Privacy Policy for Elemental Health Pte Ltd
1. INTRODUCTION
Thank you for choosing to be a part of the community at Elemental Health Pte. Ltd. (“Company”, “we”, “us”, “our”). We prioritize the protection of our visitors and users personal information and your rights to privacy. In this Privacy Policy, we seek to describe in the clearest way possible on how your personal information is collected, used, and disclose or otherwise processed, in accordance with the Singapore Personal Data Protection Act 2012 (“PDPA”), General Data Protection Regulations (GDPR), Health Insurance Portability and Accountability Act (HIPAA) and other related privacy legislations, whenever you visit and use our website, mobile, web and desktop applications, extension, services, supplements and other materials sold by us (collectively known as “Platform”).
By using our Platform in any manner, including but not limited to browsing, visiting, creating an account, booking a session, or logging into the Platform, you agree to be bound by this policy and the additional terms and conditions stated on our Platform.
As used in this Notice:
a) “Client”, “ user”, “you” or “your” – This refers to our client (which may be an individual/company/corporation/organization) who has: (i) contacted us through any means to find out more about our Platform or (ii) may or has, entered into a binding contract with us for the use and supply of the services on our Platform.
b) “Personal Information” – This refers to data, whether true or not, about our client who can be identified: (i) from the data; or (ii) from the data and other information which we have or are likely to have access to, including but not limited to the data in our records which may be updated every so often. Depending on the type of interaction and engagement through our Platform, surveys and questionnaires with us, the Personal Information voluntarily provided from you to us, our psychologists, psychotherapists, nutritionist and clinicians, includes but is not limited to: full name and alias(s), National Identification Number (NRIC Number), FIN, or work permit identification numbers, passport number, residential address, mobile number, residential telephone number, email address, nationality, race, gender, date of birth, marital status, credit card and bank data, medical records, personal goals, personal and family history, data about your friends and family, data about your hobbies, past-times, cultural, spiritual and recreational practices, data from other medical and psychiatric service providers, financial and insurance data, employment data and legal data, and personal information classified as Personal Health Information (PHI) under certain privacy laws. In addition, we also automatically collect some information about your device, including information about your web browser, IP address, time zone, and some cookies within your device; usage data; universally unique identifier (UUID); crash information; device information; unique device identifiers for advertising; geographical location/region; application opens; application updates; first launches; operating systems.
c) “Third-Party Sites” – This refers to links to other websites operated by third parties, including our business partners. Please note that we shall not be liable for the actions or liability of any of these third-party providers. The following are third parties that we use to store and process data:
i) Google Analytics – To track usage patterns on our Platform and to improve our Platform and services.
ii) Mailchimp – To send newsletters and notifications only to clients who have consented to receiving these newsletters and notifications.
iii) Plato – For booking and scheduling of appointments, payment, calls, SMS, emails and video calls (e.g., for teleconsultation appointments).
d) “Cookies” – These are small pieces of data stored in the memory of your browser on your device (including but not limited to mobile device and computer) while you access our Platform. We use cookies to personalize and improve the interaction for our clients when accessing our Platform for an enhanced user experience. You can manage your Cookie preferences and have the option to disable them. However, if you disable Cookies on our Platform, the features and functionality of our Platform may be affected. We do not extract Personal Information in Cookies.
e) “Log Files” – These track the actions happening on our Platform, including but not limited to our app, website, social media, and collect data including your browser type, IP address, internet service provider, date/time stamps, referring/exit pages and number of clicks. This allows us to analyze trends, protect and secure our Platform, track user movement in the aggregate, and gather extensive demographic information for aggregate use.
Please note that our Platform offers “Do Not Track” features to manage personal information we track and process.
2. MODIFICATION
We may revise and update this privacy policy every so often without any prior notice to reflect changes to our practices or for other operational, legal or regulatory reason. Your continued use of our Platform after revision and/or updates will constitute your acknowledgement of the modifications and acceptance to abide and be bound by the modified Privacy Policy.
3. ACQUIRING CONSENT
If you have provided us with your Personal Information, you consent to the usage of that information as stated in this policy. This included and is not limited to disclosure to third party providers stated in this policy.
4. COLLECTION OF PERSONAL INFORMATION
We collect Personal Information in the following ways:
a) when you submit any forms, including but not limited to, customer inquiry forms, registrations forms or other forms relating to any of our services;
b) when you enter into any agreement or provide documentation or information with respect to your interactions with us, or when you purchase goods or use our Platform;
c)when you interact with people working with us, including but not limited to our reception staff, administrative staff, marketing staff, clinicians, psychologists, psychotherapists, counsellors and nutritionists. Such interactions may occur through telephone calls, teleconference calls, letters, emails, short message service, multiplatform messaging apps, face-to-face meetings, our websites, social media sites and platforms;
d) when you are contacted by, and respond to, our marketing representatives and other staff;
e) when we seek information about you and receive your Personal Information in connection with your relationship with us, including but not limited to the sales of our goods and services;
f) when your employer signs you up on our Platform or when you use our Platform, at which addition data collected includes but is not limited to employee ID (if applicable), department, title, job code ID (if applicable).
