Privacy & Data Protection Policy

Updated on: 28th September, 2018

 At Zenyum Pte. Ltd. (UEN: 201816647D), a company incorporated under the laws of Singapore, and its subsidiaries, affiliates and related corporations (“Company”, “we”, “us”, or “our”), we recognise the importance of safeguarding your personal data and take our responsibility to properly manage, protect and process your personal data under the Personal Data Protection Act 2012 (No. 26 of 2012) of Singapore (the “PDPA”) seriously.

This Privacy & Data Protection Policy (the “Privacy Policy”) explains how we collect, use, disclose or process your personal data through your interactions with our services, websites, platforms, devices, applications, programmes, servers, software including the following properties which are owned and operated by us: (i) any websites owned and operated by us, including www.zenyum.sg and the associated applications and services (the “Website”); (ii) any official social media channels created by us on any social media platforms (including but not limited to Facebook, Instagram, Twitter, LinkedIN, WeChat, YouTube, Telegram and WhatsApp) (the “Channels”); and (iii) all other properties which reference this Privacy Policy in a link or otherwise (collectively, the “Services”). This Privacy Policy applies to all our interactions with you as well as other of the Services that has a reference or link to this Privacy Policy. In this Privacy Policy, “personal data” means personally identifiable information that you provide us, or we collect about or from you, through your use of any of the Services. 

Please read this Privacy Policy carefully and should you have any queries about how we may manage, protect or process your personal data, please do not hesitate to contact our Data Protection Officer at privacy@zenyum.sg. This Privacy Policy is governed by the laws of Singapore. By continuing to use our Services, you are deemed to have consented to the terms of this Privacy Policy and our Terms & Conditions (accessible at: www.zenyum.sg/terms-conditions) and this agreement supersedes any other agreement that we might have with you concerning the use of your personal data. Certain features of the Website and Channels require the provision of your personal data, and where you do not provide such requested information, we may not be able to provide you with the Services.

While we do not intend to collect any personal data about individuals under the age of 18 unless such information is collected from or with the prior consent of the parent or guardian, we cannot stop such individuals from accessing and visiting the Website and Channels. Where you are below 18 years of age (or the applicable age required for you to legally access or use the Services), the rights to consent, access and correction can only be granted by your parents or guardians. Where you are a parent or guardian of such individual, by providing us with personal data of the individual under the age of 18, you hereby consent to the processing of his/her personal data in accordance with applicable laws, and agree to be personally bound by the terms of this Privacy Policy and take full responsibility for his/her actions in relation to the Website and Channels.

Please notify us and stop using our Services immediately if you do not consent to this Privacy Policy, or do not have consent from your parent(s) or legal guardian(s).

  1. PERSONAL DATA COLLECTED BY US
  • We provide access to orthodontic treatment involving our “Zenyum Invisible Braces” (which are invisible dental aligners) and related products developed by us, by collaborating with dentists and orthodontists registered to practice dentistry in Singapore, or other third party service providers (collectively, the “Zenyum Treatment”).
  • Whose personal data is collected?: By using our Services, whether as a: (i) visitor of the Website or Channels; (ii) customer; (iii) (prospective, current or former) patient; (iv) parent / guardian of such patient; or (v) dentist / orthodontist / other dental healthcare professional, we may collect your personal data.
  • Collection: Therefore, in using the Services, you may be asked to provide us with personal data such as your name, age, contact information, health information about teeth alignment or geographical location from time to time, and we may collect your personal data either directly from you, your authorised representatives, and/or through our third-party service providers (e.g. partners or third-party applications) to personalise your experiences and improve our Services.
  • Consent: By accessing or using our Services or otherwise providing us with your personal data, we shall be entitled to assume that you understand and agree to the terms of this Privacy Policy and consent to the collection, use and disclosure of your personal data by us. If you do not consent to any of these terms, please do not access or use any of our Services, or provide us with any of your personal data.

