Updated as of Wednesday, 09 December 2020
Welcome to the Kelhealth group of companies!
The Kelhealth group presently consists of:
In each of the above disciplines, we are committed to providing our patients with experienced doctors and proven technology.
In this Policy, references to “the Kelhealth Group”; “KG”; “us”; “we” our “our”, shall include each of the member practices listed above, and all of them collectively.
Your privacy is important to us. The purpose of this Policy is to inform you of how the Kelhealth Group manages personal data in accordance with the Personal Data Protection Act 2012 (the “Act”). Please take a moment to read this Policy so that you know and understand how we collect, use and disclose your Personal Data.
By interacting with any of the practices under the Kelhealth Group; using any part of our services; submitting information to us; or signing up for any promotions or services offered by us, you agree and consent to any of the constituent members of the Kelhealth Group; our related corporations and affiliates; (collectively referred to hereinafter as "KG", "us", "we" or "our"), as well as our respective representatives collecting; using; and sharing amongst themselves your Personal Data, and disclosing such Personal Data to our authorised service providers and relevant third parties in the manner set forth in this Policy.
This Policy supplements but does not supersede nor replace any other consents you may have previously provided to us nor does it affect any rights which we may have at law in connection with the collection, use or disclosure of your Personal Data. We reserve the right to make changes to any part of this Policy at any time at our sole and entire discretion. All changes are effective immediately when we post them, and apply to all access to and use of the services thereafter. By continuing to use any part of the services after such notice, you agree to this Policy, as modified. Please check this page from time to time so you are aware of any changes, as they are binding on you.
For the avoidance of doubt, and unless otherwise stated by us in other arrangements we may enter into in writing with you, this Policy and our Standard Terms of Trade constitute the agreement between you and us in relation to your use of any part of our services (the “Agreement”). In the event of any conflict, inconsistency or conflict between this Policy and the rest of the Agreement in relation to our collection, use and disclosure of your Personal Data, this Policy shall prevail. All defined terms contained elsewhere in the Agreement shall apply to this Policy unless otherwise specifically stated.
In this Policy, “Personal Data” refers to any data or information about you from which you can be identified either (a) from that data; or (b) from that data and other information to which we have or are likely to have access. Examples of such Personal Data which you may provide to us include (depending on the nature of your interaction with us):
2.1 Generally, we collect your Personal Data in the following ways:
2.2 When you browse our website, you generally do so anonymously, but please see the section below on cookies in Clause 5, below.
2.3 If you provide us with any Personal Data relating to a third party (for e.g. information of spouse, children, parents, employees and/or authorised representatives), by submitting such information to us, you represent to us that you have obtained the consent of the third party to you providing us with their Personal Data for the respective purposes.
2.4 You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with products and services you have requested; and/or to contact you for the same.
3.1 Generally, we collect, use and disclose your Personal Data for the following purposes:
3.2 In addition, we may collect, use and disclose your Personal Data for the following purposes, depending on the nature of our relationship with you:
(a) If you have a patient account with us:
(i) to process your application for an account;
(ii) to maintain your account with us;
(iii) to verify and process your personal particulars and payments in relation to provision of services to you;
(iv) communicating with you to inform you of changes and development to our policies, terms and conditions and other administrative information, including for the purposes of servicing you in relation to products and services offered to you;
(v) resolving complaints and handling requests and enquiries;
(vi) conducting market research for statistical, profiling and statistical analysis for the improvement of services provided to you; and/or
(vii) processing of your Personal Data in relation to any of the purposes stated above.
(b) If you use download or use any part of our services (including our website and any of our social media Third Party Sites):
(i) where the app includes app subscription services, to process your application for these services;
(ii) to maintain your account with us and to ensure your access of the app is within the scope of your subscription;
(iii) to verify and process your personal particulars and payments in relation to provision of goods and services to you;
(iv) to provide you with the goods and services which you have signed up for and to push messages to you which may be relevant to you;
(v) communicating with you to inform you of changes and development to our policies, terms and conditions and other administrative information, including for the purposes of servicing you in relation to products and services offered to you;
(vi) resolving complaints and handling requests and enquiries;
(vii) conducting market research for statistical, profiling and statistical analysis for the improvement of services provided to you; and
(viii) the processing of your Personal Data in relation to any of the purposes stated above.
