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MY HEALTHCARE COLLECTIVE PTE LTD PRIVACY POLICY

My Healthcare Collective Pte. Ltd. (“MHC”, “we”, “us” or “our”) is committed to safeguarding the Personal Data you provide to us. This Privacy Policy sets out the basis upon which we will collect, store and process Personal Data that we collect from you.

Overview

By accessing and/or using MHC App and our website at MyHealthcareCollective.com as well as any website or any electronic application owned and/or maintained by MHC or any of its affiliates or related corporations (collectively, the “MHC Sites”) and/or our Services, you hereby acknowledge that you have read MHC’s Terms of Service, including this Privacy Policy, and that you are expressly agreeing to MHC’s Terms of Service and expressly consenting to our collection, use and disclosure of your Personal Data in accordance with this Privacy Policy. Please leave and do not access or use the MHC Sites and/or our Services if you do not agree and accept MHC’s Terms of Service and/or do not consent to the collection, use and disclosure of your Personal Data in the manner set forth in this Privacy Policy.

Do note that MHC reserves the right to amend its prevailing Privacy Policy at any time by posting the amended Privacy Policy at any of the MHC Sites.

Definitions

As used in this Privacy Policy:

"Applicable Law" means all laws, statutes, regulations, codes, by-laws, ordinances, treaties, orders, judgements, decrees, directives, rules, guidelines, orders, policies and other requirements of any Governmental Authority having jurisdiction, whether or not having the force of law, and includes other instruments under it and consolidations, amendments, re-enactments or replacements of any of them.

“MHC App” means MHC’s electronic health consultation, prescription and delivery application;

“PDPA” means the Personal Data Protection Act (No. 12 of 2012)

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

1. Data Collection and Use

1.1 If you choose to access and/or use the MHC Sites and/or our Services, we may collect and/or and require you to provide certain Personal Data contact and identity information, medical history and other Personal Data as indicated on the online forms in the relevant MHC Site.

“Applicable Law” means all laws, statutes, regulations, codes, by-laws, ordinances, treaties, orders, judgements, decrees, directives, rules, guidelines, orders, policies and other requirements of any Governmental Authority having jurisdiction, whether or not having the force of law, and includes other instruments under it and consolidations, amendments, re-enactments or replacements of any of them.

1.2 Personal Data which we may collect from you may include some or all of the following:

i. your name, identification number (such as passport number, NRIC and FIN), residential or registered address, e-mail, telephone or mobile number, nationality, gender and date of birth;

ii. personally identifiable medical and health-related information which you provide to us such as information or records relating to your medical or health history, health status, laboratory testing results, biometric measurements and diagnostic images;

iii. personally identifiable medical and health-related information about you prepared by healthcare providers and/or treatment providers who provide our Services to you such as medical records and treatment and examination notes;

iv. other information which you may input into the MHC Sites or provide to us pursuant to assist in or facilitate the provision of our Services;

v. financial information such as credit card information or online payment system account information, which we may need to verify the accuracy of your name, address, and other information, detect any fraud or other criminal activity, and/or to bill you for your use of our Services; and

vi. data that we may obtain from time to time in connection with your current and past activities on the MHC Sites.

1.2 Your Personal Data that is collected through the MHC Sites will be used for one or more of the following purposes:

i. to provide our Services to meet your healthcare needs. The provision of Services would include verifying your identity, responding to, handling and processing queries, requests, applications, complaints and feedback, facilitating and managing your relationship with us, processing or facilitating the processing of your claims for medical care, processing various forms of payment or credit transactions, and maintaining the MHC Sites;

ii. to improve the quality of our Services through the performance of quality reviews and similar activities and creating de-identified or anonymised information which is not used or intended to be used to personally identify an individual for the purposes of data analytics and research);

iii. to track certain information based upon your behaviour on the MHC Sites. We use this information to do internal research on our users’ demographics, interests, and behaviour to better understand, protect and serve our users in general and you in particular. This information may include information about the computer or mobile device you are using, and your IP address, site activity, browser type, connection speed, access times and physical location;

iv. where you have provided your consent, to market and promote our Services to you through promotional messages, newsletters, e-mails and text message;

v. to comply with any Applicable Laws, or assist in any law enforcement and investigations conducted by any governmental and/or regulatory authority;

vi. for any other purposes for which you have provided the information; and

vii. for any other incidental business purposes relating to or in connection with the above.

