‍InReste Pte Ltd (“InReste”) is committed to safeguarding the personal data which you provide to us. This Privacy Policy sets out the ways in which your personal data will be collected, used and protected by InReste, in accordance with the Personal Data Protection Act 2012 (“PDPA”).

This Privacy Policy applies to personal data in our possession or under our control, including personal data shared to Third Parties and/or Partners, which are engaged by InReste to collect, use, disclose or process your personal data for InReste Products purposes.

If you do not agree to this Privacy Policy or our Terms of Service, please do not use any of the InReste Products and/or Services. Your continued use of InReste Products and/or Services constitutes your acknowledgement and acceptance of this Privacy Policy.
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‍1. Data Collection and Use

1.1. Your personal data will be collected and used by InReste Products and/or Services and other modes of communication such as email, phone or text and/or otherwise:
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1.1.1. To provide our Services or utilise InReste Products to meet your healthcare and/or employee and/or insurance healthcare benefit needs such as, notwithstanding, verifying your identity, responding to, handling and processing queries, requests, applications, complaints and feedback from you, managing your relationship with us, processing or facilitating the processing of your purchase or credit transactions and/or utilisation of Services in InReste Products and notifying you of any updates available to InReste Products and/or Services.

1.1.2. To customise and improve our Services to make your experience more secure, convenient and more functionalities (including improving the quality of InReste Products and our Services through the performance of quality reviews and similar activities and creating de-identified or anonymised information which is not used or intended to be used to personally identify an individual for the purpose of data analytics and research).

1.1.3. Where you have provided consent to allow us to market and promote InReste Products and our Services to you, which may also include providing you with promotional messages, newsletters, emails, products and services.

1.1.4. To comply with any applicable laws, regulations, codes of practices, guidelines, or rules, or assist in law enforcement and investigations conducted by any governmental and/or regulatory authority.

1.1.5. Transmitting to any unaffiliated third parties partners and relevant governmental and/or regulatory authorities, whether in Singapore or abroad for the aforementioned purposes.

1.1.6. For any other purposes for which you have provided the information and for any other incidental business purposes relating to or in connection with any of the above. We only collect personal data about you that we consider reasonably necessary for achieving these purposes, such data may be provided to us voluntarily by you directly or via a third party (e.g. Myinfo), who has been duly authorised by you to disclose your personal data. Your consent shall be seek prior to collection of any additional personal data and before the use of your personal data for a purpose which has not be notified to you (except where permitted or authorised by law).

1.2. If you choose to access and/or use InReste Products and/or Services, we will require you to provide contact and identity information, medical history and other personal data as indicated on the forms in the relevant pages of InReste Products. Some example of personal data which we may collect from you include:

1.2.1. Your name, identification number such as passport number, NRIC and FIN, residential and delivery address, email address, telephone number, nationality, gender and date of birth.

1.2.2. Personally identifiable medical and health-related information which you provide to us such as information or records relating to your medical or health history, health status, laboratory testing results, biometric measurements and diagnostic images.

1.2.3. Personally identifiable medical and health-related information about you prepared by healthcare providers and/or treatment providers who provide our Services to you such as medical records and treatment and examination notes.

1.2.4.  Any other information which you may input into InReste Products or provide to us in pursuant to our provision of our Services.

1.3. A file about you and your use of InReste Products and/or Services will be maintained by InReste. We will collect, use and retain the data in your file, and such other data that we may obtain from time to time in connection with your current and past activities on InReste Products and/or Services, for as long as the purpose for which the data is collected continues or where otherwise necessary for legal purposes or the purposes of our normal business operations, which includes the purposes as set out in clause.

1.4. We may also look across multiple users to identify problems, and in particular, we may examine your personal data to identify users using multiple user-IDs or aliases. We may also compare and review your personal data for errors, omissions and/or accuracy.

1.5. Under some circumstances, we may require certain financial information from you. We will use your financial information (including credit card information or online payment system account information) to verify the accuracy of your name, address, and other information, detect any fraud or other criminal activity, and bill you for your use of our Services.

1.6. We may track certain information based upon your behaviour while using InReste Products and/or Services. We will use this information to do internal research on our users’ demographics, interests, and behaviour to better understand, protect and serve our users in general and you in particular. This information may include information about the computer or mobile device you are using, and your IP address, site activity, browser type, connection speed, access times and physical location.

1.7. We may use data collection devices such as “cookies” on certain pages of InReste Products to promote trust and security, help analyse our web page flow and measure promotional effectiveness. “Cookies” are small files placed on your hard drive that assist us in providing InReste Products and/or our Services. We may offer features that are only available through the use of a “cookie”. We also use “cookies” to reduce the number of times you need to enter your password. “Cookies” can also help us provide you with information that is targeted to your interests. You are always free to decline our “cookies” (if your browser permits you to do so), although in that case you may not be able to use certain features and you may be required to enter your password more frequently during a session on InReste Products.

‍2. Disclosure to Third Parties
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‍2.1. By default, your personal data will not be shared or disclosed to the Third Parties (whether for their marketing purposes or otherwise) without your consent. However, InReste reserve the rights to disclose your personal data to:

2.1.1. Our subsidiaries, affiliates and/or related partners.

2.1.2. Our Third Party service providers include independent contracting doctors and their staff providing the Services to you, any service provider which hosts or manages data from InReste Products, credit, debit and charge card companies, banks or other entities processing payment instructions given by you or your authorised representative.

