DATA PROTECTION NOTICE

This Data Protection Notice (“Notice”) sets out the basis which Assurance Technology Pte Ltd (“we”, “us”, or “our”) may collect, use, disclose or otherwise process personal data of persons in accordance with the Personal Data Protection Act (“PDPA”). This Notice 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. We will collect, use and disclose individual personal data pursuant to an exception

PERSONAL DATA

1. As used in this Notice:
   • “user” means an individual who has installed and uses mobile app (“App”) services by provided by us (“eHealthAssist”);
   • “personal data” means data, whether true or not, about a user 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.
2. Other terms used in this Notice shall have the meanings given to them in the PDPA (where the context so permits).

COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA

3. We collect personal data from our App users. We would only collect data that have been provided to us voluntarily by you or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”).
4. These personal data would be furnished to us in forms filled out by you during App registration. We may also keep a record of any contact you have with us. This information includes, but is not limited to, your name, phone number, date of birth, identity number, identity type, address, email address, demographic data (such as your gender, marital status, age), medical data (such as your height, weight, medical conditions) or any other information that you may choose to share with us. You may choose not to provide us with any personal information but features that require personal information will not be accessible to you.
5. The personal data collected may be used for any or all of the following purposes:
   1. to verify your identity
   2. to provide the App services
   3. assisting in law enforcement and investigations conducted by any governmental and/or regulatory authority
   4. any other purposes for which you have provided the information
   5. any other incidental usage purposes

6. We may ask you for the following app access permission:
   • Camera – take pictures of wounds or physical objects such as lab results or medical reports or medicines for recording purposes or to show to doctors.
   • Contact – enable you to setup Emergency Contact list
   • Location – enable you to find clinics near you.
   • Telephone – enable you to use the telemedicine function
   • Storage – store your health records in the phone (medicine details, invoices, eMC, & etc)
   • Bluetooth – enable compatible devices to send data into the apps (e.g. glucose meter readings)

You may choose not to deny the app access permission but features that require it will not be accessible to you.

7. We may disclose your personal data:
   1. where such disclosure is required for performing obligations in the course of or in connection with our provision of the App services requested by you; or
   2. to third party service providers, agents and other organisations we have engaged to perform any of the functions listed in clause 5 above for us. The purposes listed in the above clauses 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 (including, where applicable, a period to enable us to enforce our rights under any contract with you).
   3. We may use personal information to provide you with services and information according to your preferences including and not limited to, promotional emails and messages, newsletters, products and services which we think may be of interest to you and contacting you when necessary (such as reminding you of an appointment with a healthcare provider). We may share your personal information with healthcare providers with which you schedule an appointment to visit or in the event of an emergency. We may also need to share your personal information or any other information if we determine in good faith that such disclosure is required by law, in response to legal claims; required to protect and defend our rights, property or legitimate interests; necessary to protect our personal safety, property or other rights and those of our users or employees; or an integral part of a sale of all or part of our business. We will not sell your personal information to third parties.

8. The purposes listed in the above clauses 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 (including, where applicable, a period to enable us to enforce our rights under any contract with you).

WITHDRAWING YOUR CONSENT

9. 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 using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in via email to our Data Protection Officer at the contact details provided below.
10. 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.
11. 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 writing in the manner described in clause 9 above.
12. 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.

ACCESS TO AND CORRECTION OF PERSONAL DATA

13. Upon request and within a reasonable timeframe, we will provide the individual with access to their personal data in accordance with the requirements of the PDPA. Upon receiving your request in writing, we will correct an error or omission in the individual’s personal data that is in our possession or control in accordance with the requirements of the PDPA.
14. 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.

PROTECTION OF PERSONAL DATA

15. 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 up-to-date antivirus protection, encryption and the use of privacy filters to secure all storage and transmission of personal data by us, and disclosing personal data both internally and to our authorised third party service providers and agents 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 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

ACCURACY OF PERSONAL DATA

17. 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.

RETENTION OF PERSONAL DATA

18. 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.
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 purpose for which the personal data was 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. 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.

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:

• Attention to Data Protection Officer
• Email to DPO@eclinic.com.sg or contact +65 65632435.
• Content of your queries, feedback or request

EFFECT OF NOTICE AND CHANGES TO NOTICE

22. This Notice 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.
23. We may revise this Notice 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 Notice was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.

Effective date            :           01/10/2021
Last updated             :           01/10/2021