DATA PROTECTION NOTICE
This Data
Protection Notice ("Notice") sets out the basis which EM2AI Pte Ltd ("EM2", "we",
"us", or "our") may collect, use, disclose or otherwise process personal data
of persons in accordance with the applicable personal data protection laws and
regulations. This Notice applies to personal data in our possession or under
our control, including personal data in the possession of organisations which
we have engaged to collect, use, disclose or otherwise process personal data
for our purposes.
Personal Data
1.
As used in this Notice:
"person"
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 enter or has entered into a
contract with us for the supply of any products or services by us, or (c) has
submitted a job or internship application with us; and
"personal
data" means data, whether true or not, about an individual 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.
Under the Singapore Personal Data Protection Act
(PDPA), Business Contact Information (e.g., name, company address, company telephone
number) is not considered as personal data so long as it is used strictly for
business-to-business (B2B) transactions.
3.
Depending on the nature of your interaction with
us, some examples of personal data which we may collect from you include your
name, contact information such as your address, email address or telephone
number, nationality, gender, date of birth, marital status, photographs and
other audio-visual information, employment information, education background, and
information about your usage of and interaction with our website.
4.
Other terms used in this Notice shall have the
meanings given to them in the Singapore Personal Data Protection Act (where the
context so permits).
5.
For IDMS users, as a data intermediary, we are
only responsible for the protection, retention limitation and data breach
notification obligations. Kindly contact the clinic you had transacted with for
any enquiries, complaints or requests relating to your personal data.
Collection,
Use and Disclosure of Personal Data
6.
We may collect personal data from our customers,
business partners, contractors, employees and other individuals such as job
applicants. We would only collect, use and disclose data that (a) has been
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") after (i) you (or your authorised representative) have been
notified of the purposes for which the data is collected, and (ii) you (or your
authorised representative) have provided written consent to the collection and
usage of your personal data for those purposes, 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 authorised by law).
7.
These personal data may be furnished to us in
forms filled out by you, app registration, face to face meetings, email
messages, or telephone conversations. We may also keep a record of any contact
you have with us. These data would be collected only for business purposes or
for the purpose(s) stated by us when we gather the personal data from you.
8.
For users of the Consumer App, your personal
data may be extracted from IDMS. Such data would include your medical history, treatments
received, billing related information and images such as x-rays and photos.
9.
The personal data collected may be used for any
or all of the following purposes:
9.1
performing obligations in the course of or in
connection with our provision of the goods and/or services requested by you;
9.2
as part of our business operations;
9.3
for job application and recruitment purposes;
9.4
for billing and reporting, such as for invoicing
and account management purposes;
9.5
sending your marketing information about our
goods or services
9.6
for follow-up action regarding any complaints,
feedback, queries or requests received via our website or any other
communication channels; and
9.7
assisting in law enforcement and investigations
conducted by any governmental and/or regulatory authority.
10.
We may collect, disclose or use your personal
data pursuant to an exception under the Personal Data Protection Act or other
written law such as during the following situations:
10.1
To respond to an emergency that threatens your
life, health and safety or of another individual; and
10.2
Necessary in the national interest, for any
investigation or proceedings.
11.
We may disclose your personal data:
11.1
with your consent, where such disclosure is
required for performing obligations in the course of or in connection with our
provision of the goods or services requested by you;
11.2
to comply with any applicable laws, regulations,
codes of practice, guidelines or rules (e.g. in an emergency or when we receive
a subpoena to disclose your personal data); or
11.3
with your consent, to third party service
providers, agents and other organisations we have engaged to perform any of the
functions listed in paragraph 9
above for us. Any third parties engaged by us will be contractually bound to
keep all personal data confidential.
12.
You have the right of choice regarding the
collection, usage and/or disclosure of your personal data. If you choose not to
provide us with the personal data described in this notice, we may not be able
to perform our obligations as stated in this notice. You have the right to
object to the processing of your personal data and withdraw your consent in the
manner described below.
