Privacy and Data Protection (“Privacy Policy”)

This Privacy Policy describes the policies and procedures that apply to Adventage Group, which includes Adventage Pte Ltd, Adventage Care Pte Ltd, and Adventage Life Pte Ltd (“We”, or “Us” or the “Company”) in capturing and using Personal Data that may be provided by our clients, their family members, our employees, business partners or others (Collectively “You”) who access our web sites (“Sites”) or services (“Services”).

In so doing we are governed by Singapore law and specifically the Singapore Personal Data Protection Act (PDPA) as amended from time to time.

Please make sure you read and understand this Privacy Policy so that you know and understand the purposes for which we collect, use, and disclose your Personal Data.

By interacting with us, submitting information to us, signing up for or using our Services, accessing or using the Sites, you agree and consent to the Company and its representatives or agents collecting, using, disclosing and sharing amongst ourselves your Personal Data, and disclosing such Personal Data to our authorised service providers, principals, subsidiaries, affiliates, partners and relevant third parties in the manner set forth in this Privacy Policy. In our Sites, we may refer to consent if you submit a form, in which case we mean you consent to the terms and conditions of this Privacy Policy.

If you do not consent to this Privacy Policy, we will not be able to capture the necessary data and may not be able to provide you with our Services.

If you consent to this Privacy Policy and change your mind later, you may withdraw your consent. If you do so, we may not be able to provide or continue to provide relevant services. If you are at that time already in a contractual relationship with us, withdrawal of consent may mean you are in breach of contract and subject to legal action and damages.

This Privacy Policy is in addition to any other consents you may have previously provided to the Company 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.

We may from time to time update this Privacy Policy without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Privacy Policy was last updated. To the extent permitted by law, you agree to the prevailing terms of this Privacy Policy as updated from time to time on our Sites.

Personal Data

In this Privacy Policy, “Personal Data” refers to any 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 data in our records as may be updated from time to time.

Examples of such Personal Data you may provide to us include (depending on the nature of your interaction with us) your name, NRIC, passport or other identification number, telephone number(s), mailing address, email address and any other information relating to any individuals which you have provided us in any forms you may have submitted to us, or via other forms of interaction with you.

Personal Data may also include medical records such as diagnosis, medication, or medical history where we need it to provide services.

Basic Principles

Our policy is to always meet or exceed the requirements of the Singapore Personal Data Protection Act (PDPA), and we follow several principles in so doing:

• We only collect, process and store data lawfully and where we have a legitimate reason to do so.
• We collect and process data for specific stated purposes and will not use it for further purposes without your permission.
• We collect and retain only data that is needed for the stated purposes.
• We maintain appropriate standards of data quality and integrity, and we implement policies in respect of data accuracy, including taking steps to avoid data becoming out of date where appropriate.
• We store and process data securely.
• We retain data only as long as it is needed for the purpose collected, or as required by law.
• Where we need to share data with our partners or other third parties, we only share such data as is necessary, and require the partner to comply with standards at least as high as the PDPA.
• We only disclose data to governmental or judicial bodies, law enforcement or regulators to the extent required and allowed by law.
• Other than as set out in this Privacy Policy or where you have otherwise given your consent, all Personal Data provided to us will be kept confidential.

If you provide us with any Personal Data relating to another person, such as a family member, by submitting such information to us, you are warranting that you have a power of attorney, are a legal guardian, or have otherwise obtained the consent of the other person to provide us with their Personal Data for the stated purposes. You agree to indemnify us from any legal action or damages arising from provision of such Personal Data.

You must ensure that all Personal Data submitted to us is complete, accurate, true, and correct. Failure on your part to do so may result in our inability to provide you with the services you have requested.

When We Collect Personal Data

We may collect Personal Data which you voluntarily provide to us at the following times:

• When you use our electronic services or interact with us or use our services via our Sites or other electronic means.
• When you submit a form, including but not limited to application and registration forms, whether in paper or electronic form.
• When you enter into a contract or agreement or provide other documentation or information in respect of your interactions with us, or when you use or request for, or are referred for, our services.
• When you interact with our staff and care providers, via telephone calls (which may be recorded), mail, face-to-face meetings, email, or other electronic means such as SMS or Instant Messaging.
• When you request that we contact you or request that you be included in an email or other mailing list.
• When you submit an employment application or when you provide documents or information including your resume or CV in connection with any job opening.
• When you are contacted by, and respond to, our staff, nurses, doctors, agents, representatives and service partners.
• When you make payment or provide details to facilitate payment.
• When you submit your Personal Data to us for any other reason.

