Privacy & Data Protection Policy
Last Modified: 15 December 2023
1. INTRODUCTION
1.1 This privacy policy (“Privacy Policy”) governs your use of the Camtech Health website (URL: camtech-health.com, referred to as the “Website”) and the Camtech Health software application (referred to as the "Mobile Application") for mobile devices that is managed by Camtech Health Pte. Ltd. and/or its subsidiary(ies) and/or affiliates (hereinafter collectively referred to as the "Company", “Camtech”, “we”, “us” or “our”).
1.2 Camtech Health respects your privacy and is committed to protecting it through our compliance with this policy in accordance with the Personal Data Protection Act 2012 (“PDPA”). The Website and Mobile Application provides an online e-commerce marketplace for health and wellness test kits. In addition, the Mobile Application seeks to support the additional following functions -
a. Activate and assists the use of test kits purchased either through the Website or the Mobile Application;
b. Maintains a record of orders and results made available through the Mobile Application;
c. Assists with the scheduling and notification of (i) pick-ups / return of the test kit and (ii) virtual consult with a doctor;
d. Objectively determines the results of Camtech rapid tests based on user input to provide an easy and meaningful indicator of the user's health status; and
1.3 The Website and the Mobile application are collectively referred to as the “Camtech Digital Platforms”. Camtech Health Pte Ltd is the controller responsible for Camtech Digital Platforms. This Privacy Policy is intended to apply to all personal data submitted by you, third parties, their sub-domains, and any other websites, media platforms, applications including through the use of Camtech Digital Platforms managed by the Company (hereinafter collectively referred to as the "Channels") and any personal data that we receive from other third parties.
1.4 You should read this Privacy Policy carefully in order to understand the Company's policy and practices with regards to the treatment of personal data provided by you on the Channels. This Privacy Policy is applicable to all users of the Camtech Products, and the provisions herein may be updated, revised, varied, or amended from time to time as the Company deems necessary. If you do not agree to this Privacy Policy and our Terms and Conditions, please do not use any of the Platforms. Your continued use of the Platforms and our services constitutes your acknowledgement and acceptance of this Privacy Policy.
1.5 You have a right to make a complaint at any time to the Personal Data Protection Commission of Singapore however we would request that you contact us in the first instance to offer us the opportunity to address any issues that you may have.
2. CHILDREN UNDER THE AGE OF 18
Camtech Digital Platforms is not intended for children under 18 years of age. No one under age 18 may provide any information to or on Camtech Digital Platforms. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on the Website or on or through any of its features. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information.
3. DESCRIPTION OF CATEGORIES OF PERSONAL DATA AND AGGREGATED DATA
3.1 Identity Data: first name, last name, maiden name, username or similar identifier, marital status, title, date of birth, gender, photographs, video images. We may also collect your government-issued identification number, but we recognize that this is highly sensitive in nature and will only do so when this is necessary to verify your identity to a high degree of fidelity, and only when permitted by applicable laws.
3.2 Contact Data: delivery address, email address, mobile or other telephone numbers.
3.3 Payment Data: credit card details, expiry date, billing address and other information required to make a purchase
3.4 Device Data: includes the type of mobile device you use, device model number, a unique device identifier (e.g. your Device’s IMEI number, the MAC address of the Device’s wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use, and time zone setting.
3.5 Content Data: includes information stored on your Device, including friends’ lists, login information, photos, videos or other digital content and check-ins.
3.6 Profile Data: includes your username and password, your interests, preferences, feedback and survey responses and any other relevant information concerning your user profile.
3.7 Usage Data: includes details of your use of any of our Apps or your visits to any of Our Sites including, but not limited to, traffic data and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.
3.8 Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.
3.9 Location Data: includes your current location disclosed by GPS technology.
3.10 Health Data: includes physiological data, activity, sleep, and exercise data (such as calories burnt, steps walked, distance and speed travelled), and drinking and smoking profiles.
3.11 Biometric Data: includes thumbprints, facial images, voice recording or any personal data resulting from specific technical processing relating to the physical, physiological or behavioural characteristics of a natural person, which allow or confirm the unique identification of that natural person.
3.12 Aggregated Data: includes statistical or demographic data of any purpose that could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. E.g. we may aggregate your Usage Data to calculate the percentage of users accessing a specific Camtech Digital Platforms feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.
4. INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT IT
4.1 In the course of using the Channels, you may disclose or be asked to provide personal data. In order to benefit from and enjoy the various services offered, it may be necessary for you to provide the Company with your personal data. Although you are not obliged to provide the information and/or data as requested on the Channels, the Company will not be able to render certain services on the Channels in the event that you fail to do so.
