We at Smartfuture Pte Ltd respect the privacy and confidentiality of personal data in our possession or under our control. We have implemented policies and practices to safeguard the collection, use, disclosure, storage and other processing of personal data provided to us.
Please read this Privacy Notice carefully. By accessing or using our products and/or services, or by ticking the box for acceptance of Terms and Conditions or Privacy Notice, you acknowledge that you have read, understand and agree to be bound to our Terms and Conditions and Privacy Notice and you expressly consent to us to collect and process your personal data. If you do not agree with this Notice, do not use our products and services or provide us with your personal data.
How We Collect Your Personal Data About You
We collect personal data from the following sources:
1. MedCheck and SleepCheck Kiosk Applications (installed in tablet in Kiosk) and MedCheck and SleepCheck mobile Applications (available in Play Store and App Store) (referred as “Apps”)
2. Medical and Wellness devices such as blood pressure monitor, glucose monitor, body scale, vital signs monitor and home sleep testing device (referred as “Devices”)
3. MedCheck website www.getmedcheck.com, SleepCheck website www.getsleepcheck.com and Smartfuture website www.oursmartfuture.com (referred as “websites”)
Types of Personal Data About You that We Process
The types of personal data we collect and process (or have a service provider process on our behalf), about you and users created by you in your account, may include:
1. Personal Identifiable Information including but not limited to name, email address, phone number, username and password, date of birth and location (through websites and Apps).
2. Demographic Information including but not limited to age, gender, weight, height, and other physical characteristics (through websites and Apps)
3. Health, Fitness and related Information including but not limited to blood glucose, blood pressure, weight and BMI, home sleep test information, body measurements, body composition such as fat percentage, bone mass, muscle percentage and water percentage, ECG and Cholesterol (through Devices and Apps)
4. Health, Fitness and related Information including but not limited to participation in activities and challenges, exercise frequency, performance goals, sleep pattern, step count, active time, speed, distance, hydration, calorie intake, physiological condition (through Apps)
5. Information about mobile device such as OS, OS version, phone model, data sync log, serial number, location, and Bluetooth address (through Apps)
6. Online purchase information including but not limited to purchase details and returns (through MedCheck website)
7. Information about your usage of websites including but not limited to IP address, browser type, operating geography, pages visited, links clicked, unique device identifier assigned to your mobile device (through websites)
Our Purpose(s) for Processing Personal Data About You
We use and otherwise process the personal data we have collected about you for one or more of the following purposes:
1. To provide our products and services
2. To store, process and present your health, fitness and related information collected through MedCheck devices
3. To understand your fitness and related needs and provide tailored diet and lifestyle recommendations
4. To recommend tailored wellness activities to your employer
5. To ensure functionality and security of our products and services
6. To prevent and investigate fraud and other misuses
7. To help you manage your content and preferences
8. To develop and manage our products, services, customer care, websites, sales and marketing
9. To communicate with you to inform you that our services have changed or to send you critical alerts relating to our products and/or services
10. To process your requests
11. To inform you of new products, services or promotions we may offer
12. To allow you to send SMS and/or App Notification to phonebook contacts and doctors added by you in MedCheck App
13. To allow you to share your health, fitness and related information with your phonebook contacts and doctors
Who We Disclose Personal Data About You To
We do not sell, lease, rent or otherwise disclose your personal data to third parties unless otherwise stated below.
1. We will share aggregated and anonymous data with your employer.
2. We may share your personal data if we have your consent to do so. Some features of Apps allow you to share your personal data with your phonebook contacts and doctors.
3. We may share your personal data with your employer, provided you have expressly given consent to your employer.
4. We may share your personal data with our employees or authorized third parties who process personal data for us for the purposes described above in this Notice. They are not permitted to use your personal data for any other purposes and are required to act strictly with this Notice.
5. Our products and services may use servers and resources located in various countries around the world. Therefore, your personal data may be transferred across international borders outside your country, but we ensure that there is adequate protection for your personal data that is comparable to the protection it receives under Singapore law.
6. We may be obligated by mandatory law to disclose your personal data to certain third parties, for example, to law enforcement agencies in the countries where we or third parties acting on our behalf operate.
7. If we sell, buy, reorganize or merge our businesses, this may involve us disclosing personal data to third parties.
How We Manage the Collection, Use, Disclosure and Storage of Your Personal Data?
