Privacy Policy

This Privacy Policy outlines the principles under which Digital Health Pte Ltd and our medical partners (Health Screening Centre Pte Ltd, Kingsway Medical Clinics, "we", "us", or "our") may collect, use, disclose, or otherwise handle your personal information when using our website at https://www.Remedy.sg/ ("Website") and/or associated websites (https://www.OnlineDoctor.sg/, https://www.DigitalHealth.sg/) and/or the Digital Health Web Apps ("Software/Application(s)"), in compliance with the Personal Data Protection Act 2012 ("PDPA").

This Privacy Policy is applicable to personal information in our possession or under our control, including personal information held by organizations we have engaged to collect, use, disclose, or process personal information for our purposes. If you disagree with this Privacy Policy and our Terms and Conditions, please refrain from using any of the Platforms. Your ongoing use of the Platforms and our services signifies your acknowledgment and acceptance of this Privacy Policy.

As our partnering medical provider, Kingsway Medical (Braddell) Clinic may collect, use, handle, and disclose personal information that has been shared with or gathered by them under this Privacy Policy, as it is updated periodically, for the purposes of providing medical care. Your continued use of the video consultation feature following any changes indicates acceptance of any revised privacy policy.

Digital Health Pte Ltd is not responsible for any collection, usage, handling, or disclosure of your personal information by Kingsway Medical Clinics. For additional information, please refer to the section "Disclosure to Kingsway Medical Clinics" below.

Definitions

Customer: An individual who has engaged with any of our platforms in any way or has entered into a contract for the provision of healthcare services or products.

Kingsway Medical Clinic: refers to:

Kingsway Medical (Braddell) Pte. Ltd.

Personal data: Any data about an individual who can be identified from that data, either on its own or in combination with other information that is in the possession of, or likely to come into the possession of, a data user.

Other terms used in this Privacy Policy shall have the meanings assigned to them in the PDPA (where the context permits).

1. Personal Information Provided by the Individual

Depending on your interactions with us and the Services, we may collect various types of personal and sensitive information from you. The personal information we gather is based on your choices and the features you use, which may include:

a. Personal Identification Information:

Full name
Identification numbers (e.g., NRIC, Passport Number, FIN)
Residential address
Email address
Phone number
Nationality
Gender
Date of birth
Contact preferences
Billing addresses
Debit/credit card numbers
Contact or authentication data

b. Health-Related Data You Provide:

Medical history
Health condition
Laboratory test results
Diagnostic images
Photographs
Reports
Medical claims

c. Medical and Health Information Prepared by Healthcare Professionals:

Medical records
Treatment and examination notes
Laboratory test outcomes
Diagnostic images

d. Billing Details:

Credit card or online payment system account information

e. Device Information:

Information about the computer or mobile device you use

f. Geographical Location or Address

g. Biometric Data or Information Revealing Race or Ethnic Origin:

When necessary and permitted by applicable law or with your consent

h. Any Other Information You Input into the Platforms or Associated Services

Please ensure that all personal information you provide to us is accurate, complete, and up-to-date, and inform us of any changes to such information. You are responsible for submitting truthful and accurate information, and our company will not be responsible for errors or omissions made by you.

2. Collection, Use, and Disclosure of Personal Information

2.1 We generally do not collect your personal information unless:

You or an authorized third party provides it to us voluntarily for the purposes outlined in this Privacy Policy, including your employer or insurer if they process your medical care claims.
We may collect and use your personal information without your consent if it is permitted or required by the PDPA or other laws.

2.2 Age Requirements

Our application is intended for users who are 18 years or older. We do not knowingly collect information from or market to individuals under 18 years of age. If we discover that we have collected personal information from users under 18 years of age, we will deactivate the account and delete such data from our records. If you find any data we may have gathered from children under 18, please contact us at hello@digitalhealth.sg.