4.2 The types of data collected in order to provide this service include:
a. Identity Data;
b. Contact Data;
c. Payment Data;
d. Content Data;
e. Profile Data;
f. Location Data;
g. Health Data;
h. Rapid Test Kit Data (including but not limited to data from COVID-19 rapid test kits).
4.3 As you use the Platforms, services, or purchase or arrange for the delivery of products, certain information may be passively collected:
a. Cookies (i.e. small pieces of information that a site sends to your browser while you are viewing a website): We may use both session Cookies (which expire once you close your web browser) and persistent Cookies to make Camtech Digital Platforms and services easier to use, to make our advertising better. You can instruct your browser, by changing its options, to stop accepting Cookies or to prompt you before accepting a Cookie from the websites you visit. If you do not accept Cookies, however, you will not be able to stay logged in to the Platforms. We presently do not honour “Do Not Track” requests across all parts of our Platforms.
b. Web Analytics: as we may use Google Analytics to help analyze how users use the Website. Google Analytics uses Cookies to collect information such as how often users visit the Website, what pages they visit, and what other sites they used prior to coming to the Website. We use the information we get from Google Analytics only to improve our Website and services. Google Analytics collects only the IP address assigned to you on the date you visit the Website, rather than your name or other personally identifying information. Although Google Analytics plants a persistent Cookie on your web browser to identify you as a unique user the next time you visit the Website, the Cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to the Website is restricted by the Google Analytics Terms of Use and the Google Privacy Policy.
5. INFORMATION YOU PROVIDE TO US
5.1 We will collect and process Information that you give us. This is information (including Identity, Payment, Contact and Marketing and Communications Data) that you consent to giving us about you by providing information through the Channels, or by corresponding with us directly (e.g. via email or chat) or through our third-party commercial partners. It includes information that you provide when you register to use Camtech Digital Platforms, download or subscribe to Camtech Digital Platforms, as defined below, or enter a competition, promotion or survey and when you report a problem with the Camtech Digital Platforms or the Channels. If you contact us, we will keep a record of that correspondence.
5.2 We may also collect and process:
a. Information that we collect about you and your device. Each time you visit one of the Channels or use Camtech Digital Platforms we will automatically collect personal data including Device, Content and Usage Data. We collect this data using cookies and other similar technologies. Please see the section on cookies below for further details.
b. Location Data. We also use GPS technology to determine your current location. Some of our location-enabled services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling Location Data in your settings.
c. Data from the device’s camera (Camera Access): This app requires access to the camera to scan the QR codes associated with your test kits and to take photos of test kit results and verify their validity.
d. Data from the device’s file system (Storage access): We also need access to your file system to attach photos to your test results and download your reports.
Information that we receive from your use of your device. We also collect personal data including Identity Data, e. Contact Data, Health Data, through the use of the Channels or Camtech Digital Platforms to provide a report.
Information that we receive from other sources including third parties and publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
i. Device Data, from the following parties: (A) Camtech Digital Platforms through unique application numbers, when they are installed or updated; (B) analytics providers, including Google and Apple that have operations globally; and (C) security and resource providers, including Bugfender, Microsoft’s App center.
ii. Contact Data, from providers of technical and delivery services;
iii. Identity and Contact Data, from data brokers or aggregators that may be based globally; and
iv. Identity and Contact Data, from publicly available sources
6. HOW WE USE YOUR INFORMATION
6.1 We will only use your personal data when the law allows us to do so. Please refer to the the types of lawful basis that we will rely on to process your personal data. Most commonly we will use your personal data in the following circumstances:
a. where you have consented before the processing;
b. where we need to perform a contract that we are about to enter or have entered with you;
c. where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; and
d. where we need to comply with a legal or regulatory obligation.
6.2 We use information that we collect about you or that you provide to us:
a. To present the Website and its contents to you, and to notify you bout any changes to the Website or any products or services we offer or provide through it;
b. To install the Mobile Application and register you as a user, and provide you with information, products, services or other purposes for which you request from us;
c. To deliver service to you, including but not limited to (i) account expiry/renewal and benefits in relation to your usage of the Channels; (ii) a platform/forum for sharing insights and posting photos; (iii) a platform for posting advertisements, messages, photos, views of comments or other information on the Channels; and (iv) the opportunity to participate in special events hosted by the Company;
d. To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
e. To administer and protect our business and Camtech Digital Platforms, including troubleshooting, data analysis and systems testing.
f. To measure and analyze the effectiveness of the marketing that we use; and
g. To monitor trends that allow us to improve Camtech Digital Platforms.
