Privacy Policy

Your privacy is very important to us. This Privacy Policy describes how our services handle and secure information they collect.

Introduction

Your privacy is very important to us. This Privacy Policy (this “Policy”) is issued by Sqrdots Pte Ltd.on behalf of itself and its related corporations (collectively “our”, “us”, “we”, or “Klinify”). This Policy describes how we process your personal information. This Privacy Policy is part of, and incorporated into, the Terms of Use for any services we provide or made available to you (“Services”); or (ii)any user agreement entered into between you and us for any of our Services (if relevant). Because such Terms of Use and your User Agreement (if any) include subjects that may not be covered in this Policy, and may narrow or modify the scope of our use of information under this Policy, please review such other agreements carefully.  This Policy serves to inform you that your personal information is being processed by us and/or our related corporations and you hereby give your consent to the processing of your personal information.

Information Collected by our Services

INFORMATION YOU SUBMIT/SOURCE OF PERSONAL DATA:

Your personal information is being or is to be collected from a variety of sources, including without limitation:

When you submit information by: (i) Typing-in data (such as when you register for our Services, or type a message to send to us or another user, or type a search request, or complete an optional form); or (ii) Uploading a document, image or other data file;
When you authorise us to retrieve and import information from another user or other third party on your behalf;
When you use our Services;
From all other communications between you and us and all other information that you may provide us from time to time;
From any information submitted or provided by you to us for any of the Purposes (as defined below in the section titled “How information is used”); and/or
When you contact us through various methods such as telephone call and/or emails.

Engagement Tools and Data:

Our Services also gather information whenever you visit, log in or otherwise interact with them. As with other websites and interactive services, whenever you interact with our Services, your computer, mobile phone or tablet (a “Device”) and its software transmits a “request” to us. That request includes non-personal information received from your Device (and its software) necessary for us to identify and appropriately route the information your Device is requesting. These “requests” and “replies” are the backbone of all websites and Internet services. Therefore, whenever you carry out any of the following activities your device and its software are sending non-personal information to us:

Visit and navigate through our Services
Click on a link
Open a webpage or web form
Open a web-enabled email sent by us
Post a comment or question on a blog or user forum
Send a message via our interactive chat or instant message feature
Otherwise take an action or interact with elements of our Services or its pages, content or features

In addition to managing the appropriate routing of information, we use so-called “cookies,” “web beacons,” “server logs” and other Engagement Tools to enhance the quality of the service and content you receive. For example, we use Engagement Tools to:

Save user preferences;
Preserve session settings and activity;
Help authenticate users;
Allow users to auto-fill sign-in pages of websites they frequently visit;
Tailor the delivery of ads and other content; and
Analyze the performance of our Services and its various features and content.

Therefore, even if you do not register with us or submit any personal information on our Services, our Engagement Tools automatically receive information about your Device and the software running on it. We call such data “Engagement Data.” Engagement Data often includes elements such as the date and time a “request” is made, the model of the Device making the “request,” the type and version of operating system running on a Device (e.g., Mac OS or Microsoft Windows), the browser making the request (e.g., Internet Explorer, Chrome or Firefox), routing information, IP address, the Device’s geographic location, search terms a user enters, what URL a Device most recently visited, and, if a mobile application is used, an anonymous unique number. Engagement Data generally does not personally identify a Device’s user. However, it can be combined with personal information. If so, we treat such combined information the same way we treat personal information. Additionally, in the event that our Engagement Tools collect data elements that contain personal information, we treat those data elements as personal information. You have the ability to control how certain Engagement Tools operate by modifying the settings on your Device or its software. Most browsers, for example, allow you to refuse accepting cookies, and many mobile Devices allow you to disable the sending of location information. In some cases, doing these things could diminish the performance of our Services or render them inoperable. We do not respond to browser-based “do not track” signals. To learn more about Engagement Tools and how we use Engagement Data please see our Engagement Tools page and the section below entitled “How Information is Used.”

Third Party Tools:

We work with certain third parties who deploy their own engagement tools on our Services. In some instances they do so exclusively on our behalf. In other instances, they may retain and use the data they collect pursuant to their privacy policies. These Third Party Tools are frequently deployed by companies providing online advertising services or analytics, but they may be deployed in other contexts as well, such as social media plug-ins. We treat personal and non-personal information that we receive from these Third Party Tools the same way we treat personal and non-personal information that we directly collect from our Services. We, however, do not control how these third parties manage the information they gather. Please see our Third Party Tools for more information. In the event that you provide your personal information to any of the Third Party Tools providers, you grant your consent for us to use your personal information in accordance with this Policy.

