MIMS recognizes the importance of protecting the Personal Data collected from you in the operation of this Site, and take reasonable steps to maintain the security, integrity and privacy of any information in accordance with this Policy.
i. This Policy statement provides information on the obligation and policies of MIMS in respect of your Personal Data. MIMS undertakes to use reasonable efforts in applying, where practicable, those principles and the processes set out herein to its operations.
ii. MIMS officers, management, and members of staff shall use reasonable endeavours to respect the confidentiality of and keep safe any and all Personal Data collected and/or stored and/or disclosed and/or used for, or on behalf of, MIMS. MIMS shall use reasonable endeavours to ensure that all collection and/or storage and/or disclosure and/or usage of Personal Data by MIMS shall be done in an appropriate manner and in accordance with the Singapore Personal Data Protection Act 2012 (“Act”) and this Policy.
iii. By interacting with us, submitting information to us, you agree and consent to MIMS as well as to its respective representatives and/or agents (“Representatives”) collecting, using, disclosing and sharing amongst themselves your Personal Data, and disclosing such Personal Data to MIMS’s authorized service providers and relevant third parties in the manner set forth in this Policy.
iv. This Policy supplements but does not supersede nor replace any other consents you may have previously provided to us in respect of your Personal Data, and your consents herein are additional to any rights which we may have at law to collect, use or disclose your Personal Data.
v. For the purposes of this Policy, in line with the provisions under the Act, “Personal Data” shall mean data, whether true or not, about an individual customer who can be identified – from that data; or from that data and other information which an organization has or is likely to have access. Such Personal Data shall also refer to that which is already in the possession of MIMS or that which shall be collected by MIMS in the future.
2. CONTACTING THE DATA PROTECTION OFFICER
i. Where you legitimately request access to and/or correction of Personal Data relating to you, such Personal Data which is in the possession and control of MIMS, MIMS shall provide and/or correct that data in a reasonable time and manner in accordance with its standard procedures as stated hereinafter.
ii. In accordance with the Act, MIMS has established a process for receiving and responding to any query or complaint that may arise with respect to the application of this Act. To ensure that MIMS receives your complaints and enquiries regarding Personal Data, please send the name via email to any of our Data Protection Officer (“DPO”) at email@example.com
iii. Should you not wish MIMS to use your Personal Data for any of the purposes listed in Section 3(ii) to 3(iii), you may opt out by sending a clearly worded email to the DPO via the email address in Section 2(ii). Your request shall be processed within a reasonable time.
3. STATEMENT OF PRACTICES
i. Types of Personal Data Collected
MIMS may collect from you, through various means, including via our Site, whether accessed by mobile phone, tablet, or other devices, some or all the following Personal Data (as and when if required):
• Name (first and surname);
• Email address and subscription preferences when you sign up to our email alerts;
• Phone number (including mobile);
• Internet Protocol (IP) address; and/or
• Information on how you use the Site, using cookies and page tagging techniques.
ii Purpose of Collection of Personal Data and Information
• To operate, improve, personalise the Site;
• Communicate with Users regarding Site updates;
• Information related to the Site;
• Coordination with third party institutions (Ministry of Health, and the like);
• For system administration and to report aggregated statistical information about browsing patterns and actions which do not identify any individual;
• To administer the Site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
(b) In addition to the above, the Personal Data or information may be collected in the following means:
• Information related to Users: MIMS may also collect any generated content that you may upload to the Site (“User-Generated Content” or “UGC”).
• Advertisers: MIMS does not control the practices of the advertisers on their sites. When you click on links and/or ad banners that take you away from our Site to third-party websites, you will be subject to that party’s privacy policies.
• Information related to the status of use: MIMS will collect information related to the devices you use for accessing the Site as well as information from such devices. This includes IP address, type of browser and device, web pages that you visited prior to accessing the Site, and personal identification information related to the devices being used. Furthermore, there may be cases where the devices being used (depending on the setting) may transmit position information to the Site.
4. DISCLOSURE OF PERSONAL DATA:
i. MIMS may disclose your Personal Data to the following third parties:
• Relevant authorities;
• Regulators and law enforcement officials;
• Third Party service providers and consultants;
• Credit, debit and charge card companies, banks and other entities processing payment;
• Potential buyers or investors of MIMS; and/or
• Any online/offline data storage facility provider working with MIMS
ii. MIMS may also in certain cases, share Personal Data with others as described below.
• Third parties in partnership or contractual relationship with MIMS: MIMS has partnered and concluded contracts with third parties for attaining the purposes described in this Policy. There may be cases where information acquired through the Site is shared with such third parties.
• Advertisers: When you are exposed to an advertisement through the Site, MIMS may provide your Personal Data (such as name, specialty, and country of residence) and information about your engagement with the Site (e.g., whether you viewed, interacted with or requested information about promotional content) to advertisers and their agents or potential advertisers and their agents.