We may also from time to time collect your Personal Data that:

• You have chosen to make public, including via public online platforms (such as your social media or business networking profile)
• You have provided to third parties who are permitted to provide it to us (e.g., credit reference agencies; law enforcement authorities; etc.)

Use of “Cookies” and Analytics

When you simply browse our Sites, you generally do so anonymously, and we do not automatically collect Personal Data unless you provide such information.

We may however use “Cookies” for tracking certain anonymous statistical information for the purpose of analysing behaviour and preferences when you browse our Sites. We may from time-to-time work with analytics services from various providers, which will include the use of “Cookies”.

If you do provide Personal Data, we may combine this with tracking information and use analytics to understand your preferences and requirements.

Why we collect Personal Data and examples of what Data we collect?

We collect, use, and disclose Personal Data for necessary purposes including, but not limited to:

• Contact information such as name, email, phone, and address so we can respond to your inquiries, feedback, and requests.
• Information needed to verify your identity.
• Information needed for making or receiving payments.
• Managing our administrative and business operations
• Conducting surveys, research, and statistical analysis
• Detecting and preventing fraud, unlawful or improper activities
• Monitoring or recording interactions for quality assurance, employee training and performance evaluation
• Meeting or complying with any applicable rules, laws, regulations, codes of practice or guidelines.
• Protecting and enforcing our and your contractual and legal rights and obligations
• To promote relevant products or services to you from us or our partners
• To obtain information necessary to establish client and patient records and to commence treatment and care of the patient. This may include medical information such as diagnosis, medication and medical history depending on the nature of the services.
• To provide specialist services including medical services and advice, whether provided by us or our partners.
• To schedule and manage home care calls.
• To advise you of alternative service and treatment options
• To enable purchase of products, services, and consumables on your behalf
• To enable capture of information and specimens needed for diagnosis or provision of services.
• To send notifications to you, including relating to care issues
• To contact you, your relatives, caregivers, legal guardians for purposes for provision of services and for seeking consent from them in emergency situations
• To ensure health and safety of yourself, family members and staff of ourselves and our partners
• To manage referrals to and from other service providers including but not limited to providers of medical and other specialist services.
• Tracking and management of service quality, customer experience and satisfaction
• To administer and manage our relationship with you, including dealing with any requests or enquiries which you may have.
• To administer and manage the Services that you request to use.
• To contact you regarding any updates, events or publications related to our Services which may be of interest to you and/ or requested by you.
• Other purposes as permitted by applicable law or are reasonably required with your consent to provide our services.

How we disclose your Personal Data

Subject to the provisions of applicable law, Personal Data may be disclosed, for the purposes listed above, to the following entities or parties, whether they are located overseas or in Singapore:

• Healthcare partners, healthcare institutions and parties providing referrals of patients to us.
• Our service partners such as specialist service providers
• Caregivers, your appointed representatives, and legal guardians of patients
• Our banks and payments processors
• Our professional advisers such as accountants, consultants, auditors, and lawyers
• Relevant government agencies and regulators, where required by law or to be able to provide our services.
• Law enforcement agency, court, or any relevant party, to the extent necessary for the establishment, exercise, or defence of legal rights
• Any relevant party for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties
• Our franchisor, agents, franchisees and/or our affiliates or related corporations, and/or other relevant third parties
• If we sell or transfer all or any relevant portion of our business or assets (including in the event of a reorganization, dissolution, or liquidation), the relevant purchaser(s) and their authorised personnel.
• Third-party data processors (such as outsourced technology service providers, survey partners etc.) provided that such third-party processors will be subject to binding contractual obligations to (i) only process the Personal Data in accordance with our prior written instructions; and (ii) use measures to protect the confidentiality and security of the Personal Data; together with any additional requirements under applicable law.

Third Party Links

The Sites may contain links to third party websites whose data protection practices may differ from ours. We are not responsible for the content and privacy policies of these third-party websites, and we encourage you to consult their privacy policies before using the third-party websites.

Contact Information

If you have any question or feedback on this Privacy Policy, which to access or correct your Personal Data or wish to withdraw consent for our retention of your data please contact our Data Protection Officer at: compliance@adasilver.com.