Digital-Health Technologies Pte. Ltd. (“DHT”) respects the privacy of every person (“User”) who registers with DHT to download, install, access and use the tools offered at www.digital-healthtech.com and www.supermd.io (“Website”) and “SuperMD” mobile application (“App”). This Personal Data Protection Policy (“Policy”) supplements and should be read in conjunction with the Website Terms of Use and App Terms of Use, as amended from time to time.

User Data, Use, and Purposes

This Policy sets out the basis on which DHT collects, uses, stores, accesses, discloses and transfers (collectively, “Use”) (a) User’s personal details when registering as a User or through the continuing use of the App (e.g. response to surveys that DHT may ask User to complete for research purposes and User’s search queries on the App),. including name, NRIC, credit card numbers, and email; and/or (b) medical information and records uploaded by User or User’s caregiver and/or approved healthcare providers and any communications between User and such persons (collectively, “User Data”) for the purposes stated below (collectively, “Purposes”) in compliance with the requirements of the Personal

Data Protection Act 2012 and its regulations (“PDPA”):

• to verify User’s identity, and set-up User’s account, including managing User’s use and access to the Website and/or the App;
• to enable User and/or User’s family members and caregivers to manage User’s medical needs and requirements;
• to disclose/share the User Data with User’s family members, caregivers and approved healthcare providers in such manner approved by User, or as necessary to ensure User’s safety and health;
• to create reports and databases that may be shared with relevant governmental authorities or other licensed medical professionals that are intended to assist in medical research and development efforts and such other use as otherwise required or permitted by law;
• to comply with DHT’s compliance with applicable laws and regulations, or provide assistance in any law enforcement and investigations conducted by any governmental and/or regulatory authority; and transfer to any unaffiliated third parties and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes;
• to protect and enforce DHT’s contractual and legal rights and obligations;
• to store information about User’s preferences, allowing DHT to customise the App according to User’s preferences and speed up User’s use of the Website and/or the App;
• to assist User with User’s enquiries, obtain User’s feedback, invite User to participate in relevant medical or related events and programmes, and send advertisements and information to User of DHT’s and other third parties’ goods and services that may be of interest to User; and
• for any other incidental business purposes related to or in connection with the above, or otherwise with User’s consent.

User Consent

User must register with the Website or the App, and affirmatively consent to use the Website and/or the App including consent to this Policy and the Use as stated herein. User may at any time, upon giving reasonable notice to DHT, withdraw User’s consent for DHT to Use the User Data. If User withdraws his/her consent, User shall be informed of the consequences of withdrawing such consent. If User is providing DHT with another person’s personal data (including family members), User warrants that User is authorised to act on the other person’s behalf, and such person accepts that his/her personal data shall be subject to this Policy.

Accuracy of User Data

DHT shall rely on User to ensure that the User Data is current, accurate and complete. User shall immediately notify DHT of any changes to any User Data.

Storage and Security

DHT stores User Data in a cloud-based server via AWS. DHT uses commercially acceptable means of securing, and protecting the integrity of, User Data. However, no method of transmission over the internet, or method of electronic storage, is 100% secure and reliable. Computer hackers that circumvent DHT’s security measures may gain access to certain portions of User Data. Technological bugs, errors and glitches may cause inadvertent disclosures of User Data. For these reasons, DHT cannot guarantee absolute security of any User Data. DHT’s employees and contractors are bound by strict obligations as to confidentiality and know that they are required to strictly adhere to this Policy and other applicable laws and regulations. DHT does not generally transfer Personal Data to territories outside of Singapore but if it does so, DHT shall ensure that such cross-border transfer shall be conducted in accordance with the requirements under the PDPA.

DHT shall notify all Users if DHT learns of an information security breach with respect to any User Data whereby Users shall be notified via e-mail in the event of such a breach except that such notice may be delayed in order to address the needs of law enforcement, determine the scope of network damage, and to engage in remedial measures.

Aggregation and Anonymised Data

Subject to applicable laws and regulations, including but not limited to DHT’s obligations under the PDPA, DHT may license, sell, or otherwise share aggregated and anonymised versions of any User Data (“Anonymised Data”) with DHT’s affiliates, partners, customers, investors, and contractors for any purpose. User hereby agrees and acknowledges that DHT is the sole and exclusive owner of any Anonymised Data created by DHT and that User has no ownership or other intellectual property rights in or to any of the Anonymised Data and any database containing all or part of the Anonymised Data.

User Access

User shall be entitled to log into User’s account to correct any error or omission in any User Data provided to DHT, or failing such access, User may contact DHT. If there is any chargeable fee for such access, DHT shall notify User before processing any such request, and the access request shall be processed within 30 days. User is solely responsible for ensuring the security of his account and must notify DHT promptly of any unauthorised use or security breach of User’s account.

Cookie Information

DHT uses a variety of cookies and similar technologies at the Website and/or the App to help DHT collect relevant information. User can set User’s browser to refuse all or some browser cookies or to alert User when cookies are being sent. If User disables or refuses DHT’s cookies or blocks DHT’s use of other tracking technologies, some parts of the Website and/or the App may then be inaccessible or may not function properly.

Third Party Services

This Policy does not apply to any third party applications or software that integrate with the Website and/or the App, or any other third party products, services or businesses. DHT does not control third parties' collection or use of User’s information whether to serve interest-based advertising or otherwise.

These third parties may provide User with ways to choose not to have User’s information collected or used in this way and it is User’s responsibility to opt out of receiving targeted ads.

Variation to this Policy

DHT may from time to time vary this Policy. User is required to check this Policy regularly to ensure that User is aware of any variations made by DHT. If User continues to use the Website and/or the App, User is deemed to have accepted any such variation. If User does not agree to any variation, User must not use the Website and/or the App.

Governing Law

This Policy is governed by the laws of Singapore.

Complaints and Feedback Procedure

Complaints and feedback can be provided via email or telephone call, and DHT shall use best efforts to respond to the complaint within five (5) working days to notify User that the complaint is being investigated and the estimated time needed to investigate and/or resolve the complaint. Upon completion of the investigation, DHT shall provide written report to User containing the investigation findings and steps to resolution, and confirm with User that complaint has been satisfactorily resolved.

If you have any query or complaint about this Policy, please contact DHT at:

Person-in-charge	: Alan Ho
Address	: Marina Bay Financial Centre, Tower 1, 8 Marina Blvd, Singapore 018981
Email	: info@digital-healthtech.com
Tel No.	: +6562920288