1. Obtaining Consent: If we collect personal data directly from you, we will ordinarily first notify you of the purposes for which we are collecting it and obtain your express consent to us collecting, using and disclosing it for those purposes. However, when you voluntarily provide personal data to us for a purpose and it is reasonable that you do so we may rely on you being deemed to have consented to us collecting, using and disclosing your personal data for that purpose. Under certain circumstances, we may collect, use and/or disclose personal data about you without your consent for example, so that we can comply with our statutory obligations or where personal data is publicly available.
2. Third-Party Consent: If you have a one-on-one meeting with us or do a transaction with us on behalf of another individual, you must first obtain consent from that individual in order for us to collect, use or disclose his/her personal data.
How You Can Limit Processing of Personal Data About You?
1. Withdrawal of Consent: If you have given us consent to collect, use, disclose and otherwise process personal data about you, you may withdraw that consent at any time. You should give us reasonable advance notice of your withdrawal of consent. We will notify you of the likely consequences of your withdrawal of consent, e.g. without your personal contact information we may not be able to inform you of future updates or that the quality of our service may be impacted. Your request for withdrawal of consent can take the form of an email to us.
2. Accessing and Making Correction to Personal Data About You: You may ask us in writing to tell you what personal data we hold about you and how we have, or may have, used or disclosed it within a year before the date of your request. We will respond to your request as soon as reasonably possible and, in any event, we will respond to you within 30 days after receiving your request. We may charge a fee for processing your request, but we will let you know the amount of the fee before you incur it. You may also ask us to correct an error or omission in the personal data we hold about you. Unless we are satisfied on reasonable grounds that a correction should not be made, we will correct the personal data as soon as practicable. When you make any such request, we may need to verify your identity – for example, by checking your identity card number or other legal identification document.
3. Accuracy of Your Personal Data: We will take reasonable precautions and make reasonable verification checks to ensure that the personal data we hold is reasonably accurate, complete and up-to-date. From time to time, we may do a verification exercise for you to update us on any changes to the personal data we hold about you. If we are in an ongoing relationship with you, it is important that you update us if there are any changes in the personal data we hold about you (such as a change in your home address).
Protection of Personal Data
We have implemented an Information Security Policy that governs how we protect personal data. We make reasonable security arrangements to protect personal data about you that is in our possession or under our control to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks. All our employees will take reasonable and appropriate measures to maintain the confidentiality and integrity of your personal data and will only share your data with authorised persons on a ‘need to know’ basis.
Entities that provide services to us to process personal data on our behalf will be bound by contracts with us that that require them to provide sufficient guarantees in respect of the technical and organisational security measures governing the processing to be carried out and to take reasonable steps ensure compliance with those measures.
Retention of Personal Data
We will not retain any documents containing personal data about you as soon as it is reasonable to assume that the purpose for which we collected that personal data is no longer being served by retention of it and retention is no longer necessary for legal or business purposes.
We have a Document Retention Policy that spells out when we must cease to retain personal data and that requires documents and personal data to be destroyed (paper documents) or deleted (electronic documents and data stored in databases) securely. Certain retention periods are based on statutory or regulatory requirements.
Children’s Online Privacy Protection
Our products and services are typically intended for general audiences. We do not knowingly collect information of children without the consent of their parents or guardians. We do not knowingly collect Personal Data from children under 13. If you become aware that a child has provided us with Personal Data without parental consent, please contact us through email@example.com. If we become aware that a child under 13 has provided us with Personal Data without parental consent, we will take steps to remove the information and terminate the child’s account.
Links to Other Sites
Our websites and Apps may contain links to other websites that are not operated by us. If you click on a third-party link, you will be directed to that third party’s website. It is important that you review the Privacy Notice of every site you visit. We have no control over, and are unable to assume any responsibility for, the content, privacy policies or practices of any third-party sites or services.
Changes to this Privacy Notice
We may update our Privacy Notice from time to time. We will notify you of any changes by posting the notice on this page. You will find link to this Privacy Notice in Smartfuture website. Please revisit this page periodically for any changes. Changes to this Notice are effective when they are posted on this page.
If you have any questions about our collection, use, and/or disclosure of personal data about you; feedback regarding this Notice, or any complaint you have relating to how we collect, use, disclose and store personal data about you, you may contact our Data Protection Officer(s) at firstname.lastname@example.org.
Any query or complaint should include, at least, the following details:
1. Your full name and contact information
2. A brief description of your query or complaint
Last updated: Jan 16, 2020 (subject to future changes)