6.3 We will only send you direct marketing communications (including but not limited to newsletters/stories/articles, advertisements, recommendations in the form of promotional materials) by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us.
6.4 We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
7. DISCLOSURE OF YOUR INFORMATION
7.1 We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
7.2 We may disclose personal information that we collect or you provide as described in this privacy policy:
a. To our subsidiaries and affiliates.
b. To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal data confidential and use it only for the purposes for which we disclose it to them.
c. To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the Company about the Camtech Digital Platforms users is among the assets transferred;
d. To fulfill the purpose for which you provide it, for any other purpose disclosed by us when you provide the information with your consent.
7.3 We may also disclose your personal information:
a. To comply with any court order, law, or legal process, including to respond to any government or regulatory request;
b. To enforce or apply our Terms & Conditions of Use or Terms of Sale and other agreements, including for billing and collection purposes;
c. If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Camtech and our customers, or others.
8. CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION
8.1 We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:
a. Tracking Technologies. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of the Website may then be inaccessible or not function properly.
b. Promotional Offers from the Company. If you do not wish to have your email address used by the Company to promote our own products or services, you can opt out by scrolling to the footer of any email and clicking “unsubscribe.” If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt out does not apply to information provided to the Company as a result of a product purchase, warranty registration, product service experience, or other transactions.
9. DATA SECURITY
9.1 The security of your personal data is important to the Company. The Company has implemented appropriate electronic and managerial measures in order to safeguard, protect, and secure your personal data. All personal data provided by you is only accessible by the authorized personnel of the Company or its authorized third parties, and such personnel shall be instructed to observe the terms of this Privacy Policy when accessing such personal data. You should safeguard your unique username and password by keeping them secret and confidential and by never sharing these details with anyone.
9.2 The Company follows generally accepted industry standards to protect the personal data submitted by you to the Channels, both during transmission and once the Company receives it. However, no method of transmission over the internet, or method of electronic storage, is completely secure. Therefore, while the Company strives to protect your personal data against unauthorized access, the Company cannot guarantee its absolute security.Any transmission of personal data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on Camtech Digital Platforms.
9.3 We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.
10. RETENTION OF PERSONAL DATA
We will retain personal data in accordance with the Privacy Laws and/or other applicable laws. That is, we will destroy or anonymize your personal data when we have reasonably determined that (i) the purpose for which that personal data was collected is no longer being served by the retention of such personal data; (ii) retention is no longer necessary for any legal or business purposes; and (iii) no other legitimate interests warrant further retention of such personal data. If you cease using Camtech Digital Platforms, or your permission to use Camtech Digital Platforms is terminated or withdrawn, we may continue storing, using and/or disclosing your personal data in accordance with this Privacy Policy and our obligations under the Privacy Laws. Subject to applicable law, we may securely dispose of your personal data without prior notice to you.
11. TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE
We generally do not transfer your personal data to countries outside of Singapore. However, if we do so, we will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.
12. CHANGES TO THIS PRIVACY POLICY
The Company reserves the right to update, revise, modify, or amend this Privacy Policy at any time as the Company deems necessary.
a. The Company may change and if it does, these changes will be posted on this page and where appropriate, notified to you by email OR when you next start Camtech Digital Platforms. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of Camtech Digital Platforms or Channels.
b. It is important that the personal data that we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.
13. YOUR LEGAL RIGHTS
Under certain circumstances you have the following rights under data protection laws in relation to your personal data:
a. Request access to your personal data.
b. Request correction of your personal data.
c. Request erasure of your personal data.
d. Object to processing of your personal data.
e. Request restriction of processing your personal data.
f. Request transfer of your personal data.
g. Right to withdraw consent
h. Right to ask us not to continue to process your personal data for marketing purposes
i. Right to exercise any of these rights at any time by contacting us at support@camtech-health.com.
14. GOVERNING LAW AND JURISDICTION
Nothing in this Privacy Policy shall limit your rights under the Personal Data Protection Act 2012 of Singapore, the General Data Protection Regulation or any other data protection or privacy related law that is applicable to you. This Privacy Policy shall be governed by the laws of the Republic of Singapore and you agree to submit to the exclusive jurisdiction of the Singapore courts.
15. CONTACT DETAILS
CAMTECH HEALTH PTE LTD
5 Jalan Kilang Barat, #01-01 Petro Centre, Singapore, 159349