PATIENTCARE+ PRIVACY POLICY
Last updated: 05 Apr 2024
This PatientCare+ application (“PC+”) is made available to you for download and use by Zuellig Pharma (SG) Solutions Pte Ltd or its licensee. PC+ is made available for download only in the following jurisdictions: Singapore, Malaysia, Thailand, Indonesia, Philippines and Taiwan. This Privacy Policy sets out how Zuellig Pharma (SG) Solutions Pte Ltd and its affiliates (“we”, “us” or “our”) handle the personal data that you share with us through PC+ in accordance with the data protection laws that apply to us. You agree that the data protection laws applicable to us shall be the data protection laws of the jurisdiction in which you are enrolled in a patient program administered by us including any statute, rule, regulations, code, ordinance, decree, legal requirement, by-laws and sub-legislation and/or any order enacted or issued by any national or local legislative body in the jurisdiction (“Applicable Laws”).
This Privacy Policy outlines our general practices in relation to the collection, use, disclosure (hereinafter referred to as “processing”) and protection of the personal data you provide through PC+, or when you communicate with us and/or our authorised agents through various media and communication channels in relation to PC+. This Privacy Policy also explains your rights and the choices available to you regarding the use of, your access to, and how to update and correct your personal data.
In this Privacy Policy, “personal data” generally refers to any information that can be used, directly or indirectly (e.g. in combination with other types of data that we may have access to), to identify an individual (i.e. the “data subject”). Local data protection laws may have differing definitions of this, and to the extent that our definition used here conflicts with the law, the stricter definition will apply.
Processing of Personal Data
In the course of your dealings with us, we may process personal data about you or any other person for the purposes stated in this Privacy Policy. This may occur when you voluntarily provide such personal data to us, or, where necessary, we receive such personal data from third parties including but not limited to your authorized healthcare professional, authorized healthcare organization, legal guardian, or from the public domain.
In your interaction with us or by your usage of PC+, we may process the following categories of personal data, including, but not limited to:
Unless prohibited by Applicable Laws , we will usually notify you before collecting your personal data
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 changes to your personal data.
If you provide us personal data about other individuals for any particular purpose, you represent and warrant to us that they have appointed you to act on their behalf and have agreed that you can:
Source of Personal Data
The personal data processed by us are obtained from various legitimate and transparent sources, including, but not limited to the following:
We must have a lawful basis to process personal data. We typically rely on at least one of these lawful bases to do so:
We generally rely on consent to process personal data. In addition, the table below summarises some of the common purposes for which we may process personal data and our legal basis for doing so:
Purpose |
Legal basis |
---|---|
|
Where necessary to perform our contract with you Where required to comply with a legal obligation Where it is in our legitimate interests to ensure that services requested of us are effectively and appropriately delivered |
|
Where required to comply with a legal obligation Where it is in our legitimate interests to ensure that complaints are investigated and appropriately resolved |
|
Where required to comply with a legal obligation Where it is in our legitimate interests to: (a)
ensure that pharmacovigilance is done; and/or
(b)
promote public health and safety
|
|
Where required to comply with a legal obligation Where it is in our legitimate interests to: (a)
ensure the smooth operation of our business; and/or
(b)
keep accurate records of our business
|
|
Where it is in our legitimate interests to: (a)
develop new product or service offerings to meet the needs of
our customers; and/or
(b)
improve user experience when using our products and service
offerings, including PC+
|
|
Where required to comply with a legal obligation Where it is in our legitimate interests to: (a)
prevent and investigate legal disputes, potential breaches,
illegal activities or prohibited content;
(b)
enforce contractual rights; and/or
(c)
operate with regulators and law enforcement bodies
|
|
Where required to comply with a legal obligation Where it is in our legitimate interests to undertake any corporate restructuring for the growth or optimisation of our businesses |
|
Where it is in our legitimate interests, and subject to obtaining your consent when required under applicable laws, to provide you with marketing information that may be of interest to you |
Unless stated otherwise, the personal data provided to us are wholly voluntary in nature and you are not under any obligation or duress to do so. However, in some circumstances if you do not provide us with your personal data described in this Privacy Policy, we shall not be held liable for any of the consequences arising therefrom. These include:
In order for us to fulfil the purposes listed above, we may disclose your personal data to the following parties, including, but not limited to:
Third parties are legally tasked with processing the personal data in line with the principles specified by us. Third parties are also held legally responsible for securing the personal data at an appropriate level of security in relation to applicable data protection laws and widely accepted industry standards.
