Your privacy is important to Nervotec, and we do our best to ensure that you are aware of how we collect, use and disclose your Personal Data.
This Privacy Policy is incorporated in and forms part of the {Nervohealth End User Terms of Service} (the “Terms”) and applies to you if you use the Application. Except as otherwise defined, the capitalised terms in this Privacy Policy have the same meanings as those in the Terms.
Nervotec has adopted this Privacy Policy to inform you about how we handle your Personal Data derived from your use of the Application.
Please read this Privacy Policy carefully.
This Privacy Policy may be changed by us from time to time without any prior notice. You may determine if any such changes have taken place by referring to the “Last Updated” date on which this Privacy Policy was last updated. You are encouraged to check for any updates to this Privacy Policy prior to your use of the Application. Your continued use of the Application constitutes your acknowledgement and acceptance of this Privacy Policy as changed from time to time.
- GENERAL DEFINITIONS
- In this Privacy Policy, unless the context otherwise requires, the following general definitions apply:
- “Data Protection Laws” means applicable laws and regulations relating to the use and/or processing of personally identifiable information and data and privacy.
- “Personal Data” means:
- data, whether true or not, about an individual who can be identified:
- from that data; or
- from that data and other information to which we have or are likely to have access; and
- any data that is analogous to the foregoing, as defined in Data Protection Laws.
- data, whether true or not, about an individual who can be identified:
- “Purposes” means the purposes set out in this Privacy Policy.
- Unless the context otherwise requires, the rules of interpretation set out in the Terms shall apply to this Privacy Policy.
- In this Privacy Policy, unless the context otherwise requires, the following general definitions apply:
- HOW DO WE COLLECT YOUR PERSONAL DATA?
- We receive your Personal Data when you:
- download the Application;
- register for an Account; and
- use the Application (which includes accessing and using the Content or the Services).
- In connection with the Services, and to the extent permitted by applicable laws (including Data Protection Laws), we may also be collecting from sources other than yourself, your Personal Data, for one or more of the Purposes, and thereafter using, disclosing and/or processing such Personal Data for one or more of the Purposes. We may combine information we receive from other sources with information you give to us and information we collect about you. We may use this information and the combined information for the Purposes (depending on the types of information we receive). If you suspect that any of your Personal Data has not been lawfully disclosed to us, please contact us (details are set out at the end of this Privacy Policy).
- Unless otherwise stated, this Privacy Policy does not cover any collection, use or disclosure by third-parties, including through any applications, websites, products or services that we do not control or own.
- We receive your Personal Data when you:
- WHAT PERSONAL DATA DO WE COLLECT FROM YOU?
- In connection with your use of the Application, we may collect the following Personal Data from you:
- your personally information, including contact and registration information such as your name, your organisation’s name, email address and/or mobile phone number to make sure your account is completely personalised, as well as other information requested for your input on the Application, such as your birthdate and national identification number;
- vital signs derived from your use of the Application, such as: Heart Rate (BPM), Oxygen Saturation (SpO2%), Respiration (BPM), Stress level, Emotional state and HRV-SDNN (ms), and other calculated and related data to track and maintain your historical measurement data;
- your contact information, such as your mailing address, email address and telephone number;
- specific usage data from your use of the Application;
- technical information related to your use of the Application, such as IP addresses, browser information and mobile device information;
- if applicable, payment details in order to process payments for purchases made on the Application; and
- aggregated information such as statistical or usage data (note that such aggregated and statistical data may be derived from your Personal Data but is anonymised).
- Note on collection of your national identification number (e.g. NRIC): We are fully aware of the sensitive nature of your national identification number, and we only collect, use and disclose such information to the extent necessary under applicable laws and regulations, as well as in order to accurately establish and verify your identity to a high degree of fidelity. The reason for this is that your use of the Application relates to health information which may be used or delivered to healthcare institutions, and it is therefore essential to reduce the risk of misuse of the Application and the delivery of fraudulent data. Please refer to the sections below for further information on how we use, disclose and maintain your Personal Data.
- In connection with your use of the Application, we may collect the following Personal Data from you:
- HOW DO WE USE YOUR PERSONAL DATA?