The Personal Data that we collect may be provided to us by you or via a third party (for example, your employer or insurer if they process or facilitate the processing of your claims for medical care and/or utilisation of your healthcare and/or employee and/or insurance healthcare benefit needs) who has been duly authorised by you to disclose your Personal Data.

1.3 Cookies

We may use data collection devices such as “cookies” on certain pages of the MHC Sites to promote trust and security, help analyse our web page flow and measure promotional effectiveness. “Cookies” are small files placed on your hard drive that assist us in providing the MHC Sites and/or our Services. We may offer features that are only available through the use of a “cookie”. We also use “cookies” to reduce the number of times you need to enter your password. “Cookies” can also help us provide you with information that is targeted to your interests. You may reject or decline our “cookies” (if your browser permits you to do so), although in that case you may not be able to use certain features on the MHC Sites and you may be required to enter your password more frequently during a session on the MHC Sites.

2. Protection of Personal Data

2.1 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.

2.2 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.

3. Retention of Personal Data

3.1 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.

3.2 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.

4. Sharing with and Disclosure to Third Parties

4.1 As a matter of policy, your Personal Data will not be shared or disclosed to third parties (whether for their marketing purposes or otherwise) without your consent. However, we reserve the right to disclose your Personal Data to:

i. our subsidiaries, affiliates and/or related corporations;

ii. our third party service providers (including the panel of healthcare providers and their nurses and staff, pharmacies, any third party service provider which hosts or manages data from the MHC Sites, credit, debit and charge card companies, banks or other entities processing payment instructions given by you through the MHC Sites, lawyers, auditors, any other agents or subcontractors acting for and on our behalf);

iii. your employer, medical provider(s), insurer(s), insurance agent(s) and/or other relevant parties who may assist with registration with the relevant healthcare services and/or facilitate the processing of your claims for medical care and/or utilisation of your healthcare and/or employee and/or insurance healthcare benefit needs;

iv. government or regulatory authorities (including the Ministry of Health of Singapore); and/or

v. limited information to facilitate the delivery of prescriptions.

whether within or outside of Singapore, to the extent required in the normal course and scope of our business in the provision of our Services, where required by Applicable Law or court order, and/or where we believe in good faith that disclosure is necessary to protect your safety or the safety of others, or our rights, or investigate fraud.

4.2 We also reserve the right to disclose your Personal Data to a potential buyer or other successor in the event of a merger, divestiture, restructuring, reorganisation, dissolution or other sale or transfer of some or all of MHC’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, where personal data maintained on the MHC Sites is among the assets transferred and/or any other person or organisation disclosed by us when you provide the information.

4.3 The purposes listed in the above clauses may continue to apply even in situations where your relationship with us has ceased or been altered in any way, for a reasonable period thereafter.

4.4 If you use or agree to the use of our Services pursuant to your healthcare and/or employee and/or insurance healthcare benefit plan, you agree and hereby authorise MHC to share basic identification information and, where necessary, medical data, including information relating to your diagnosis, referral, management and treatment through the MHC Sites with your employer, medical provider(s) and insurer(s) and their respective related companies and/or other relevant parties who may process or facilitate the processing of your claims for medical care and/or utilisation of your healthcare and/or employee and/or insurance healthcare benefit needs and consent to and authorise any of them to share the same with any relevant party for the purposes of processing or facilitating the processing of your claims for medical care and/or utilisation of your healthcare and/or employee and/or insurance healthcare benefit needs.

5. Accessing and Updating your Data

If you wish to access, update or otherwise change or remove any personal data that you provide for MHC’s use, please send us an email at info@myhealthcarecollective.com for assistance. However, if you remove any personal data, which is necessary for us to provide you with Services, our provision of our Services to you may become impossible, impeded or deficient. 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 is required under Applicable Laws.

6. Governing Law

This Privacy Policy is governed by and shall be construed in accordance with Singapore law, without giving effect to any principles of conflicts of law. By accessing and/or using the MHC Sites and/or our Services and providing personal data or information requested, you agree to submit to the exclusive jurisdiction of the Singapore courts.

7. Contact

If you have further questions about this Privacy Policy or wish to contact us regarding our privacy practices and policies, please do not hesitate to send us an email at info@myhealthcarecollective.com.