Privacy Policy

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Privacy Policy

This Privacy 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. 

This Privacy Policy applies to any individual’s Personal Data which is in our possession or under our control (including Personal Data in possession of organisations which we have engaged to collect, use, disclose or Process Personal Data for our purposes), and shall govern your use of our Services. This Privacy Policy is in addition to the other terms and conditions which may apply in respect of your use of our Services.

You hereby acknowledge and agree that you have read and understood the practices described in this Privacy Policy and hereby agree to the collection, use, disclosure or otherwise Processing of your Personal Data by us in accordance with this Privacy Policy when you click on “Agree”, provide us with Personal Data, or otherwise access or use our Services. If you do not agree to this Privacy Policy, you should not use our Services.

Notwithstanding the foregoing, you may withdraw your consent for us to collect, use or disclose your Personal Data, but this may affect our ability to provide you with the Services. We will not be liable for any failure to provide any Services if such failure is due to your consent hereunder being withdrawn.

If you, at any time, have any queries on this policy or any other queries in relation to how we may manage, protect and/or Process Personal Data, please do not hesitate to contact our Data Protection Officer at the contact details below.

1. definitions

1.1. In this Privacy Policy:

Personal Data” means any data, whether true or not, about a person 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.

Platform” means collectively the Site and the Services.

Process” means the carrying out of any operation or set of operations in relation to the Personal Data, including without limitation to recording, holding, organizing, adapting, altering, modifying, retrieving, combining, transmitting, erasing or destroying.

Site” means Industrial Craft Co ’ websites, online locations, mobile applications, user interfaces and application programming interface.

1.2. Depending on the nature of your interaction with us, some examples of Personal Data which we may collect from you include name, postal code, email address, telephone number, gender, date of birth, employment information and financial information.

1.3. We may also collect details of your visit to the third party service providers from such third party service providers, including the date and time of the visit, your diagnosis, consultation, medicine/treatment/procedure/tests that are prescribed or administered, medical certificates issued, packages and/ or other services provided, bill amount (including breakdown of the bill amount), and method of payment.

1.4. Other terms used in this Privacy Policy shall have the meanings as given to them in the Member Terms of Services.

2. collection and use of personal data

2.1. We generally do not collect your Personal Data unless:

(a) it is provided to us voluntarily by you directly;

(b) it is provided to us by 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 consented to the collection and usage of your Personal Data for those purposes. In this regard, you hereby acknowledge and agree that third party service providers who have provided health and wellness services to you may disclose to us your Personal Data, and we may collect your Personal Data from such third party service providers, for the purposes as set out in this Privacy Policy; or

(c) collection and use of Personal Data without consent is permitted or required by the PDPA or other laws.

2.2. We will 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 the PDPA or other laws).

2.3. We may collect and use your Personal Data for any or all of the following purposes:

(a) performing obligations in the course of or in connection with our provision of the Services requested by you; to measure the performance of the Services; to monitor the Services provided by or made available through us; to personalise and improve the provision of the Services; to develop new products and services;

(b) to verify your identity, conduct due diligence checks and identify you as a user in our system;

(c) to facilitate the creation of, administration, access, use and security of your account in connection with our provision of the Services requested by you;

(d) to verify and determine your geographic location, provide localised versions of the Services, provide you with customised or personalised recommendations or content, determine your Internet service provider; to optimise our selection and recommendation algorithm and delivery;

(e) to determine if your visit to a third party service provider is claimable and payable by Industrial Craft Co, and to process payment or credit transactions;

(f) to prevent, detect and investigate fraud or other potentially prohibited, unauthorised or illegal activities; to detect, prevent and remediate any violations of our policies or terms and conditions;

(g) to respond to, handle, and process queries, requests, applications, complaints, and feedback from you; to address or investigate any complaints, claims or disputes;

(h) to send administrative communications relating to our Services;

(i) to communicate with you to assist you with operational requests (such as, password reset requests);

(j) to handle requests for data access or correction;

(k) to analyse and understand our users; to improve our Services (including, but not limited to, our user interface experiences); to participate in industry exercises and studies; to conduct research and measurement activities;

(l) to train our employees and third party service providers; to monitor for quality assurances;

(m) to manage your relationship with us, and to respond to, handle, and to process queries, requests, applications, complaints, and feedback from you;

3. disclosure and transfer of personal data

3.1. We may disclose your Personal Data:

(a) where such disclosure is required for performing obligations in the course of or in connection with our provision of the Services requested by you; or

(b) to public authorities, such as government, public, regulatory, judicial and law enforcement bodies or authorities, in circumstances in which we are legally required to disclose information, including to comply with a legal obligation or processes, such as a court order, subpoena or other legal processes, or where we have a good faith belief that such sharing is reasonably necessary to enforce our terms of service and other agreements, address issues relating to security or fraud, or protect our users;

(c) to your employer to allow them to administer your account with us and to determine if services which you have obtained from third party service providers are claimable in accordance with your employer’s policies;

(d) to the third party service provider for them to verify your identity, provide personalised services to you, process payment by your employer; and

(e) to our employees, third party service providers, agents and other organisations, located anywhere in the world, whom we have engaged to perform any of the functions with reference to the above mentioned purposes.

3.2. In the event that Industrial Craft Co is or may be acquired by or merged with another company or involved in any other business deal (or negotiation of a business deal) involving the sale or transfer of all or part of our business or assets, we may transfer or assign your Personal Data as part of or in connection with the transaction. In the event of insolvency, bankruptcy, or receivership, Personal Data may be transferred or disclosed as a business asset.

3.3. We may transfer, store, Process and/or deal with your Personal Data outside of Singapore, in compliance with applicable data protection or privacy laws.

3.4. The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to the terms of use) 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).

4. withdrawing your consent

4.1. 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.

4.2. 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 fourteen (14) business days of receiving it.

4.3. 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 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 clause 4.1 above.

4.4. 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.

5. access to and correction of personal data

5.1. 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.

5.2. 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.

5.3. We will respond to your request as soon as reasonably possible. In general, our response will be within fourteen (14) 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).

6. protection of personal data

6.1. To safeguard your Personal Data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, organisational, physical and technical measures (such as up-to-date antivirus protection, encryption, use of privacy filters), and disclosing Personal Data both internally and to our authorised third party service providers and agents only on a need-to-know basis.

6.2. 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.

7. accuracy of personal data

7.1. We generally rely on the Personal Data provided by you (or your authorised representative).

7.2. In order to ensure that your Personal Data is current, complete and accurate, please update us if there are any changes to your Personal Data by informing our Data Protection Officer in writing or via email at the contact details provided below. You are responsible for the completeness and accuracy of all Personal Data provided to us.

8. retention of personal data

8.1. Your Personal Data is retained for so long as the purpose for which it was collected remains and until it is no longer necessary for any other legal or business purposes. This period is generally 7 years from the date of termination or expiry of the last of your contract or relationship with us, but may possibly be for a longer period if, for example, an investigation or legal proceedings should commence within that period.

8.2. 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.