PERSONAL DATA PROTECTION NOTIFICATION AND CONSENT
BioMark takes your data privacy very seriously. We are committed that you retain full control over your personal and health information. We will not disclose or use any of your information for any other purpose except those outlined below.
Collection, Use and Disclosure of Personal Data
We hereby inform you that we, Biomark Pte Ltd (hereinafter referred to as the "Company", "we", "our" or "us") (whether or not controlled by us) have, may or will collect, use and/or disclose one, or all of the following categories of personal information about you strictly for Purposes (as defined below) only.
- master data: name, gender, date of birth;
- contact details: home address, correspondence address, billing address, e-mail address;
- verification details: information pertaining to the verification of identity, including identification type, and NRIC / passport numbers;
- health-related data: height, weight, blood pressure, sleeping habits, resting heart rate, family history and social habits such as smoking and drinking habits;
- any such information as we deem necessary or appropriate from time to time in connection with your commercial relationship with us (collectively, "Personal Data").
To the extent that you willfully and voluntarily disclose to us any personal information (whether or not coming within the definition of Personal Data) above of any individual, we shall assume, without independent verification, that you have obtained such individual's consent for and notified such individual of the purposes of the collection, use and disclosure of the same in accordance with the terms of this notification ("Notification").
Sources of Information
Your Personal Data has and / or will be obtained from the following sources, where applicable, or such other sources which we may see fit from time to time:
- information provided or submitted by you and third parties, through among others, tests with a local medical laboratory recommended by the Company;
- information gathered through promotional and / or marketing activities;
- cookies that your web browser stores on your computer when you visit a website;
- as applicable, publicly available or publicly accessible information; and
- such other written or verbal communications or documents delivered to us prior to and during the course of our contractual or pre-contractual dealings with you.
As the accuracy of your Personal Data depends largely on the information you provide to us, kindly inform us as soon as practicable if there are any errors in your Personal Data or if there have been any changes to your Personal Data.
Purpose of Collection, Use and Disclosure of Personal Data
We will collect, use and disclose the Personal Data that you have provided to us for the following purposes, including but not limited to (“Purposes”):
- to inform you of your blood profile;
- to inform you of the possible health risks based on the analysis of your blood results, whether autonomously generated by algorithm and/or through a review by a doctor;
- to send you health and wellness tips and advice;
- to promote and market products and services which may address your health risks;
- to create a data pool which may be used for research and development for drugs, medicines and other health products and services;
- to deliver of notices, services or products to you;
- in order for you to enter into the necessary agreement and/or contract to purchase the products from us;
- in order for you to enter and participate in the various contests organized by us;
- for user or consumer relationship management purposes;
- for business contact purposes;
- for the facilitation of transactions that you have or may have with us;
- for processing of orders and payment clearing;
- for those purposes specifically provided for in any particular service or product offered by us;
- for collection of outstanding payments from you;
- for consumer care and/or defect rectification works;
- to respond to your inquiries;
- for membership registration and to offer you benefits and privileges;
- for conducting marketing, promotional and client profiling activities in connection with our services and related products for us, our vendors and business partners and other selected companies;
- for evaluation purposes and for the further enhancement of our products and services;
- for our internal record keeping;
- the prevention of crime including but not limited to fraud, money-laundering, and bribery;
- meeting any legal or regulatory requirements relating to our provision of services and products and to make disclosure under the requirements of any applicable law, regulation, direction, court order, by-law, guideline, circular, code applicable to us or any of our member companies; and / or
- in order to fulfill any purpose directly related to the above purposes.
Storage and Security
We store your Personal Data in hard and soft copy. Soft copy data is stored on, amongst others, the file server, e-mail server, personal computers, notebooks, tapes and compact disc.
There are security policies and procedures in place which among others confines access to your Personal Data to authorised personnel only on a strictly need to know basis to the relevant department such as the administration, finance, sales and/or consumer service departments of the Company.