- We may use your Personal Data for the following purposes:
- to facilitate and administer your use of the Application, including providing you with the Content and the Services;
- to administer and keep track of your Account, including verifying your information in connection with your use of the Application;
- to personalise your user experience on the Application;
- to monitor and analyse your use of the Application;
- to help you track your health information and wellness;
- to inform you of updates and announcements regarding the Application;
- to enforce the Terms, including managing our licenses,
- to comply with court orders and warrants, and assist law enforcement agencies, to collect debts, prevent fraud, misappropriation, infringements, identity thefts and any other misuse of the Application, and to take any action in any legal dispute or proceeding.
- to improve the Application; and/or
- to contact you with information in relation to your use of the Application, or at your request.
- We may also use your Personal Data to work with third-party service providers to facilitate the use of and administer the Application, or to provide other products or services in connection with the use of the Application (including tele-medicine service and digital certification service providers and platforms).
- We may collect, use, disclose or process your Personal Data for other purposes that do not appear in this Privacy Policy. However, we will notify you of such other purposes at or before the time of obtaining your consent, unless processing of your Personal Data without your consent is permitted by Data Protection Laws.
- We may use your Personal Data for the following purposes:
- HOW DO WE DISCLOSE YOUR PERSONAL DATA?
- We may need to disclose your Personal Data to third-parties, whether located within or outside Singapore, for one or more of the Purposes, as such third-parties, would be processing your Personal Data for one or more of the above Purposes. In this regard, you hereby acknowledge, agree and consent that we are permitted to disclose your Personal Data to such third-parties (whether located within or outside Singapore) for one or more of the above Purposes and for the said third-parties to subsequently collect, use, disclose and/or process your Personal Data for one or more of the above Purposes. Without limiting the generality of the foregoing, such third-parties include:
- any of our agents, contractors or third-party service providers that process or will be processing your Personal Data on our behalf including but not limited to those which provide administrative or other services to us;
- our professional advisers, for example, our auditors and lawyers, as well as our insurers;
- third-parties to whom disclosure by us is for one or more of the Purposes and such third-parties would in turn be collecting and processing your Personal Data for one or more of the Purposes; and
- any actual or proposed assignee or transferee of the business of Nervotec, or a merged entity in the event Nervotec is merged to create the said merged entity.
- Where we disclose your Personal Data, we will do so only in accordance with Data Protection Laws. This includes taking steps to ensure the security and privacy of your Personal Data, and where required, it will be subject to contractual terms ensuring the security and protection of any Personal Data under any sub-processor or data intermediary, whether within or outside of Singapore.
- We may need to disclose your Personal Data to third-parties, whether located within or outside Singapore, for one or more of the Purposes, as such third-parties, would be processing your Personal Data for one or more of the above Purposes. In this regard, you hereby acknowledge, agree and consent that we are permitted to disclose your Personal Data to such third-parties (whether located within or outside Singapore) for one or more of the above Purposes and for the said third-parties to subsequently collect, use, disclose and/or process your Personal Data for one or more of the above Purposes. Without limiting the generality of the foregoing, such third-parties include:
- HOW DO WE MAINTAIN YOUR PERSONAL DATA?
- Security of your Personal Data is important to us. We will put in place reasonable security arrangements to ensure that your Personal Data is adequately protected and secured. Appropriate security arrangements will be taken to prevent any unauthorised access, collection, use, disclosure, copying, modification, leakage, loss, damage and/or alteration of your Personal Data. However, we cannot assume responsibility for any unauthorised use of your Personal Data by third-parties which are wholly attributable to factors beyond our control.
- We will put in place measures such that your Personal Data in our possession or under our control is destroyed and/or anonymised as soon as it is reasonable to assume that (i) the purpose for which your Personal Data was collected is no longer being served by the retention of such Personal Data; and (ii) retention is no longer necessary for any other legal or business purposes.
- COOKIES
- We may also obtain information about your use of the Application through the use of ‘cookies’ which enable us to make certain parts of the Application easier to use and to improve the Application generally.
- A cookie is a small file which asks permission to be placed on your device’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular website or web-based application. Cookies allow web-based applications to respond to you as an individual. The website or web-based application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.
