We at Respiree Pte Ltd take your personal data and privacy seriously.
References to “you” or “your” are to you as an individual using our website or otherwise contacting us (whether on behalf of yourself, or another individual, or organisation).
Our Platform is not intended for children and we do not knowingly collect data relating to children.
Third party links
(2) IMPORTANT INFORMATION ABOUT US
Where we process your personal data because you use our Platform or services as a result of your relationship with a customer who we supply our services to, we are not the data controller as we would be processing personal data on behalf of our customer as a data processor.
Full name of legal entity: Respiree Pte Ltd Email address: firstname.lastname@example.org
Postal address: 176 Orchard Road #05-05, The Centrepoint, Singapore 238843
(3) THE PERSONAL DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
– Identity Data includes first name, last name, username or similar identifier, marital status, title, job title, date of birth and gender.
– Contact Data includes billing address, email address and telephone numbers.
– Financial Data includes bank account and payment card details.
– Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
– Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our Platform.
– Profile Data includes your username and password, purchases or orders made by you (including the time and place of your orders), your interests, preferences, feedback and survey responses.
– Usage Data includes information about how you use our Platform or services.
– Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
– Special Categories of Personal Data includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data.
We may collect Special Categories of Personal Data about you so we can provide you with personalised health insights (including physiology and cognitive health metrics) through our Platform and otherwise effectively deliver our services to you. In particular, we may collect and process information relating to your physical and mental health, medical history, past diagnosis, on-going diagnosis if any, medical and health-related symptoms and questionnaires and any other lifestyle data (e.g., questionnaires on how you feel, any symptoms).
Special Categories of Personal Data are subject to special protections under the UK and/or EU data protection regime (as applicable). We will only process Special Categories of Personal Data in accordance with specific lawful processing basis and processing conditions as permitted by data the UK and/or EU data protection regime (as applicable). Please see the ‘How we use your personal data’ section below for further information.
If you choose to provide us with Special Categories of Personal Data through your use of our Platform in circumstances where we do not ask for it, you are giving us your explicit consent to process such data about you to the extent permitted by the UK and/or EU data protection regime (as applicable).
If you are providing us with Special Categories of Personal Data about persons other than yourself, you must obtain each of their explicit written consent for us to process their data. Their explicit written consent which you obtain must be supplied to us if so requested. If a person does not give explicit consent to our processing their Special Categories of Personal Data, then such data should not be supplied to us.
We do not ask you for any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
(4) HOW YOUR PERSONAL DATA IS COLLECTED
We use different methods to collect data from and about you including through:
– Direct interactions. You may give us your Identity, Contact, Financial and Special Category Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
(a) access or use our Platform;
(b) create an account on our Platform;
(c) subscribe to our mailing lists or newsletters;
(d) request to place an order for our products or services;
(e) participate in any promotion, activity, campaign or survey;
(f) give us feedback or contact us;
(g) log into your account or otherwise interact with us via an external service or application; or
(h) use our sensors and gateway systems (which may be connected to the world-wide web)
– Third parties or publicly available sources. We may receive personal data about you from various third parties (including public sources) worldwide (who may be based outside Singapore, the UK, and/or the European Economic Area (“EEA”) as applicable) as set out below:
(a) Technical Data from parties such as:
(i) analytics providers;
(ii) search information providers; and
(iii) advertising networks.
(b) Contact, Financial and Transaction Data from providers of technical and payment services.
(c) Identity and Contact Data from data brokers or aggregators.
(d) Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the UK.
(e) Identity, Contact, Financial and Special Category Data from our mobile phones and web-dashboards.
(5) HOW WE USE YOUR PERSONAL DATA
Our lawful bases
We will only use your personal data when the law allows us to. The types of lawful bases that we most commonly rely on to process your personal data are as follows:
– Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best product/service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
– Where we need to comply with a legal obligation
– Where we need to perform the contract we are about to enter into or have entered into with you. This includes processing your data where it is necessary for the performance of a contract to which you are a party, or to take steps at your request before entering into such a contract.
Where we process Special Categories of Personal Data, we rely on the following special processing conditions:
– Health or social care. This includes processing your personal data where it is necessary for the purposes of preventive or occupational medicine, the assessment of an employee’s working capacity, medical diagnosis, the provision of health care or treatment, the provision of social care, or the management of health or social care systems.
