Privacy Notice

When you sign up to become a User with iSabel, you acknowledge and agree to abide by the General Terms, applicable Service-Specific Terms of Use and iSabel’s policies. Please read this Privacy Policy carefully before using the iSabel mobile application operated by iSabel Health Tech Pte Ltd as it contains important information on who we are, how and why we collect, store, use and share personal information, your rights in relation to your personal information and on how to contact us in the event you have a complaint.

Privacy Policy

This Data Protection Policy (“Policy”) sets out the basis upon which ISABEL HEALTH TECH PTE. LTD (“Company”) may collect, use, disclose or otherwise process personal data of the users of the iSabel platform (“iSabel”) in accordance with the Personal Data Protection Act (“PDPA”). This policy applies to personal data in the Company’s possession or under the Company’s control, including personal data in the possession of organisations which the Company has engaged to collect, use, disclose or process personal data.

APPLICATION OF THIS POLICY

1. This Policy applies to all persons who are registered users with an account on iSabel (“User”).
2. By using and accessing iSabel, or otherwise providing information or communicating with the Company, the User is deemed to have agreed to the Company’s collection, use, processing and disclosure of personal data in accordance with this Policy.
3. This Policy shall be governed by, and construed in accordance with the laws of the Republic of Singapore. Any dispute arising out of or in connection with this Policy shall be referred to and finally resolved by the Courts of Singapore.

PERSONAL DATA

4. As used in this Policy, “personal data” means data, whether true or not, about a User which can be identified: (a) from that data, or (b) from that data and other information to which the Company has or are likely to have access.
5. Generally, personal data which the Company may collect from the User includes, without limitation:
   1. Name, work and personal email IDs;
   2. device information such as the device name, device identification code, mobile device language, operating systems and versions, and mobile network information;
   3. log information such as Internet Protocol (IP) address, the dates and times that the User accesses iSabel, length of visit, the features or type of content that the User views and the number of views, the links that the User clicks and other system activity relating to iSabel;
   4. depending on the location setting - location information including the User’s approximate or precise location;
   5. personal opinions made known to the Company (e.g feedback on iSabel);
   6. photographs; and
   7. any other personal data reasonably required in order for the User to access and use iSabel.
6. Generally, the Company obtains personal data in, but not limited to the following ways:
   1. Through information submitted by the User or the User’s employer which includes information submitted during the registration process, providing answers to security questions, completing any confirmations, declaration or forms or through accessing and viewing iSabel and the contents therein; and
   2. Through the public domain and the relevant third parties.
7. Other terms used in this Policy shall have the meanings given to them in the PDPA (where the context so permits).

COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA

8. The Company generally collects personal data that:
   1. The User knowingly and voluntarily provides in the course of or in connection with the use of iSabel, or via the User’s employer or a third party who has been duly authorized by the User to disclose his/her personal data to the Company after:
      1. The User (or his or her authorised representative) have been notified of the purposes for which the data is collected, and
      2. The User (or his or her authorised representative) have provided written consent to the collection and usage of the User’s Personal data for those purposes, or
   2. collection and use of personal data without consent is permitted or required by the PDPA or other laws.
      1. The Company shall seek the User’s consent before collecting any additional personal data and before using the User's personal data for a purpose which has not been notified to User (except where permitted or authorised by law).
9. The User’s personal data will be collected and used by the Company for the following purposes and the Company may disclose the User’s personal data to third parties where necessary for the following purposes:
   1. Verifying your identity
   2. Service and feedback. The Company may use information about the User and/or collected from the User to respond to the User’s requests, applications, instructions and feedback, or take other actions to address the User’s inquiries, to verify the User’s identity, or post the User’s comments and feedback on any social media platform maintained by the Company.
   3. iSabel improvement and troubleshooting. The Company may use the User’s personal data to improve and enhance the content, appearance and utility of iSabel, or by customizing iSabel viewed through the User’s account to his/her particular interests. The Company may use the personal data and other information for the purposes of troubleshooting, functionality testing, and addressing issues regarding iSabel and its functionalities.
   4. Marketing and corporate communications. The Company may need to contact the User for marketing and corporate communications such as iSabel updates, new offerings and promotions. Unless the User has expressly stated his/her preference to opt out, the Company may also use the User’s personal data to send marketing collaterals or for advertising purposes.
   5. Security and keeping the User’s information safe. The Company works hard to keep iSabel secure and to prevent abuse and fraud. From time to time, the User’s information may be accessed by personnel of the Company to facilitate this process.
   6. Compliance purposes. The Company may disclose the User’s personal data to comply with any applicable laws, regulations, code of practice, policies, procedures guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority.
   7. Other purposes. The Company may disclose the User’s personal data for fulfilling any purpose directly related to the above purposes or any other purpose that are appropriate or authorized by any applicable laws.
10. The purposes listed in the above clauses may continue to apply even in situations where the Company’s relationship with the User has been terminated or altered in any way, for a reasonable period thereafter.
11. The User’s personal data may be disclosed with the following:
    1. To whom disclosure is required for performing obligations in the course of or in connection with the use of iSabel;
    2. To third party service providers, partners, agents and other organisations which the Company may appoint from time to time to provide services in connection with iSabel such as content, social media services, programming, marketing and promotion, data processing and analysing the application.
    3. To the Company’s directors, officers, employees, representatives, shareholders and related corporations;
    4. To the Company’s professional advisers, consultants and auditors;
    5. Pursuant to a request by any relevant governmental or regulatory authority (regardless of the reason for such request and whether such request is exercised under an order of court or otherwise); and
    6. To any persons to whom the Company believes in good faith, is under an obligation to make disclosure as required by any applicable law.