Personal and Non-Personal Information:

We may collect a variety of your personal information including but not limited to your name, e-mail address, contact number and/or other personal information which is submitted or made available by you to us and all other personal information we again collect from you on any subsequent occasion. Information you submit to us that identifies you or can be used to contact you (e.g., email or mailing address) is your “personal information.” This includes identifiers that a governmental authority, financial institution or insurance carrier may use to uniquely identify you (e.g., a Identity number, credit card or ACH account number). When we combine non-personal information with personal information, or non-personal information with other non-personal information in a way that renders the combined information personal information, we treat that combined information the same way we treat personal information. When we combine personal information with information from third party sources, we also treat that combined information the same way we treat personal information.

How Information is Used

WE USE PERSONAL AND NON-PERSONAL INFORMATION (INCLUDING ENGAGEMENT DATA) FOR THE FOLLOWING PURPOSES:

Performing our pre-contractual and contractual obligations with you;
Operating, maintaining, managing and administering our Services, including processing registrations and payments, and providing customer support;
Providing you with the services which may be provided or made available by us to you from time to time through our website or other relevant online platform (Klinify);
Responding to questions and communications, which we retain in the ordinary course of business;
Administrative announcements about features, functionality, terms or other aspects of our Services; and, if applicable, informing you about offers for services or products we believe may be of interest (for further information, see also “Service Emails and other Communications” below);
Safeguarding and protecting our Services, the information they safeguard, the rights of third parties and in response to legal process, in each case, as more fully described below in “The Importance of Protecting our Services and the Information they Safeguard;”
Resolving any disputes (between users of our Services and/or between you and us);
Complying with any legal or regulatory requirements and preventing or investigating any fraudulent or criminal activities; and
Any other purpose described in this Policy or your User Agreement. (Collectively, the “Purposes”.)

We use non-personal information for the following purposes:

Auditing, research, measurement and analysis in order to maintain, administer, enhance and protect our Services, including analyzing usage trends and patterns and measuring the effectiveness of content, advertising, features or services;
Creating new features and services;
Contextual and cookie-based automated content delivery, such as tailored ads or search results;
Health and medical research; public health and service activities; healthcare- and medical-related services; and
Other purposes described in this Policy or your User Agreement.

We may also use non-personal information to prepare aggregate reports for current or future advertisers, sponsors or other partners to show trends about the general use of our Services. Such reports may include anonymised data such as age, gender, geographic, demographic or other general user information, but do not include personal information.

Consents and Authorizations:

It is obligatory that you supply us the details marked with asterisk (*) during the registration or singing-up process (collectively, “compulsory personal information”). If you fail to supply us the compulsory personal information, we may refuse to process your personal information for any of the Purposes and/or result in us being unable to provide you with the services and/or products requested. From time to time, we may request your consent or authorization (your “consent”) in connection with the use or sharing of your information. In some instances, this will be because your User Agreement, this Policy or applicable law or regulations requires us to obtain such consent. In other instances, such consent will be for informational purposes. In the latter case, the request to obtain your consent should not be interpreted as narrowing the scope or applicability of your User Agreement or this Policy – by entering into your User Agreement or using the applicable Services, you have accepted and agreed to our information handling practices in the manner described in your User Agreement and this Policy.

In cases where you consent or “opt-in” to the use or sharing of your personal information, you will have the ability to rescind your consent and “opt-out” of our use or sharing of such information in the future. You have the right to contact us with any inquiries or complaints in respect of your personal information (including the possible choices and means for limiting the processing of your personal information or to cease or not begin processing your personal information for purposes of direct marketing) by contacting us through the details below. In that event, we will refrain from further use or sharing of such information, but we may not be able to require the removal of such information from the databases of the recipients with whom such information has been shared.