Our purposes for using your personal data
We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases (and special processing conditions, where applicable) we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below
|Type of Data
|Our lawful bases and processing conditions (where applicable)
|To register you as a new customer
|(a) Identity (b) Contact (c) Special Categories
|(a) Performance of a contract with you (b) Explicit consent (c) Health or social care
|To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us
|(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications
|a) Performance of a contract with you (b) Necessary for our legitimate interests (e.g., to recover debts due to us)
|(a) Identity (b) Contact (c) Profile (d) Marketing and Communications (e) Special Categories
|(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (e.g., to keep our records updated and to study how customers use our products/services) and for your legitimate interests (e.g., to ensure only you or someone you have authorised can access your account) (d) Explicit consent (e) Health or social care
|To provide, personalise and tailor our products or services to you
|(a) Identity (b) Contact (c) Profile (d) Transaction (e) Usage (f) Technical (g) Marketing and Communications (h) Special Categories
|(a) Performance of a contract with you (b) Necessary for our legitimate interests (e.g., to provide you with a good service) (c) Explicit consent (d) Health or social care
|To enable you to complete a survey or similar
|(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Special Categories
|(a) Performance of a contract with you (b) Necessary for our legitimate interests (e.g., to study how customers use our products/services, to develop them and grow our business) (c) Explicit consent (d) Health or social care
|To evidence our claims or charges where there is a dispute
|(a) Identity (b) Contact (c) Financial (d) Transaction
|Performance of a contract with you
|To administer and protect our business and our Platform (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
|(a) Identity (b) Contact (c) Technical
|(a) Necessary for our legitimate interests (e.g., for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
|To deliver relevant Platform content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
|(a) Identity (b) Contact (c) Profile (d) Usage (e) Technical (f) Marketing and Communications
|Necessary for our legitimate interests (e.g., to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
|To be as responsive as possible to you, for example, when answering your customer support queries
|(a) Identity (b) Contact (c) Profile (d) Technical (e) Usage (f) Marketing and Communications (g) Special Categories
|(a) Necessary for our legitimate interests (e.g., to provide you with good service) and for your legitimate interest (e.g., to receive assistance promptly) (b) Explicit consent (c) Health or social care
|To use data analytics to improve our Platform, products/services, marketing, customer relationships and experiences
|(a) Technical (b) Usage
|Necessary for our legitimate interests (e.g., to define types of customers for our products/services, to keep our Platform updated and relevant, to develop our business and to inform our marketing strategy)
|To make suggestions and recommendations to you about products/services that may be of interest to you, including those offered by selected third parties
|(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications (g) Special Categories
|(a) Necessary for our legitimate interests (e.g., to develop our products/services and grow our business) (b) Explicit consent (c) Health or social care
|To monitor your health and provide you with feedback on your health outcome via push notifications on your mobile application or a web-based browser (as applicable).
|(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Special Categories
|(a) Performance of a contract with you (b) Necessary for our legitimate interests (e.g., to provide you with a good service) (c) Explicit consent (d) Health or social care
|To utilise your data for research and academic purposes
|(a) Identity (b) Special Categories
|(a) Necessary for our legitimate interests (e.g., to further our business and ensure our services stay relevant) (b) Explicit consent (c) Health or social care
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Marketing and promotional material from us
We may send you marketing communications by email, telephone, or mail.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You may receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can always ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time to exercise your right to object and withdraw your consent.
Where you opt out of receiving marketing messages, this will not apply to personal data you provided to us as a result of a product/service purchase, product/service experience or other transactions.
If you choose to object to the communications, unsubscribe or withdraw your consent, this will not make our processing of your personal data before you withdrew your consent unlawful.
Cookies and other similar technologies
Automated decision making
Automated decisions are made by technological means, mostly based on algorithms subject to predefined criteria. Such automated decision-making, taken solely by technological means without any human intervention, may have legal effects or similarly significant effects on you.
We do not make any automated decisions.
Push notifications and email notifications
You may, in most cases, opt-out of receiving push notifications by visiting your device settings (such as the notification settings for mobile phones and then change those settings for the website).
Note that disabling push notifications may negatively affect your use of our Platform.
(6) DISCLOSURES OF YOUR PERSONAL DATA
– Our service providers acting as subcontractors or sub-processors which we use from time to time, including, for example:
(a) Amazon Web Service for processing data;
(b) Apple for mobile applications for acquiring and displaying processed data;
(c) Android for mobile applications for acquiring and displaying processed data; and
(d) Google Chrome for displaying processed data.
– Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in Singapore, UK, EEA and other applicable jurisdictions who provide consultancy, banking, legal, insurance and accounting services.
– HM Revenue & Customs, regulators and other authorities based in Singapore, UK, EEA and other applicable jurisdictions who require reporting of processing activities in certain circumstances.
– Internal third parties acting as joint controllers or processors and provide services including IT and system administrative services and undertake certain reporting functions.
– Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
(7) INTERNATIONAL TRANSFERS OF PERSONAL DATA
Whenever we transfer your personal data out of the UK and/or the EEA (as applicable), we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
– We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
– If we transfer your personal data to any other country which is not subject to an adequacy decision of the UK or the European Commission (as applicable) regarding an adequate level of protection of personal data, we will ensure that there is a legal basis and, if required, a relevant safeguard method for such data transfer so that your personal data are treated in a manner that is consistent with, and respects the applicable laws and regulations on data protection in the UK or the EEA (as applicable).
– Where we use certain service providers outside of the UK and/or the EEA (as applicable), we may use specific contracts approved for use in the UK and/or the EEA (as applicable) which give personal data the same protection it has in the UK and/or the EEA (as applicable).
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK and/or the EEA.
(8) DATA SECURITY
We have implemented technology and policies with the objective of protecting your personal data from unauthorized access and improper use. In particular, we use encryption and apply authentication and verification processes for access to our services, and we regularly test, assess and evaluate the effectiveness of our security measures. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us.
In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so
(9) DATA RETENTION
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, or other requirements.
We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
(10) YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
– Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
– Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
– Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
– Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
– Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
(a) if you want us to establish the data’s accuracy;
(b) where our use of the data is unlawful but you do not want us to erase it;
(c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
(d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
– Request the transfer of your personal data to you or to a third party. We will provide you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use, or where we used the information to perform a contract with you.
– Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdrew your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent. To withdraw your consent for allowing us to process Special Categories of Personal Data, please contact email@example.com. Note that such withdrawal in certain circumstances may mean we can no longer continue to provide services or information to you.
If you wish to exercise any of the rights set out above, please contact us.
You have the right to make a complaint at any time to the ICO, the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach any supervisory authorities, so please contact us in the first instance.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated