THE CLAUSES DESCRIBED IN THIS DOCUMENT ARE RELATED TO YOUR PERSONAL DATA. PLEASE READ THESE TERMS CAREFULLY.
DATA PROTECTION POLICY
This Data Protection Notice (“Notice”) sets out the basis which Kinexcs Pte Ltd (“we”, “us”, or “our”) may collect, use, disclose or otherwise process personal data of our customers in accordance with the Personal Data Protection Act (“PDPA”) of Singapore. This Notice applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose or process personal data for our purposes.
1. As used in this Notice:
“customer” means an individual who (a) has contacted us through any means to find out more about any goods or services we provide, or (b) may, or has, entered into a contract with us for the supply of any goods or services by us; and
“personal data” means data, whether true or not, about a customer who can be identified: (a) from that data; or (b) from that data and other information to which we have or are likely to have access.
2. Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include your name and identification information such as your patient ID or NRIC number, contact information such as your address, email address or telephone number, nationality, gender, date of birth, marital status, photographs and other audio-visual information, employment information and financial information such as credit card numbers, debit card numbers or bank account information, medical history such as drug usage, allergies, surgical procedures performed, menstrual information, diet.
3. Other terms used in this Notice shall have the meanings given to them in the PDPA (where the context so permits).
COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA
4. We generally do not collect your personal data unless (a) it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”) after (i) you (or your authorised representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorised representative) have provided written consent to the collection and usage of your personal data for those purposes, (b) collection and use of personal data without consent is permitted or required by the PDPA or other laws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorised by law).
5. Information that you provide directly to us:
a. name, age, gender, email address, telephone number, country;
b. health and wellness-related data, such as height, weight;
c. For KIMIA Recover Users: Information related to your surgery such as date of surgery, type of surgery, affected joint, joint range of motion, activities of daily living, pain scores and description, wound images, activity levels
d. We may also collect data, such as health and wellness-related data and fitness and nutrition-related information when you link KIMIA Recover app on your mobile device to other third-party devices an apps, included when such data is saved to your KIMIA Recover App.
6. Information about your use of KIMIA Recover:
a. In addition to the information you provide, we will collect information about your use of our KIMIA Recover App through software on your devices and by other means. We will collect:
b. Information about your use of KIMIA Recover, such as preference settings, and in-app usage information, including menus and settings clicked, features used, frequency and duration of use of the app, and crash report data (including crash logs and error messages displayed);
c. Device information, such as firmware version, operating system and device identifiers, including MAC address, serial number and mobile advertising identifiers.
d. Location data: Bluetooth and Wifi signals and other information related to your location and with your permission your device’s precise geolocation when you use location-based features. Please note that if you decline to allow KIMIA Recover to collect your precise geolocation, you may not be able to use all of the KIMIA Recover services or features.
e. Information about your use of KIMIA Recover in ways that we describe to you at the time of collection or otherwise with your consent.
7. 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 goods and/or services requested by you;
b. verifying and authenticating your identity;
c. responding to, handling, and processing queries, requests, applications, complaints and feedback from you;
d. managing your relationship with us;
e. complying with any applicable laws, regulation, codes or practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;
f. any other purposes for which you have provided the information;
g. transmitting to any unaffiliated third parties including our third-party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes; and
h. any other incidental business purposes related to or in connection with the above.
8. 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 goods or services requested by you; or
b. to third party service providers, agents and other organisations we have engaged to perform any of the functions listed in clause 5 above for us.
9. The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under any contract with you).
WITHDRAWING YOUR CONSENT
10. 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 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 through the contact details provided below.
11. 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.
12. Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our goods or services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in clause 8 above.
13. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.
ACCESS TO AND CORRECTION OF PERSONAL DATA
14. 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 through the contact details provided below
15. 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.
16. We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing generally 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). Should we not respond to your request within a reasonable time after the guideline of thirty (30) days, you may submit another request with reference to previous requests.
PROTECTION OF PERSONAL DATA
17. To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as up-to-date antivirus protection, encryption and the use of privacy filters to secure all storage and transmission of personal data by us and disclosing personal data both internally and to our authorised third-party service providers and agents only on a need-to-know basis.
18. 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.
ACCURACY OF PERSONAL DATA
19. We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided below.
RETENTION OF PERSONAL DATA
20. We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.
21. 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.
DATA PROTECTION OFFICER
22. You may contact us if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, in the following manner:
Contact email: firstname.lastname@example.org
Contact no.: +65 9731 0962
EFFECT OF NOTICE AND CHANGES TO NOTICE
23. This Notice 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.
24. We may revise this Notice from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Notice was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.
Last updated: Sept 2022