NOVI Health (“we”, “us”, “our” or “NOVI Health”) recognises the importance of protecting the privacy and the rights of individuals in relation to their personal data.

This privacy policy (“Privacy Policy”) tells you how we will collect, use, disclose or otherwise process your personal data.

1             Collection of your information

1.1         We may collect the following types of personal data about you:

1.1.1       general information about you such as your name; residential and mailing address; location data; email address; ethnic group; gender; nationality; personal identification number (e.g. identity card, NRIC, FIN or passport number); telephone contact number; age or date of birth;

1.1.2       physiological information (e.g. weight; height), information relating to health (e.g. family health history, previous conditions, drug allergy information, blood glucose level, medicine taken, blood pressure, food intake, activity level etc.), photographs when required for diagnosis and/or record keeping purposes; medical records (electronic or hardcopy);

1.1.3       next of kin information (e.g. emergency contact name, relation to client and contact details);

1.1.4       bank account and credit card details;

1.1.5       data related to your insurer, employer or other payor, if these parties are paying for the service; and

1.1.6       cookies.

1.2         We generally do not collect your personal data unless: (a) it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your personal data to us, after: (i) you (or your authorised representative) have been notified of the purposes for which the data is collected; and (ii) you (or your authorised representative) have provided written consent to the collection and usage of your personal data for those purposes; or (b) collection and use of your personal data without consent is permitted or required by the Personal Data Protection Act 2012 (“PDPA”) or other laws.

1.3         If you provide personal data of a third party with us (e.g. next-of-kin information), you confirm that you are duly authorised by that third party to do so for the purposes for which you have provided that personal data to us.

1.4         When collecting personal data, we may collect it in various ways including:

1.4.1       through our clinic when you complete a patient registration form;

1.4.2       through our staff or other representatives;

1.4.3       through our Novify mobile app or website;

1.4.4       through other medical and health related service providers;

1.4.5       through emails, messaging applications or other file sharing means that you use to provide the personal data to us; and

1.4.6       through the use of cookies.

1.5         If you do not provide us with the personal data described above, we may not be able to provide the requested services to you, either to the same standard as if you had provided the personal data or at all.

2             Purpose of Collection, Use and Disclosure

2.1         We collect, use, process and disclose your personal data for the following purposes:

2.1.1       setting up your patient account with our clinic;

2.1.2       providing medical and health related services to you;

2.1.3       updating patient records and sharing patient records with other medical and health related service providers;

2.1.4       providing a reply to doctors or other healthcare organisations or providers who have referred patients to us;

2.1.5       providing you with the services and functions of the Novify mobile app;

2.1.6       further developing our products, services and mobile app;

2.1.7       communicating with insurance companies and other payors relating to your claims;

2.1.8       processing and responding to any complaints or enquiries made by you;

2.1.9       uploading onto computer systems operated or managed by third parties patient health records and relevant photographs for record keeping purposes;

2.1.10     carrying out research, planning, and statistical analysis and for the purposes of product development, outcome evaluation and operational needs;

2.1.11     complying with any law, rule, regulation, lawful and binding determination, decision or direction of a regulator, or to co-operate with any governmental authority; and

2.1.12     sending patients newsletters, email reminders, text messages and other electronic means of communication.

2.2         We will not be sharing, selling, renting or disclosing your personal data other than as described in this Privacy Policy.

3             Disclosure of Personal Data

3.1         We may disclose your personal data to:

3.1.1       our affiliates, contractors or third party services providers for the purposes set out in paragraph 2.1;

3.1.2       medical and health related service providers and other healthcare institutions upon referral to provide healthcare services (whether that is upon our referral of a patient or another party’s referral to us);

3.1.3       websites, publications or scientific forums or to be used in promotional material for the purposes of publishing research results and outcomes (and as far as possible, for such data to be anonymised);

3.1.4       insurers, employers and other payors in relation to patient claims;

3.1.5       the purchaser (or prospective purchaser) of any business or asset which NOVI Health is (or is contemplating) selling;

3.1.6       law enforcement agencies or regulatory authorities where we are required to do so by law;

3.1.7       relevant parties where it is necessary for legal proceedings; or

3.1.8       any other organisations for any authorised purpose with your express consent.

3.2         The purposes listed in the above clauses may continue to apply even in situations where your relationship with us has been terminated or altered in any way, for a reasonable period thereafter (e.g. to allow for the transfer of your medical records to another doctor or health service provider).

4             Direct Marketing

4.1         We may send you direct marketing communications and information about our products and services, as well as products and services of third parties, that we consider may be of interest to you. These communications are sent in various forms, including mail, text messages, telephone calls and email, in accordance with applicable laws.

4.2         You may at any time opt-out of receiving marketing communications from us by contacting us at the details below.

5             Access and Correction

5.1         You may access or correct any personal data we hold about you at any time by contacting us at the details below. Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request. We do not charge for making any corrections to your personal data.

6             Data Security

6.1         We take reasonable steps to ensure your personal data is protected from misuse or loss, and unauthorised access, modification or disclosure.

6.2         Access to your sensitive data is restricted to authorized personnel only, and is governed by strict access control policies.

6.3         We only collect and retain the minimum amount of sensitive data necessary to provide our services.

6.4         We conduct regular security audits and assessments to ensure our data protection measures are effective.

6.5         Where possible, we anonymize or pseudonymize your sensitive data to further protect your privacy.

7             Retention of Personal Data

7.1         We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.

8             Transfers of Personal Data Outside of Singapore

8.1         We generally do not transfer your personal data to countries outside of Singapore. However, if we do so, we will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.

9             Cookies

9.1         We may send “cookies”, which are unique identifiers, to your device to enable our systems to recognise your device. If you do not wish to receive cookies, you can adjust your browser setting so that your device does not accept them.

10          Contacts

If you have any questions in relation to this Privacy Policy or your personal data, or if you wish to remove your data, please contact our Data Protection Officer at info@novi-health.com.

11          Changes to this Privacy Policy

We may revise this Privacy Policy from time to time without any prior notice. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.

This Privacy Policy was last updated on 23 Oct 2020.