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CaringUp Privacy Policy

We have the highest regard for your privacy and personal data and realize that the success of our services depends on the trust that you have in the way we handle your personal data. By entrusting us with your information, we would like to assure you of our commitment to keep such information private. We have taken considerable steps to protect the confidentiality, security and integrity of this information. We encourage you to review the following information carefully.

Capitalised terms used in this Privacy Policy shall have the same meaning assigned to them under CaringUp Terms and Conditions.

  1. APPLICATION
    1. This Privacy Policy applies to the Users when browsing, visiting, accessing and/or using the CaringAide Platform.
    2. This Privacy Policy sets out our commitments and explains the rights that you have with respect to your personal data. If you do not agree to the terms of this Privacy Policy, please do not use the Service or any part thereof.
  2. GROUNDS FOR DATA COLLECTION
    1. By browsing, visiting, accessing and/or using the CaringAide Platform and/or when you provide personal data to us, you consent to the collection, storage, use, disclosure and other uses and processing of your personal data by us in accordance with this Privacy Policy, and such consent shall remain effective unless you otherwise notify us in writing of the withdrawal of your consent and the reason thereto. You shall not use our Service if you do not consent to this Privacy Policy and you shall immediately cease using our Service if you withdraw your consent for us to process your personal data.
    2. Personal data” and other terms defined under the Personal Data Protection Act 2012 (No. 26 of 2012) of Singapore (“PDPA”) when used in this Privacy Policy shall have the same meaning as defined under the PDPA.
    3. Processing of your personal data is necessary for the performance of our contractual obligations towards you under the Agreement and providing you with our Service, to protect our legitimate interests, and to ensure compliance with legal and financial regulatory obligations. Failure to provide the relevant data to us or the limitation placed on us in the processing of your personal data may affect our ability to provide the Service and/or your ability to enjoy some benefits from us.
  3. HOW DO WE RECEIVE INFORMATION ABOUT YOU?
    1. While you may use some of the functionality of the Service without creating a profile or registration, certain tools of the Service require registration and provision of your information, including personal data.
    2. If you use the Service without creating a profile or registering – we will only collect information through the use of cookies, web beacons, device data, and navigational data collection, as well as any voluntary information you provide us, including Health Information (as defined below). While we cannot directly identify you through such data, in some jurisdictions, this information is still subject to applicable data protection laws and requires your consent as described below.
    3. If you choose to create a profile or register with us – you will be asked to provide personal data which will be associated with your Health information.
    4. Whenever you submit information via our Service – including, but not limited to, by telephone or email with customer service, we may collect Health Information and other personal data (whether belonging to you or other person) you provide us, in order to provide you or such other person with our Service.
    5. If you choose to sign up via your social media accounts or other authentication providers – when you sign-up to the Service via your social media accounts or other authentication providers (such as Google account or Facebook account), we will have access to basic information made publicly from such account, such as your full name, home address, email address, birthdate, profile picture, friends list, personal description, as well as any other information you made publicly available on such account, or agreed to share with us.
    6. If you are referred to us by a third party – your pharmacies, healthcare service providers or insurers may introduce our Service to you, and with your consent, the pharmacies, healthcare service providers or insurers will provide your name and contact detaisl to us for us to get in touch with you.
    7. It is your voluntary decision whether to provide us with any personal data or Health Information, however if you do not provide the information we require or requested, you may not be able to create a profile or register with the Service and your use of the Service may be limited.
    8. To enable us to provide our Service to you effectively, the information you provide to us shall be accurate, complete, not misleading and without material omission, and that such information is kept up-to-date. If you discover that the information is inaccurate, incomplete, misleading, contains material omission or is outdated, please update us with the true, accurate, complete and updated information.
    9. If you provide us personal data about another person, you confirm that such other person has appointed you to act for him/her, to consent to the processing of his/her personal data by us in accordance with this Privacy Policy and to receive on his/her behalf any data protection notices.
  4. WHAT TYPES OF INFORMATION WE COLLECT?
    1. We collect the following personal data about you:
      1. Create Profile and Registration information – you will be required to provide your name, email address, gender, birth date, zip code, country of residency, home address and phone number;
      2. If you are a healthcare provider, you will be asked to provide information regarding your professional qualifications as well as additional personal data during registration.
      3. Payment information – you may be required to provide your bank account details, credit card or debit card details (if you subscribe for Subscribed Service);
      4. Voluntary information – when you communicate with us (for example when you send us an email or use a “contact us” form) we collect the personal data you provided us with.
      5. Technical information – we collect certain technical information that is automatically recorded when you use our Service, such as your IP address, device approximate location.
      6. Personal Health Information – you may choose to use certain features of the Service that will allow you to input other personal data with respect to your health, such as the medications you take, the date of your prescriptions, the number of refills you have made, how often you take your medication, dosage, physical measurements your doctor’s name, the name of your pharmacy, your health (both physical and mental) condition (collectively your “Health Information”).
    2. We also collect the following information:
      1. CaringAide Platform usage data – we collect information about your use of the CaringAide Platform. This includes, but not limited to: type of computing or mobile device you use, language of your operating system, the Internet browser you are using, geo-location and use of the CaringAide Platform.
      2. Health Information – we may also collect your non-identifiable Health Information if you choose to provide it (in case of non-registered users).
      3. Technical information – CaringAide Platform might also access a list of installed apps on your device. This is done only to ensure proper quality of service, as some apps might interfere with the CaringAide Platform’s functionality, such as blocking notifications, and in such cases we will notify you.
  5. TRACKING TECHNOLOGIES – COOKIES
    1. A cookie is a small piece of text that is sent to your CaringAide Platform or your browser when you access the CaringAide Platform. The CaringAide Platform provides this piece of text to your device when you return. We use cookies to help personalize your experience with the CaringAide Platform.
    2. A “persistent” cookie may be used to help save your settings and customizations. Also, if you log in to the CaringAide Platform, such a cookie will be used to recognize you as a valid user so you will not need to log in each time you use the CaringAide Platform.
    3. CaringAide Platform automatically accept cookies however allow you to modify security settings so you can approve or reject cookies on a case-by-case basis or reject all cookies.
    4. Also, you are free to delete any existing cookies at any time. If you delete or disable cookies from the CaringAide Platform, some parts or functions of the CaringAide Platform may not work properly for you.
    5. We also use “Google Analytics” to collect information about the use of the Service. Google Analytics collects information such as how often users visit the Service, what pages they visit, when they do so, and what other sites they used prior to coming to the Service. Google Analytics collects only the IP address assigned to you on the date you use the Service, as well as information regarding your operating system, language and information regarding your use of the Service, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personal data. We use the information we get from Google Analytics only to improve the Service. Google’s ability to use and share information collected by Google Analytics about your use of the Service is restricted by the Google Analytics Terms of Use and the Google Privacy Policy.
  6. HOW DO WE USE THE INFORMATION WE COLLECT?
    We use your information collected for the following purposes:
      1. Provision of Service – we will use your information for the provision and improvement of our Service to you, and for the processing of your requests and queries. For example, data collected automatically on the Service may be used to help diagnose problems with our servers, to make our Service more useful, to customize it and personalize its content for you (for example, we will use your Health information to send you reminders to take your medications).
      2. Monitoring compliance – we also use your personal data to monitor your compliance with the Agreement and other applicable laws.
      3. Enforcement – we may use your personal data for the purpose of enforcing our rights under the Agreement or to defend ourselves.
      4. General communication – we also use your personal data to send you texts, emails or other communications regarding general adherence information, Service maintenance, updates, or changes to this Privacy Policy or any other relevant agreements.
      5. Marketing purposes – we will use your personal data (such as your email address or phone number) to communicate with you. We may also send you promotional material concerning our services or our partners’ services (which we believe may interest you), including but not limited to, by building an automated profile based on your personal data, for marketing purposes.
        1. Opt-out of receiving marketing materials – If you do not want us to use or share your personal data for marketing purposes, you may request us to cease processing your personal data for marketing purposes using the information below under “How to Contact Us”. Please note that even if you opt-out, we may still use and share your personal data with third parties for non-marketing purposes (for example to fulfil your requests, communicate with you and respond to your inquiries, etc.). In such cases, the organisation with whom we share your personal data are authorized to use your personal data only as necessary to provide these non-marketing services.
      6. Analytics, surveys and research – we are always trying to improve our services and think of new and exciting features for our users. From time to time, we may conduct surveys or test features, and analyze the information we have to develop, evaluate and improve these features.
      7. Anonymised data – we may analyse and evaluate your personal data in connection with the Service, anonymise and aggregate our analysis and evaluation, and commercialise such anonymised and aggregated analysis and evaluation in any manner as we think fit.
      8. Protecting our interests – we may use your personal data when we believe it’s necessary in order to take precautions against liabilities, investigate and defend ourselves against any third party claims or allegations, investigate and protect ourselves from fraud, protect the security or integrity of our Service and protect the rights and property of CaringUp, its users and/or partners.
      9. Enforcing of policies – we may use your personal data in order to enforce our policies, including but limited to our Terms and Conditions.
      10. Compliance with legal and regulatory requirements – we also use your personal data as required by or for the purpose of compliance with law, regulation or other governmental authority, or to comply with a subpoena or similar legal process.
      11. Record-keeping – we will collect and retain your personal data in the ordinary course of our business and for so long as necessary for the fulfilment of the purposes set out in this Privacy Policy or as is required by any legal, regulatory and/or accounting requirements.
      12. Ancillary purpose – we may use your personal data for any purposes in connection with, relating or ancillary to any of the above.
  7. WITH WHOM YOUR PERSONAL DATA MAY BE SHARED?
    1. We may share your personal data with the following persons:
      1. Research partners – we may share your personal data with third parties, such as research institutes, healthcare systems and healthcare providers, that they may associate with other information that they have about you, for research purposes and for improvement of our services.
      2. Providers of personalized third party content – from time to time, we may also ask whether you would like us to share your personal data with another organisation that may want to send you information about their products or services. If you consent to such transfer by us of your personal data to another organisation, please note that the information provided will be subject to such organisation’s privacy practices and shall not be within our control.
      3. Content providers – we may also use your personal data in order to provide you with personalized third party content or links to third party sites that might interest you. We provide this third party content and/or links to third party sites for information purposes only and are not liable for such content or sites. For more information see the “Links to other Websites or Apps” section below.
      4. Service providers – we might share your personal data, as is reasonably necessary, with our contractors or consultants, including vendors and suppliers that provide us with development services, technology (such as Google Analytics), services, or content for the operation, development and maintenance of our Service or data and analysis on Service use, who are bound by an obligation of confidentiality, provided that we will only share personal data to the extent necessary with such contractors or consultants.
      5. Law authorities – we may share your personal data with law enforcement authorities, courts and tribunals, including with legal advisors and consultants, in case we need to respond to law enforcement requests or other legal requests or pursuant to a requirement imposed by law, order, judgment or decree, or courts in order to protect and defend our rights and property or those of Service users.
      6. Merger, acquisition or sale – we may transfer your personal data to another organisation in the event of a merger, acquisition or sale of all or a portion of our assets.
      7. Auditor, legal and professional advisor – we may share your personal data with our auditor if requested for the purpose of audit on our business. We may also share your personal data with our legal and other professional advisors for the purpose of enforcing our rights or defending any claims against us, or for any other purpose in connection with the Service.
      8. Data intermediary – we may appoint an organisation to process personal data on our behalf in connection with the Service. In this respect, we will share your personal data to the appointed organisation, who will be required to process your personal data in accordance with this Privacy Policy.
      9. Group companies – we may share your personal data with CaringUp group of companies for internal reporting purposes.
    2. We may offer you, from time to time and at our sole discretion, participation in customized programs, based on specified criteria (“Programs”). Participation in Programs may require sharing of your personal data with additional third parties. If you choose to participate, we will provide you with additional information and seek your consent for such sharing.
    3. You may share the following information through our Service:
      1. Guardian – you may send family members or friends an invitation to be your “Guardian” by means of the Service, so that such Guardian will receive alerts and information in connection with the features you have opted for, such as regarding your compliance with your medication regime, emergency alert on your health anomalies. By sending such invitation, you represent that you have the right to contact the Guardian and that you consent to us sending your personal data (including Health Information) to the Guardian. Sharing of your personal data in this manner is solely your responsibility.
      2. Medical professionals and doctors – you may use the Service in order to share your personal data or other information with your doctor or healthcare providers. Such sharing may be enabled by inviting your healthcare provider to monitor your personal data, by accepting an invitation from your healthcare provider to download and use the Service, or otherwise using the Service settings to share your information with your healthcare provider; in these cases you consent to us sending your personal data (including Health Information) with your healthcare providers. Confirm with your healthcare provider that they have sent you an invitation to download the CaringAide Platform. Such sharing of your information is at your discretion and is solely your responsibility.
      3. Pharmacies – you may choose to share your personal data with pharmacies with which we partner, in order that we may provide you with reminders to get your prescription refilled. If you choose to share your personal data in this manner, please note that such information may be disclosed to the pharmacies and will be subject to their privacy practices. Such sharing of your information is at your discretion and is solely your responsibility.
    4. While we take great care to keep your personal data confidential and secure, when you share your health or medication information with others or provide feedback regarding health matters, medications and otherwise, including by means of social media sites, or when you participate in a forum on the Service, any information disclosed by you in such way is solely your responsibility. You should exercise caution when disclosing any information (including personal data) in such ways, as you do not know who will access or use such information and for what purposes.