2.3 Purposes for Collecting and Using Personal Data

We may collect and use your personal data for one or more of the following objectives:

To enable you to create and access your account, and to ensure that your account functions properly. This includes facilitating account creation, authentication, and account management.
To deliver or facilitate delivery of services requested by you (including any medical or healthcare services and the shipment of products purchased by you).
To verify your identity.
To provide support to our users, addressing, managing, and processing inquiries, requests, applications, complaints, and feedback from you.
To facilitate payment or credit transactions for the provision of goods and services.
To improve the quality of medical or healthcare services by performing quality assessments and similar activities.
To generate de-identified data, which is information not used or intended for personally identifying an individual (e.g., aggregate statistics related to the utilization of the services on the Platforms).
To inform you of updates to our platform.
For advertising and promoting the Platforms, as well as the services and products offered on the Platforms to you.
To provide you with health and wellness information.
To comply with any relevant laws, regulations, codes of practice, guidelines, or rules, or to support law enforcement and investigations conducted by any governmental and/or regulatory authority. We may collect, use, and disclose your personal data without your consent to detect and prevent fraudulent activities and misuse of our services (refer to the "legitimate interests" exception under PDPA).
To transform personal data into anonymized data for the purposes of analytics and research to improve health outcomes.
For any other objectives for which you have supplied the information.
To communicate with unaffiliated third parties, including our third-party service providers and agents, and pertinent governmental and/or regulatory authorities, both in Singapore and overseas, for the aforementioned objectives.

2.4 Consent to Being Contacted by the Company & Partnering Entities

In the event we contact you for any of the above objectives, you consent to being contacted via email, text, or call at the email address or telephone number provided to us by you or your authorized representative.

2.5 Disclosure of Personal Data to Kingsway Medical Clinics

If you use our platform for health-related services provided by Kingsway Medical Clinics, any personal data collected or derived during a "Digital Health" video consultation with Kingsway Medical Clinics doctors will be disclosed to Kingsway Medical Clinics. This may include your medical records, documentation, or reports. Kingsway Medical Clinics may collect, use, process, and disclose this personal data in accordance with our privacy policy.

2.6 Use of Anonymous Data

We may passively gather certain information that doesn't directly reveal your identity. This may include device and usage data, such as:

a. Web Analytics, Log, and Usage Data:

Service-related, diagnostic, usage, and performance data automatically collected when you use our Services.
Includes your IP address, device information, browser type, activity details, and device event data such as error reports or hardware settings.

b. Device Data:

Details such as your IP address, device and application identification numbers, location, browser type, hardware model, and operating system.

c. Real-Time Location:

Some features of the Platforms use GPS technology to gather real-time information about the location of your device, allowing the Platforms to connect you with a medical provider near you.

3. Sharing of Personal Data

We may share your personal data when:

Such sharing is essential for fulfilling obligations during or in relation to our provision of goods and services you request.
For any purposes mentioned above:
- With our subsidiaries, associated companies, affiliates, or partners.
- With relevant parties who may handle your claims for medical care (which may include your employer or insurer if you file claims under your employee or insurance benefits scheme or policy). In such cases, we might disclose your medical diagnosis/information to those parties for claims processing and/or utilization verification, if required by them.
- With contractors (including specialists and other healthcare providers), service providers, and other third parties we engage to support our business, who are contractually obligated to maintain personal information confidentiality and use it solely for the purposes we disclose it to them (including logistics service providers and data service providers).
- As mandated by law, which can encompass providing information as required by a court order.
- When we genuinely believe that sharing is necessary to protect your safety or the safety of others, safeguard our rights, investigate fraud, or respond to a government request.
- To a purchaser or other successor in case of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Digital Health Pte Ltd or Kingsway Medical Clinics' assets, whether as an ongoing concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal data maintained on the Platforms is among the assets transferred.
- To any other individual or organization disclosed by us when you provide the information.

4. Retention of Personal Data

The purposes mentioned above may persist even in situations where your relationship with us has ended or changed in any manner, for a reasonable time thereafter (including, where applicable, a period to enable us to enforce our rights under a contract with you).

5. Third-Party Websites

This Privacy Policy solely applies to information we gather through the Platforms and in email, text, and other electronic communications sent through or in connection with the Platforms. This policy does not apply to information collected by any third party. When you click on links on the Platform, you may exit our site. We are not accountable for the privacy practices of other sites, and we encourage you to read their privacy statements.

6. Withdrawal of Consent

Your consent for the collection, use, and disclosure of your personal data will remain valid until you withdraw it in writing. You may revoke consent and request that we 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.