We may retain the Personal Data and that of other individuals that you provide to us for a reasonable period having regard to the Purposes for which the personal data was collected. We will cease to retain the Personal Data as soon as it is reasonable to assume that the purpose for which that Personal Data was collected is no longer being served by retention of the personal data, and retention is no longer necessary for legal or business purposes, and at all times subject to prevailing legal requirements.
Personal Data provided to us will, generally, be kept confidential but you hereby consent and authorise us to provide and / or disclose your Personal Data to the following categories of parties:
- any person to whom we are compelled or required to do so under law or in response to a legitimate instruction from a competent or government agency;
- pursuant to an order of a court of competent jurisdiction;
- any related and associated companies, affiliates and subsidiaries of the Company, including those established in the future;
- data intermediaries processing your Personal Data on our behalf;
- employees of the Company and our business partners such as Innovative Diagnostics Pte Ltd.
- where applicable, third parties who provide related services or products in connection with our business such as our vendors, business partners, and any party assisting us in carrying out the Purposes laid our above;
- parties which participate in joint marketing schemes with us;
- any agent, contractor or service provider who provides administrative, order processing, payment clearing, credit reference, debt collecting or other services necessary to the operation of our business;
- organisations including their professional service providers and relevant regulatory authorities whether within or outside Singapore, in connection with the acquisition, disposition and / or intended acquisition or disposition of the Company's assets and / or the Company itself whether directly or indirectly;
- any party or organisation who are bound by confidentiality agreements with us, which may include but are not limited to pharmaceutical and medical device companies, and clinician panels;
- any person to whom we are, in our belief in good faith, under an obligation to make disclosure as required by any applicable law;
- government agencies, statutory authorities and industry regulators;
- our auditors, consultants, accountants, lawyers or other financial or professional advisers; and / or
- our sub-contractors or third party service or product providers as may be determined to be necessary or appropriate.
Please rest assured that consistent with the law, we will only disclose the minimum amount of information which we deem necessary for the Purpose and that we will take all appropriate safeguards to ensure the integrity and security of the Personal Data.
In addition, you will appreciate that we are part of the BioMark group of companies which operates in multiple jurisdictions. Accordingly, access to your Personal Data may be granted to other entities within the BioMark group of companies and may be transferred out of Singapore for the purpose of data storage, onward transmission and / or processing by the BioMark group globally.
Impact resulting from failure to supply and consent to the collection, use and disclosure of Personal Data
- Except for Personal Data which is collected, used and disclosed for direct marketing purposes, it is obligatory for you to provide the categories of Personal Data which we request from you for the said Purpose. Failure to supply and consent to the collection, use and disclosure of the Personal Data in relation to the Purpose will:
- result in us being unable to analyse your blood sample and provide you with among others, information on your blood profile;
- result in us being unable to provide you with the information, notices, services and/or products requested;
- affect your ability to enter and participate in any contests organised by us; and
- affect the ability of the parties to enter into the necessary agreement in relation to the provision of our services to you.
- It is optional for you to provide the categories of Personal Data which we request from you for direct marketing purposes.
Your Rights of Access and Correction
You have the right to, subject to payment of reasonable fees where applicable, request access to and/or correct your Personal Data and/or withdraw consent for the collection, use and disclosure thereof. In this respect, you may:
- check whether we hold or use your Personal Data and request access to such data;
- request that we correct any of your Personal Data that is inaccurate, incomplete or out-of-date;
- request for information concerning the ways your Personal Data has been or may have been used or disclosed by us within a year before the date of your request;
- request that we specify or explain our policies and procedures in relation to Personal Data and the categories of Personal Data collected, used and disclosed by us;
- withdraw, in full or in part, your consent given previously, in each case subject to any applicable legal restrictions, contractual conditions and a reasonable time period.
Please address all requests and / or questions or concerns which you may have regarding the subject matter and contents of this Notification to [email protected].