PRIVACY POLICY
1. INTRODUCTION
1.1 Welcome to www.healthbeta.co, cloud.healthbeta.co and/or the BETA mobile application operated by Health BETA Pte. Ltd. and/or its affiliates (“BETA”). BETA takes the privacy of its Users seriously and is committed to respecting the privacy rights and concerns of all Users of the Platform and/or the Services.
1.2 This Privacy Policy is designed to assist the User in understanding how BETA collects, uses, discloses and/or processes (a) the Personal Data and information the User has provided to BETA; and/or (b) the Personal Data and information that BETA possesses in relation to the User.
1.3 BETA may update this Privacy Policy from time to time. Any changes made to the Privacy Policy in the future will be reflected on the Platform. Where permissible under Data Protection Laws, the User’s continued use of the Services or access to the Platform following the modifications, updates or amendments to this Privacy Policy (whether or not the User has reviewed such document) shall constitute the User’s acknowledgment and acceptance of the changes BETA has made to this Privacy Policy. The User agrees that it is the User’s responsibility to review and check the Privacy Policy frequently to see if any updates or changes have been made to this Privacy Policy.
1.4 This Privacy Policy applies in conjunction with other notices, contractual clauses, consent clauses that apply in relation to the collection, storage, use, disclosure and/or processing of the User’s Personal Data by BETA and is not intended to override those notices or clauses unless BETA expressly states otherwise.
1.5 In this Privacy Policy, unless the context otherwise requires, the following general definitions shall apply:
(a) “Data Protection Laws” means applicable laws and regulations relating to the use and/or processing of personally identifiable information and data and privacy.
(b) “Information” means, collectively, all web pages on the Platform, including the information, images, links, sounds, graphics, video, health data, medical data, software, applications, and other materials displayed or made available on the Platform and the functionalities or services provided on the Platform.
(c) “Personal Data” means:
(i) data, whether true or not, about an individual who can be identified:
(1) from that data; or
(2) from that data and other information to which BETA has or are likely to have access; and
(ii) any data that is analogous to the foregoing, as defined in Data Protection Laws.
(d) “Platform” means (a) both the cloud, web and mobile versions of the website operated and/or owned by BETA which is presently located at the following URL: cloud.healthbeta.co and www.healthbeta.co; and (b) the mobile applications made available from time to time by BETA, including the iOS and Android versions.
(e) “Purposes” means the purposes for which BETA collects the User’s Personal Data as set out in this Privacy Policy.
(f) “Services” means the website features, application features for mobile, functions and services provided from time to time through the Platform.
(g) “Physician” or “Technician” means qualified medical professionals licensed to conduct medical practices.
(h) “Users” means the users of the Platform and/or the Services, each a “User”.
2. COLLECTION OF PERSONAL DATA
2.1 Type of User’s Personal Data and information
(a) The Personal Data and information that BETA collects include but is not limited to the following:
(i) name;
(ii) email address;
(iii) mobile or telephone number;
(iv) date of birth;
(v) Government issued identification or other like information National identification number;
(vi) ethnicity (race);
(vii) gender;
(viii) billing and/or delivery address;
(ix) information sent by or associated with the device(s) used to access the Platform and/or the Services;
(x) information about the User’s network, including the User’s contact list when the User share permissions on the User’s device, and the people and accounts the User interacts with;
(xi) medical and health data and records;
(xii) photographs or audio or video recordings;
(xiii) marketing and communications data, such as the User’s preferences in receiving marketing from BETA and third parties, the User’s communication preferences and history of communications with BETA, BETA’s service providers, and other third parties;
(xiv) usage and transaction data, including details about the User’s searches, orders, the advertising and content the User interacts with on the Platform, and other products and services related to the User;
(xv) location data;
(xvi) any other information about the User when the User signs up to use the Services or Platform, and when the User uses the Services or Platform, as well as information related to how the User uses the Services or Platform; and
(xvii) aggregate data on content the User engages with.
(b) The User agrees not to submit any information to BETA which is inaccurate or misleading, and the User agrees to inform BETA of any inaccuracies or changes to such information. BETA reserves the right at it sole discretion to require further documentation to verify any information provided by the User.
(c) If the User does not want BETA to collect the aforementioned information or Personal Data, the User may opt out at any time by notifying BETA’s Data Protection Officer at support@healthbeta.co. Further information on opting out can be found in this Privacy Policy.
2.2 Methods of collecting the User’s Personal Data and information
(a) BETA may collect the User’s Personal Data and information:
(i) when the User registers and/or uses the Services or Platform, or open an account with BETA;
(ii) when the User submits any form, including, but not limited to, application forms or other forms relating to the Services, whether online or by way of a physical form;
(iii) when the User enters into any agreement or provide other documentation or information in respect of the User’s interactions with BETA, or when the User uses the Services;
(iv) when the User interacts with BETA, such as via telephone calls (which may be recorded), letters, fax, face-to-face meetings, social media platforms and emails, including when the User interacts with BETA’s customer service agents;
(v) when the User grants permissions on the User’s device to share information with the Platform;
(vi) when the User carry out transactions through the Services;
(vii) when the User list products and/or services for sale on the Platform and conduct transactions with other Users in respect of the sale and purchase of those products and/or services;
(viii) when the User activates or uses any payment related functions available on the Platform or provided by BETA’s third-party service providers;
(ix) when the User uses the internal messaging and/or chat function on the Platform;
(x) when the User provides BETA with feedback or complaints;
(xi) when the User subscribes to BETA’s publications or marketing collaterals;
(xii) when the User registers for a competition, promotion or survey;
(xiii) when the User participates in any activity or campaign on the Platform;
(xiv) when any other User posts any comments on the contents the User has uploaded on the Platform, or when the User posts any comments on other Users’ content uploaded on the Platform;
(xv) when a third-party lodge a complaint against the User or the content the User has posted on the Platform; and
(xvi) when the User submits the User’s Personal Data to us for any reason.
