Ubie, Inc. ("Ubie", "we", "us" or "our") places the utmost importance on protecting the privacy of those who provide us with their information.
This Privacy Policy (this "Policy") describes how we may collect, use, and disclose and process your Personal Data (hereinafter defined) when you:
(a) access or use our website and applications (mobile, web-based, or otherwise) including the AI Health Assistant or Symptom Checker (collectively, “Applications”), and services; and/or
(b) provide us with your Personal Data, regardless of the medium through which such Personal Data is provided.
Please read this Policy to understand how we handle your Personal Data. By providing us with your Personal Data, accessing or using the Applications and services, you are deemed to have read, understood, and consented to our collection, use, and disclosure (including transfer) of your Personal Data in accordance with this Policy. If you do not agree to this Policy, please do not access or use our Application.
This Policy may be available in languages other than English. To the extent of any inconsistency or conflict, the English language version of this Policy shall prevail.
1. Information you give us
1.1. For the purposes of this Policy, “Personal Data” shall mean data, whether true or not, about an individual 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, including but not limited to name, identification number, birth date, address, postal code, and contact information. Such Personal Data shall also refer to that which is already in our possession or that which shall be collected by us in the future.
1.2. We may collect your Personal Data directly or indirectly, through various channels, such as when:
(a) you access or use the Applications;
(b) you use our services or enter into transactions with us;
(c) you contact us by telephone, email, via our Applications, or any other means;
(d) we seek information about you and receive your Personal Data in connection with your relationship or business dealings with us;
(e) you register for and/or attend events organised by us;
(f) you participate in competitions, contests or games organised by us;
(g) your images are captured by us via CCTV cameras while you are within our premises, or when photographs or videos of you are taken when you attend events organised by us;
(h) you submit an application for a position with us and/or when you provide documents or information including your resume/CVs in connection with such applications; and/or
(i) you provide us with your Personal Data for any other reason.
1.3. The information we obtain from you may include:
(a) Demographic data: name, gender, date of birth;
(b) Contact details: home address, correspondence address, billing address, e-mail address;
(c) Verification details: information pertaining to the verification of identity, including identification type, and identification/passport numbers;
(d) Health-related data, for example, height, weight, blood pressure, symptoms, sleeping habits, resting heart rate, and social habits such as smoking and drinking habits; and
(e) Any such information as we deem necessary or appropriate from time to time in connection with our service to be provided to you.
2. Collection, Use and Disclosure of Personal Data
2.1. We generally do not collect your Personal Data unless (a) it is provided to us voluntarily by you directly or via a third party (including your doctors and health providers) 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 Personal Data is collected, and (ii) you (or your authorised representative) have provided 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 Act or other laws. 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).
2.2. We may collect, use and store your Personal Data for any or all of the following purposes:
(a) managing your relationship with us;
(b) processing, authenticating, operating, maintaining and managing your user account;
(c) facilitating your use of the Applications;
(d) performing our obligations in the course of or in connection with our provision of any services requested by you, including but not limited to provide you with general information on your health and allowing your health service provider to refer to your Personal Data such as past health-related information;
(e) creating a data pool which may be used for research and development for drugs, medicines and other health products and services;
(f) facilitating transactions that you have or may have with us, including but not limited to processing payment or credit transactions, if applicable;
(g) for consumer care and/or defect rectification works;
(h) evaluating and further enhancing our products and services;
(i) for our internal record keeping;
(j) meeting any legal or regulatory requirements relating to our provision of services and products and to make disclosure under the requirements of any applicable law, regulation, direction, court order, by-law, guideline, circular, code applicable to us or any of our member companies; and/or
(k) carrying out analysis, market research, and customer surveys;
(l) responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
(m) complying with any applicable laws, regulations, codes of practice, guidelines or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority, including but not limited to prevention of crime such as fraud, money-laundering, and bribery;
(n) any other purposes for which you have provided the information;
(o) administrative purposes, including finance, IT and HR purposes, quality assurance and staff training, and compliance with internal policies and procedures, including audit, accounting, risk management, and record keeping;
(p) security and safety purposes;
(q) transmitting to any third parties including our affiliates, data intermediaries, third-party service providers (including doctors and health service providers) and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes; and/or
(r) any other reasonable business purposes related to or in connection with the above.
2.3. We may disclose your Personal Data:
(a) where such disclosure is necessary for performing obligations in the course of or in connection with our provisions of the services requested by you;
(b) where such disclosure is required by any applicable laws, regulations, codes of practice, guidelines or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority; and
(c) to any third parties such as below, whether in Singapore or abroad, for the purposes listed in clause 2.2 above;
i. any related and associated companies, affiliates, and subsidiaries of Ubie, including those established in the future and those in Japan;
ii. any data intermediaries processing your Personal Data on our behalf;
iii. where applicable, third parties who provide related services or products in connection with our business such as our vendors, business partners, and any party assisting us in carrying out the Purposes above;
iv. where you have consented for your information to be available, parties which participate in joint marketing schemes with us;
v. any agent, contractor, or service provider who provides administrative, order processing, payment clearing, credit reference, debt collecting, or other services necessary to the operation of our business;
vi. organisations including professional service providers and relevant regulatory authorities whether within or outside Singapore, in connection with the acquisition, disposition, and/or intended acquisition or disposition of Ubie's assets and/or Ubie itself whether directly or indirectly;
vii. any party or organisation who are bound by confidentiality agreements with us;
viii. any person to whom we are, in our belief in good faith, under an obligation to make disclosure as required by any applicable law; including, but not limited to government agencies, statutory authorities, and industry regulators; and
ix. our auditors, consultants, accountants, lawyers, or other financial or professional advisers.