2.1.3. Your employer, medical provider(s), insurer(s), insurance agents(s) and/or other relevant parties who may assist with the registration with the relevant healthcare services and/or facilitate the processing of your payments and/or claims and/or utilisation of InReste Products and/or Services.

2.1.4. Government or regulatory authorities (including the Ministry of Health of Singapore), whether within or outside of Singapore, to the extent required in the normal course and scope of our business in the provision of our Services (including for the avoidance of doubt, claims tracking and processing of and facilitating the processing of claims for medical care and/or utilisation of healthcare and/or employee and/or insurance healthcare benefit needs), where required by applicable law, statute, stock exchange regulation or by-law, regulatory or governmental order or court order, and/or where we believe in good faith that disclosure is necessary to protect your safety or the safety of others, or our rights, or investigate fraud. We also reserve the right to disclose your personal data to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganisation, dissolution or other sale or transfer of some or all of InReste’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, where personal data maintained on InReste Products is among the assets transferred and/or any other person or organisation disclosed by us when you provide the information.

The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to your employment 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 a contract with you).

2.2. We may also disclose your anonymised data to data analytic platforms, technical support providers, and delivery service providers.

2.3. If you use or agree to the use of our delivery services to deliver your prescription, you authorise InReste to share basic identification and, where necessary, medical data with our delivery partner for the purposes of verifying your identification on collection of your prescription. InReste will take all reasonable steps to protect your personal data in accordance with this Privacy Policy.

‍3. Security
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‍3.1. Your privacy is important to us. We have put in place reasonable security arrangements (which shall at least be equivalent to industry standard practices) to protect your privacy and personal data, in such manner and to such extent as we deem reasonably appropriate in our sole discretion to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks. However, there is no such thing as “perfect security” and we do not guarantee in any way, and you should not expect, that your personal data or private communications will always remain private and/or safe from any abuse or misuse by third parties.

3.2. Your personal data to be used by InReste Products is stored on InReste’s servers located within its premises or those of its data service providers. We will use such procedural and technical safeguards as we deem reasonably necessary in our sole discretion to protect your privacy and protect your personal data against loss, theft and unauthorised access, collection, use, disclosure, copying, modification or disposal. We will also employ such security techniques deemed appropriate at our sole discretion, to reasonably protect data against loss, theft, and unauthorised access, collection, use, disclosure, copying, modification or disposal by users inside and outside InReste. If we transfer any data outside Singapore, we will take appropriate steps to ascertain whether, and ensure that, the recipient of your transferred personal data is bound by legally enforceable obligations to provide to the transferred personal data a standard of protection at least comparable to the Singapore Personal Data Protection Act 2012 (No. 26 of 2012). We will also transfer your personal data outside Singapore only if such transfer is necessary for the performance of a contractual obligation between InReste and you, or where such transfer is necessary to respond to a life-threatening or health-threatening emergency.

3.3. InReste’s employees are required, as a condition of their employment, to treat personal data held by InReste as confidential, and to maintain the confidentiality of that personal data.

3.4. As “perfect security” does not exist, each of InReste and its affiliates, related companies, and third party service providers and their respective officers, directors, employees and agents do not represent or warrant that there will not be, and hereby disclaim any responsibility or liability directly or indirectly arising out of or in connection with, any loss, theft, or unauthorised access, collection, use, disclosure, copying, modification, disposal or similar actions with regard to any data held or maintained by any of the aforesaid entities or persons. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.

3.5. This Privacy Policy applies only to information we collect through InReste Products and in email, text and other electronic communications set through or in connection with InReste Products. This policy does not apply to information collected by any third party. When you click on external links in InReste Products, you may leave our application and/or sites. We are not responsible for the privacy practices of other sites, and we encourage you to read their privacy statements.

‍4. Accessing and Updating your Personal Data
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‍4.1. If you wish to access, update or otherwise change or remove any personal data that you provide for InReste’s use, you may do within InReste Products on your own volition. In the event that you encounter any difficulty and/or require assistance, please send us an email at connect@inreste.com.

However, if you remove any personal data, which is necessary for us to provide you with Services, our provision of our Services to you may become impossible, impeded or deficient. 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 is required under applicable laws.

‍5. Withdrawing your Consent
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‍5.1. 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 collecting, using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to connect@inreste.com.

5.2. 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 ten (10) business days of receiving it.

5.3. 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.

5.4. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws. For the avoidance of doubt, such withdrawal of consent shall not require us to delete any personal data that has already been collected by us from our records.

‍6. Retention of Personal Data
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‍6.1. 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.

6.2. 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.

‍7. Changes to Privacy Policy
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‍7.1. InReste reserves the right to amend its prevailing Privacy Policy at any time by posting the amended Privacy Policy at any of the InReste Products.

‍8. Governing Law
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‍8.1. This Privacy Policy is governed by and shall by construed in accordance with Singapore law, without giving effect to any principles of conflicts of law. By accessing and/or using InReste Products and/or Services and providing personal data or information requested, you agree to submit to the exclusive jurisdiction of the Singapore courts.

If you have any further questions, please send us an email to connect@inreste.com.