The above does not purport to be exhaustive and sets out some common instances of when Personal Data and information about the User may be collected.
(b) BETA may collect Personal Data and information about the User from the User directly, BETA’s affiliates, third parties, and from other sources, including without limitation business partners (such as test laboratories, logistics or payment service providers), credit bureaus or scoring agencies, marketing service providers or partners, referral or loyalty programs, other users of the Services or publicly available or governmental sources of data.
(c) During the course of the User’s use of the Platform and BETA’s provision of the Services, the User agrees that the User has provided consent (whether to BETA or the third party) to the transfer of the User’s Personal Data from third parties and BETA’s affiliates for the Purposes.
(d) BETA will only be able to collect certain categories of Personal Data if the User voluntarily provides the Personal Data to BETA or as otherwise provided for under this Privacy Policy. If the User chooses not to provide such Personal Data to BETA or subsequently withdraws the User’s consent to use of the User’s Personal Data, BETA may not be able to provide the User with certain features or functionality for the Services or the Platform.
(e) In some situations, the User may provide Personal Data of other individuals to BETA (such as the User’s family members or friends or persons in the User’s contact list). If the User provides BETA with such Personal Data, the User represents and warrants that the User has obtained their consent for their Personal Data to be processed in accordance with this Privacy Policy.
2.3 Collection of computer data
(a) As with most websites and mobile applications, the User’s device sends information which may include data about the User that gets logged by a web server when the User browses the Platform. This typically includes without limitation the User’s device’s Internet Protocol (“IP”) address, computer/mobile device operating system and browser type, type of mobile device, the characteristics of the mobile device, the unique device identifier (“UDID”) or mobile equipment identifier (“MEID”) for the User’s mobile device, the address of a referring web site (if any), the pages the User visit on the Platform and the times of visit, and sometimes a “cookie” (which can be disabled using the User’s browser preferences) record the User’s last access to the Platform. If the User is logged in, this information is associated with the User’s personal account. The information is also included in anonymous statistics to allow BETA to understand how Users use the Platform.
(b) The User’s mobile applications may collect precise information about the location of the User’s mobile device using technologies such as GPS, Wi-Fi, etc. BETA collects, uses, discloses and/or processes this information for one or more Purposes including, without limitation, location-based services that the User requests or to deliver relevant content to the User based on the User’s location or to allow the User to share the User’s location to other Users as part of the Services. For most mobile devices, the User would be able to withdraw the User’s permission for BETA to acquire this information on the User’s location through the User’s device settings.
(c) As and when the User views pages on the User’s website or mobile application, when the User watches content and advertising and access other software on the Platform or through the Services, such information may be sent to BETA (including, without limitation, IP Address, operating system, information on the content, advertisement viewed and/or software installed by the Services and the Platform from time to time).
2.4 Cookies
(a) BETA or BETA’s authorized service providers and advertising partners may from time-to-time use “cookies” or other features to allow BETA or third parties to collect or share information in connection with the User’s use of the Services or Platform. These features help BETA improve the Platform and the Services it offers, help BETA offer new services and features, and/or enable BETA and BETA’s advertising partners serve more relevant content to the User, including through remarketing. “Cookies” are identifiers that are stored on the User’s computer or mobile device that record data about computer or device, how and when the Services or Platform are used or visited, by how many people and other activity within the Platform. BETA may link cookie information to Personal Data. Cookies also link to information regarding the items the User has selected for purchase and web pages the User has viewed. This information is used to keep track of the User’s shopping cart, to deliver content specific to the User’s interests, to enable BETA’s third-party advertising partners to serve advertisements on sites across the internet, and to conduct data analysis and to monitor usage of the Services.
(b) The User may refuse the use of cookies by selecting the appropriate settings on the User’s browser or device. However, refusing the use of such cookies may affect the full functionality of the Platform or the Services.
3. USE OF PERSONAL DATA AND INFORMATION
3.1 Use of Personal Data and Information: BETA may collect, use, disclose and/or process the User’s Personal Data and information for one or more of the following purposes:
(a) to facilitate the User’s use of the Services or access to the Platform;
(i) to allow Physician and Technician to review User’s medical records online;
(ii) to allow Physician and Technician to generate medical reports using the Platform;
(iii) to allow Physician and Technician to make referral during the required circumstances;
(b) to administer the online account that the User may have set up with BETA;
(c) to conduct analytics, research, business and development:
(i) to better understand user experience with the Services and the Platform;
(ii) to improve the layout or content of the pages of the Platform and customise them for users;
(iii) to identify visitors on the Platform;
(iv) to conduct surveys, including carrying out research on the Users’ demographics and behaviour to improve BETA current technology (e.g. physical activities, diet intake, sleeping habits, etc) via machine learning or other means;
(v) to derive further attributes relating to the User based on Personal Data provided by the User (whether to BETA or third parties), in order to provide the User with more targeted and/or relevant information;
(vi) to conduct data analysis, testing and research, monitoring and analysing usage and activity trends; and
(vii) to further develop the Platform and the Services.
(d) for legal and operational purposes, including:
(i) to ascertain the User’s identity in connection with fraud detection purposes;
(ii) to compare information, and verify with third parties in order to ensure that the information is accurate;
(iii) to process any complaints, feedback, enforcement action and take-down requests in relation to any content the User has uploaded to the Platform;
(iv) to produce statistics and research for internal and statutory reporting and/or record-keeping requirements;
(v) to store, host, back up the User’s Personal Data for operational, legal or business purposes;
(vi) to prevent or investigate any actual or suspected violations of the Terms of Service, Privacy Policy or any of our policies, fraud, unlawful activity, omission or misconduct, whether relating to the User’s use of the Services or any other matter arising from the User’s relationship with BETA;
(vii) to perform due diligence checks;
(viii) to comply with legal and regulatory requirements (including, where applicable, the display of the User’s name, contact details and company details), including any law enforcement requests, requests by any governmental or regulatory authority having jurisdiction over BETA, in connection with any legal proceedings, or as otherwise deemed necessary by BETA; and
(ix) to protect the life, health or personal safety of BETA’s employees, the Users and/or the public.
