DATA PROTECTION POLICY
The Company, Flower Moon TCM Service Pte. Ltd. (“FMC”) is committed to protecting your privacy and we take responsibility under Singapore’s Personal Data Protection Act 2012 (the “PDPA”). We also recognize the importance of the personal data you have entrusted to us and believe that it is our responsibility to properly manage, protect and process your personal data.
This Data Protection Policy is designed to assist you in understanding how we collect, use, disclose and/or process the personal data you have provided to us, as well as to assist you in making an informed decision before providing us with any of your personal data.
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 your personal data, please do not hesitate to contact our Personal Data Protection Officer (the “PDPO”) at: fmtcmclinic@gmail.com. Your indication at the subject header that it is a PDPA queries would assist us in attending to your queries speedily by passing it on to the relevant staff in our organisation to handle. For example, you could insert the subject header as “PDPA Queries”.
PERSONAL DATA PROTECTION
1. INTRODUCTION TO THE PDPA
1.1 “Personal Data” is defined under the PDPA to mean data, about an individual who can be identified from that data; or from that data and other information to which an organisation has or is likely to have access. Common examples of personal data could include names, identification numbers, contact information, photographs and video images.
1.2 We will collect your personal data in accordance with the PDPA. We will notify you of the purposes for which your personal data may be collected, used, disclosed and/or processed, as well as obtain your consent for the collection, use, disclosure and/or processing of your personal data for the intended purposes, unless an exception under the law permits us to collect and process your personal data without your consent.
2. PURPOSES FOR COLLECTION, USE, DISCLOSURE AND PROCESSING OF PERSONAL DATA
2.1 The personal data which we collect from you may be collected, used, disclosed and/or processed for various purposes, including one or more of the following purposes, depending on the circumstances for which we may/will need to process your personal data, as the case may be:
– To render medical and consultancy services to you;
– To transfer or share your data with other members of FMC or third party vendors engaged by us for the purpose of rendering medical care to you. These health services may be located outside of Singapore.
– To communicate with your company or personal insurance for claims, reinsurance and compliance/audit purposes pertaining to your care.
– To respond to your enquiries, provide you advice and services to ensure continuity of care.
– To evaluate and/or process your registration record with us whereby you may be given access to possible rewards, discounts, privileges, promotions, offers, services and/or products, offered by FMC, FMC’s related corporations or associated companies, as well as partners, merchants and/or third party organisations with whom FMC may collaborate, partner or tie up with;
– To administer, manage and/or maintain your medical record with FMC;
– To administer, manage and execute marketing activities;
– To provide and send you marketing, advertising and/or promotional information and materials relating to products, events and/or services that FMC or FMC Partners may be selling, marketing, offering and/or promoting, via various modes of communication such as postal mail to your postal address(es) and/or electronic transmission to your email address(es);
– To deal with or facilitate customer service and reservations, carry out your instructions, or deal with or respond to any enquiries given by you or on your behalf;
– To produce statistics and research for internal reporting and/or record-keeping requirements;
– To conduct research, analysis and development activities (including but not limited to data analytics, surveys, product and service development and/or profiling) to improve FMC’s services or products and/or to enhance your healthcare needs experience.
– storing, hosting, backing up (whether for disaster recovery or otherwise) of your personal data, whether within or outside Singapore;
– any other purposes which we notify you of at the time of obtaining your consent.
2.2 As the purposes for which we may/will collect, use, disclose or process your personal data depend on the circumstances at hand, such purpose may not appear above. However, we will notify you of such other purpose at the time of obtaining your consent, unless processing of your personal data without your consent is permitted by the PDPA or by law.
2.3 We may share this personal data with partners and third parties in order to demonstrate the activities of the company and enable them to improve their service. We respect the confidentiality of the personal data you have provided to us. We do not sell your personal data to third parties. Where we disclose your personal data to third parties, we will employ our best efforts to require such third parties to protect your personal data.
3. SPECIFIC ISSUES FOR THE DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES
3.1 We respect the confidentiality of the personal data you have provided to us.
3.2 In that regard, we will not disclose your personal data to third parties without first obtaining your consent permitting us to do so, with such consent being either express or deemed, as permitted by law. However, please note that we may disclose your personal data to third parties without first obtaining your consent in certain situations, including, without limitation, the following:
(a) cases in which the disclosure is required or authorized based on the applicable laws and/or regulations;
(b) cases in which the purpose of such disclosure is clearly in your interests, and if consent cannot be obtained in a timely way;
(c) cases in which the disclosure is necessary to respond to an emergency that threatens the life, health or safety of yourself or another individual;
(d) cases in which the disclosure is necessary for any investigation or proceedings;
(e) cases in which the personal data is disclosed to any officer of a prescribed law enforcement agency, upon production of written authorisation signed by the head or director of that law enforcement agency or a person of a similar rank, certifying that the personal data is necessary for the purposes of the functions or duties of the officer;
(f) cases in which the disclosure is to a public agency and such disclosure is necessary in the public interest; and/or
(g) where such disclosure without your consent is permitted by the PDPA or by law.