2.4. The third parties set out above may be situated in Singapore or elsewhere. You fully understand and unambiguously consent that we may transfer your Personal Data to any location outside of Singapore for the purposes set out above. We are committed to safeguarding your Personal Data when it is transferred across jurisdictions. We will ensure that your Personal Data receives an adequate level of protection regardless of the jurisdiction to which it is transferred.
2.5. The purposes listed in clauses 2.2 and 2.3 above may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under any contract with you).
2.6. As the accuracy of your Personal Data depends largely on the information you provide to us, you warrant and represent that Personal Data which you disclose to us shall be accurate and complete. If you provide us with Personal Data relating to a third party, you warrant and represent to us that you have obtained the consent of the third party and are authorised by the third party to do so. Please kindly update us as soon as possible if there are any errors or if there have been any changes to your Personal Data by informing our Data Protection Officer in writing or via email at the contact details provided below.
2.7. If you have provided us with your consent, we may use your personal data for the purposes of marketing our products and services and those of our partners and business associates (e.g. informing you of our latest activities, special offers, and promotions). In order for us to market products and services which are of special interest and relevance to you, we may analyse and rely on your overall interaction with us (such as but not limited to your participation in promotions or events and your interactions with us).
2.8. The decision to provide us with your Personal Data is solely yours to make, but you acknowledge that we require certain types of Personal Data so that we can provide our services to you and if you decline to provide us with such Personal Data, or request us to delete it, we may not be able to provide our services to you.
2.9. We may use cookies on our websites or Applications to track website or application visitorship and experience. Most web browsers are designed to accept cookies. If you do not wish to receive any cookies, you may set your browser to refuse them. However, this may affect the functionality of the Applications.
2.10. Please be informed that when you use any Applications, such Applications may acquire information such as your location, device identification details, as well as mobile device information. If you do not wish to provide us with such information, you may activate the function to disable location on your mobile device. However, this may affect the functionality of the Applications.
3. Withdrawing Your Consent
3.1. 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 using and/or disclosing your Personal Data for any or all of the purposes listed in clauses 2.2 and 2.3 above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.
3.2. Upon receipt of your 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 ten (10) business days of receiving it.
3.3. 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 in clause 3.1 above.
3.4. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose Personal Data where such collection, use and disclosure without consent is permitted or required under applicable laws.
4. Retention of Personal Data
4.1. We retain your Personal Data for as long as we need the Personal Data to fulfil the purposes we collected it for, and to satisfy our business and/or legal purposes, including audit, accounting, or reporting requirements.
4.2. In some circumstances, we may anonymise your Personal Data so that it can no longer be associated with you, in which case we are entitled to retain and use such data without restriction.
5. Protection of Personal Data
5.1. While precautions will be taken to ensure that the Personal Data you provide is protected against unauthorised or unintended access, we cannot be held responsible for unauthorised or unintended access that is beyond our control.
5.2. To safeguard your Personal Data from unauthorised access, collection, use, disclosure, or similar risks, we, to the extent required by the Act, have introduced appropriate administrative, physical, and technical measures such as up-to-date antivirus protection and disclosing Personal Data both internally and to our authorised third-party service providers and agents only on a need-to-know basis.
5.3. 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.
6. Use of statistical data
You acknowledge that Ubie may use the Personal Data obtained from you to create statistical data based on which individuals cannot be identified.
Given the nature of such statistical data not being able to identify individuals, Ubie may use such statistical data without restriction including, without limitation, to provide them to any third parties.
7. Your rights to access, limit and correct your Personal Data
You may contact us by email at compliance@dr-ubie.com at any time and you may:
(a) check whether we hold or use your Personal Data and request access to such data;
(b) request that we correct any of your Personal Data that is inaccurate, incomplete, or out-of-date;
(c) request that we limit the processing of your Personal Data;
(d) request for information concerning the ways your Personal Data has been or may have been used or disclosed by us within a year before the date of your request;
(e) request the transfer of certain of your Personal Data to another party under certain conditions;
(f) request that we specify or explain our policies and procedures in relation to Personal Data and the categories of Personal Data collected, used, and disclosed by us; and/or
(g) withdraw, in full or in part, your consent given previously, in each case subject to any applicable legal restrictions, contractual conditions, and a reasonable time period.
Please address all requests and/or questions or concerns which you may have regarding the subject matter in writing or via email to our Data Protection Officer at the contact details provided below.
8. Data Protection Officer
If you have any inquiries or wish to make any request relating to your Personal Data, you may contact our Data Protection Officer at:
Name: Naoto Shimazu
Address: 111 North Bridge Road, #08-10, Peninsula Plaza, Singapore 179098
Email: privacy@dr-ubie.com
Weekdays: Monday-Friday 10 AM-5 PM
9. Changes of this Policy
We may revise this Policy from time to time without any prior notice. Any amended Policy will be posted on our website. You are encouraged to visit our website regularly to ensure you are familiar with our latest Personal Data policies. 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 acknowledgment and acceptance of such changes.
Last Updated: 25 Jun 2021