(e) to respond to legal processes or to comply with or as required by any applicable law, governmental or regulatory requirements of any relevant jurisdiction or where BETA has a good faith belief that such disclosure is necessary, including, without limitation, meeting the requirements to make disclosure under the requirements of any law binding on BETA (including, where applicable, the display of the User’s name, contact details and company details);
(f) to respond to any threatened or actual claims asserted against BETA or other claim that any Information violates the rights of third parties;
(g) to store, host, back up (whether for disaster recovery or otherwise) of the User’s Personal Data, whether within or outside of the User’s jurisdiction; or
(h) any other purpose to which the User’s consent has been obtained, in compliance with BETA obligations under Data Protection Laws, including to notify the User at the time of obtaining the User’s consent,(collectively, the “Purposes”).
3.2 Mandatory access, preservation and disclosure: The User acknowledges, consents and agrees that BETA may access, preserve and disclose the User’s Personal Data and Information if required to do so by law or pursuant to an order of a court or by any governmental or regulatory authority having jurisdiction over BETA or in a good faith belief that such access preservation or disclosure is reasonably necessary to: (a) comply with legal process; (b) comply with a request from any governmental or regulatory authority having jurisdiction over BETA; (c) enforce the Terms of Service or this Privacy Policy; (d) respond to any threatened or actual claims asserted against BETA or other claim that any Information violates the rights of third parties; (e) respond to the User’s requests for customer service; or (f) protect the rights, property or personal safety of BETA, the Users and/or the public.
4. DISCLOSURE OF PERSONAL DATA AND INFORMATION
4.1 Disclosure of Personal Data and Information: In conducting BETA’s business, BETA will/may need to use, process, disclose and/or transfer the User’s Personal Data to BETA’s third-party service providers, agents and/or BETA’s affiliates or related corporations, and/or other third parties, which may be located in Singapore or outside of Singapore, for one or more of the Purposes. Such third-party service providers, agents and/or affiliates or related corporations and/or other third parties would be processing the User’s Personal Data either on BETA’s behalf or otherwise, for one or more of the above-stated Purposes. BETA endeavours to ensure that the third parties and BETA’s affiliates keep the User’s Personal Data secure from unauthorised access, collection, use, disclosure, processing or similar risks and retain the User’s Personal Data only for as long as the User’s Personal Data is needed for the above-mentioned Purposes. Such third parties include, without limitation:
(a) BETA’s subsidiaries, affiliates and related corporations;
(b) the User has transacted with or interacted with on the Platform or in connection with the User’s use of the Services for the above-stated Purposes;
(c) other Users for one or more of the above-stated Purposes;
(d) contractors, agents, service providers and other third parties BETA uses to support BETA’s business. These include but are not limited to those parties which provide administrative or other services to BETA such as mailing houses, logistics service providers, financial services providers, advertising and marketing partners, telecommunication companies, information technology companies, and data centres;
(e) governmental or regulatory authorities having jurisdiction over BETA or as otherwise permitted under Clause 3.2;
(f) a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of BETA’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which Personal Data held by BETA in relation to the Users is among the assets transferred; or to a counterparty in a business asset transaction that BETA or any of its affiliates or related corporations is involved in; and
(g) third parties to whom disclosure by us is for one or more of the Purposes and such third parties would in turn be collecting and processing the User’s Personal Data for one or more of the Purposes.
4.2 Sharing with third parties: BETA may share user information, including statistical and demographic information, about the Users and information about their use of the Services with medical service partners and third-party suppliers of health care services, and/or other programming.
4.3 Disclosure without consent: For the avoidance of doubt, in the event that the Data Protection Laws permit an organisation such as BETA to collect, use or disclose the User’s Personal Data without the User’s consent, such permission granted by the Data Protection Laws shall continue to apply. Consistent with the foregoing and subject to the Data Protection Laws, BETA may use the User’s Personal Data for recognized legal grounds including to comply with BETA’s legal obligations, to perform BETA’s contract with the Users, to achieve a legitimate interest and BETA’s reasons for using it outweigh any prejudice to the User’s data protection rights, or where necessary in connection with a legal claim.
4.4 Compliance by Users selling merchandise: Notwithstanding anything set forth herein, Users selling merchandise on the Platform (including any employees, agents, representatives, or any other person acting for such User or on such User’s behalf) shall comply with all applicable Data Protection Laws and, in respect of any Personal Data and information of the purchasers received from BETA, (i) are not permitted to use such purchasers’ Personal Data except as reasonably necessary to respond to the purchasers’ enquiries and to carry out respond to, process, deal with or complete a transaction without the purchasers’ and BETA’s prior written consent; (ii) should refrain from contacting purchasers using such information outside of the BETA platform; (iii) are not permitted to disclose such Purchasers’ Personal Data to any unauthorized third parties without the purchasers’ and BETA’s prior written consent; (iv) shall employ sufficient security measures to protect each User’s Personal Data in their possession, retain such data only for as long as necessary for the Purposes and in accordance with the Data Protection Laws, and to delete or return such data to BETA upon any request from BETA or as soon as reasonably possible upon completion of the transaction; and (v) to inform BETA’s Data Protection Officer at support@healthbeta.co in the event of any potential data breach or other loss of such User’s data.
5. PROTECTION AND RETENTION OF USER INFORMATION AND PERSONAL DATA
5.1 Security of Personal Data and User’s information: BETA implements a variety of security measures and strive to ensure the security of the User’s Personal Data and information on the Platform. The User’s Personal Data and information is contained behind secured networks and is only accessible by a limited number of employees who have special access rights to such systems. However, there can inevitably be no guarantee of absolute security.