USE OF COOKIES AND RELATED TECHNOLOGIES

12. iSabel tech platform and application use cookies. A cookie is a small text file placed on the User’s device when the User accesses or uses iSabel. Cookies collect information about the User and his/her visit to iSabel. The Company uses cookies and technologies such as pixel tag to facilitate the User’s sessions and use of iSabel, suggest certain content on iSabel according to the User’s preferred setting.
13. The Company also uses certain analytic programs for web analytics purposes to manage and improve iSabel and the Company’s services. Accordingly, the User’s information may be collected for reports such as impression reporting, demographic reporting, interest reporting and to assist with the Company’s efforts to provide the User with a better experience on iSabel.

WITHDRAWING CONSENT

14. The consent that the User provides for the collection, use and disclosure of the User’s personal data will remain valid until the termination of the User’s account with iSabel or such time it is being withdrawn by the User in writing or via email to the Company at the contact details provided below in clause 31.
15. Upon receipt of the User’s written request to withdraw his/her consent, the Company may require reasonable time (depending on the complexity of the request and its impact on the Company’s relationship with the User) for the User’s request to be processed and for the Company to notify the User of the consequences of the Company acceding to the same, including any legal consequences which may affect the User’s rights and liabilities to the Company. In general, the Company shall seek to process and effect such request within fourteen (14) working days of receiving it.
16. In the event of a User’s written request to withdraw his/her consent, the Company will cease provision of any services in connection with iSabel and terminate the User’s account with iSabel with immediate effect from the Company’s receipt of such notice. Should you decide to cancel your withdrawal of content, please inform us in writing in the manner described in clause 14 above.
17. Please note that withdrawing consent does not affect the Company’s right to continue to collect, use and disclose personal data where such collection, use and disclosure without consent is necessary to protect the Company’s rights and/or comply with a judicial proceeding, court order, or legal process served, permitted or required under applicable laws.

ACCESS TO AND CORRECTION OF PERSONAL DATA

18. If the User wishes to make (a) a request for access to a copy of the User’s personal data which the Company holds about the User or information about the ways in which the Company uses or discloses the User’s personal data, or (b) a correction request to correct or update any of the User’s personal data which the Company holds, the User may submit a request in writing or via email to us at the contact details provided below in clause 30 to the Company.
19. The Company will respond to the User’s access request as soon as reasonably possible. Should the Company not be able to respond to the User’s access request within fourteen (14) working days after receiving the User’s access request, the Company will inform the User in writing within fourteen (14) working days, of the time by which the Company will be able to respond to the User’s request. If the Company is unable to provide the User with any personal data or to make a correction requested by the User, the Company shall generally inform the User of the reasons why the Company is unable to do so (except where the Company is not required to do so under the PDPA).
20. Depending on the request that is being made, the Company will only need to provide the User with access to the personal data contained in the documents requested, and not to the entire documents themselves. In those cases, it may be appropriate for the Company to simply provide the User with confirmation of the User’s personal data that the Company has on record, if the record of the User’s personal data forms a negligible part of the document.

PROTECTION OF PERSONAL DATA

21. To safeguard the User’s personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, the Company has introduced appropriate administrative, physical and technical measures to secure all storage and transmission of personal data by the Company, and only disclosing personal data both internally and to authorised third party service providers and agents only on a need-to-know basis.
22. The User should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, the Company will strive to protect the security of the User’s information and are constantly reviewing and enhancing the Company’s information security measures.

ACCURACY OF PERSONAL DATA

23. The Company generally rely on personal data provided by the User (or his/her authorized representative). In order to ensure that the User’s personal data is current, complete and accurate, the User shall update the Company if there are changes to the User’s personal data, in writing.

RETENTION OF PERSONAL DATA

24. The Company may retain the User’s personal data for as long as it is necessary to fulfil the purposes for which they were collected, or as required or permitted by applicable laws.
25. The Company will cease to retain the User’s personal data, or remove the means by which the data can be associated with the User as soon as it is reasonable to assume that such retention no longer serves the purposes for which the personal data were collected, and are no longer necessary for legal or business purposes.

TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE

26. The Company may transfer the User’s personal data to countries outside of Singapore, including India, for the purposes of storing or processing data. The User consents to the transfer to be made and the Company will take steps to ensure that the User’s personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA and this Privacy Policy, by implementing security measures to protect the personal data, ensuring that the data is deleted from the storage upon the User’s request, and legal mechanisms such as personal data protection clauses in any third-party providers’ agreements.

EFFECT OF POLICY AND CHANGES TO POLICY

27. This Policy applies in conjunction with any other policies, notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of the User’s personal data by the Company.
28. The Company may revise this Privacy Policy from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Privacy Policy was last updated. Your continued use of iSabel constitutes your acknowledgement and acceptance of such changes.

CONSENT

29. The User agrees to and acknowledges the terms of the Policy herein and consent to the collection, use and disclosure of User’s personal data for the purposes set out in this Policy. The User may withdraw consent for such use and disclosure, and make an access or correction request in respect of the User’s personal data in accordance with this Policy.
30. CONTACT US

    Please contact us at wearehere@isabel.sg if you;

    • have any questions about this Privacy Policy
    • have any enquiries or feedback on our personal data protections and procedures