After receiving your written request to withdraw consent, we may need a reasonable amount of time (depending on the complexity of the request and its impact on our relationship with you) to process your request and inform you of the consequences of complying with it, including any legal consequences that may affect your rights and liabilities with us. In general, we aim to process your request within fourteen (14) business days of receiving it.

While we respect your decision to withdraw consent, please note that depending on the nature and scope of your request, we might not be able to continue providing our goods or services to you, and we will notify you before completing the processing of your request. If you decide to cancel your consent withdrawal, please inform us in writing in the manner described above.

Kindly note that withdrawing consent will not impact our right to keep collecting, using, and disclosing personal data when such actions without consent are allowed or mandated by applicable laws. To eliminate any doubt, withdrawing consent does not obligate us to erase any personal data we have already collected. Such retention is subject to prevailing laws, including laws governing retention of medical records.

7. Access to and Correction of Personal Data

If you wish to submit:

An access request for a copy of the personal data we possess about you or information regarding how we use or disclose your personal data.
A correction request to amend or update any of your personal data in our possession.

You may send your request in writing or via email to our Data Protection Officer using the contact details provided below. Such requests should include the requester's details, a description of the personal data requested, and the date and time range when the personal data is believed to have been collected.

Be aware that a reasonable fee may be charged for an access request. If so, we will notify you of the fee before processing your request.

We will reply to your request as promptly as possible. Generally, our response will be within fourteen (14) business days. If we cannot respond to your request within thirty (30) days of receipt, we will notify you in writing within thirty (30) days regarding the time by which we will be able to address your request. If we cannot provide you with any personal data or make a correction as requested, we will typically inform you of the reasons for our inability to do so (except when we are not obligated to do so under the PDPA).

8. Protection of Personal Data

To protect your personal data from unauthorized access, collection, use, disclosure, copying, modification, disposal, or similar risks, we have implemented suitable administrative, physical, and technical measures, such as up-to-date antivirus protection, encryption, and disclosing personal data internally and to our authorized third-party service providers and agents only on a need-to-know basis.

We have implemented appropriate technical and organizational security measures to protect the personal information we process. However, it is important to recognize that no electronic transmission over the Internet or information storage method is entirely foolproof. Despite our continuous efforts to strengthen the security of your information, we cannot guarantee that hackers, cybercriminals, or other unauthorized third parties won't be able to compromise our security and unlawfully collect, access, steal, or modify your information. While we strive to protect your personal information, the transmission of personal information to and from our Services is at your own risk. We recommend that you only access the Services within a secure environment.

9. Accuracy of Personal Data

We generally rely on personal data provided by you (or your authorized representative). To ensure that your personal data is up-to-date, complete, and accurate, please inform us of any changes by contacting our Data Protection Officer in writing or via email at the contact details provided below.

10. Retention of Personal Data

We may allow you to delete some of the records stored on the Application by clicking "Settings" > "Delete." This action will only delete your records from the Application, but a backup copy may be retained under the following circumstances:

We may keep your personal data as long as necessary to fulfill the purpose for which it was gathered or as required or permitted by applicable laws.
We will stop retaining your personal data, or remove the means by which the data can be associated with you when it is reasonable to assume that retaining the data no longer serves the purpose for which it was collected and is no longer necessary for legal or business purposes.

11. Transfer of Personal Data Outside Singapore

We generally do not transfer your personal data to countries outside Singapore. However, if we do, we will take steps to ensure that your personal data continues to receive a standard of protection comparable to that provided under the PDPA.

12. Data Protection Officer

If you have any questions or feedback about our personal data protection policies and procedures or wish to make any request, you can reach out to our Data Protection Officer using the contact information provided below:

Data Protection Officer
Contact No.: +65 8897 7900
Email Address: admin@digitalhealth.sg

13. Updates to This Privacy Policy

This Privacy Policy operates alongside any other notices, contractual clauses, and consent provisions that are applicable to the collection, use, and disclosure of your personal data by us.

We reserve the right to update this Privacy Policy periodically without prior notice. You can determine if any revisions have occurred by checking the date when this Privacy Policy was last modified. By continuing to use our services, you acknowledge and accept any changes made to the Privacy Policy.

Effective Date: 1 May 2024
Last Updated: 4 Oct 2024