5.2 Retention of Personal Data and User’s information: BETA will retain Personal Data and information in accordance with the Data Protection Laws and/or other applicable laws. That is, BETA will destroy or anonymize the User’s Personal Data when BETA has reasonably determined that (i) the purpose for which that Personal Data was collected is no longer being served by the retention of such Personal Data; (ii) retention is no longer necessary for any legal or business purposes; and (iii) no other legitimate interests warrant further retention of such Personal Data. If the User ceases to use the Platform, or the User’s permission to use the Platform and/or the Services is terminated or withdrawn, the User may continue storing, using and/or disclosing the User’s Personal Data in accordance with this Privacy Policy and our obligations under the Data Protection Laws. Subject to the Data Protection Laws, BETA may securely dispose of the User’s Personal Data without prior notice to the User.
5.3 Transfer of Personal Data and information: The User’s Personal Data and/or information may be transferred to, stored or processed outside of the User’s country for one or more of the Purposes. BETA will only transfer the User’s Personal Data and information overseas in accordance with the Data Protection Laws.
6. INFORMATION ON MINORS
6.1 BETA does not provide the Services or the use of the Platform to minors (which is to be determined based on the applicable law). BETA does not knowingly collect any Personal Data relating to minors.
6.2 The User hereby confirms and warrants that the User is above the age of minority and the User is capable of understanding and accepting the terms of this Privacy Policy. If the User is a minor, the User may use the Platform only with the involvement of a parent or legal guardian.
6.3 Parents or legal guardians should not allow minors under their care to submit Personal Data to BETA. In the event that such Personal Data of a minor is disclosed to BETA, such parent or legal guardian hereby consents to the processing of the minor’s Personal Data and accept and agree to be bound by this Privacy Policy and take responsibility for the minor’s actions.
7. THIRD PARTY SITES
7.1 Third party sites: To provide the Users with increased value, BETA may choose various third-party sites to link to, and frame within, the Platform. BETA may also participate in co-branding and other relationships to offer e-commerce and other services and features to the Users. These linked sites may separately access, and allow a third party to view, the User’s identifiable information, such as the User’s name, the User’s user ID, the User’s device’s IP Address or other information such as any cookies that the User may previously have installed or that were installed for the User by a third party software application or website. Additionally, these applications may ask the User to provide additional information directly to third parties. These linked sites have separate and independent privacy policies as well as security arrangements. Even if the third party is affiliated with BETA, BETA has no control over these linked sites, each of which has separate privacy and data collection practices independent of BETA. Data collected by BETA’s co-brand partners or third party sites (even if offered on or through our Platform) may not be received by BETA. The User is encouraged to read the terms and other policies published by such third parties on their websites or otherwise.
7.2 Exclusion of liability: In relation to such third-party sites:
(a) BETA does not guarantee the security of Personal Data and/or other information that the User provides on third party sites.
(b) BETA therefore has no responsibility or liability for the content, security arrangements (or lack thereof) and activities of these linked sites. These linked sites are only for the User’s convenience and the User therefore access them at the User’s own risk. Nonetheless, BETA seeks to protect the integrity of the Platform and the links placed upon each of them and therefore welcome any feedback about these linked sites (including, without limitation, if a specific link does not work).
8. UPDATING PERSONAL DATA
8.1 User’s responsibility: It is important that the Personal Data the User provides to BETA is accurate and complete for you to continue using the Platform and for us to provide the Services. The User is responsible for informing BETA of changes to the User’s Personal Data, or in the event the User believes that the Personal Data BETA has of the User is inaccurate, incomplete, misleading or out of date.
8.2 Updating Personal Data: The User can update the User’s Personal Data anytime by accessing the User’s account on the Platform.
8.3 Sharing with third parties: BETA may take steps to share the updates to the User’s Personal Data with third parties and our affiliates with whom BETA have shared the User’s Personal Data if the User’s Personal Data is still necessary for the Purposes.
9. REQUESTING ACCESS TO OR CORRECTION OF PERSONAL DATA
9.1 Access to or correction of Personal Data: The User may request information about the User’s Personal Data which BETA has collected, or enquire about the ways in which the User’s Personal Data may have been used, disclosed, stored or processed by BETA by contacting BETA using the contact details in Clause 11 below. The User may also request correction of any error or omission in the User’s Personal Data which BETA have collected in the same way. In order to facilitate processing of the User’s request, it may be necessary for BETA to request further information relating to the User’s request. Where permissible under law, BETA may refuse such correction requests if deemed vexatious or unreasonable, and/or in accordance with the provisions as set out in the Data Protection Laws.
9.2 Administrative fee: Where permitted by the Data Protection Laws, BETA reserves the right to charge a reasonable administrative fee for retrieving the User’s Personal Data records. If so, BETA will inform the User of the fee before processing the User’s request.
10. WITHDRAWING CONSENT
10.1 Withdrawing consent: The User may communicate the withdrawal of the User’s consent to the continued use, disclosure, storing and/or processing of the User’s Personal Data by contacting BETA using the contact details below, subject to the conditions and/or limitations imposed by applicable laws or regulations.
10.2 Disclaimer: If the User communicates the User’s withdrawal of the User’s consent to the User’s use, disclosure, storing or processing of the User’s Personal Data for the Purposes and in the manner as stated above or exercise the User’s other rights as available under the Data Protection Laws, BETA may not be in a position to continue to provide the Services to the User or perform any contract BETA has with the User, and BETA will not be liable in the event that BETA does not continue to provide the Services to, or perform BETA’s contract with the User. BETA’s legal rights and remedies are expressly reserved in such an event.
11. QUESTIONS, FEEDBACK, CONCERNS, SUGGESTIONS OR COMPLAINTS
In the event of any questions or concerns in relation to the privacy practices of BETA, please contact BETA’s Data Protection Officer at support@healthbeta.co.