5. USAGE, SHARING AND OTHERWISE PROCESSING OF PERSONAL INFORMATION
The Personal Information obtained through the above channels are used and processed for the following purposes:
a) For existing, former or future clients, we use the Personal Information to:
i) verify your identity;
ii) provide customer service and support, including but not limited to, customer relationship management, respond to, handle and process queries, requests, applications, complaints, feedback, process registration, process subscriptions, process and settlement of bills, process payments or credit transactions, arrange, facilitate and provide confirmations and reminders of your appointments, provide follow-up calls, and provide administrative and technical support;
iii) provide access to the services we offer on our Platform;
iv) notify you on all the assigned or upcoming tasks on our Platform;
v) browse our website through your browser’s cookies;
vi) administer and process your requests, including but not limited to, creating and maintaining profiles of clients in our database for administrative purposes;
vii) personalize your experience, conduct market research, efficacy research, understand and analyze our client’s preferences and demographics, in order to improve our Platform for our clients (upon your agreement to explicit consent to process this information, e.g., agreeing to the use of cookies until you withdraw your consent);
viii) comply with any relevant and applicable laws and regulations, codes of practice, guidelines, or rules, or to assist law enforcements in their investigations conducted by any government or regulatory authority, e.g., search warrant or court order;
ix) provide marketing or promotional information about our Platform and other products, including but not limited to emails or messages, from time to time, upon your approval to receiving such materials;
x) keep our Platform safe and secure; it enables us to protect our legitimate interests and our clients by ensuring that the Platform is secure and protected against spam, fraud, and abuse, etc.
b) For appointed next-of-kin of our client, we use the Personal Information to:
i) Inform you of the client’s medical status, whereabouts and in cases of emergencies.
c) De-identified Information
We may from time to time de-identify our client’s information to do the following:
i) Monitor usage of our Platform and website for us to optimize and improve our Platform;
ii) provide details to employers on our client’s performance, stress levels, assess mental health and risk impact of our clients;
iii) send to academic journals and external publications for research and analysis purposes; the statistics will not contain information that can be used to identify you.
6. DISCLOSURE OF PERSONAL INFORMATION
We will take reasonable steps to protect your Personal Information against unathorised disclosure. However, we may disclose your Personal Information if we deem that it is necessary and reasonable to do so in certain circumstances, in our sole and exclusive discretion. Such circumstances include but are not limited to the following circumstances:
i) For any legal reasons or regulations;
ii)To respond to legitimate requests, such as discovery, criminal, civil, administrative, subpoenas, court orders or writs from law enforcement or other government or legal bodies;
iii) To bring legal action against a user who has violated the law or violated the terms of use for our Platform;
iv) To cooperate with any legitimate lawful investigation involving our users;
v) If necessary for the operation of our Platform;
vi) If there are any suspected fraudulent activity on our Platform or have detected activity which is in violation of our terms of use;
vii) To third party providers for the purpose of providing our Platform and services to you;
vii) To third party providers that we have engaged to provide services on our behalf, this includes but is not limited to processing transactions and other services on our Platform. Please note that we have taken all necessary actions to enter into agreements that require these third parties to protect such information and use Personal Information they receive only to perform the required services for us;
ix) To inform the necessary legal authorities or next-of-kin about emergency situations involving imminent danger, such as threat to life, emergency crisis, suicidal tendencies, reckless actions of the user which can affect others and other related actions by the user.
7. STORAGE OF PERSONAL INFORMATION
Our client’s Personal information are stored on our data processing server. Our data processor is Plato Medical. Kindly go through their Privacy Policy to learn and understand how your information is being stored. Except as otherwise mentioned in this privacy policy, your Personal information are kept only for as long as they are required by us to provide you with our Platform and services you have requested; to comply with other legal and compliance obligations; to support a claim or defence in court; to resolve potential and actual disputes; conduct research and development for our Platform (if stated within our agreement with your employer permits use of your Personal Information for this purpose); enforce our agreements.
8. SECURITY
9. ACCURACY OF PERSONAL INFORMATION
We generally rely on the Personal Information provided by you or your authorised representative. In order to ensure that your Personal Information is current, complete and accurate, please update us if there are any changes to your Personal information by informing our staff or service providers, or by informing our Data Protection Officer in writing or via email at enquiries@elementalhealth.sg
You should ensure that all of the Personal Information provided to us is complete, accurate, correct and true. Failure to do so may result in our inability to provide you with the goods and services requested or a delay in providing our goods and services.