Contact Details:

Designation: Celestine Tham
Email Address: celestine@klinify.com

Directories and Location Tools:

If you are a healthcare provider or healthcare-related service provider who has entered into a User Agreement with us, your contact and directory information may be listed in one or more of our public and professional directories. These directories include profile information (e.g., contact, specialty and other information) and other features that allow users to locate and contact you. If you are a healthcare service provider who is a user of our Klinify software, you shall be solely responsible for procuring and maintaining all necessary consents and approvals (statutory, contractual or otherwise) for us to process any third party personal information provided by you to us on your behalf for any or all of the Purposes. You shall be solely responsible for any unauthorised disclosure or use of such third party’s information by you. We merely process the relevant third party personal information provided or made available by you to us on your behalf for the Purposes.

One-on-One Communications:

Our Services can be used to facilitate one-on-one communications between users. Examples include:

Sending an appointment or other reminder to another user;
Making a referral;
Sending a prescription to a pharmacy; or
Sending a test requisition to a clinical laboratory.

In any one-on-one communication, users are sending information to one another. Depending on the message, this could include contact and other personal information. See also “Service Emails and other Communication” below.

SERVICE EMAILS AND OTHER COMMUNICATIONS

Our Services allow users to communicate with others through our in-product instant messaging services, Service-branded emails, SMS and other electronic communication channels. Communications that are sent by or on behalf of a user are indicated as being “From” that user. Communications that are sent by us are indicated as being from us or one of our account or support specialists assigned to assist you. Either type of communications may be “real time” communications or communications triggered automatically upon the occurrence of certain events or dates – such as a repeated sign-in failure, an appointment reminder and the like.

Messages may be sent to you about upcoming features /surveys and the engagement rates will be tracked by us. Where applicable, we may send messages to your customers or other third parties on your behalf upon your authorisation. Responses rates in respect of the messages sent will be tracked by us.

Our Services may deploy Engagement Tools (such as “cookies,” “web beacons” and “server logs”) on outbound emails to users and others to collect Engagement Data, and we may use vendors to assist us in sending outbound emails to users who may deploy Third Party Tools.

We will not share personal information you submit except under the following circumstances:

When you choose to share such information through our Services. Under certain circumstances this may require a specialized consent before our Services complete certain such transmissions;
When you are otherwise notified at the time we collect such information or we otherwise have your express consent;
When your account has been issued by an account administrator with administrative rights over your account, your account administrator will have access to your account information, including your personal information. Your account administrator may: (i) receive and retain your account information, (ii) change your account password, (iii) restrict your ability to submit, delete or edit information; (iv) suspend or terminate your account access, or (v) access or retain information you submit or otherwise stored as part of your account for any purposes required or permitted under applicable law;
We share such information with our current and future affiliates, our financial and professional advisors, banks, governmental departments and/or agencies, regulatory and/or statutory bodies and any such third party requested or authorized by you for any of the Purposes;
We share such information with trusted business partners and/or service providers operating on our behalf consistent with the terms of this Policy and your User Agreement. Such business partners and/or service providers will be bound by appropriate confidentiality and security obligations, which may include, as applicable, business associate contract obligations. We will not sell, rent or trade your personal information with any third parties for their promotional or marketing purposes;
When we protect our Services, the information they safeguard, the rights of third parties and in response to legal process, as more fully described below in “The Importance of Protecting our Services and the Information they Safeguard;”
In connection with a sale, merger, transfer, exchange, reorganization or other disposition (whether of assets, stock, or otherwise) of all or a portion of the business conducted by the services to which this Privacy applies. If such a transaction occurs, the acquiring/restructured company’s use of your personal information will remain subject to this Policy; and/or
Any other purposes described in this Policy or your User Agreement.

THE IMPORTANCE OF PROTECTING OUR SERVICES AND THE INFORMATION THEY SAFEGUARD

Many of our Services are protected by technical measures intended to safeguard the confidentiality, integrity and accessibility of sensitive information our users store and share on our Services. Further, certain regulations require us to investigate potential or suspected threats on our Services or the confidentiality, integrity or availability of the information they safeguard. Accordingly, we may preserve, use and disclose information – including personal and non-personal information – when we have a good faith belief it is necessary or advisable to:

Detect, prevent and address potential or suspected: threats on our Services or the confidentiality, integrity or availability of any information they house; fraud and other illegal activity; or violations of our User Agreements or Terms of Use; and
To protect ourselves, you and third parties. We may also preserve, use and disclose such information in response to a search warrant, court order, subpoena, judicial proceeding or other legal process if we have a good faith belief that the law requires us to do so. Such legal process may prohibit us from notifying the users or other individuals or entities identified by such information or take such other actions as would otherwise be a violation of your User Agreement or this Policy. When we preserve information pursuant to this section, it may be for extended periods of time, as we in good faith believe are necessary or appropriate under the circumstances, and may include the preservation of information from accounts that have been disabled.
Please note that Klinify is not required to state in this Policy the security policies or measures taken by Klinify.