13.
If you choose not to provide us with your
personal data for the purposes listed in paragraphs 9 and 10, you may submit a request in writing or
via email to our Data Protection Officer at the contact details provided below
or indicate in the personal data collection form submitted to us (if any). By
choosing not to provide us with your personal data, depending on our
relationship, we may not be able to provide services to you or process your job
application. Depending on the complexity of the request and its impact to our
relationship with you, we will not collect or, within 30 days of our receipt of
your request, cease using and/or disclosing your personal data in accordance
with your request.
14.
The purposes listed in paragraph 9 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
any contract with you).
15.
In the case where we receive unsolicited
personal data via email or any other communication channels, the unsolicited
personal data will not be retained and will be securely disposed of
immediately.
Withdrawal
of Consent
16.
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. You may withdraw your consent and request us to
stop 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.
17.
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. Should we require more time to give effect to
a withdrawal notice, we will inform you of the time frame by which the
withdrawal of consent will take effect.
18.
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 in paragraph 16 above.
19.
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
20.
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.
21.
We will respond to your request as soon as
reasonably possible. Before we accede to your access or correction request, we
may need to verify your identity by checking identification document, and the
legitimacy of your request. Should we not be able to respond to your request within
thirty (30) days after receiving your request in writing (including both
electronic and non-electronic methods), 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).
22.
If your request relates to personal data which we
are processing on behalf of another organisation, we will instead forward your request
to the relevant organisation for their necessary action.
23.
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.
Protection
of Personal Data
24.
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 authorised third parties and agents only on a need-to-know
basis.
25.
If there is a need to disclose your Personal
Data to third parties in line with the purposes mentioned in paragraph 11, we will ensure that they provide
sufficient guarantees to us to have implemented the necessary security measures
to protect your Personal Data.
26.
However, 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 personal data and
are constantly reviewing and enhancing our information security measures. In
the event of a personal data breach, we will endeavour to notify the affected
parties no later than within 3 calendar days from when we become aware of the
breach.
Accuracy
of Personal Data
27.
We will make every reasonable effort to ensure
that personal data collected by us or on our behalf is accurate and complete.
28.
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 Officers at the contact
details provided in paragraph 34 below.
Retention
of Personal Data
29.
We may retain your personal data for as long as
it is necessary to fulfil the purpose(s) for which it was collected, or as
required or permitted by applicable laws.
30.
We dispose of or destroy such documents
containing your personal data in a secure manner when the retention limit is
reached and it is reasonable to assume that the permitted purpose is no longer
being served by their retention.
Cross-border
Transfers of Personal Data
31.
Unless for business-related needs, we generally
do not transfer your personal data to other jurisdictions. 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,
including entering into an agreement with the receiving party to accord similar
levels of data protection as those in Singapore.
Data
Breach Notification
32.
In the event a breach of security leading to
accidental or unlawful destruction, loss, alteration, unauthorized disclosure
of, or access to, personal data, we shall promptly assess the impact and if
appropriate, report this breach within 3 calendar days to the Personal Data
Protection Commission (PDPC). We will notify you when the data breach is likely
to result in significant harm to you after our notification to PDPC. We may
also notify other relevant regulatory agencies, where required. If we are a
Data Intermediary, we shall inform the Data Controller immediately of any data
breach so they can promptly assess the impact and comply with their data breach
notification obligation.
Data
Protection Officer
33.
You may contact our Data Protection Officer if
you have any enquiry, feedback or complaint regarding our personal data
protection policies and procedures, if you wish to make any request, or if you
believe that information we hold about you is incorrect or out-dated.
34.
You may contact our Data Protection Officer via
email at dpo@em2.ai
Modifications
35.
We may revise this Notice at any time without
any prior notice. Your continued use of our services and/or products constitutes
your acknowledgement and acceptance of such changes.
Effective: 9 December 2022
Last Updated: 9 December 2022
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