 

  1. PURPOSES FOR COLLECTION, USE, DISCLOSURE & PROCESSING OF PERSONAL DATA
  • We use your personal data to provide you with relevant Services and to operate our business. We may also use the data collected to communicate with you, for instance, to inform you about new features of the Services, security updates, or to inform you about your account. Your personal data may also be used to show you more relevant information, content, advertisements, whether through the Services or third-party applications and in combination with information from other sources.
  • Some examples of how we generally use your personal data include:
    • to process, record, monitor and fulfil your transactions or your requests;
    • facilitating our provision of the Services;
    • communicating with you for research, marketing, advertising and promotional purposes;
    • administrative matters on your purchases and/or subscriptions to the Services, managing your accounts, processing your sign-ups/registrations for mailing lists, etc.;
    • diagnosis and maintenance of the Services;
    • maintaining the security of the Services;
    • to protect you and other users of the Services and visitors;
    • enforcement of our policies and procedures;
    • to permit you to submit questions, feedback or complaints; and/or
    • such other purposes notified to you from time to time.
  • Where you are a visitor, (prospective, current or former) patient, or parent/guardian of such patient (collectively, the “Patients”) some examples of our use of your personal data include:
    • to allow you to access online facilities, to book an appointment with our partner dentist(s) / orthodontist(s) / other dental healthcare professional(s);
    • to provide you with details of dentist(s) / orthodontist(s) / other dental healthcare professional(s); and/or
    • to generate preliminary compatibility assessment reports to assist in determining your suitability for the Zenyum Treatment.
  • Where you are a dentist / orthodontist / other dental healthcare professional, some examples of our use of your personal data include:
    • to provide you with information on prospective or actual Patients;
    • to allow you to accept appointment bookings or other requests from Patients; and/or
    • to allow the creation of profiles which can be viewed by Patients (which may include details such as dental professional’s name and contact details, the dental clinic’s name and contact details, and other relevant information such as practice experience and specialisations).
  • The manner in which your personal data is used will depend on the circumstances at hand, and it will be used in compliance with applicable laws and regulations.
  • We may process and use your personal information to facilitate a change of control or sale of the Company or to facilitate a restructuring or other corporate rearrangement.

 

  1. SHARING YOUR PERSONAL DATA WITH THIRD PARTIES
  • It may also be necessary in certain circumstances for us to share your personal data with third parties such as our subsidiaries, affiliates, related corporations, service providers, vendors, as an extension of your patient care as part of the Zenyum Treatment, or regulatory authorities or other third parties. Such third parties processing your personal data either on our behalf or otherwise may be located in a different country from the point of collection of your personal data (e.g. transfer to servers located outside of the country you are accessing the Services from), or may have multiple physical locations and backups (e.g. cloud based services).
  • Where your personal data must be shared with third parties in circumstances that are not reasonably contemplated within the normal course of our dealings with you, we would usually first seek your consent unless the disclosure:
    • is required or authorised based on the applicable laws and/or regulations;
    • is clearly in your interests, and if consent cannot be obtained in a timely way;
    • is necessary to respond to an emergency that threatens the life, health or safety of yourself or another individual;
    • is necessary for any investigation or proceedings;
    • is required by a law enforcement agency;
    • is to a public agency and necessary in the public interest; and/or
    • where such disclosure without your consent is permitted by law.
  • Where we disclose your personal data to third parties, we will employ our best efforts to require such third parties to protect your personal data.
  • By using our Services, you agree that the transfer of your personal data to various countries is reasonably necessary for us to provide you with these Services.

 

  1. REQUEST FOR ACCESS AND/OR CORRECTION OF PERSONAL DATA
  • You may request access to or correct the personal data held by us by submitting a written request at any time to privacy@zenyum.sg.
  • We may require further information from you to verify your identity as well as the nature of your request, to deal with your request. Handling and processing fees may be payable before we can proceed with your request.
  • Once we have sufficient information to deal with your request, we will seek to provide you with the relevant personal data or information within thirty (30) days of your request, unless otherwise stated.

 

  1. REQUEST TO WITHDRAW CONSENT

 

  • Should you wish to withdraw your consent to our use of your personal data, please stop using the Services immediately and notify us in writing at privacy@zenyum.sg to inform us that you wish for us to stop collecting, using or sharing your personal data and we will process your request within a reasonable time from such a request. You may also elect to withdraw your consent to the use of your personal data for a specific purpose, so please ensure that your notification contains sufficient and specific information to enable us to comply with your request.
  • However, your withdrawal of consent could result in certain legal consequences arising from such withdrawal. In this regard, depending on the extent of your withdrawal of consent for us to process your personal data, it may mean that we will not be able to continue with your existing relationship with us.

