GENERAL DATA PROTECTION POLICY (“this Policy”)
Introduction
This Policy sets out the basis which Novem Healthcare Pte Ltd and its’ subsidiaries and affiliates, may collect, use, disclose and otherwise process personal data about shareholders, employees, partners, customers, suppliers and other individuals for a variety of reasonable purposes as described below. In this Policy, “personal data” has the same meaning given to that term in the Personal Data Protection Act 2012 and its regulations (“PDPA”).

Collection, Use and Disclosure of Personal Data
– Novem Healthcare Pte Ltd collects, uses and discloses personal data in accordance with the data protection principles under the PDPA:

1. Consent and Notification – The individual whose personal data is required (“data subject”) will be informed of the purposes for which the Novem Healthcare Pte Ltd requires the use of personal data so that consent of the data subject for the collection, use and disclosure of such personal data can be obtained accordingly.

2. Withdrawal of Consent – The data subject may withdraw his/her consent at any time, e.g. by opting out of the mailing list, or using the “unsubscribe” function. If the data subject wishes to withdraw his/her consent to his/her personal data, depending on the nature of the request, the Novem Healthcare Pte Ltd may not be in a position to continue to provide its products or services to the data subject or administer any contractual relationship in place, which may result in the termination of agreements with the Novem Healthcare Pte Ltd.

3. Purpose – Novem Healthcare Pte Ltd collects, uses, discloses and/or processes personal data for a variety of reasonable business purposes, including but not limited to the following:

– because it is necessary to enable you to access or use a service on the Site;
– to identify you when you access and use the Site in order for you to enjoy a customised and personalised experience;
– to send you information, promotions, updates, and marketing and advertising materials in relation to our goods and services;
– to improve the design and marketing of our range of products and services for your use

– to verify and process your personal particulars and payments;
– to provide goods and services to you;
– to respond and deal with enquiries, complaints and other customer-care matters or otherwise communicate with you;

– to comply with legal requirements;
– to enforce our legal rights and obligations;
– for other purposes for which we have obtained your consent; and
– for any other purposes reasonably necessary, ancillary or related to the above specified purposes.

4. Access and Correction – If any data subject wishes to withdraw consent to use of his/her personal data or obtain access to or correct his or her personal data records, please log in to the relevant account through which such personal data was first provided, if any, failing which, the data subject can contact Novem Healthcare Pte Ltd Data Protection Officer (“DPO”) whose contact details are set out below. The access request will be processed within 30 days or if not, Novem Healthcare Pte Ltd will notify the data subject.

5. Accuracy – Novem Healthcare Pte Ltd will rely on personal data protected by the data subject. In order to ensure that such personal data is current, complete and accurate, the data subject will be required to update Novem Healthcare Pte Ltd if there are changes to any personal data.

6. Protection– Novem Healthcare Pte Ltd does not disclose personal data to third parties except when required by law, or expressly or impliedly consented by the data subject. Novem Healthcare Pte Ltd has implemented generally accepted standards of technology and operational security to protect the personal data under its control from unauthorised/unlawful processing, accidental loss, destruction and damage.

7. Retention – Novem Healthcare Pte Ltd will not keep personal data for any longer than necessary to fulfil the purpose(s) for which the data subject gave his consent, and its legal/business needs.

8. Transfers – Novem Healthcare Pte Ltd does not generally transfer personal data to territories outside of Singapore. Where it does, it will ensure that any transfer of personal data to a territory outside of Singapore will be conducted in accordance with the PDPA.

Use of Cookies
In order to improve our services to you, we also use automated tracking devices such as a “cookie”. A cookie is a small amount of data that our Web server sends to your Web browser when you visit certain parts of our Site and the use of which is intended to assist our understanding of your interest in our Site. However, you can always choose to disable cookies from being stored on your computer by changing your browser settings. Disabling cookies, however, may result in a limited experience of our functionality and services and in some cases may mean that we are unable to provide you with the services, or parts of the services, that you have requested. Some of our business partners whose content is incorporated into or linked to from the Site may also use cookies. However, we have no access to or control over these cookies.

By accessing and using our website and services, you consent to the storage of cookies, other local storage technologies, beacons and other information on your devices. You also consent to the access of such cookies, local storage technologies, beacons and information by us or our representatives or agents.

Photography and Filming
During Novem Healthcare Pte Ltd ‘s events, photography, sound recording, videotaping and filming may be conducted for use in its publicity materials, e.g. website, brochures, email direct mailers and social media. Photos, sound recordings, videos and film recordings of certain individuals may be made during Novem Healthcare Pte Ltd’s events. If any individual does not wish for any photos, sound recordings, videos and film recordings where he appears to be used by Novem Healthcare Pte Ltd in its publicity materials, please notify Novem Healthcare Pte Ltd at the time of registration for the event. Otherwise, every individual attending the Novem Healthcare Pte Ltd’s events will be deemed to have given his/her consent to the use of any photos, sound recordings, videos and film recordings where such individual appear to be used by Novem Healthcare Pte Ltd.

Governing Law
You may contact our Data Protection Officer if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, The DPO can be contacted as follows:

Address: 23, New Industrial Road, #03-08, Solstice Business Center, Spore 536209
Email : dpo@novemhealthcare.com
Tel No. : +65 6443 3673

Effect of, and Changes to, this Policy
We may revise this Policy from time to time without any prior notice. The revised Policy will be available on this Site. You may determine if any such revision has taken place by referring to the date on which this Policy was last updated. We invite you to check this Policy periodically.
By continuing to communicate with Novem Healthcare Pte Ltd, by continuing to use the Sites and/or providing your personal data to us or allowing our collection of your personal data, following the revisions to this Policy, this shall signify your acceptance of such revisions.

Last updated on 01 September 2021

dpo@novemhealthcare.com