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Privacy Policy

January 23, 2023

Privacy Policy

This is the Privacy Policy of Asia Digital Doctor Pte. Ltd. (“ADD” or “we”).

ADD respects your privacy and is committed to protecting the personal information that we collect. The following is our Privacy Policy. When we gather and use information from you, we will comply with this Privacy Policy as well as any applicable Singapore privacy laws.

ADD operates the website located at hatchplus.com.sg and other related websites (collectively, “Websites”). We hope the following Privacy Policy will help you understand how ADD collects, uses and/or discloses and safeguards the information that is collected on our Website or is otherwise in our possession or under our control. It also sets out your rights in relation to your information, and who you can contact for more information or queries.

ADD may amend and update this Privacy Policy at our sole discretion from time to time. Any amendments or revisions to this Privacy Policy will be posted on our Website, upon which said amendments or revisions will take effect immediately. You are therefore advised to check our Website from time to time to ensure that you are aware of any amendments to the Privacy Policy.

By continuing to use our Website, you signify that you have read and understood this Privacy Policy, and accepted and agreed to be bound by the terms of this Privacy Policy as well as any amended version thereof.

By accepting this Privacy Policy or continuing to access and use our Website, you are deemed to have aged and consented to allow ADD, its subsidiaries or affiliates to:

(a) collect, use, disclose and/or process information about you that you have provided or may in the future provide to ADD, its subsidiaries or affiliates for the purposes set out in this Privacy Policy; and

(b) disclose information about you in accordance with this Privacy Policy.

If you do not agree with this Privacy Policy, please do not access or use our Website.

  1. General Principles

As a matter of principle, we try to minimise the amount of personal data we collect from you. We do not ask for more than that which is required to service your account and provide the products or services you select.

  1. Collection of Data

The Types of Data We Collect from You

The information that we collect from our users fall into the following five broad categories:

  1. Personal data. For the purposes of this Privacy Policy, “personal data” shall have the meaning ascribed to it under the Singapore Personal Data Protection Act 2012 (“PDPA”). This is information that identifies you specifically.

For the purposes of your account registration process and subsequent purchase and/or use of our products and/or services, we may collect personal data from you which may include, without limitation:

(a) your name, age, date of birth, occupation, gender, mailing address, email address, details of your identification document(s), and telephone or mobile number;

(b) medical and health information that you provide us, which may include information or records relating to your medical or health history, health status and laboratory testing results, diagnostic images, and other medical and health related information; and

(c) billing information that you provide us, for example credit card or online payment system account information.

We use the aforementioned information to open an account for you, verify that you are a unique visitor, and enable you to purchase the products or use the services offered on our Website.

  1. Technical data. This is information that we collect in order to track how the user is using the Website. We may use “cookies”, web beacons, and other technologies to collect this information. Examples of what we collect may include information on the server your computer is logged onto, your browser type (i.e., Firefox, Safari, etc.), your Internet protocol address, and your selection of the various functions on the Website. We use this information to measure usage rates of the Website’s functions and/or services and deliver customised content and advertising within our Website to users whose behaviour indicates that they are interested in a particular subject area, amongst others. These measurements, in turn, help us to improve the Website and our services to our users. Also, note that at any time, you may adjust settings on your browser to refuse cookies. However, if you choose to disable cookies, many of the features and services on the Websites will not operate properly.

How We Collect Your Data

We collect the aforementioned data directly from you when you access and use our Website, or when you contact us in connection with our products and/or services.

When you provide data on behalf of another individual, you undertake and will ensure that the individual whose data is supplied to us has authorised the disclosure of his data to us, is informed of and agrees to the terms of this Privacy Policy.

If you prefer not to provide your personal data to us, you may opt not to do so. In addition, you have the right to withdraw your consent at any time by contacting our Data Protection Officer (at the address stated in Section X below). However, please note that by denying the provision of your personal data, you may not be able to purchase some of the products or use some of the services on our Website that require submission of your personal data and/or be able to benefit from the services that we provide which may require such personal information.