PRIVACY POLICY
1. INTRODUCTION
1.1 Welcome to www.healthbeta.co, cloud.healthbeta.co and/or the BETA mobile application operated by Health BETA Pte. Ltd. and/or its affiliates (“BETA”). BETA takes the privacy of its Users seriously and is committed to respecting the privacy rights and concerns of all Users of the Platform and/or the Services.
1.2 This Privacy Policy is designed to assist the User in understanding how BETA collects, uses, discloses and/or processes (a) the Personal Data and information the User has provided to BETA; and/or (b) the Personal Data and information that BETA possesses in relation to the User.
1.3 BETA may update this Privacy Policy from time to time. Any changes made to the Privacy Policy in the future will be reflected on the Platform. Where permissible under Data Protection Laws, the User’s continued use of the Services or access to the Platform following the modifications, updates or amendments to this Privacy Policy (whether or not the User has reviewed such document) shall constitute the User’s acknowledgment and acceptance of the changes BETA has made to this Privacy Policy. The User agrees that it is the User’s responsibility to review and check the Privacy Policy frequently to see if any updates or changes have been made to this Privacy Policy.
1.4 This Privacy Policy applies in conjunction with other notices, contractual clauses, consent clauses that apply in relation to the collection, storage, use, disclosure and/or processing of the User’s Personal Data by BETA and is not intended to override those notices or clauses unless BETA expressly states otherwise.
1.5 In this Privacy Policy, unless the context otherwise requires, the following general definitions shall apply:
(a) “Data Protection Laws” means applicable laws and regulations relating to the use and/or processing of personally identifiable information and data and privacy.
(b) “Information” means, collectively, all web pages on the Platform, including the information, images, links, sounds, graphics, video, health data, medical data, software, applications, and other materials displayed or made available on the Platform and the functionalities or services provided on the Platform.
(c) “Personal Data” means:
(i) data, whether true or not, about an individual who can be identified:
(1) from that data; or
(2) from that data and other information to which BETA has or are likely to have access; and
(ii) any data that is analogous to the foregoing, as defined in Data Protection Laws.
(d) “Platform” means (a) both the cloud, web and mobile versions of the website operated and/or owned by BETA which is presently located at the following URL: cloud.healthbeta.co and www.healthbeta.co; and (b) the mobile applications made available from time to time by BETA, including the iOS and Android versions.
(e) “Purposes” means the purposes for which BETA collects the User’s Personal Data as set out in this Privacy Policy.
(f) “Services” means the website features, application features for mobile, functions and services provided from time to time through the Platform.
(g) “Physician” or “Technician” means qualified medical professionals licensed to conduct medical practices.
(h) “Users” means the users of the Platform and/or the Services, each a “User”.
2. COLLECTION OF PERSONAL DATA
2.1 Type of User’s Personal Data and information
(a) The Personal Data and information that BETA collects include but is not limited to the following:
(i) name;
(ii) email address;
(iii) mobile or telephone number;
(iv) date of birth;
(v) Government issued identification or other like information National identification number;
(vi) ethnicity (race);
(vii) gender;
(viii) billing and/or delivery address;
(ix) information sent by or associated with the device(s) used to access the Platform and/or the Services;
(x) information about the User’s network, including the User’s contact list when the User share permissions on the User’s device, and the people and accounts the User interacts with;
(xi) medical and health data and records;
(xii) photographs or audio or video recordings;
(xiii) marketing and communications data, such as the User’s preferences in receiving marketing from BETA and third parties, the User’s communication preferences and history of communications with BETA, BETA’s service providers, and other third parties;
(xiv) usage and transaction data, including details about the User’s searches, orders, the advertising and content the User interacts with on the Platform, and other products and services related to the User;
(xv) location data;
(xvi) any other information about the User when the User signs up to use the Services or Platform, and when the User uses the Services or Platform, as well as information related to how the User uses the Services or Platform; and
(xvii) aggregate data on content the User engages with.
(b) The User agrees not to submit any information to BETA which is inaccurate or misleading, and the User agrees to inform BETA of any inaccuracies or changes to such information. BETA reserves the right at it sole discretion to require further documentation to verify any information provided by the User.
(c) If the User does not want BETA to collect the aforementioned information or Personal Data, the User may opt out at any time by notifying BETA’s Data Protection Officer at support@healthbeta.co. Further information on opting out can be found in this Privacy Policy.
2.2 Methods of collecting the User’s Personal Data and information
(a) BETA may collect the User’s Personal Data and information:
(i) when the User registers and/or uses the Services or Platform, or open an account with BETA;
(ii) when the User submits any form, including, but not limited to, application forms or other forms relating to the Services, whether online or by way of a physical form;
(iii) when the User enters into any agreement or provide other documentation or information in respect of the User’s interactions with BETA, or when the User uses the Services;
(iv) when the User interacts with BETA, such as via telephone calls (which may be recorded), letters, fax, face-to-face meetings, social media platforms and emails, including when the User interacts with BETA’s customer service agents;
(v) when the User grants permissions on the User’s device to share information with the Platform;
(vi) when the User carry out transactions through the Services;
(vii) when the User list products and/or services for sale on the Platform and conduct transactions with other Users in respect of the sale and purchase of those products and/or services;
(viii) when the User activates or uses any payment related functions available on the Platform or provided by BETA’s third-party service providers;
(ix) when the User uses the internal messaging and/or chat function on the Platform;
(x) when the User provides BETA with feedback or complaints;
(xi) when the User subscribes to BETA’s publications or marketing collaterals;
(xii) when the User registers for a competition, promotion or survey;
(xiii) when the User participates in any activity or campaign on the Platform;
(xiv) when any other User posts any comments on the contents the User has uploaded on the Platform, or when the User posts any comments on other Users’ content uploaded on the Platform;
(xv) when a third-party lodge a complaint against the User or the content the User has posted on the Platform; and
(xvi) when the User submits the User’s Personal Data to us for any reason.