CHILDREN UNDER 18

Our Services are not intended for or designed to attract children under the age of 18. If we collect personal information of children under the age of 18, we will take steps to check that such data is obtained with the consent of their parents, guardians, or persons who has parental responsibility of the child. If you become aware that your child or ward has provided us with personal information without your consent, please contact us immediately at the contact information below.

TRANSFER OF PERSONAL DATA TO A PLACE OUTSIDE MALAYSIA

We may transfer your personal information and any personal information made available by you to us in connection with the Purposes to a place outside Malaysia and you hereby give your consent to, and warrant that you have procured all the necessary consents and approvals for, such transfer.

THIRD PARTY SERVICES

This Policy applies only to our Services. It does not apply to services offered by third parties, including websites and other online services that our Services may display links to or advertisements for. When you click on such links or advertisements, you will be visiting websites or interactive services operated by third parties, who have their own information collection practices and may also collect information through the use of tracking tools, such as cookies, web beacons, server logs and the like. When you click on or interact with an ad appearing in our Services, the advertiser or sponsor may infer that you meet targeting criteria that they may have used in connection with the sponsoring such ad. This may lead to similar ads being targeted to you on our Services or elsewhere. We do not have control over how any third party gathers or uses information, so you should review their privacy policies to learn of their information gathering and handling practices.

CHANGES TO THIS POLICY

We work hard to continuously improve and enhance our Services. Some of these improvements and enhancements may result in changes to this Policy. We will post such changes along with their effective date on this page, and if the changes are significant, we will provide a more prominent notice. Because our Policy can change at any time, we encourage you to reread it periodically to see if there have been any changes that affect you. If you disagree with any changes to this Policy and do not wish your information to be subject to the revised Policy, you will need to deactivate your account before the new Policy becomes effective. Your use of our Services following any such change constitutes your agreement that all information collected from or about you through our Services after the revised Policy is posted will be subject to the terms of the revised Policy.

VIEWING, UPDATING AND DEACTIVATING INFORMATION

Our Services aim to provide you with access to the personal information you submit and the means to update it. You are responsible for ensuring that the information you provide us is accurate, complete, not misleading and kept up to date. You have the right to request access to and to request correction of your personal information by contacting us through the details set out above. Subject to provisions of the Malaysian Personal Data Protection Act 2010,

(a) you may, upon payment of a prescribed fee, make a data access or correction request in writing to us; and
(b) we may refuse to comply with a data access request or a data correction request and shall, by notice in writing, inform you of our refusal and the reasons of our refusal.

This can be accomplished by logging into our Services or contacting us using the contact information provided to you by us herein. Under certain circumstances, we may ask you to verify your identity before your request is processed. This will be done free of charge except where it would require a disproportionate effort.

If you desire to deactivate your account please contact us. Upon your request, your account will be deactivated and your personal information and Records will be securely archived. We retain archived information for a period of five years (or longer if required by law) as necessary to comply with legal obligations, resolve disputes and enforce our agreements and other authorized uses under this Policy.

Please note that, unless you are an administrator who has administrative rights over another user’s account pursuant to a Healthcare Provider User Agreement, you are not entitled to review the content of another user’s account. Accordingly, if you have used our Services to share personal information with another user or other party, you will not be able to access, update or delete that shared information pursuant to this Policy or your User Agreement. Please also note that other users may submit personal information that identifies you. In either case, certain users – such as healthcare providers – may be required under HIPAA and other applicable laws or regulations to retain such information for extended periods of time. This means that until our User Agreement with such user(s) terminate(s), we will continue to retain such information on their behalf.

You should also be aware that we store indefinitely non-personal information, including Engagement Data and de-identified health information, as well as all information that you have share on any of our public forums, blogs, communities, surveys and the like.

Thank you for taking the time to read through and understand Klinify’s Privacy Policy.