We ensure that all appropriate confidentiality obligations and technical and organisational security measures are in place to protect the confidentiality and security of your personal data collected through the various methods described in this Privacy Policy to prevent any unauthorised access, unauthorised or unlawful alteration, disclosure or processing of such information and data, and the accidental loss or destruction of or damage to such information and data.
Some of the security measures we put in place include, but are not limited to:
Compliance with these provisions will be required by all authorised third parties who may access the personal data as described above.
In accordance with Applicable Laws, in respect of the personal data which you have submitted to us, you may have the right at any time to:
Should you wish to exercise any of the abovementioned rights and such right is recognised within your country, please write in to us using the contact information found at Part XIV (Contact Us) below. In respect of requests for access to or to make correction of your personal data in our records, such requests must be supported with submission of the relevant documents as may be required by us. Depending on the nature and sensitivity of the request, we may require you to submit these documents in person so as to verify your identity from time to time to the address found at Part XIV (Contact Us) below. We will only make appropriate corrections based on the verifiable/verification and updated information provided by you. Your request may also be subject to payment of a fee in accordance with applicable legal requirements.
With regard to the withdrawal of consent, you may withdraw, in full or in part, your consent given to us.
You may request for deletion of your personal data by us, and we will use commercially reasonable efforts to honour your request. However, please note that we may be required to keep such information and not delete it for such period of time required by law or in order to fulfil our legal obligations. When we delete any information, it will be deleted from the active database but may remain in our archives. We may also retain your information for fraud prevention and detection or similar purposes.
Your exercise of any of the rights or withdrawal of consent referred to above is, in each case, subject to any applicable legal restrictions, contractual conditions, and a reasonable time period. This may also be subject to whether it would affect the operation of our business and our ability to meet our legal obligations.
We may also, in accordance with Applicable Laws, refuse to comply with your request. If we refuse to comply with such request, we will inform you of our refusal and reason for our refusal.
The personal data you submit to us will only be retained for as long as is required for the purpose for which it was collected or as permitted by Applicable Laws.
Even though our systems are designed to carry out data deletion processes according to the above guidelines, we cannot promise that all data will be deleted within a specific timeframe due to technical constraints. When we no longer need to use your personal data, it is removed from our systems and records or anonymised so that you can no longer be identified from it.
PC+ generally processes your data in Singapore. However, to provide our services and to ensure the smooth running of PC+, we may transfer your personal data to our affiliates and authorised employees, agents and third parties in the jurisdictions where we operate or where we deem it appropriate or desirable (unless Applicable Laws provides otherwise) for the purposes stated in this Privacy Policy. In particular, we may transfer your personal data to our overseas affiliate(s) where our information technology storage facilities and servers may be located. There may be a possibility that the data protection levels in other jurisdictions do not completely meet the requirements of Applicable Laws , but all such transfers are performed in accordance with the requirements of Applicable Laws.
PC+ may contain links to and from the websites and applications of our partner networks, advertisers and/or other third parties. If you click on a link to any of these websites or applications, you will leave PC+ and be redirected to the website or application you selected. As we cannot control the activities of third parties, we cannot accept responsibility for any use of your personal data by such third parties, and we cannot guarantee that they will adhere to the same data privacy practices as us. We encourage you to review the privacy policy of these websites or applications before providing any personal data.
In the event of any inconsistency between the English version and the local language version of this Privacy Policy, the English version shall prevail.
We reserve the right to modify, update and/or amend this Privacy Policy at any time. We will take reasonable steps to ensure amendments to this Privacy Policy are communicated by posting all amendments prominently on PC+ and other places we deem appropriate for a reasonable period of time. Amendments to this Privacy Policy will be effective immediately once published on any of PC+ unless otherwise noted. We invite you to check this Privacy Policy periodically to be informed of any relevant amendments to it, especially before providing any information to us. Your continued access or usage of PC+ and/or providing your personal data to us, following any amendments to this Privacy Policy, indicates your consent to the practices described in the revised Privacy Policy. If you do not agree, you should immediately discontinue your use of PC+, cease providing to us any of your personal data and notify us in writing in the manner described in Parts VII (Your Rights) and XIV (Contact Us).
If you have any feedback or questions about this Privacy Policy and the way we handle your personal data, or you wish to exercise any of your rights above, you may contact us contact us at the following:
Zuellig Pharma (SG) Solutions Pte. Ltd.
47 Scotts Road, #10-00, Goldbell Tower, Singapore 228233
Email: pcdpo@zuelligpharma.com
Attn to: Data Protection Officer