The above does not purport to be exhaustive and sets out some common instances of when Personal Data and information about the User may be collected.
(b) BETA may collect Personal Data and information about the User from the User directly, BETA’s affiliates, third parties, and from other sources, including without limitation business partners (such as test laboratories, logistics or payment service providers), credit bureaus or scoring agencies, marketing service providers or partners, referral or loyalty programs, other users of the Services or publicly available or governmental sources of data.
(c) During the course of the User’s use of the Platform and BETA’s provision of the Services, the User agrees that the User has provided consent (whether to BETA or the third party) to the transfer of the User’s Personal Data from third parties and BETA’s affiliates for the Purposes.
(d) BETA will only be able to collect certain categories of Personal Data if the User voluntarily provides the Personal Data to BETA or as otherwise provided for under this Privacy Policy. If the User chooses not to provide such Personal Data to BETA or subsequently withdraws the User’s consent to use of the User’s Personal Data, BETA may not be able to provide the User with certain features or functionality for the Services or the Platform.
(e) In some situations, the User may provide Personal Data of other individuals to BETA (such as the User’s family members or friends or persons in the User’s contact list). If the User provides BETA with such Personal Data, the User represents and warrants that the User has obtained their consent for their Personal Data to be processed in accordance with this Privacy Policy.
2.3 Collection of computer data
(a) As with most websites and mobile applications, the User’s device sends information which may include data about the User that gets logged by a web server when the User browses the Platform. This typically includes without limitation the User’s device’s Internet Protocol (“IP”) address, computer/mobile device operating system and browser type, type of mobile device, the characteristics of the mobile device, the unique device identifier (“UDID”) or mobile equipment identifier (“MEID”) for the User’s mobile device, the address of a referring web site (if any), the pages the User visit on the Platform and the times of visit, and sometimes a “cookie” (which can be disabled using the User’s browser preferences) record the User’s last access to the Platform. If the User is logged in, this information is associated with the User’s personal account. The information is also included in anonymous statistics to allow BETA to understand how Users use the Platform.
(b) The User’s mobile applications may collect precise information about the location of the User’s mobile device using technologies such as GPS, Wi-Fi, etc. BETA collects, uses, discloses and/or processes this information for one or more Purposes including, without limitation, location-based services that the User requests or to deliver relevant content to the User based on the User’s location or to allow the User to share the User’s location to other Users as part of the Services. For most mobile devices, the User would be able to withdraw the User’s permission for BETA to acquire this information on the User’s location through the User’s device settings.
(c) As and when the User views pages on the User’s website or mobile application, when the User watches content and advertising and access other software on the Platform or through the Services, such information may be sent to BETA (including, without limitation, IP Address, operating system, information on the content, advertisement viewed and/or software installed by the Services and the Platform from time to time).
2.4 Cookies
(a) BETA or BETA’s authorized service providers and advertising partners may from time-to-time use “cookies” or other features to allow BETA or third parties to collect or share information in connection with the User’s use of the Services or Platform. These features help BETA improve the Platform and the Services it offers, help BETA offer new services and features, and/or enable BETA and BETA’s advertising partners serve more relevant content to the User, including through remarketing. “Cookies” are identifiers that are stored on the User’s computer or mobile device that record data about computer or device, how and when the Services or Platform are used or visited, by how many people and other activity within the Platform. BETA may link cookie information to Personal Data. Cookies also link to information regarding the items the User has selected for purchase and web pages the User has viewed. This information is used to keep track of the User’s shopping cart, to deliver content specific to the User’s interests, to enable BETA’s third-party advertising partners to serve advertisements on sites across the internet, and to conduct data analysis and to monitor usage of the Services.
(b) The User may refuse the use of cookies by selecting the appropriate settings on the User’s browser or device. However, refusing the use of such cookies may affect the full functionality of the Platform or the Services.
3. USE OF PERSONAL DATA AND INFORMATION
3.1 Use of Personal Data and Information: BETA may collect, use, disclose and/or process the User’s Personal Data and information for one or more of the following purposes:
(a) to facilitate the User’s use of the Services or access to the Platform;
(i) to allow Physician and Technician to review User’s medical records online;
(ii) to allow Physician and Technician to generate medical reports using the Platform;
(iii) to allow Physician and Technician to make referral during the required circumstances;
(b) to administer the online account that the User may have set up with BETA;
(c) to conduct analytics, research, business and development:
(i) to better understand user experience with the Services and the Platform;
(ii) to improve the layout or content of the pages of the Platform and customise them for users;
(iii) to identify visitors on the Platform;
(iv) to conduct surveys, including carrying out research on the Users’ demographics and behaviour to improve BETA current technology (e.g. physical activities, diet intake, sleeping habits, etc) via machine learning or other means;
(v) to derive further attributes relating to the User based on Personal Data provided by the User (whether to BETA or third parties), in order to provide the User with more targeted and/or relevant information;
(vi) to conduct data analysis, testing and research, monitoring and analysing usage and activity trends; and
(vii) to further develop the Platform and the Services.
(d) for legal and operational purposes, including:
(i) to ascertain the User’s identity in connection with fraud detection purposes;
(ii) to compare information, and verify with third parties in order to ensure that the information is accurate;
(iii) to process any complaints, feedback, enforcement action and take-down requests in relation to any content the User has uploaded to the Platform;
(iv) to produce statistics and research for internal and statutory reporting and/or record-keeping requirements;
(v) to store, host, back up the User’s Personal Data for operational, legal or business purposes;
(vi) to prevent or investigate any actual or suspected violations of the Terms of Service, Privacy Policy or any of our policies, fraud, unlawful activity, omission or misconduct, whether relating to the User’s use of the Services or any other matter arising from the User’s relationship with BETA;
(vii) to perform due diligence checks;
(viii) to comply with legal and regulatory requirements (including, where applicable, the display of the User’s name, contact details and company details), including any law enforcement requests, requests by any governmental or regulatory authority having jurisdiction over BETA, in connection with any legal proceedings, or as otherwise deemed necessary by BETA; and
(ix) to protect the life, health or personal safety of BETA’s employees, the Users and/or the public.
