DATA
18. We may retain your personal data for as long as it is necessary to fulfill the purposes for which they were collected or as required or permitted by applicable laws.
19. 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 purposes for which the personal data were collected and is no longer necessary for legal or business purposes.
TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE
20. We generally do not transfer your personal data to countries outside of Singapore except in providing goods and services. However, if we do so, 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.
DATA PROTECTION OFFICER
21. 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:
Data Protection Officer
Mr. Lim Jamson
Email Address: email@example.com
EFFECT OF POLICY AND CHANGES TO POLICY
22. This Policy applies in conjunction with any other policies, notices, contractual clauses, and consent clauses that apply concerning the collection, use, and disclosure of your personal data by us.
23. We may revise this Policy from time to time without any prior notice. You may determine if any such revision has occurred by referring to the date on which this Policy was last updated.
24. The laws of Singapore shall govern this Policy. You agree to submit to the exclusive jurisdiction of the Singapore courts.
Effective date: 11/07/2011
Last updated: 01/09/2022