III. Use of Data

We use your personal data for the following purposes:

  1. opening and maintaining your account with us;
  2. verifying that you are a unique user of our Website;
  3. introducing you to medical practitioners and wellness experts (collectively, “Practitioners”) and enabling you and the Service Providers to conduct consultations (“Consultations”) via our Website or any other platform that we may make available from time to time. In order to facilitate this service, we will need to share your personal data with the Practitioner who you have chosen or connected with. Your data will only be shared with the aforementioned Practitioner and only for the purposes of facilitating the conduct of the Consultations;
  4. providing you with information or products or services that you have requested;
  5. providing you with our products and services, and customising our products and services to you;
  6. processing fees for completed Consultations or or any transactions relating to any other products or services purchased or used by you;
  7. notifying you about changes to our products or services;
  8. improving the Website and ensuring that the content on the Website is presented in the most effective manner for you and your device;
  9. administering the Website, including internal operations such as troubleshooting, data analysis, testing, research, statistical and survey purposes;
  10. keeping the Website safe and secure;
  11. responding to your queries, requests or feedback;
  12. enforcing our terms, conditions and policies;
  13. completing our customer screening and identity verification process including checks in relation to fraud detection and prevention, anti-money laundering, know-your-client and the countering of the financing of terrorism;
  14. detecting, investigating and preventing fraudulent transactions or illegal activities;
  15. aggregating data into anonymised statistical data, which we will use for statistical analysis so that we can improve our service offering to serve you better;
  16. with your consent, contacting you and sending you marketing and promotional materials in relation to products and services that we, our subsidiaries and/or affiliates offer. In this regard, if you have provided an incorrect address or phone number (or any other contact detail) (collectively, “Contact Addresses”), you may not receive these communications. We will not be responsible for any breach of privacy due to correspondence going to an incorrect Contact Address; 
  17. sending you our newsletters.
  18. administering a contest, promotion, survey, research study and/or market research activity, or any other services provided by us. When you reply to a giveaway campaign on our Website, you agree that (i) we use your personal data as mentioned in the paragraph “We use personal data held about you in the following ways” above and (ii) we share your personal data with our giveaway partner and, starting from there, our giveaway partner’s privacy policy shall apply and we recommend you to refer to them.
  19. sending you advertorials from our partners and advertisers.
  20. sending our advertisers any special offers or information services that may interest them for any upcoming promotional campaigns. (applicable for B2B communication), and
  21. any other purposes that we may notify you from time to time.
  1. Disclosure of Data

We may disclose your personal data in the following circumstances:

  1. when we obtain your permission;
  2. when we find it necessary to disclose your personal data to our subsidiaries and/or affiliates in order to respond to your queries, requests or feedback;
  3. when we find it necessary to disclose information to third-party service provider(s) who have confidentiality agreement(s) with us, in order to provide the products or services indicated to you. The services performed by the third-party service provider(s) may include, without limitation, performing statistical analysis, sending you emails or postal mails, providing user support, arranging for deliveries, or any other service which we deem necessary in order to provide the products or services indicated to you;
  4. when we find it necessary to disclose information to a buyer or other successor in the event of a merger or acquisition, restructuring, reorganisation, or other sale or transfer of some or all of ADD’s assets, in which your personal data maintained by the Website is among the assets transferred; and
  5. when we find it necessary to disclose information to our legal advisors or other professional advisors, or as otherwise authorised or required by law.

The third-party service provider(s) referred to in paragraph (3) above may be located within or outside Singapore. In this regard, by accepting this Privacy Policy or continuing to access or use our Website, you are deemed to have agreed and consented that such third-party service provider(s) may, to the extent necessary to provide the products or services to you, collect, use, disclose and/or process information about you.

We also reserve the right to share your personal data as is necessary to prevent a threat to the life, health or security of an individual or corporate entity. Further, we reserve the right to disclose personal data, as is necessary, to law enforcement, governmental agencies, or authorised third parties, in response to a verified request relating to a criminal investigation or alleged illegal activity or any other activity that may expose us to legal liability.

  1. Safeguards of Data

As part of our commitment to keeping your personal data (which is in our possession or control) secured, we have taken reasonable steps to protect the information you share with us in order to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks. Such measures include, but are not limited to, setup of processes, equipment and software to avoid unauthorised access or disclosure of this information. We limit access to personal data only to ADD employees who are reasonably required to come in contact with that information in order to provide services to you or in order to do their jobs.

