Smarter Health Privacy Statement

Smarter Health Pte. Ltd. and its affiliates (“Smarter Health”) are committed to protecting your privacy and ensuring you have a positive experience on our electronic platforms and in using our products and services, and websites. This Privacy Statement describes, inter alia, how we handle personal information and the choices available to you regarding the use of, your access to, and how to update and correct your personal information. Additional information on our personal information practices may be provided in notices provided at the time of data collection. This Privacy Statement applies to personal data in our possession or under our control, including personal information in the possession of organisations which we have engaged to collect, use, disclose or process personal data for our purposes.

Collection, Use and Disclosure of Your Personal Information

We may collect information, including personal information, about you or your customers, as you use our websites and interact with our electronic platforms. “Personal information” is any data or information, whether true or not, that can be used to identify an individual, and may include name, address, email address, phone number, clinic name, or MCR number. If we link other data with your personal information, we will treat that linked data as personal information. We also collect personal information from trusted third-party sources and engage third parties to collect personal information to assist us.

We may collect and use personal information for any or all the following purposes (“Purposes”):

(i) Performing obligations during or in connection with our provision of products and services requested by you (e.g. processing your order, booking of transactions).

(ii) Verifying your identity.

(iii) Managing your relationship with us.

(iv) Processing registrations related to any events organised by us.

(v) Communicating with you regarding any specific event for which you registered.

(vi) Communication to market and promote the products and services offered to you.

(vii) Personalising your online experience.

(viii) Responding to, handling, and processing queries, requests, applications, complaints, and feedback from you.

(ix) Complying with any applicable laws, regulations, codes of practice, guideline, or rules, or to assist law enforcement and investigations conducted by any governmental and/or regulatory authority.

(x) Converting the personal data to anonymised data for the purposes of analytics and market research.

(xi) Any other purposes for which you have provided the personal information.

(xii) Transmitting to any unaffiliated third parties including third party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the purposes.

(xiii) Any other incidental business purposes related to or in connection with the above.

We and the third parties we engage may combine the information we collect from you over time and across our electronic platforms with information obtained from other sources. This helps us improve its overall accuracy and completeness and better tailor our interactions with you.

If you choose to provide Smarter Health with a third party’s personal information (such as name, email, and phone number), you represent that you have the third party’s permission to do so. Third parties may unsubscribe from any future communication by contacting dpo@smarterhealth.sg.

In some instances, as you use our websites, Smarter Health and the third parties we engage may automatically collect data through cookies, web logs, web beacons, and other similar applications. This information is used to better understand and improve the usability, performance, and effectiveness of the websites and to help tailor content for you.

We may disclose your personal data where: (i) such disclosure is required for performing obligations during or in connection with our provision of goods and services to you; or (ii) for any of the Purposes:

(i) To our subsidiaries, related companies, affiliates, or partners for purposes of data processing or storage.

(ii) To business partners, suppliers, authorized third-party agents, or contractors we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them. Examples include but are not limited to: hosting websites, hosting seminar registration, assisting with sales-related efforts or post-sales support, and providing customer support.

(iii) To co-organisers of any event as reasonable necessary for the management and organisation of the specific event for which you registered.

(iv) In connection with, or during negotiations for, any merger, sale of company assets, consolidation, restructuring, financing, or acquisition of all or part of our business by another company.

(v) In response to a request for information by a competent authority if we believe disclosure is in accordance with, or is otherwise required by, any applicable law, regulation or legal process.

(vi) When we believe in good faith that disclosure is necessary to protect your safety or the safety of others, to protect our rights, to investigate fraud, or to respond to a government request.

(vii) To any other person or organisation disclosed by us when you provide the information.

This Privacy Statement applies solely to information collected through our websites and via email, text, and other electronic communications. It does not cover information collected via external third parties’ websites. If you click on links on our websites that direct you to external sites, please note that we are not responsible for the privacy practices of those sites, and we encourage you to review their privacy policies.

Withdrawing Your Consent

The consent you provide for the collection, use, and disclosure of your personal information will remain valid until withdrawn by you in writing. You may withdraw your consent by submitting a request via email to the contact details provided below.

Upon receiving your request, we may require a reasonable amount of time (depending on the complexity of your request and its effect on our relationship with you) to process it and to inform you of any potential consequences. Generally, we aim to process your request within ten (10) business days.

While we respect your decision to withdraw consent, please note that depending on the nature and scope of your request, we may be unable to continue providing goods or services to you. In such cases, we will notify you before finalizing the withdrawal process. Should you wish to cancel your withdrawal, please notify us via email to the contact details provided below.