If you have provided us with any Personal Information relating to a third party, including but not limited to your partner, spouse, children, parents, friends, employees or employers, you represent to us that you have obtained the necessary consent of the third party to provide us with their Personal Information for the purposes stated in Clause 5b.
10. YOUR RIGHTS AND LAWS
You have your rights to the processing of your Personal Information under the relevant privacy laws, including but not limited to Singapore PDPA, EU GDPR, and US HIPAA. These rights include:
a) Access
You have the right to know whether or not we process Personal Information about you, and if we do, to access the information we hold about you and how we use it and who we share it with.
If you would like to know details and access to your Personal Information held by us, please contact us at enquiries@elementalhealth.sg
b) Correction
You have the right to correct any Personal Information we have about you that you may believe is inaccurate and incomplete. When you do request a correction, please explain in detail why you believe that the Personal Information we hold about you is inaccurate or incomplete so that we can determine if a correction is required.
c) Objection
You have the right to object to our processing of your Personal Information. Please provide us with details about why you object to our processing so that we may assess whether necessary overriding interest for us to continue to process such data or if we need to process it for legal reasons.
You also have the right to object to our processing of your Personal Information for marketing purposes and we will stop processing data for that purpose.
d) Restriction from Processing to Storage Only
You have the right to request us to stop processing your Personal Information other than for storage purposes under the following circumstances:
i) You deem that the Personal Information held by us is not accurate for the period which it takes for us to verify the accuracy of the information;
ii) We would like to delete your Personal Information, however, you would like us to restrict the use of that information only;
iii) We no longer require your Personal Information for processing, however you would like for us to keep it for legal, compliance, exercise, establishment purposes;
iv) You have objected to us processing your Personal Information based on our legitimate interests and would like us to stop processing your information while we determine if there are any necessary overriding interest for us to continue to retain these Personal Information.
e) Withdrawal of Consent
Wherever you have provided your consent to us to collect, use, process and disclose your Personal Information, it will remain valid unless withdrawn by you in a notice to us by emailing us at enquiries@elementalhealth.sg
Upon receiving your request to withdraw your consent, we will require approximately five business days to process your withdrawal. We will notify you of the outcome, after considering several factors, including but not limited to the provision of our Platform requested by you; you or your family’s or another’s psychiatric, physical or medical health and wellbeing; financial consequences; legal consequences which may affect your rights and liabilities to us. If we are unable to respond to your request within five business days, we will notify you and let you know the additional time required.
Please note that the withdrawal of your consent may result in us being unable to continue providing our Platform and other goods and services to you. For such circumstances, we will notify you before completing your request. Withdrawal of your consent may also result in the termination of any agreements or contracts with us, and you breaching your contractual obligations or undertakings. The legal rights and remedies in such events are expressly reserved.
Please be aware that your withdrawal of consent does not affect our rights to continue to collect, use and disclose Personal Information, where such collection, usage and disclosure without consent is permitted under applicable laws, including but not limited to PDPA.
f) Opt-Out of Marketing Communications
You may request to opt-out of our marketing communications with you by emailing to us at enquiries@elementalhealth.sg or by using the unsubscribe link (if any) found at the bottom of the marketing email.
Upon receiving your request to opt out of our marketing communications, it may take approximately thirty business days to process your withdrawal and for it to be reflected in our system. As such, you may still receive marketing and promotional communications during this period.
Please note that certain communications from us are considered as transactional or service communications. These communications include but are not limited to, important account notifications, billing information, appointment reminder notification. Your account(s) on our Platform are provided to you on the condition that you receive these communications from us. If you do not wish to receive any such communications from us, you must cancel your account(s) on our Platform. You may still receive marketing and promotional communications from us, unless you opt-out of our marketing and promotional communications, as mentioned above.
g) Erasure of Personal Information
You may request for us to erase Personal Information that we hold about you under the following circumstances, including but not limited to you deeming that it is no longer necessary for us to hold onto your Personal Information; we are processing your Personal Information based on your consent and you wish to withdraw your consent; we are processing your Personal Information based on our legitimate interest and you disagree to such processing; you no longer wish for us to use your Personal Information to send you marketing and promotional materials; you believe that we are unlawfully processing your Personal Information.
Upon receiving your request to erase your Personal Information, we will require approximately thirty working days to delete your Personal Information. We may notify you upon the deletion of your Personal Information. Please note that once your Personal Information has been deleted, it is permanent and we will not be able to retrieve such data. In order to still access and use our Platform, you may be required to create a new account.
11. CONTACT US
By using our Platform, you agree and consent to our Privacy Policy and agree to its Terms and Conditions. If you have any questions about our Privacy Policy, please contact us at enquiries@elementalhealth.sg
