PRIVACY & DATA PROTECTION POLICY
We are dedicated to safeguarding your privacy and are committed to maintaining the confidentiality of the Personal Data and information that you submitted through Minmed’s Website or Application. These Personal Data, comprising identity data, contact data, account data, and/or medical data, are collected and used to provide medical and wellness services tailored to meet your healthcare needs.
Collection, Use and Disclosure of Personal Data
We generally do not collect your personal data unless
- it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”, such as your parent, spouse, children, employer, medical claims insurer, specialists, diagnostic and medical laboratories, and other healthcare providers of your medical care) after
- you (or your authorised representative) have been notified of the purposes for which the data is collected, and
- you (or your authorised representative) have provided written consent to the collection and usage of your personal data for those purposes, or
- 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 authorised by law).
If you provide us with Personal Data related to a third party (e.g. your employee, spouse, children, and/or parents), you are deemed to be the authorised representative of that third party and have obtained the necessary consent to provide us with their Personal Data for the specified purposes.
We may collect and use your personal data for any or all of the following purposes:
- performing obligations in the course of or in connection with our provision of the goods and/or services requested by you;
- verifying your identity;
- responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
- managing your relationship with us;
- processing payment or credit transactions;
- 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;
- any other purposes for which you have provided the information;
- 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
- any other incidental business purposes related to or in connection with the above.
We may disclose your personal data:
- 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;
- to third party service providers, agents and other organisations we have engaged to perform any of the functions with reference to the above mentioned purposes; or
- to assist a bona fide law enforcement agency or any governmental or authorised agency responsible for government or public safety and/or security in the performance of their function as required by law.
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).
To enhance service efficiency, we may use mechanisms to analyze traffic patterns and profiles in Minmed Website or Application. These mechanisms do not personally identify you but may collect technical details about your computer or mobile device, such as hardware model, operating system version, browser type and version, Internet Protocol (IP) address, advertising identifier, unique application identifiers, unique device identifiers, browser type, language, wireless network, and mobile network information. You can configure your browser to notify you of received ‘cookies’ and choose to accept or reject them.
Protection of Personal Data
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 minimised collection of personal data, authentication and access controls (such as good password practices, need-to-basis for data disclosure, etc.), encryption of data, 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.
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.
Withdrawing your Consent
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 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.
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.
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 above.
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.
As a licensed healthcare institution in Singapore, we are obligated to maintain your Medical Records according to the regulations outlined in Annex B of the National Guidelines for Retention of Medical Records. We are committed to respecting your deletion requests for Medical Records based on the rights defined in the Personal Data Protection Act but are restricted by the overriding legislation.
You may request the deletion of your account within Minmed Website and/or Application by emailing [email protected] or through the in-app function ‘Account Deletion’. However, Medical Records will be retained as required by Annex B of the National Guidelines for Retention of Medical Records.
We may periodically share news, information, and updates about related activities and services via mail, email, and/or SMS. To opt-out, please use the ‘unsubscribe’ function or email us at [email protected].
Access and Correction of Personal Data
If you wish to make
- 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
- 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.
Please include in your request the details of the requester, a description of the personal data to be accessed or corrected, and the date and time range when the personal data was believed to be collected.
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.
We will respond to your request as soon as reasonably possible. In general, our response will be within ten (10) 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).
Accuracy of Personal Data
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
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.
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
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
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:
Email Address : [email protected]
Address : 8 Kaki Bukit Avenue 1, #02-05/6/7, S417941
Effect of Policy and Changes to Policy
This Policy 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.
We may revise this Policy 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 Policy was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.
Last Updated: 31 December 2023