Withdrawing consent does not affect our right to collect, use, or disclose personal information where such actions are permitted or required by applicable laws.

Access to and Accuracy of Your Personal Information

If you wish to make (a) a request for access to a copy of the personal information we hold about you, or to obtain details on how we use or disclose your personal information, or (b) a request to correct or update any personal information we hold about you, please submit your request via email to the contact details provided below. Your request should include your details, a description of the personal information being requested, and the date and time range during which the data was believed to have been collected.

We make good faith efforts to honour reasonable requests to access or correct your data if it is inaccurate. We will respond to your request within thirty (30) days.

Your Choices and Selecting Your Communication Preferences

By using our websites or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the websites. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on our websites or by sending an email to you. You may have a legal right to receive this notice in writing. To withdraw your consent from receiving electronic notice of a security breach, please notify us.

Security of Your Personal Information

We intend to protect the personal information entrusted to us and treat it securely in accordance with this Privacy Statement. Smarter Health implements physical, administrative, and technical safeguards to help protect your personal information from unauthorized access, use, or disclosure. We also require that our suppliers protect such information from unauthorized access, use and disclosure. The Internet, however, cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any personal information you provide to us.

Retention of Personal Information

We will retain your personal information as needed to fulfil the purposes for which it was collected. We will retain and use your personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We will cease to retain your personal information, or remove the means of associating it with you, as soon as it is reasonable to assume that retention no longer serves the purpose for which it was collected and is no longer required for legal or business purposes.

Use of Cookies and other Web Technologies

Like many websites, Smarter Health uses automatic data collection tools, such as cookies, embedded web links, and web beacons. These tools collect certain standard information that your browser sends to our websites such as your browser type and the address of the websites from which you arrived at our website. They may also collect information about:

(i) Your Internet Protocol (IP) address. This is a number automatically assigned to your computer whenever you are surfing the web. It allows web servers to locate and identify your computer, this is a unique address assigned to your PC by your Internet service provider or information systems department on a TCP/IP network.

(ii) Clickstream behaviour. For example, the pages you view and the links you click.

These tools help make your visit to our websites easier, more efficient, and more valuable by providing you with a customized experience and recognizing you when you return.

Our websites includes widgets, which are interactive mini-programs that run on our site to provide specific services from another company (such as displaying the news, opinions, music, and more). Personal information, such as your email address, may be collected through the widget. Cookies may also be set by the widget to enable it to function properly. Information collected by this widget is governed by the privacy policy of the company that created it. Our widget may have an import contacts feature to help you email your contacts. At your request, we will search your email address book to help you import your contacts to our website.

Some web browsers may give you the ability to enable a “do not track” feature that sends signals to the websites you visit, indicating that you do not want your online activities tracked. This is different than blocking or deleting cookies, as browsers with a “do not track” feature enabled may still accept cookies. There is currently no industry standard for how companies should respond to “do not track” signals, although one may develop in the future. We do not respond to “do not track” signals at this time. If we do so in the future, we will describe how in this Privacy Statement.

We partner with third parties to either display advertising on our website or to manage our advertising on other sites. Our third party partners may use cookies or similar technologies in order to provide you with advertising based upon your browsing activities and interests.

Linked Websites

We may provide links to other third-party websites and services that are outside our control and not covered by this Privacy Statement. Please note that we are not responsible for the privacy practices of those sites, and we encourage you to review the privacy statements posted on those websites (and all websites) you visit.

Consent to Transfer, Processing and Storage of Personal Information

We generally do not transfer your personal data to countries outside of Singapore. 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.

By using our goods and services, websites or providing any personal information to us, where applicable law permits, you consent to the transfer, processing, and storage of such information outside of Singapore where data protection standards may be different.

Updates to this Privacy Statement

We may update this Privacy Statement from time to time without any prior notice. If we modify our Privacy Statement, we will post the revised version here, with an updated revision date. You agree to visit these pages periodically to be aware of and review any such revisions. If we make material changes to our Privacy Statement, we may also notify you by other means prior to the changes taking effect, such as by posting a notice on our websites or sending you a notification. By continuing to use our website after such revisions are in effect, you accept and agree to the revisions and to abide by them.

Contacting Us

You have the choice on how your personal information it can be used and shared. To exercise your data protection and privacy rights, contact us anytime at dpo@smarterhealth.sg.

The Smarter Health Privacy Statement was revised and posted as of 23 September 2024.