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Privacy Statement

 

Sheares Healthcare Solutions Pte. Ltd., a wholly owned subsidiary of the Sheares Healthcare Group,  and its affiliates (collectively “Sheares Healthcare”, “we”,  “us” or “our”) are committed to protecting and respecting your personal data.
 
This Privacy Policy sets out the basis on which Sheares Healthcare will process personal data we collect from you, or that you provide to us. Please read the following carefully to understand Sheares Healthcare’s views and practices regarding your personal data and how we will treat it. By visiting our website, using the Ripple® app,  participating in the Ripple® Health Coaching Programme (“Programme”) and/or accessing our Programme content via other platforms, you are accepting and consenting to our practices described in this Privacy Policy.
 
Collection and processing of personal data
You can use and browse our website without having to disclose your personal data, except as may be necessary to allow us to respond to your requests or in cases where you contact us directly.
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We collect personal data and sensitive personal data only when you provide it to us, through registration, completion of forms, emails, enquiries and requests, communications with your Ripple® coach, use of the Ripple® app and similar situations in which you have chosen to provide the information to us or have consented to us collecting your personal data from another source, for example from your general medical practitioner, clinic or from outputs from your medical device(s). The information you give us may include, but is not limited to, your name, address, phone number, email, medical records, lifestyle, behaviours, diet, exercise habits and other medical details. We may record your audio and video conversations with your Ripple® coach for quality control and training purposes. 
 
If you choose not to provide such information, it may not be possible for us to respond to your request or enquiry or for you to participate in the Programme.
 
We will retain control of, and responsibility for, the use of any personal data you disclose to us. Such data shall remain in our possession, or that of data intermediaries acting on our behalf.

Purposes of use 
All personal data and other information collected (including behavioural data) may be used by us and may be combined with other information for the following purposes:

  • provision of the Programme Services:

    • assignment of a Ripple® coach;

    • lifestyle health assessment;

    • habit changing advice and coaching (coach guided or self guided using Ripple®’s proprietary content); 

    • development of a tailored lifestyle health programme (coach guided or self guided using Ripple®’s proprietary content); 

    • ongoing monitoring and coaching to achieve lifestyle health goals (coach guided or self guided using Ripple®’s proprietary content); and

    • ancillary services;

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  • responding to your enquiries or requests pursuant to your online queries, appointments, emails, telephone calls, and/or submission of form(s);

  • responding to your job application or your recruitment queries;

  • responding to and taking follow-up action on complaints;

  • performing office and operational administrative matters following your request;

  • improving our Programme services and content;

  • designing and creating new programmes;

  • data analytics, testing and research;

  • legal, compliance and risk management;

  • referring you to other specialised services; and

  • seeking feedback and comments on our business and operational matters.

 

IP Addresses
When you use our website, we may collect and store information about your computer (including your IP address, operating system and browser type) for system administration. This is statistical data about our users' browsing actions and patterns. This data could possibly lead to your identification, but we, and our data intermediaries, do not use it to do so unless permitted by law.
 
Cookies
Our website uses cookies to distinguish you from other users of our website by generally storing non-personally identifiable information (i.e. session information such as the number of times you visit our website and the location from which you are accessing the website). If you wish to disable cookies on your computer, you may do so by changing your browser settings. Please note that changing these settings may limit the functionality of some web pages or prevent them from loading properly.

Third party websites
Our website may, from time to time, contain links to and from third party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

Use of the Ripple® app

You will be provided with access to the Ripple® app as part of your participation in the Programme. You may access the Ripple® app to chat with and schedule appointments with your Ripple® coach, track your habits and activities, input your health data, review health data trends, complete lifestyle health assessments and access our Programme content.  We collect data in relation to usage of the Ripple® app to provide the Programme services to you and for the other Purposes of Use outlined under that heading above.

 

Please keep your login details for the Ripple® app confidential and change your passcode immediately if you consider there is a risk that the confidentiality of your passcode has become compromised.