  8. USE OF AGGREGATED DATA
    We make every effort to ensure that aggregated data does not include any personally identifiable information . We may analyze and/or combine all information we receive, including Health Information and information regarding your use of the Service, with information from other users to create aggregated data that may be disclosed to and utilized by us, our affiliates and by third parties without restriction, on commercial terms that we can determine in our sole discretion, for purposes such as: content marketing, research purposes, in order to understand behavior patterns, in order to increase adherence to medication regimens, marketing strategies and for entering into commercial contracts in order to provide our users with the Service.
  9. ACCESS AND CORRECTION
    You may request access to and correction of, your personal data and limit the processing of your personal data, or make any enquiries or complaints in respect of the processing of your personal data, by contacting us at the contact details set out in “How to Contact Us” section below.
  10. INTERNATIONAL TRANSFERS
    1. You hereby consent that we may transfer your personal data out of Singapore or the jurisdiction in which the Service was obtained or is used for the purposes set out in Clauses 6 and 7 above. Where your personal data is transferred out of Singapore or the jurisdiction in which the Service was obtained or is used, such personal data shall be processed outside Singapore or such jurisdiction in accordance with this Privacy Policy.
    2. We may transfer our databases containing your personal data in connection with the transfer or sale of all (or substantially all) of our business assets, or in the event of a merger, consolidation or similar transaction.
    3. We store Contents on cloud (which may be on Amazon and/or MS Azure), where your data can be stored and/or backed up in any of the jurisdictions where the cloud service providers provide their cloud service. You hereby consent that we may store your personal data on our cloud server, which may be located outside Singapore or the jurisdiction in which the Service was obtained or is used.
  11. RETENTION
    We will retain your personal data for as long as necessary to provide our services or as required by any legal, regulatory and/or accounting requirements. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time. Without prejudice to the foregoing, where you do not use our Service for 1 consecutive year, we will delete all your Health Information from our records.
  12. LINKS TO OTHER WEBSITES OR APPS
    Our Service may link to or refer to websites or mobile device services that we do not control. Any personal data you provide on the linked pages is provided directly to this third party and is subject to this third party’s provider’s privacy policy. This Privacy Policy does not apply to such other websites or mobile device services, and we are not responsible for the privacy practices or content of any website or mobile device service not controlled by us. If you have any concerns, we urge you to review the terms of those other websites or mobile device services for more information about their applicable policies.
  13. HOW WE PROTECT YOUR INFORMATION
    1. We have implemented administrative, technical, and physical safeguards to help prevent unauthorized access, use, or disclosure of your personal data. Your information is stored on secure servers and isn’t publicly available. We limit access of your information only to those employees or partners that need to know the information in order to enable the carrying out of the agreement between us.
    2. You need to help us prevent unauthorized access to your account by protecting your password appropriately and limiting access to your account (for example, by signing off after you have finished accessing your account). You will be solely responsible for keeping your password confidential and for all use of your password and your account, including any unauthorized use.
    3. While we seek to protect your information to ensure that it is kept confidential, we cannot absolutely guarantee its security. You should be aware that there is always some risk involved in transmitting information over the internet. While we strive to protect your personal data, we cannot ensure or warrant the security and privacy of your personal data or other content you transmit using the Service, and you do so at your own risk.
  14. CHILDREN
    Our Service is intended for use by persons 18 years of age and older. Under no circumstances should the Service be used by children under 18 years of age, and we will not knowingly collect personal data from any person we know to be in this age group. If any person discovers that his/her child has been using the Service without his/her consent, or that someone has been using the Service for or on behalf of his/her child without his/her consent, please contact us using the information below under “How to Contact Us” and we will take reasonable steps to delete the child’s information from our active databases. We reserve the right to check our user base from time to time and remove users whom we have grounds to believe they are in fact minors, including without limitation, restricting those user accounts, or deleting them, as we may deem appropriate.
  15. MODIFICATIONS OF THIS PRIVACY POLICY
    We reserve the right to update or modify this Privacy Policy at any time and from time to time. By continuing to use the Service after any such changes, you agree to follow and be bound by this Privacy Policy as changed. For these reasons, we encourage you to periodically review this Privacy Policy for the latest version.
  16. HOW TO CONTACT US

    IF YOU HAVE ANY QUESTIONS, COMMENTS, REQUESTS, OR CONCERNS RELATED TO THIS PRIVACY POLICY OR THE PRIVACY PRACTICES FOR OUR SERVICE, PLEASE CONTACT US AT:

    CARINGUP PTE. LTD.
    ATTN: Chief Data Protection Officer
    7 Temasek Boulevard, #12-07 Suntec Tower One, Singapore 038987
    support@caringup.com

    You may also contact our Data Protection team: dataprotection@caringup.com

  17. ENGLISH VERSION AND MALAY VERSION
    If there is a conflict between this English version of the Privacy Policy and the corresponding Bahasa Malaysia version, the terms in this English version shall prevail.