 

  1. RETENTION, ADMINISTRATION & MANAGEMENT OF PERSONAL DATA
  • We will take reasonable efforts to ensure that your personal data is accurate and complete, based on the information that you have provided us with. Please ensure that all information provided to us is up to date and keep us informed of any relevant changes.

 

6.2     We value your privacy and have security arrangements to ensure that your personal data is adequately protected and secured. We will also 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 that 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. Otherwise, personal data collected by us is generally only retained for as long as it is reasonably necessary for the purpose for which the data provided and we may destroy or delete any information or personal data provided by you thereafter, unless required by law, regulation or other business or audit requirements.

 

6.3     Where your personal data is to be transferred out of Singapore or such other jurisdiction in which it is collected, we shall take reasonable steps to ascertain that the recipient of the personal data is bound by legally enforceable obligations to protect your personal data in accordance with this Privacy Policy and the PDPA.

 

  1. SHARING OF PERSONAL DATA VIA CHANNELS

Where you are a user of any of the Channels and/or other social media platforms with public account settings and you use any hashtags which may be related to Zenyum, the Zenyum Treatment or any of its campaigns and/or products or services, we will be able to retrieve your reviews of our services from the Channels and post them on our Website or Channels, for the purposes of sharing your opinions about our products with the visitors of our Website and Channels. You hereby agree not to use such hashtags if you do not wish for your reviews/feedback/content to be made available on any of our Website or Channels. By posting or otherwise making available any content on the Channels or a social media platform about your experience in relation to the Zenyum Treatment, and responding “yes” where we request your permission to share your content on any of our Website or Channels, you represent and warrant that you are 18 years of age or older and that you agree to the terms and conditions listed on the Website and Channels.

 

  1. COMPLAINTS PROCESS

 If you do not consent to any of the terms of this Privacy Policy, our use of your personal data or have any complaint or grievance regarding about how we handle your personal data, we welcome you to contact us with further details at:

 

E-mail address: privacy@zenyum.sg

(please attention it to the ‘Data Protection Officer’)

 

Office address: Block 81, Ayer Rajah Crescent, #01-69

                                           JTC Launchpad

                                           Singapore 139967

(please attention it to the ‘Data Protection Officer’)

 

  1. UPDATES ON DATA PROTECTION POLICY
  • As part of our efforts to ensure that we properly manage, protect and process your personal data, we will be reviewing our policies, procedures and processes and may update, at our absolute discretion, update the terms of this Privacy Policy from time to time. Any revised Privacy Policy will be posted on our Website and can be accessed at https://zenyum.sg/privacy-policy.
  • You are encouraged to visit the above Website from time to time to ensure that you are well informed of our latest policies in relation to personal data protection.

 

  1. COOKIE POLICY
  • We may collect information from you (or others on your behalf) de-identified information to help us in our business and provide you with the relevant Services. Such anonymised and de-identified information may be transferred, disclosed, assigned, leased, licensed, sold and otherwise shared with and by our partners, service providers, advertisers and/or other third parties for purposes permitted under law.
  • Cookies (small text files placed on your device that record information about your preferences and enable log-ins, provide interest-based advertising, analyse how our Services are performing) are an example of such anonymised data which we collect. While compiling information about your browsing habits, cookies can also enhance your user experience. There may also be third party cookies on our Websites and Channels. For more information on cookies, please refer to allaboutcookies.org/manage-cookies/.
  • You can control cookies through your web browser settings. This allows you to determine which cookies to allow and which to refuse. If you disallow the use of cookies on our Website or Channels, please note that you may not be able to access the full range of functions that our Website or Channels offer.
  • Our advertising partners may also transmit cookies to your browser or device, when you click on advertisements that appear on the Services. Further, if you click on a link to a third-party website or service, a third party may also transmit cookies to you. For the avoidance of doubt, this Privacy Policy does not cover the use of cookies by any third parties, and we are not responsible for their privacy policies and practices. Please be aware that cookies placed by third parties may continue to track your activities online even after you have left our Services, and those third parties may not honour ‘Do Not Track’ requests that you have set using your browser or device.
  • If you do not consent to our use of cookies, you should adjust your browser settings accordingly or not use any of the Services.