In conducting our business, Kingston Medical Group (“KMG”) may collect, use, disclose or otherwise process Personal Data relating to you.
Kingston Medical Group consists of 1) Kingston Medical Group Pte Ltd, 2) Kingston Medical Clinic Pte Ltd
Please read the following carefully to understand our views and practices regarding your Personal Data, and how we will treat such Personal Data.
- COLLECTION AND PROCESSING OF PERSONAL DATA
1.1 We may collect Personal Data (which may include sensitive Personal Data) when you provide it to us. Generally, we collect Personal Data in the following ways:
1.1.1 When you submit any form, including but not limited to consent and order forms, as well as customer inquiry forms or other forms relating to any of our services;
1.1.2 When you enter into any agreement or provide documentation or information in respect of your interactions with us, or when you use our services;
1.1.3 When you interact with our staff, either directly or indirectly through referral intermediaries (for example, the doctors, nurses, healthcare assistants, swabbers, or customer service officers at our screening centres or any of our places of business) via telephone calls (which may be recorded), letters, fax, video-calls, face-to-face meetings and emails;
1.1.4 When you request that we contact you or request that you be included in an email or other mailing list;
1.1.5 When we seek information about you and receive your Personal Data in connection with us, including our services, for example, from business partners, public agencies, referral intermediaries and the relevant authorities; and/or
1.1.6 When you have chosen to provide or submit your Personal Data to us.
1.2 Examples of such Personal Data you may provide to us include (depending on the nature of your interaction with us) your name and identification information such as your NRIC, passport or other identification), contact information such as your address, email address or telephone number, nationality, gender, date of birth, marital status, photographs and other audio-visual information, and any other information which you have provided us (including financial information such as credit card numbers, debit card numbers or bank account information), in any forms you may have submitted to us, or via other forms of interaction with you.
1.3 If you provide us with any Personal Data relating to a third party (e.g. information of your spouse, children and/or parents), by submitting such information to us, you represent to us that you have obtained the consent of the third party to provide us with their Personal Data for the respective purposes. We may also use various technologies on our websites which may lead to information being automatically collected and stored by us, including device-specific and other technical information about your mobile or computer device such as the hardware model, operating system version, browser type and version, Internet Protocol (IP) address, advertising identifier, unique application identifiers, unique device identifiers, browser type, language, wireless network, and mobile network information. This information does not generally, but may, contain your Personal Data, and we, and our data.
- PURPOSES OF USE
2.1 All Personal Data and other information collected may be used by us for any of the following purposes:
2.1.1 Ensuring that content from our site is presented in the most effective manner for you and for your computer
2.1.2 Providing customer service and support (including but not limited to customer relationship management, processing and settlement of bills, contacting you regarding your reports and results);
2.1.3 Responding to, handling, and processing your enquiries or requests pursuant to your emails, telephone calls, faxes and/or submission of form(s);
2.1.4 Responding to and taking follow-up action on feedback or complaints;
Providing you with alerts, newsletter, education materials or information that you requested or signed up to
2.1.5 Allowing you to participate in interactive features of our service, when you choose to do so;
2.1.6 Researching, designing and launching services or products including seminars/events/forums;
2.1.7 Designing and conducting surveys/questionnaires for client profiling/segmentation, statistical analysis, improving and furthering the provision our products and services;
2.1.8 Troubleshooting crashes associated with specific hardware and software used to access our website;
2.1.9 Monitoring and tracking your usage of our website, in order to assist us in understanding user behaviour, trends and preferences;
2.1.10 Managing our administrative and business operations, including contracts, and complying with internal policies and procedures;
2.1.11 Liaising with third party specialist doctors, clinics, hospitals, medical institutions and/or our affiliate business partner in relation to our services to you;
2.1.12 Providing relevant offers and rewards from our Business Partners with whom we may jointly collaborate or whose products or services may be offered on our marketing campaign. If you choose to access these bundled services, we will on occasion share your Personal Information with those business partners.
2.1.13 Administering debt recovery and debt management;
2.1.14 Complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority; and/or
2.1.15 Any other purpose(s) that do not appear above where permissible under any written law, as may be notified by us to you from time to time.
2.2 We intend to use your data in direct marketing and we require your consent (which includes an indication of no objection) for that purpose. In this connection, please note that:
2.2.1 Your name, contact details (including address, contact number, email address), products and services information, transaction pattern and behaviour, background and demographic data held by us from time to time may be used by us in direct marketing;
2.2.2 The following classes of services, products and subjects may be marketed in direct marketing:
- A) Services and products related to our site and/or our business partners and affiliates (including marketing affiliates programs we are a part of);
- B) Reward, loyalty or privileges programmes, promotional offers and related services; and
- C) Invitations to events such as seminars/webinars/tele-seminars, conferences, live programs or events.
2.2.3 We may conduct direct marketing via fax, email, direct mail, telephone and other means of communication or send e-newsletters to you. You may choose not to receive promotional materials, by simply telling us (see below for contact details), and we will cease to do so, without charge.
2.3 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).
- DISCLOSURE OF YOUR INFORMATION
4.2 A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.
4.3 We use the following cookies:
- A) Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
- B) Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
4.5 Our website uses Google Analytics, a web traffic analysis service provided by Google Inc. (“Google”). Please refer to http://www.google.com/policies/privacy/partners to find out more about how Google uses data when you use our website and how to control the information sent to Google.