- We may use traffic log cookies to identify which pages are being used. This helps us analyse data about web-based traffic and improve the Application in order to tailor it to user needs. If we do use such cookies, we will only use this information for statistical analysis purposes and then the data is removed from the system thereafter.
- Overall, cookies help us provide you with a better Application, by enabling us to monitor which sections you find useful and which you do not. A cookie in no way gives us access to your device or any information about you, other than the data you choose to share with us.
- You can generally choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. However some cookies are essential and some websites or web-based applications won’t operate as expected without them and some features of the website or web-based application may not be available.
- WHERE YOU PROVIDE US WITH THIRD-PARTY PERSONAL DATA
- Should you provide us with Personal Data of any individual other than yourself, you represent, undertake and warrant to us that:
- for any Personal Data of individuals that you disclose to us, you would have prior to disclosing such Personal Data to us obtained consent from the individuals whose Personal Data are being disclosed, to:
- permit you to disclose the individuals’ Personal Data to us for the Purposes; and
- permit us to collect, use, disclose and/or process the individuals’ Personal Data for the Purposes;
- at our request, you will use such form(s) or document(s) provided by us in obtaining such consents from the individuals in question (for the avoidance of doubt, we are under no obligation to you to create any such form(s) or document(s));
- any Personal Data of individuals that you disclose to us are accurate; and
- for any Personal Data of individuals that you disclose to us, that you are validly acting on behalf of such individuals and that you have the authority of such individuals to provide their Personal Data to us and for us to collect, use, disclose and process such Personal Data for the Purposes.
- for any Personal Data of individuals that you disclose to us, you would have prior to disclosing such Personal Data to us obtained consent from the individuals whose Personal Data are being disclosed, to:
- Should you provide us with Personal Data of your child or children, you confirm, declare and agree that you are the parent and/or legal guardian of such child/children, and that we may collect, use and/or disclose your child’s or children’s Personal Data for the Purposes and in the manner as set out in this Privacy Policy.
- Should you provide us with Personal Data of any individual other than yourself, you represent, undertake and warrant to us that:
- THIRD-PARTY LINKS
The Application may contain links to third-party websites and applications whose data protection practices may differ from ours. We are not responsible for the content and privacy policies of these third-party websites and applications, and we encourage you to consult their privacy policies before accessing or using the third-party websites and applications.
- YOUR RIGHTS IN RESPECT OF YOUR PERSONAL DATA
- If you have any questions about the processing of your Personal Data or about this Privacy Policy, if you do not accept an amended Privacy Policy, if you wish to withdraw any consent you have given us at any time, or if you wish to update or have access to your Personal Data, you are welcome to contact us through the contact details listed at the end of this Privacy Policy.
- You have the right to access and/or correct any Personal Data that we hold about you, subject to exceptions under the law. This right can be exercised at any time by contacting us through the contact details listed at the end of this Privacy Policy. We will need enough information from you in order to ascertain your identity as well as the nature of your request, so as to be able to deal with your request. All requests for correction or for access to your Personal Data must be in writing. We will endeavour to respond to your request within 30 days, and if that is not possible, we will inform you of the time by which we will respond to you.
- We may be prevented by law from complying with any request that you may make. We may also decline any request that you may make if the law permits us to do so.
- In many circumstances, we need to use your Personal Data in order for us to enable your use of the Application. If you do not provide us with the required Personal Data, or if you do not accept an amended Privacy Policy or withdraw your consent to our use and/or disclosure of your Personal Data for the Purposes, it may not be possible for us to continue to enable your use of the Application.
- We may charge you a fee for responding to your request for access to your Personal Data which we hold, or for information about the ways in which we have (or may have) used your Personal Data. If a fee is to be charged, we will inform you of the amount beforehand and respond to your request after payment is received.
- We are fully committed to protecting your Personal Data and ensuring that you are able to enjoy all the rights granted to you in relation to your Personal Data under Data Protection Laws. Nothing in this Privacy Policy should be construed as limiting any of your rights prescribed for under Data Protection Laws.
- CONTACT US
If you have any questions about this Privacy Policy, or if you wish to access, update or correct your Personal Data or withdraw your consent to the use, collection and disclosure of your Personal Data in accordance with this Privacy Policy, please email us at support@nervotec.com.