While we are committing to taking reasonable steps to protect the security of the information communicated through our Website, the Internet is not a secure method of transmitting information, and accordingly we do not assume any responsibility for the information you submit to or receive from us through the Internet or for any unauthorised access or use of that information. We also cannot and do not guarantee that information communicated by you to us or by us to you will be received or that it will not be altered before or after its transmission to us or to you, as the case may be. In any event, you agree to not hold us, our subsidiaries or affiliates, our past, present and future employees, officers, directors, contractors, consultants, suppliers, vendors, service providers, agents, representatives, predecessors, successors and assigns liable for any loss or damage of any sort incurred as a result of any misappropriation, interception, modification, deletion, destruction or use of the information provided through our Website.

The security of your personal data also relies on your protection of your personal data. In this regard, we kindly ask that you protect the password given or created by you for your use of our Website without sharing the same with anyone.

  1. Retention and Transfer of Data

We shall not retain your personal data in our possession and/or database if your personal data is no longer required to meet the purposes for which they were collected and/or no longer serves a legal and/or business purpose.

Some of the recipients of your personal data (for example, our third-party service providers) may be based in countries outside of Singapore. We are committed to adequately protecting your personal data regardless of where the data resides and to providing appropriate protection for your data where such data is transferred outside of Singapore. We will use our best efforts to ensure that the third-party service providers engaged by us to provide the products and services to you will not transfer information about you to a place outside Singapore without our prior written consent. In the event that we provide such consent, we will use our best efforts to procure that the relevant third-party service provider provides a written undertaking to us that the information about you which is transferred outside of Singapore will be protected at a standard that is at least comparable to that under the PDPA. If the relevant third-party service provider transfers information about you to any person overseas, we will use our best efforts to procure that such third-party service provider procures the same written undertaking from such person.

VII. Access and Correction of Data

Access

If you have provided personal data to ADD, you have the right to access, at any time, personal data we hold about you and information about the ways in which your personal data has been or may have been used or disclosed by ADD within one (1) year before the date of your request.

Where permitted by law, we reserve the right to charge a reasonable administrative fee for this service. In exceptional circumstances and where permitted by the applicable laws, we reserve the right to deny you access to your personal data and may provide an explanation as required by applicable laws.

Correction

You have the right to correct any personal data held about you that is inaccurate.

If you would like to inquire, make any corrections or request deletion of your personal data, please contact our Data Protection Officer (at the address stated in Section X below).

VIII. Accuracy of Data

We require your assistance to ensure that your personal data is accurate and complete. As such, please inform us of any changes to your personal data by contacting our Data Protection Officer (at the address stated in Section X below).

  1. Social Sharing Feature and links to other websites

Our Website may offer social sharing features, links to social media and other integrated tools. Depending on the settings you use with the entity that provides the social sharing feature or social media, your use of such social sharing feature or social media may enable the sharing of your information with your contacts or with the public. You are advised to visit the privacy policies of the entities that provide these social sharing features or social media to obtain information about the way they collect, use and/or disclose your personal data.

In addition, we may, from time to time, provide you with links to other websites for your convenience and information, or other third-party websites may share link to our Website. If you follow a link to any of these websites and/or otherwise access third-party websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. You access these websites at your own risk and we are not responsible for these websites. Whilst we endeavour to protect your personal data on our Website, we cannot control or be responsible for the policies of other sites we may link to, or the use of any personal data you may share with them. Please note that the Privacy Policy does not cover these other websites, and we would recommend that you are apprised of their specific policies.

Please refer to our Terms of Use, which is hereby incorporated herein by reference, for the services provided

  1. Contact Us

If you have any comments, questions, complaints about or requests relating to this Privacy Policy, please contact our Data Protection Officer at the address stated below, referencing “Privacy Policy”:

Asia Digital Doctor Pte. Ltd.

50 East Coast Rd, #01 -74

Singapore 428769

Email address: hello@hatchplus.com.sg

— Updated as at February 2023