We, SMG Women’s Health and its related corporations (as defined in Section 4(1) of the Companies Act (Chapter 50)) (collectively referred to as “us” or “our” or “we”), recognize the importance of the collection, storage, use and disclosure of Personal Data (defined in Paragraph 1) of persons interacting with us (such persons hereon referred to as “you” or “yours”, which include any minor on whose behalf you are acting for the purpose of this Privacy Notice (“this Notice”)).
1. What is Personal Data?
Personal Data is defined in the Personal Data Protection Act 2012 to mean any data, whether true or not, about an individual who can be identified from that data or from that data and other information to which we have or are likely to have access, and this may include name, age, gender, date of birth, telephone number, address, e-mail address and credit card details.
2. Consent for the collection of Personal Data
When you provide your Personal Data to us, you have consented by your action to the collection, storage, use and disclosure of your Personal Data by us in accordance with this Notice. If you provide Personal Data relating to a third party (e.g. information of your child, dependent, spouse, parent, ward or employees) to us, by submitting such information to us, you represent that the consent of that third party has been obtained for the collection, storage, use and disclosure of the Personal Data by us in accordance with this Notice and you hereby indemnify us against any liability arising from such representation being false. Where collection of children’s Personal Data is made through persons claiming to be parents or guardians, we may (but are not obliged to) require proof to verify such claims.
3. Collection of Personal Data
Personal Data may be collected by us via any form of interaction with you, including:
- by entering into a transaction with us;
- by using any services provided by us through offline and online platforms, including our centres, websites, or social networking sites;
- by making enquiries, requests, applications and feedback to us;
- by participating in any events related to us, including marketing and promotions, corporate social responsibility programmes, contests, interviews and market researches;
- through closed circuit television cameras or other photography and videography while you are in our premises; and
- by applying for a job with us.
4. Refusal to provide Personal Data or withdrawal of consent
All Personal Data is provided voluntarily. You may refuse to do so or withdraw your consent in respect of our collection, storage, use or disclosure of your Personal Data at any time. However, if you limit, or do not provide, the requested Personal Data, it may result in us being unable to:
- process the relevant enquiry, request or application;
- provide the products or services to you in a continuous manner;
- provide the products or services to the extent stated in our promotional materials; or
- provide new products or services that may be offered by us from time to time.
5. Use of Personal Data
Your Personal Data may be used by us independently, or together with our industry partners, for the following purposes:
- For identification and verification.
- To process your transactions with us.
- To manage the safety and security of our centres.
- To provide the products and services you have requested.
- To administer promotions and contests, including joint promotions and contests with our industry partners, or your participation in any events or interviews.
- To communicate with you on our products and services or those of our industry partners.
- To respond to your enquiries, requests, applications and feedback or to obtain your feedback or participation in market research.
- To communicate with you via SMS, telephone, e-mail, facsimile, mail or any other appropriate communication channels which you have approved.
- To process and analyse your Personal Data either individually or collectively with other individuals.
- For internal functions, such as evaluating the effectiveness of marketing, statistical analysis and modelling, reporting, audit and risk management.
- To comply with all applicable law, codes of practice or guidelines and to assist in investigations by the relevant authorities.
- To manage potential or ongoing dispute resolution.
- Any other purpose relating to any of the above.
In order to conduct our business operations more smoothly, we may also be disclosing your Personal Data to our service providers, agents and/or other third parties whether sited in Singapore or outside of Singapore, in connection with one or more of the above-stated purposes. Where we disclose your Personal Data to third parties in connection with one or more of the above-stated purposes, we will use best efforts to require such third parties to protect your Personal Data.
6. Management of Personal Data
Reasonable security arrangements including the use of various hardware and software technologies have been put in place by us to ensure that your Personal Data are protected against unauthorized access, use, disclosure, copying, modification and disposal.
We will not be responsible for relying on inaccurate or incomplete Personal Data provided by you or arising from your failure to update your Personal Data.
7. Request for Access, Corrections and Withdrawal of Consent
If you, at any time, have any enquiries, requests and feedback relating to your Personal Data or this Notice, please email firstname.lastname@example.org. This includes any request:
(a) for a copy of your Personal Data in our possession or control (in which case we may charge an administrative fee);
(b) to withdraw your consent for the collection, storage, use and disclosure of your Personal Data by us; or
(c) to correct your Personal Data in our possession or control.
In respect of your right to access or correct your Personal Data, we have the right to take steps to verify your identity before fulfilling your request.
Please be aware that it may take up to 30 days from the date which your request was sent for any change to be reflected in our systems. Therefore, you may still receive marketing or promotional materials/communication during this period of time. Do also note that upon your withdrawal of consent, we may not be in a position to continue to provide our products or services to you.
8. Retention of Personal Data
We have in place measures such that your Personal Data in our possession or under our control are destroyed and/or anonymised as soon as it is reasonable to assume that the purpose for which your Personal Data was collected is no longer being served by the retention thereof, and/or that retention thereof is no longer necessary for any other legal or business purposes.
We may update this Notice from time to time. This Notice supplements but does not supersede nor replace any other consents you may have previously provided to us in respect of your Personal Data, and your consents herein are additional to any rights to which we may have at law to collect, store, use and/or disclose your Personal Data.
This Notice is construed and governed under the laws of Singapore.