3.3 In addition, where permitted under the Act, we may also collect, use and disclose your Personal Data for the following purposes (which we may describe in our documents and agreements as "Additional Purposes" for the handling of Personal Data):
3.4 If you have provided your telephone number(s) and have indicated that you consent to receiving marketing or promotional information via your telephone number(s), then from time to time, we may contact you using such telephone number(s) (including via voice calls, text messages, fax messages or other means) with information about our products and services (including discounts and special promotions).
3.5 In relation to particular products or services or in your interactions with us, we may also have specifically notified you of other purposes for which we collect, use or disclose your Personal Data. If so, then we will collect, use and disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.
3.6 You also consent to the collection, use and disclosure of your Personal Data by KG in connection with any transaction relating to the acquisition, divestment, securisation, amalgamation, listing or other transaction relating to any interest in KG, the shares or assets of KG, and any other corporate transaction involving KG, including any evaluation or due diligence relating thereto, as well as to the collection, use and disclosure of such information by the counterpart(ies) thereto for the same purposes, and the provision of goods and services by such counterpart(ies) following such transaction, as may be relevant.
4.1 We shall take reasonable steps to protect your Personal Data against unauthorised disclosure. Subject to the provisions of any applicable law, this Personal Data may be disclosed, for the purposes listed above (where applicable), to the following third parties, whether they are located overseas or in Singapore:
5.1 When you interact with us on our websites, we may collect or analyse anonymised information from which individuals cannot be identified (“Aggregate Information”), such as number of users and their frequency of use, the number of page views (or page impressions) that occur on the website and common entry and exit points into website.
5.2 KG uses "cookies", where a small data file is sent to your browser to store and track Aggregate Information about you when you enter our websites. The cookie is used to track information such as the number of users and their frequency of use, profiles of users and their preferred sites.
5.3 KG may use an independent company (the “Third Party Market Research Company”) to measure and analyse the Internet usage across KG web sites. KG uses the Third Party Market Research Company’s services to collect the following core information on the usage of our websites, including:
5.4 This information is aggregated by the Third Party Market Research Company and provided to KG to assist in analysing the usage of our websites. Such data is also accessible by media organizations and research companies, for the purpose of conducting industry comparisons with other Internet portals.
5.5 Pages on KG websites may be coded with software which enables the Third Party Market Research Company to track visitors to our websites.
5.6 Should you wish to disable the cookies associated with these technologies, you may do so by changing the setting on your browser. However, you may not be able to enter certain part(s) of our website.
Our websites may contain links to other websites operated by third parties, such as our business partners. We are not responsible for the privacy practices of websites operated by third parties that are linked to our website. We encourage you to learn about the privacy policies of such third party websites. Some of these third party websites may be co-branded with our logo or trade mark, even though they are not operated or maintained by us. Once you have left our websites, you should check the applicable terms, conditions and policies of the third party website to determine how they will handle any information they collect from you.
7.1 Should you wish to withdraw consent to use of your Personal Data or obtain access to or make corrections to your Personal Data records, please log in to the relevant account through which the Personal Data was provided, if any, failing which please contact the relevant Personal Data Protection Officer, who may be contacted at firstname.lastname@example.org.
7.2 Please note that if your Personal Data has been provided to us by a third party, you should contact such party directly to make any queries, feedback, and access and correction requests to KG on your behalf.
7.3 Please note that if you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, KG may not be in a position to continue to provide at least some of its products or services to you or administer any contractual relationship in place, and this may also result in the termination of any agreements with KG and your being in breach of your contractual obligations or undertakings, and KG’s legal rights and remedies in such event are expressly reserved.
8.1 You hereby acknowledge and agree that:
This Personal Data Protection Policy shall be governed in all respects by the laws of Singapore.
10.1 We will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
10.2 To determine the retention period for your Personal Data, we (amongst other things) consider the nature of the Personal Data, the risk of unauthorised use or disclosure of your Personal Data, the purposes for which we process it and the applicable legal requirements.
10.3 Details of retention periods for different aspects of your Personal Data are available on request, by contacting us.
10.4 In some circumstances we may anonymise your Personal Data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
11.1 Should you wish to access; correct; or update your Personal Data in our records, please contact the relevant Personal Data Protection Officer, who may be contacted at email@example.com.
11.2 You will, generally, not have to pay a fee to access your Personal Data. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
11.3 We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
11.4 We try to respond to all legitimate requests within one (1) month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Please contact our Data Protection Officer (“DPO”) by email if you have any questions about this Personal Data Protection Policy or the information we hold about you using the details are shown below:
Our DPO’s contact details