4.6 You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.
4.7 Furthermore, you can prevent Google’s collection and processing of data by using the Google Ads Settings page or downloading and installing their browser plug-in (https://tools.google.com/dlpage/gaoptout).
- STORAGE AND TRANSFER OF PERSONAL DATA
5.1 All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
5.2 Pursuant to the purposes and activities as set out herein, it may be necessary for the Personal Data that we collect from you to be transferred to, and stored at, a destination outside Singapore. It may also be processed by staff operating outside Singapore who work for us or for one of our service providers.
5.3 By providing your Personal Data, you agree and consent to the aforesaid transfer, storing and processing, on the understanding that the recipients of such Personal Data will take appropriate steps to ensure that your data is treated securely and continues to receive a standard of protection that is at least comparable to that provided under the PDPA, applicable laws and in accordance with this Privacy Statement.
5.4 Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk and you agree not to hold us responsible for any breach of security while accessing the internet that is out of our control. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.
- WITHDRAWAL OF CONSENT, ACCESS TO, CORRECTION AND DELETION OF PERSONAL DATA
6.1 You have the right to withdraw consent, request access to, make corrections to, or request deletion of the Personal Data that we hold about you in accordance with applicable laws.
6.2 All requests for withdrawal of consent, access to, correction or deletion of Personal Data held by us shall be made in writing or via email addressed to our Data Protection Officer at:
Attention: Alfred Ng, Kingston Medical Group Data Protection Officer;
Address: 152 Ubi Ave 2, Smart Innovation Centre, #02-01
6.3 We may charge a reasonable fee for processing your request for access. If so, we will inform you of the fee before processing your request.
6.4 Please note that if your Personal Data has been provided to us by a third party (for example, a general practitioner) you should contact that organization or individual to make such queries, complaints, and access any correction request to us on your behalf.
6.5 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 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 applicable laws).
6.6 If you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, we may not be in a position to continue to provide our services to you, or administer any contractual relationship in place, which in turn may result in the termination of any agreements with us.
6.7 We are obligated to maintain your Medical Records to the extent stipulated in the relevant legislature. We commit to respect and support your deletion requests for Medical Records, but we may be limited in our capacity to support deletion requests solely based on your rights stipulated in the Personal Data Protection Act, in view of other potentially superseding legislation.
6.8 The above limitations stipulated in Section 6, sub-section (G), do not apply to general personal data beyond the scope and definitions outlined in the Private Hospitals and Medical Clinics Act.
- PROTECTION OF PERSONAL DATA
7.1 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.
7.2 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 However, we cannot accept responsibility for misuse or loss of, or unauthorised access to your Personal Data.
8.1 To the fullest extent permitted by law, we shall not be liable in any event for any special, exemplary, punitive, indirect, incidental or consequential damages of any kind or for any loss of reputation or goodwill, whether based in contract, tort (including negligence), equity, strict liability, statute or otherwise, suffered as a result of unauthorized or unintended use, access or disclosure of your Personal Data.
- RETENTION OF PERSONAL DATA
9.2 Whilst we will securely dispose of or anonymise Personal Data which we can reasonably determine is no longer needed and we do not generally hold on to Personal Data “just in case” – it is in the interests of any caregiver or person treating you, as the patient, to be able to refer to a complete set of medical records to avoid risks to your health and safety. As such, in respect to any medical records, unless specific contrary instructions are received from you, as a patient, we may (but are not obliged to) retain such medical records.
9.3 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.
- THIRD PARTY WEBSITES
10.1 Our website may, from time to time, contain links to and from third party websites who are not related to Kingston Medical. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. These links are provided for your information and convenience only and are not an endorsement by Kingston Medical of the content of such websites or third parties.
- DATA PROTECTION OFFICER
11.2 All complaints will be evaluated by us in a timely manner. After we have completed our evaluation, our Data Protection Officer (or duly appointed representative) will respond to the person who submitted the complaint or feedback, with the results of the evaluation.
11.3 We may be prevented by law from complying with any request that you make. We may also decline any request that you may make if the law permits us to do so.
- YOUR CONSENT AND RIGHTS
13.1 By using our service, making an application or visiting our website, you consent to the collection and use of your information and other activities as outlined in this policy.
13.2 Under the Personal Data Protection Act (the “PDPA“), individuals have the right: A) to check whether we hold personal data about you and to access such data;
- B) to require us to correct as soon as reasonably practicable any data relating to you that is inaccurate;
- C) to ascertain our policies and practices in relation to personal data and the kind of personal data held by us; and
- D) to object to the use of your personal data for marketing purposes and we shall not use your personal data for marketing purposes after you communicate your objection to us.
13.3 You may exercise your opt-out right by notifying us if you wish to object to the use of your personal data for direct marketing purposes. Please send requests for such objections, access to data, correction of data, information regarding policies and practices and kinds of data held, questions or complaints to:
Mr. Alfred Ng
152 Ubi Ave 2, Smart Innovation Centre, #02-01
+65 9481 7818
13.4 In accordance with the terms of the PDPA, we have the right to and may charge a minimum fee for processing any data access request.
13.5 Limitations may apply regarding access and deletion requests of Medical Records in accordance with the Advisory Guidelines For the Healthcare Sector due to our obligations towards the relevant legislation cited in Annex B of the National Guidelines for Retention Periods of Medical Records.
- GOVERNING LAW AND JURISDICTION