Privacy Policy – 42 by Detalytics

Detalytics Pte. Ltd. (the “Company,”, “Detalytics”, “we”, “us”, or “our”) realizes that privacy is an important issue, and we take your privacy seriously. Please read the following to learn more about how we collect, safeguard, use, disclose or otherwise process personal data of our customers, in accordance with the Personal Data Protection Act (“PDPA”). This Privacy Policy is subject to modification and/or update as set forth below under the caption “Updates to this Policy.”

APPLICABILITY OF THIS POLICY

This Privacy Policy applies to personal data in our possession or under our control, collected from you via

the www.detalytics.com website;
the “42 by Detalytics” mobile application;
third parties which we have engaged to collect, use, disclose or process personal data in connection with offering our services (collectively, the “Services”); or
other websites, web applications and mobile applications which are specifically added to this Privacy Policy (collectively, the “Sites”).

As used in this Privacy Policy:

“personal data” means data, whether true or not, about a customer who can be identified: (a) from that data; or (b) from that data and other information to which we have or are likely to have access.
Other terms used in this Privacy Policy shall have the meanings given to them in the PDPA (where the context so permits).

WHAT DATA DO WE COLLECT?

Depending on the nature of your interaction with us, some examples of personal data which we may collect include

personally identifiable information, including but not limited to your name, email address, telephone number, gender, date of birth, photograph;
your health data, including but not limited to data synced from your health app, information you provide in questionnaires, clinical reports and test results, and assessment scores and recommendations generated as a result of your use of our Services;
other information collected in connection with offering our services, including but not limited to billing information, customer service information about you as a Site user, and information about persons or processes that referred you to Detalytics; and
information about your use of our Sites, including but not limited to how frequently you use our Sites, and your responses to any offerings and advertisements presented on the Sites.

HOW DO WE COLLECT YOUR PERSONAL DATA?

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 (your “authorised representative”) 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 personal data without consent is permitted or required by the PDPA or other laws.

We may collect your personal data (i) when you register to become a user of the Services through the Sites, (ii) when you “opt in” for certain services or features of the Sites, such as electing to receive emails, (iii) when you voluntarily provide us with information through emails or providing comments on our social media sites, (iv) when you click on Facebook, Twitter, Linkedin or other social media “plug-ins” on the Sites and (v) automatically as further described below.

COOKIES AND ADVERTISING ON THIRD PARTY PLATFORMS

We also receive the automatic and passive data (both personally identifiable and otherwise) from the computer, mobile phone or other device you use to access the Sites and the Services, and when you interact with the Sites. In this regard, the Sites use common automated information gathering tools such as logs files that record page activity, including a particular user’s visits to a page and how many “hits” a particular item is receiving, as well as other user activity. We may also collect information through other technologies, in particular the following:

advertisers (known as “third party cookies”). Most web browsers automatically accept cookies, but you may choose not to receive a cookie file by enabling your Web browser to refuse cookies or to prompt you before accepting a cookie. Please be aware, however, that by refusing to accept cookies, you will be unable to access a significant portion of the Site and unable to use a significant portion of the Services.
“Clear gifs.” Similarly, our analytics and any third party advertising partners may employ a software technology called clear gifs (a.k.a. web beacons/web bugs), that help us better manage content on our Sites by informing us what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users. In contrast to cookies, which are stored on a user’s computer hard drive, clear gifs are embedded invisibly on Web pages and are about the size of the period at the end of this sentence. We do not tie the information gathered by clear gifs to our users’ personally identifiable information.
“Flash LSOs.” When we post videos on our site, third parties may use local shared objects, also known as Flash cookies, to store your preferences for volume control, or to personalize certain video features. Flash cookies are different from browser cookies because of the amount of, type of, and how data is stored. Cookie management tools provided by your browser will not remove Flash cookies.

WHAT WILL WE DO WITH THE DATA WE HAVE COLLECTED?

USE OF PERSONAL DATA

We may use your personal data for any or all of the following purposes:

performing obligations in the course of or in connection with our provision of the services requested by you;
verifying your identity;
responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
managing your relationship with us;
processing payment or credit transactions; and
any other purposes for which you have provided the information.

DISCLOSURE OF PERSONAL DATA

We may disclose your personal data:

to third-party service providers, agents and other organizations we have engaged to perform any of the functions with reference to the above-mentioned purposes; and
to third party organizations for which you have provided explicit consent for the disclosure of your personal data.

We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorised by law).

INTERNATIONAL TRANSFERS OF PERSONAL DATA

We generally do not transfer your personal data to countries outside of Singapore. However, if we do so, we will obtain your consent for the transfer to be made and 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.

PROTECTION OF PERSONAL DATA

To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as minimised collection of personal data, authentication and access controls (such as good password practices, need-to-basis for data disclosure, etc.), encryption of data, up-to-date antivirus protection, regular patching of operating system and other software, securely erase storage media in devices before disposal, web security measures against risks, usage of one time password(OTP)/ 2 factor authentication (2FA)/ multi-factor authentication (MFA) to secure access, security review and testing performed regularly, and offsite data storage with regular data backup procedures and a data recovery plan for downtime mitigation.

You 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, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.

THIRD PARTY SERVICES, ADVERTISERS AND APPLICATIONS

We do not sell any data to third parties for marketing or any other purpose. You completely control what you would like to share when connecting to a service via 42 app.

YOUR RIGHTS WITH RESPECT TO YOUR PERSONAL DATA

WITHDRAWING YOUR CONSENT

The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop collecting, using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing. For more information on how to submit your request, click here.

Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within seven (7) business days of receiving it.

Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our goods or services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described above.

Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.

ACCESS TO AND CORRECTION OF PERSONAL DATA

If you wish to make (a) an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, or (b) a correction request to correct or update any of your personal data which we hold about you, you may submit your request in writing. For more information on how to submit your request, click here.

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 will respond to your request as soon as reasonably possible. In general, our response will be within seven (7) business days. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).

ACCURACY OF PERSONAL DATA

We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing us via email at the contact details provided below.

RETENTION OF PERSONAL DATA

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.

We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.

UPDATES TO THIS POLICY

This Policy applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.

We may revise this 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 Policy was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.

HOW TO CONTACT US

If you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, you contact us at support@detalytics.com.