However, we will NEVER provide these Advertisers with your personal contact information such as email, phone number or mailing address without your consent.
• MIMS’s affiliates: There may be cases where information acquired through the Site is shared with MIMS’s affiliates for attaining the purposes described in this Policy. Furthermore, if MIMS is involved in corporate reorganization, merger, acquisition, asset sales or the like, there may be cases where information acquired through this Site is transferred or shared as a part of such involvement.
5. POSSIBILITY OF DISCLOSURE OF INFORMATION
MIMS may disclose your Personal Data to a third party;
• To the extent that MIMS is required to do so by the law;
• In connection with any legal proceedings or prospective legal proceedings;
• To establish, exercise or defend MIMS legal rights;
• To the purchaser (or prospective purchaser) of any business or asset which MIMS is (or is contemplating) selling;
• To any person and/or entity for the purpose of processing such information on MIMS behalf;
• To prevent and/or protect a person from death or serious bodily injury;
• With your consent; or
• For the purposes of disaster recovery.
6. TRANSFER OF PERSONAL DATA OVERSEAS
Your Personal Data may be processed by MIMS, its affiliates, agents and third parties providing services to MIMS, in jurisdictions outside of your country where data privacy laws in these countries may differ from the Act. For example, information collected within the European Economic Area (“EEA”) may be transferred, stored, and processed outside of the EEA for the purposes described in this Policy. Where we transfer store, and process your Personal Data outside of the EEA we have ensured that appropriate safeguards are in place to ensure an adequate level of data protection.
7. ACCURACY OF PERSONAL DATA
Where possible, MIMS will validate data provided using generally accepted practices and guidelines. In some instances, MIMS is able to validate the data provided against pre-existing data held by MIMS. In some cases, MIMS is required to see original documentation before we may use the Personal Data. To assist in ensuring the accuracy of your Personal Data in the possession of MIMS, please inform us of any updates of any parts of your Personal Data by sending a clearly worded email to the DPO at the email address provided at Section 2(ii).
8. PROTECTION OF PERSONAL DATA
MIMS uses commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of your Personal Data and will not knowingly allow access to this data to anyone outside of MIMS, other to you or as described in this Policy. However, MIMS cannot ensure or warrant that such information may not be accessed, altered, collected, copied, destroyed, disposed of, disclosed or modified by breach of any MIMS’s physical, technical, or managerial safeguards.
9. ACCESS, RETENTION AND CORRECTION OF PERSONAL DATA
i. Under this Policy, you have the right to:
• Check whether MIMS holds any Personal Data relating to you and, if so, obtain copies of such data; and
• require MIMS to correct or amend any Personal Data relating to you which is inaccurate for the purpose for which it is being used.
• Removing or deleting your Personal Data that you do not wish MIMS to retain;
• Withdrawing your consent; or
• Raising enquiries or filing complaints of the use of your Personal Data.
ii. MIMS reserves the right to charge a reasonable administrative fee in order to meet your requests under Section 9(i) above. Upon payment of the requisite fee, your request shall be processed within a reasonable time.
iii. If you wish to verify the details you have submitted to MIMS or if you wish to check on the manner in which MIMS uses and processes your Personal Data, MIMS’s security procedures mean that MIMS may request proof of identity before we reveal information. This proof of identity will take the form of full details of name and NRIC, Passport or FIN number. You must therefore keep this information safe as you will be responsible for any action which MIMS takes in response to a request from someone using your details.
10. STORAGE AND RETENTION OF PERSONAL DATA
To the extent necessary for achieving the purposes described in this Policy, MIMS will retain your Personal Data.
If you request the deletion of your Personal Data, MIMS will delete as requested. However, in the foregoing case, please take note of the following points:
• it may take some time to delete your Personal Data from the MIMS server and its backup storage;
• MIMS may in certain cases retain your Personal Data due to legal obligations, for dispute resolution, or upon enforcement of the written consent regarding MIMS; and
• MIMS may anonymize Personal Data and permanently retain the same for the purpose of research, and the like.
11. CONTACTING YOU
MIMS reserve the right to modify this Policy at any time in compliance with local legislation and/or to meet its global policy requirements, and for any other purpose deemed reasonably necessary by MIMS. If we make changes to this Policy, we will post the revised Policy on this Site and update the “Last Updated” date at the top of this Policy.
13. GOVERNING LAW
This Policy is governed by and shall be construed in accordance with the laws of Singapore. All disputes, arguments or disagreements arising out of or in connection with this Policy shall be referred to and finally resolved by arbitration in the Republic of Singapore in accordance with the arbitration rules of the Singapore International Arbitration Centre. The arbitration proceedings shall be in English, and the number of arbitrators shall be one (1) arbitrator.