3.3 The instances listed above at paragraph 3.2 are not intended to be exhaustive. For more information on the exceptions, you are encouraged to peruse the Second, Third and Fourth Schedules of the PDPA which is publicly available at statutes.agc.gov.sg or https://sso.agc.gov.sg/Act/PDPA2012
3.4 Where we disclose your personal data to third parties with your consent, we will employ our best efforts to require such third parties to protect your personal data.
4. REQUEST FOR ACCESS AND/OR CORRECTION OF PERSONAL DATA
4.1 You may request to access and/or correct the personal data currently in our possession or control by submitting a written request to us, by writing to our PDPO. We will need enough information from you in order to ascertain your identity as well as the nature of your request, so as to be able to deal with your request.
4.2 For a request to access personal data, once we have sufficient information from you to deal with the request, we will seek to provide you with the relevant personal data within 30 days. Where we are unable to respond to you within the said 30 days, we will notify you of the soonest possible time within which we can provide you with the information requested. Note that the PDPA exempts certain types of personal data from being subject to your access request.
4.3 For a request to correct personal data, once we have sufficient information from you to deal with the request, we will:
(a) correct your personal data within 30 days. Where we are unable to do so within the said 30 days, we will notify you of the soonest practicable time within which we can make the correction. Note that the PDPA exempts certain types of personal data from being subject to your correction request; and
(b) subject to paragraph 4.4, we will send the corrected personal data to every other organisation to which the personal data was disclosed by FMC within a year before the date the correction was made, unless that other organisation does not need the corrected personal data for any legal or business purpose.
(c)Due to the sensitive nature of the data, all requests of Correction Of Personal Data have to be made in person and the relevant original documents are required:
– For change of name, please provide original NRIC or passport.
– For changes in NRIC/FIN/Passport No., please provide the original NRIC, FIN or passport.
– For changes in local or foreign residential address, please provide one of the following documents (within the last 3 months) :
o Telecommunication/Internet bill/ Utilities bill
o Statement/letter from HDB
o Credit Card/ Bank/ Insurance Statement
o Tenancy agreement for residence
4.4 Notwithstanding paragraph 4.3 (b), we may, if you so consent, send the corrected personal data only to specific organisations to which the personal data was disclosed by us within a year before the date the correction was made.
4.5 We will also be charging you a reasonable fee for the handling and processing of your requests to access your personal data. We will provide you with a written estimate of the fee we will be charging. Please note that we are not required to respond to or deal with your access request unless you have agreed to pay the fee.
5. REQUEST TO WITHDRAW CONSENT
5.1 You may withdraw your consent for the collection, use and/or disclosure of your personal data in our possession or under our control by submitting your request by sending an e-mail to our PDPO.
5.2 We will process your request within a reasonable time from such a request for withdrawal of consent being made, and will thereafter not collect, use and/or disclose your personal data in the manner stated in your request.
5.3 However, your withdrawal of consent could result in certain legal consequences arising from such withdrawal. In this regard, depending on the extent of your withdrawal of consent for us to process your personal data, it may mean that we will not be able to continue with your existing relationship with us.
6. ADMINISTRATION AND MANAGEMENT OF PERSONAL DATA
6.1 We will take reasonable efforts to ensure that your personal data is accurate and complete, if your personal data is likely to be used by FMC to make a decision that affects you, or disclosed to another organisation. However, this means that you must also update us of any changes in your personal data that you had initially provided us with. We will not be responsible for relying on inaccurate or incomplete personal data arising from you not updating us of any changes in your personal data that you had initially provided us with.
6.2 We will also put in place reasonable security arrangements to ensure that your personal data is adequately protected and secured. Appropriate security arrangements will be taken to prevent any unauthorized access, collection, use, disclosure, copying, modification, leakage, loss, damage and/or alteration of your personal data. However, we cannot assume responsibility for any unauthorized use of your personal data by third parties which are wholly attributable to factors beyond our control.
6.3 We will also put in place measures such that your personal data in our possession or under our control is destroyed and/or anonymized as soon as it is reasonable to assume that (i) the purpose for which that personal data was collected is no longer being served by the retention of such personal data; and (ii) retention is no longer necessary for any other legal or business purposes.
6.4 Where your personal data is to be transferred out of Singapore, we will comply with the PDPA in doing so. In this regard, this includes us obtaining your consent unless an exception under the PDPA or law applies, and taking appropriate steps to ascertain that the foreign recipient organisation of the personal data is bound by legally enforceable obligations to provide to the transferred personal data a standard of protection that is at least comparable to the protection under the Act. This may include us entering into an appropriate contract with the foreign recipient organisation dealing with the personal data transfer or permitting the personal data transfer without such a contract if the PDPA or law permits us to.
7. COMPLAINT PROCESS
7.1 If you have any complaint or grievance regarding about how we are handling your personal data or about how we are complying with the PDPA, we welcome you to contact us with your complaint or grievance.
7.2 Please contact us through one of the following methods with your complaint or grievance:
(a) Singapore telephone number: +65 9 864 864 7.
(b) E-mail: fmtcmclinic@gmail.com and Attention to: ‘Personal Data Protection Officer’
(c) Office address: Flower Moon TCM Service Pte. Ltd.