(e) to respond to legal processes or to comply with or as required by any applicable law, governmental or regulatory requirements of any relevant jurisdiction or where BETA has a good faith belief that such disclosure is necessary, including, without limitation, meeting the requirements to make disclosure under the requirements of any law binding on BETA (including, where applicable, the display of the User’s name, contact details and company details);
(f) to respond to any threatened or actual claims asserted against BETA or other claim that any Information violates the rights of third parties;
(g) to store, host, back up (whether for disaster recovery or otherwise) of the User’s Personal Data, whether within or outside of the User’s jurisdiction; or
(h) any other purpose to which the User’s consent has been obtained, in compliance with BETA obligations under Data Protection Laws, including to notify the User at the time of obtaining the User’s consent,(collectively, the “Purposes”).
3.2 Mandatory access, preservation and disclosure: The User acknowledges, consents and agrees that BETA may access, preserve and disclose the User’s Personal Data and Information if required to do so by law or pursuant to an order of a court or by any governmental or regulatory authority having jurisdiction over BETA or in a good faith belief that such access preservation or disclosure is reasonably necessary to: (a) comply with legal process; (b) comply with a request from any governmental or regulatory authority having jurisdiction over BETA; (c) enforce the Terms of Service or this Privacy Policy; (d) respond to any threatened or actual claims asserted against BETA or other claim that any Information violates the rights of third parties; (e) respond to the User’s requests for customer service; or (f) protect the rights, property or personal safety of BETA, the Users and/or the public.
4. DISCLOSURE OF PERSONAL DATA AND INFORMATION
4.1 Disclosure of Personal Data and Information: In conducting BETA’s business, BETA will/may need to use, process, disclose and/or transfer the User’s Personal Data to BETA’s third-party service providers, agents and/or BETA’s affiliates or related corporations, and/or other third parties, which may be located in Singapore or outside of Singapore, for one or more of the Purposes. Such third-party service providers, agents and/or affiliates or related corporations and/or other third parties would be processing the User’s Personal Data either on BETA’s behalf or otherwise, for one or more of the above-stated Purposes. BETA endeavours to ensure that the third parties and BETA’s affiliates keep the User’s Personal Data secure from unauthorised access, collection, use, disclosure, processing or similar risks and retain the User’s Personal Data only for as long as the User’s Personal Data is needed for the above-mentioned Purposes. Such third parties include, without limitation:
(a) BETA’s subsidiaries, affiliates and related corporations;
(b) the User has transacted with or interacted with on the Platform or in connection with the User’s use of the Services for the above-stated Purposes;
(c) other Users for one or more of the above-stated Purposes;
(d) contractors, agents, service providers and other third parties BETA uses to support BETA’s business. These include but are not limited to those parties which provide administrative or other services to BETA such as mailing houses, logistics service providers, financial services providers, advertising and marketing partners, telecommunication companies, information technology companies, and data centres;
(e) governmental or regulatory authorities having jurisdiction over BETA or as otherwise permitted under Clause 3.2;
(f) a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of BETA’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which Personal Data held by BETA in relation to the Users is among the assets transferred; or to a counterparty in a business asset transaction that BETA or any of its affiliates or related corporations is involved in; and
(g) third parties to whom disclosure by us is for one or more of the Purposes and such third parties would in turn be collecting and processing the User’s Personal Data for one or more of the Purposes.
4.2 Sharing with third parties: BETA may share user information, including statistical and demographic information, about the Users and information about their use of the Services with medical service partners and third-party suppliers of health care services, and/or other programming.
4.3 Disclosure without consent: For the avoidance of doubt, in the event that the Data Protection Laws permit an organisation such as BETA to collect, use or disclose the User’s Personal Data without the User’s consent, such permission granted by the Data Protection Laws shall continue to apply. Consistent with the foregoing and subject to the Data Protection Laws, BETA may use the User’s Personal Data for recognized legal grounds including to comply with BETA’s legal obligations, to perform BETA’s contract with the Users, to achieve a legitimate interest and BETA’s reasons for using it outweigh any prejudice to the User’s data protection rights, or where necessary in connection with a legal claim.
4.4 Compliance by Users selling merchandise: Notwithstanding anything set forth herein, Users selling merchandise on the Platform (including any employees, agents, representatives, or any other person acting for such User or on such User’s behalf) shall comply with all applicable Data Protection Laws and, in respect of any Personal Data and information of the purchasers received from BETA, (i) are not permitted to use such purchasers’ Personal Data except as reasonably necessary to respond to the purchasers’ enquiries and to carry out respond to, process, deal with or complete a transaction without the purchasers’ and BETA’s prior written consent; (ii) should refrain from contacting purchasers using such information outside of the BETA platform; (iii) are not permitted to disclose such Purchasers’ Personal Data to any unauthorized third parties without the purchasers’ and BETA’s prior written consent; (iv) shall employ sufficient security measures to protect each User’s Personal Data in their possession, retain such data only for as long as necessary for the Purposes and in accordance with the Data Protection Laws, and to delete or return such data to BETA upon any request from BETA or as soon as reasonably possible upon completion of the transaction; and (v) to inform BETA’s Data Protection Officer at support@healthbeta.co in the event of any potential data breach or other loss of such User’s data.
5. PROTECTION AND RETENTION OF USER INFORMATION AND PERSONAL DATA
5.1 Security of Personal Data and User’s information: BETA implements a variety of security measures and strive to ensure the security of the User’s Personal Data and information on the Platform. The User’s Personal Data and information is contained behind secured networks and is only accessible by a limited number of employees who have special access rights to such systems. However, there can inevitably be no guarantee of absolute security.
