Privacy & Data Policy

DATA PROTECTION NOTICE FOR CUSTOMERS 

This Data Protection Notice (“Notice”) sets out the basis which Advantage Medical Group  Pte Ltd (“we”, “us”, or “our”) may collect, use, disclose, or otherwise process personal data  of our customers 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 organizations which we have engaged to collect, use, disclose or process  personal data for our purposes. 

PERSONAL DATA 

1. As used in this Notice: 

“customer” means an individual 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 or are likely to have access. 

2. Depending on the nature of your interaction with us, some examples of personal  data which we may collect from you include name, residential address, email  address, telephone number, nationality, gender, date of birth, marital status,  

photograph, employment information, financial information, and medical  information. 

3. 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 

4. We generally do not collect your personal data unless (a) it is provided to us  voluntarily by you directly or via a third party who has been duly authorized by you  to disclose your personal data to us (your “authorized representative”) after (i) you  (or your authorized representative) have been notified of the purposes for which the  data is collected, and (ii) you (or your authorized representative) have provided  written consent to the collection and usage of your personal data for those  purposes, including any direct marketing purposes such as WhatsApp marketing, or  (b) collection and use of personal data without consent is permitted or required by  the PDPA or other laws. We shall seek your consent before collecting any additional  personal data and before using your personal data for a purpose which has not been  notified to you (except where permitted or authorized by law). 
5. We may collect and use your personal data for any or all of the following purposes: 

(a) performing obligations in the course of or in connection with our provision of the  goods and/or services requested by you, including pre-employment check-ups; (b)  verifying your identity; (c) responding to, handling, and processing queries, requests,  applications, complaints, and feedback from you; (d) managing your relationship 

with us; (e) processing payment or credit transactions; (f) complying with any  applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law  enforcement and investigations conducted by any governmental and/or regulatory  authority; (g) any other purposes for which you have provided the information; (h)  transmitting to any unaffiliated third parties including our third-party service  providers and agents, and relevant governmental and/or regulatory authorities,  whether in Singapore or abroad, for the aforementioned purposes; and (i) any other  incidental business purposes related to or in connection with the above. (j) with your  consent, providing you with marketing and promotional information about our  services or updates via WhatsApp or other messaging services (collectively, “direct  marketing communications”), in accordance with applicable laws such as the PDPA. 

6. We may disclose your personal data: 

(a) where such disclosure is required for performing obligations in the course of or in  connection with our provision of the goods and services requested by you; or (b) to  third party service providers, agents and other organizations we have engaged to  perform any of the functions with reference to the above-mentioned purposes,  including delivering marketing messages or campaigns on our behalf. 

7. 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 a contract with  you). 

RELIANCE ON THE LEGITIMATE INTERESTS EXCEPTION 

8. In compliance with the PDPA, we may collect, use or disclose your personal data  without your consent for the legitimate interests of Advantage Medical Group Pte  Ltd or another person. In relying on the legitimate interests exception of the PDPA,  Advantage Medical Group Pte Ltd will assess the likely adverse effects on the  individual and determine that the legitimate interests outweigh any adverse effect. 
9. In line with the legitimate interests exception, we will collect, use or disclose your  personal data for the following purposes: 

(a) Fraud detection and prevention; (b) Detection and prevention of misuse of  services; (c) Collection and use of personal data on company-issued devices to  prevent data loss; and (d) To provide necessary medical services, including pre employment check-ups. 

The purposes listed in the above clause 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. 

WITHDRAWING YOUR CONSENT

10. The consent that you provide for the collection, use and disclosure of your personal  data will remain valid until such time it is withdrawn by you in writing. This includes  any consent you have given for receiving direct marketing communications (e.g.,  WhatsApp marketing messages). 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. 
11. 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 five (5) business days of receiving it. 
12. 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 (including certain promotional or  marketing benefits), 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  10 above. 
13. 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 

14. If you wish to make (a) an access request for access to a copy of the personal data  which we hold about you or information about the ways in which we use or disclose  your personal data, or (b) a correction request to correct or update any of your  personal data which we hold about you, you may submit your request in writing or  via email to our Data Protection Officer at the contact details provided below. 
15. 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. 
16. We will respond to your request as soon as reasonably possible. In general, our  response will be within five (5) business days. Should we not be able to respond to  your request within thirty (30) days after receiving your 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). 

PROTECTION OF PERSONAL DATA 

17. 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 such as minimized  collection of personal data, authentication and access controls (such as good 

password practices, need-to-basis for data disclosure, etc.), encryption of data, data  anonymization, up-to-date antivirus protection, regular patching of operating system  and other software, securely erase storage media in devices before disposal, web  security measures against risks, usage of one-time password (OTP)/2-factor  authentication (2FA)/multi-factor authentication (MFA) to secure access, and  security review and testing performed regularly. 

18. 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 

19. 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 or via email at the contact details provided  below. 

RETENTION OF PERSONAL DATA 

20. We may retain your personal data for as long as it is necessary to fulfill the purpose  for which it was collected, or as required or permitted by applicable laws. 21. 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. 

Data Retention: 

• Medical Records: We retain medical records for periods necessary to fulfill the  purposes for which they were collected, or as required by applicable laws and  regulations. This includes: 

o Digital Records: Retained for the lifetime of the individual (defined as up to  110 years of age) plus an additional 6 years. 

o Paper Records: Retention periods vary based on the individual’s status (adult,  minor, or person lacking mental capacity) and range from 15 years after the  last treatment or consultation to the individual’s lifetime plus an additional 7  years. 

• Billing Records: Billing records will be retained for a period of 7 years following the  completion of a transaction or the creation of the record, in accordance with the  regulations set by the Monetary Authority of Singapore (MAS). 
• Insurance Records: Records related to the provision of insurance are retained for the  lifetime of the policy. For servicing of an insurance policy that is still in force, records  are retained for the duration of the policy and 7 years following the termination of  business relations with the individual.

TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE 

22. The personal data that we collect from you may be transferred to, maintained,  accessed, and stored at a destination outside the country where you are located. In  order to support the provision of our services, we may transfer personal data to our  third-party sub-processors and service providers outside of Singapore. By submitting  your personal data, you agree to this transfer, storing, and processing. 

Where personal data is transferred by us to any third parties outside of Singapore, we will  ensure that such transfers are compliant with the requirements under the PDPA, such as by  making sure that overseas recipients are bound by legally enforceable obligations to provide  a standard of protection to the personal data so transferred that is comparable to the  protection under the PDPA. 

DATA BREACH NOTIFICATION 

23. In 2021, the Personal Data Protection Commission (PDPC) introduced the Personal  Data Protection (Notification of Data Breaches) Regulations, which mandate data  breach notifications. These regulations include a list of prescribed data classes,  deemed to cause significant harm to individuals (“whitelist”), and outline how  organizations must notify affected individuals and authorities in the event of a data  breach. 

Specified Medical Information: 

The PDPA whitelist includes specified medical information. Table 1 lists the types of medical  information subject to breach notification requirements if compromised.