Disclosure of your personal data

If you provide your consent by providing us with the name and contact details of your general medical practitioner, we will disclose your personal data to your general medical practitioner or clinic to support the delivery of our Programme Services and to assist your general medical practitioner or clinic to provide their services to you.  We may also disclose your personal data to any member of our group or to third parties such as our agents, advisers, service providers, data intermediaries and professional advisors in connection with the delivery of our Programme Services to you and for the Purposes of Use set out under that heading above. You hereby authorise us to transfer your personal data to such third parties, who will process your personal data in accordance with this Privacy Policy. Your personal data will not be disclosed to any further parties, unless we have obtained your consent or we are legally permitted or required to do so. If you provide an Emergency Contact we may contact that person and disclose your personal data as we consider necessary if we are unable to reach you and have an urgent concern regarding your health or safety.


Accuracy of your personal data

You agree that the personal data provided by you to us is current, accurate and complete in all respects. If there is any change to your personal data provided to us, you agree to inform us promptly.


Where we store your personal data
The data that we collect from you may be transferred to, and stored at, a destination outside Singapore. It may also be processed by staff operating outside Singapore who work for us or for one of our service providers or data intermediaries. By submitting your personal data, you agree to this transfer, storing and processing. We will take appropriate steps to ensure that your data is treated securely and in accordance with this Privacy Policy.
 
Security
We use technical and organisational security precautions to protect your data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risk. Our security procedures are continuously revised based on new technological developments. However, while we use commercially reasonable endeavours to ensure the security of your personal data, there are inherent risks associated with electronic information (including use of mobile or web-based applications and transmission of data by internet or otherwise), and you understand and agree that we cannot guarantee the security, integrity or freedom from error or infection of the Ripple® app, any electronic communications or information sent or received by you.
 
Data retention
We retain your personal data for as long as necessary for the fulfilment of the purposes for which it was collected or to which you have given your consent, except where otherwise provided for by applicable laws, regulations or medical guidelines.
 
Right to withdraw consent, request access to, and correction of personal data
You have the right to withdraw consent, request access to, and correction of personal data that we hold about you in accordance with applicable laws.
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All requests for the withdrawal of consent, access to, or correction of personal data held by us should be made by contacting dpo@sheareshealthcare.com.sg
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Please note that under applicable law, we are not required to correct or otherwise alter any professional or expert opinion. We may also be required and/or entitled to retain your personal data under applicable laws or regulations notwithstanding the withdrawal of your consent.

Changes to our privacy policy
This Privacy Policy may be amended, supplemented, modified and updated from time to time. Please visit www.ripple.sg/privacy-policy to view our current Privacy Policy.
 
Contact
Questions, comments, complaints and requests regarding your personal data or this Privacy Policy should be addressed to dpo@sheareshealthcare.com.sg.
 
Complaints procedure
We are committed to managing personal data in compliance with the Personal Data Protection Act (“PDPA”). This section sets out how we manage complaints on personal data protection.


​Complaints related to PDPA can include:

  1. Collection, use or disclosure of personal data without valid consent

  2. Misuse of personal data

  3. Failure to correct personal data on request

  4. Failure to provide access to personal data on request

  5. Loss or exposure of personal data
     

We will ensure that rights afforded to individuals under the PDPA are protected. If you have a complaint, please contact our Data Protection Officer at dpo@sheareshealthcare.com.sg. To help us process your complaint, please provide us with: 

  • Your full name

  • Your contact details

  • Name of the officer and corporation that collected, used or disclosed the relevant personal data

  • Date and timing of the incident

  • Details of the incident

  • Any relevant supporting documentation
     

Once we receive your complaint, our Data Protection Officer will provide you with a written notification of acknowledgement, together with an estimate of our response time (which will depend on the nature of the investigation and the availability of information provided to us to adequately carry out such investigation). We will use reasonable endeavours to respond as promptly as possible. If we cannot respond within the estimated time initially informed to you, we will contact you to advise you on the additional time needed.
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Upon conclusion of our investigation, you will be notified in writing on the outcome. If you are not satisfied with the outcome of your appeal, you may take the matter to the Personal Data Protection Commission.

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