5.2 Retention of Personal Data and User’s information: BETA will retain Personal Data and information in accordance with the Data Protection Laws and/or other applicable laws. That is, BETA will destroy or anonymize the User’s Personal Data when BETA has reasonably determined that (i) the purpose for which that Personal Data was collected is no longer being served by the retention of such Personal Data; (ii) retention is no longer necessary for any legal or business purposes; and (iii) no other legitimate interests warrant further retention of such Personal Data. If the User ceases to use the Platform, or the User’s permission to use the Platform and/or the Services is terminated or withdrawn, the User may continue storing, using and/or disclosing the User’s Personal Data in accordance with this Privacy Policy and our obligations under the Data Protection Laws. Subject to the Data Protection Laws, BETA may securely dispose of the User’s Personal Data without prior notice to the User.
5.3 Transfer of Personal Data and information: The User’s Personal Data and/or information may be transferred to, stored or processed outside of the User’s country for one or more of the Purposes. BETA will only transfer the User’s Personal Data and information overseas in accordance with the Data Protection Laws.
6. INFORMATION ON MINORS
6.1 BETA does not provide the Services or the use of the Platform to minors (which is to be determined based on the applicable law). BETA does not knowingly collect any Personal Data relating to minors.
6.2 The User hereby confirms and warrants that the User is above the age of minority and the User is capable of understanding and accepting the terms of this Privacy Policy. If the User is a minor, the User may use the Platform only with the involvement of a parent or legal guardian.
6.3 Parents or legal guardians should not allow minors under their care to submit Personal Data to BETA. In the event that such Personal Data of a minor is disclosed to BETA, such parent or legal guardian hereby consents to the processing of the minor’s Personal Data and accept and agree to be bound by this Privacy Policy and take responsibility for the minor’s actions.
7. THIRD PARTY SITES
7.1 Third party sites: To provide the Users with increased value, BETA may choose various third-party sites to link to, and frame within, the Platform. BETA may also participate in co-branding and other relationships to offer e-commerce and other services and features to the Users. These linked sites may separately access, and allow a third party to view, the User’s identifiable information, such as the User’s name, the User’s user ID, the User’s device’s IP Address or other information such as any cookies that the User may previously have installed or that were installed for the User by a third party software application or website. Additionally, these applications may ask the User to provide additional information directly to third parties. These linked sites have separate and independent privacy policies as well as security arrangements. Even if the third party is affiliated with BETA, BETA has no control over these linked sites, each of which has separate privacy and data collection practices independent of BETA. Data collected by BETA’s co-brand partners or third party sites (even if offered on or through our Platform) may not be received by BETA. The User is encouraged to read the terms and other policies published by such third parties on their websites or otherwise.
7.2 Exclusion of liability: In relation to such third-party sites:
(a) BETA does not guarantee the security of Personal Data and/or other information that the User provides on third party sites.
(b) BETA therefore has no responsibility or liability for the content, security arrangements (or lack thereof) and activities of these linked sites. These linked sites are only for the User’s convenience and the User therefore access them at the User’s own risk. Nonetheless, BETA seeks to protect the integrity of the Platform and the links placed upon each of them and therefore welcome any feedback about these linked sites (including, without limitation, if a specific link does not work).
8. UPDATING PERSONAL DATA
8.1 User’s responsibility: It is important that the Personal Data the User provides to BETA is accurate and complete for you to continue using the Platform and for us to provide the Services. The User is responsible for informing BETA of changes to the User’s Personal Data, or in the event the User believes that the Personal Data BETA has of the User is inaccurate, incomplete, misleading or out of date.
8.2 Updating Personal Data: The User can update the User’s Personal Data anytime by accessing the User’s account on the Platform.
8.3 Sharing with third parties: BETA may take steps to share the updates to the User’s Personal Data with third parties and our affiliates with whom BETA have shared the User’s Personal Data if the User’s Personal Data is still necessary for the Purposes.
9. REQUESTING ACCESS TO OR CORRECTION OF PERSONAL DATA
9.1 Access to or correction of Personal Data: The User may request information about the User’s Personal Data which BETA has collected, or enquire about the ways in which the User’s Personal Data may have been used, disclosed, stored or processed by BETA by contacting BETA using the contact details in Clause 11 below. The User may also request correction of any error or omission in the User’s Personal Data which BETA have collected in the same way. In order to facilitate processing of the User’s request, it may be necessary for BETA to request further information relating to the User’s request. Where permissible under law, BETA may refuse such correction requests if deemed vexatious or unreasonable, and/or in accordance with the provisions as set out in the Data Protection Laws.
9.2 Administrative fee: Where permitted by the Data Protection Laws, BETA reserves the right to charge a reasonable administrative fee for retrieving the User’s Personal Data records. If so, BETA will inform the User of the fee before processing the User’s request.
10. WITHDRAWING CONSENT
10.1 Withdrawing consent: The User may communicate the withdrawal of the User’s consent to the continued use, disclosure, storing and/or processing of the User’s Personal Data by contacting BETA using the contact details below, subject to the conditions and/or limitations imposed by applicable laws or regulations.
10.2 Disclaimer: If the User communicates the User’s withdrawal of the User’s consent to the User’s use, disclosure, storing or processing of the User’s Personal Data for the Purposes and in the manner as stated above or exercise the User’s other rights as available under the Data Protection Laws, BETA may not be in a position to continue to provide the Services to the User or perform any contract BETA has with the User, and BETA will not be liable in the event that BETA does not continue to provide the Services to, or perform BETA’s contract with the User. BETA’s legal rights and remedies are expressly reserved in such an event.
11. QUESTIONS, FEEDBACK, CONCERNS, SUGGESTIONS OR COMPLAINTS
In the event of any questions or concerns in relation to the privacy practices of BETA, please contact BETA’s Data Protection Officer at support@healthbeta.co.