101 Irrawaddy Road #15-02, Royal Square Medical Centre @ Novena, Singapore 329565.
Attention to: ‘Personal Data Protection Officer’
7.3 Where it is an email or a letter through which you are submitting a complaint, your indication at the subject header that it is a PDPA complaint would assist us in attending to your complaint speedily by passing it on to the relevant staff in our organisation to handle. For example, you could insert the subject header as “PDPA Complaint”.
7.4 We will certainly strive to deal with any complaint or grievance that you may have speedily and fairly.
8. UPDATES ON DATA PROTECTION POLICY
8.1 As part of our efforts to ensure that we properly manage, protect and process your personal data, we will be reviewing our policies, procedures and processes from time to time.
8.2 We reserve the right to amend the terms of this Data Protection Policy at our absolute discretion. Any amended Data Protection Policy will be posted on our website and can be viewed at tcmconfinement.com/privacy-policy.
8.3 You are encouraged to visit the above website from time to time to ensure that you are well informed of our latest policies in relation to personal data protection.
OUR WEBSITE
9. PERSONAL DATA AND OUR WEBSITE
9.1 In your use of the tcmconfinement.com (“Website”), we may collect, use, disclose and/or process certain personal information or data about you. Such personal information or data comprises, but is not limited to:
(a) Name;
(b) Email address;
(c) Date of birth;
(d) Billing address;
(e) Shipping address;
(f) Telephone number; and
(g) Gender.
9.2 Such personal data may/will be collected, used, disclosed and/or processed by FMC for various purposes, including one or more of the following purposes, depending on the circumstances for which we may/will need to process your personal data, as the case may be:
(a) Managing and/or administering your use and/or access of the Website;
(b) Managing, operating, administering and providing you the services offered on the Website;
(c) For identification and/or verification;
(d) For contacting you on matters relating to your transactions on the Website and your requested services on the Website, and any enquiries and/or requests submitted by you through the Website or otherwise;
(e) Social Media marketing using direct and open graph techniques (if you have consented to the same);
(f) For digital and conventional marketing purposes such as sending you direct mailers and post about new products, special offers or other information which we think you may find interesting (if you have consented to the same);
(g) Publishing customers review in digital and print format to open public (if you have consented to the same); and/or
(h) any other purposes which we notify you of at the time of obtaining your consent.
9.3 Paragraph 2.2 above will also apply to your personal data for the Website Management or Transaction Purposes.
9.4 By browsing and using this Website, or by registering for or using the services on the Website, you:
(a) consent to FMC and/or FMC’ affiliates or related corporations, collecting, using, disclosing and/or processing your personal data for one or more of the Website Management or Transaction Purposes; and
(b) consent to FMC and/or FMC’ affiliates or related corporations disclosing your personal data to third party service providers, agents and/or FMC’ affiliates or related corporations, and/or other third parties, whether sited in Singapore or outside of Singapore, for one or more of the Website Management or Transaction Purposes.
9.5 If you believe that any information we are holding of you is incorrect or incomplete, please contact us at fmtcmclinic@gmail.com.
10. LINKS TO OTHER WEBSITES
Our Website may contain links to other websites of interest. However, once you have used these links to leave our Website, you should note that we do not have any control over that other website. Please note that we are not responsible for the privacy practices of such other websites and advise you to read the privacy statements of each website you visit which collects personal information. We are also not responsible for the content of any such websites nor do we make any representations whatsoever of the content of any such websites.
11. USE OF COOKIES
11.1 Please note that we might use cookies on our website. Cookies are text files that we put on your computer and they store/record information about your visit to and use of the Website. It enables our own system to recognise you when you visit our Website again and improve our service to you. Overall, cookies help us provide you with a better Website by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify the browser setting to decline cookies if you prefer. However, note that this may prevent you from taking full advantage of the Website.
11.2 We might use cookies for the following purposes :
• to improve your user experience on this website;
• to remember your preferences;
• to help us understand how this website is performing;
• to monitor traffic to the website;
• to enable this website to function properly;
11.3 You can control cookies through your web browser settings. This allows you to determine which cookies to allow and which to refuse. If you disallow the use of cookies on our website, please note that you may not be able to access the full range of functions that our website offers.
11.4 Personal data (if any) that we collect from you through cookies may be passed to our third party service providers, whether located in Singapore or elsewhere, for one or more of the Purposes, for managing and/or administering our website, or for the purpose of data hosting/storage/backup.
11.5 Your use of our website constitutes consent by you to our use of cookies and to the matters set out herein.
12. FMC reserve the right to amend this policy at our absolute discretion. Any amended policy will be posted on our website and can be viewed at tcmconfinement.com/privacy-policy. You are encouraged to visit the website from time to time to ensure that you are well informed of our latest policies in relation to personal data protection.
13. PDPA Forms
Respective forms can be downloaded at the link as below:
-Personal Data Correction Form
-Request to Access Personal Data Form
-Complaint Form
-Click the Link here to access the forms (Note: hand phone need Google Drive apps to access the form)