Last updated 1st March 2023
As a matter of principle, we try to minimize the amount of personal data we collect from you. We do not ask for more than that which is required to service your account and provide the services you select.
Collection of Data
The Types of Data We Collect from You
The information that we collect from our users fall into the following broad categories:
(a) your name, age, date of birth, gender, mailing address, email address, details of your identification document(s), and telephone or mobile number;
(b) medical and health information that you provide us, which may include information or records relating to your medical or health history, health status and laboratory testing results, diagnostic images, and other medical and health related information We use the aforementioned information to open an account for you, verify that you are a unique visitor, and enable you to purchase the products or use the services offered on our Websites and/or Apps.
How We Collect Your Data. We collect the aforementioned data directly from you when you access and use our Websites or Apps, or when you contact us in connection with our products and/or services.
Use of Data. We use your personal data for the following purposes:
- opening and maintaining your account with us;
- verifying that you are a unique user of our Websites and Apps;
- introducing you to medical practitioners and allied healthcare providers (collectively, “Practitioners”) and enabling you and the Providers to conduct consultations (“Consultations”) via our Websites or Apps or any other platform that we may make available from time to time. In order to facilitate this service, we will need to share your personal data with the Practitioner who you have chosen or connected with. Your data will only be shared with the aforementioned Practitioner and only for the purposes of facilitating the conduct of the Consultations;
- providing you with information or products or services that you have requested;
- providing you with our products and services, and customizing our products and services to you;
- processing fees for completed Consultations or or any transactions relating to any other products or services purchased or used by you;
- notifying you about changes to our products or services;
- improving the Websites and Apps and ensuring that the content on the Websites and Apps is presented in the most effective manner for you and your device;
- administering the Websites and Apps, including internal operations such as trouble shooting, data analysis, testing, research, statistical and survey purposes;
- keeping the Websites and Apps safe and secure;
- responding to your queries, requests or feedback;
- enforcing our terms, conditions and policies;
- completing our customer screening and identity verification process including checks in relation to fraud detection and prevention;
- detecting, investigating and preventing fraudulent transactions or illegal activities;
- aggregating data into anonymized statistical data, which we will use for statistical analysis so that we can improve our service offering to serve you better;
- with your consent, contacting you and sending you marketing and promotional materials in relation to products and services that we, our subsidiaries and/or affiliates offer. In this regard, if you have provided an incorrect address or phone number (or any other contact detail) (collectively, “Contact Addresses”), you may not receive these communications. We will not be responsible for any breach of privacy due to correspondence going to an incorrect Contact Address; and
any other purposes that we may notify you from time to time.
Disclosure of Data
We may disclose your personal data in the following circumstances:
- when we obtain your permission;
- when we find it necessary to disclose your personal data to our subsidiaries and/or affiliates in order to respond to your queries, requests or feedback;
- when we find it necessary to disclose information to third-party service provider(s) who have confidentiality agreement(s) with us, in order to provide the products or services indicated to you. The services performed by the third-party service provider(s) may include, without limitation, performing statistical analysis, sending you emails or postal mails, providing user support, arranging for deliveries, or any other service which we deem necessary in order to provide the products or services indicated to you;
- when you choose to integrate our App(s) with any third party’s mobile application(s) (for example the Health application provided and maintained by Apple Inc. and/or its subsidiaries and affiliates), whereupon we may disclose your personal data to said third party in response to requests made by such third party;
- when we find it necessary to disclose information to a buyer or other successor in the event of a merger or acquisition, restructuring, reorganisation, or other sale or transfer of some or all of Khmermedical’s assets, in which your personal data maintained by the Websites or Apps is among the assets transferred; and
- when we find it necessary to disclose information to our legal advisors or other professional advisors, or as otherwise authorised or required by law.
For the purposes of disclosure of your personal data under paragraph (4) above, Khmermedical shall not integrate our App(s) with the third party’s mobile application(s) unless you grant Khmermedical access to said third party’s mobile application(s). If you grant Khmermedical access to the third party’s mobile application(s), you are deemed to have consented to the disclosure or transfer of your personal data collected by Khmermedical and stored on your device to the database which stores your data collected by the third party, in response to requests made by such third party. Conversely, Khmermedical may access your data collected by and stored in the third party’s database. Khmermedical shall not disclose or transfer your data collected from the third party’s database to any other third party unless Khmermedical has obtained your prior consent. For the avoidance of doubt, Khmermedical is in no way responsible for the protection of your data (including personal data) that is stored within the third party’s database. You and the third party are solely responsible for the protection of such data. Please therefore review the applicable data protection policies and procedures before integrating our App(s) with the third party’s mobile application(s).
We also reserve the right to share your personal data as is necessary to prevent a threat to the life, health or security of an individual or corporate entity. Further, we reserve the right to disclose personal data, as is necessary, to law enforcement, governmental agencies, or authorized third parties, in response to a verified request relating to a criminal investigation or alleged illegal activity or any other activity that may expose us to legal liability.
Safeguards of Data
As part of our commitment to keeping your personal data (which is in our possession or control) secured, we have taken reasonable steps to protect the information you share with us in order to prevent unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks. Such measures include, but are not limited to, setup of processes, equipment and software to avoid unauthorized access or disclosure of this information. We limit access to personal data only to Khmermedical employees who are reasonably required to come in contact with that information in order to provide services to you or in order to do their jobs.
While we are committing to taking reasonable steps to protect the security of the information communicated through our Websites or Apps, the Internet is not a secure method of transmitting information, and accordingly we do not assume any responsibility for the information you submit to or receive from us through the Internet or for any unauthorized access or use of that information. We also cannot and do not guarantee that information communicated by you to us or by us to you will be received or that it will not be altered before or after its transmission to us or to you, as the case may be. In any event, you agree to not hold us, our subsidiaries or affiliates, our past, present and future employees, officers, directors, contractors, consultants, suppliers, vendors, service providers, agents, representatives, predecessors, successors and assigns liable for any loss or damage of any sort incurred as a result of any misappropriation, interception, modification, deletion, destruction or use of the information provided through our Websites or Apps.
The security of your personal data also relies on your protection of your personal data. In this regard, we kindly ask that you protect the password given or created by you for your use of our Websites or Apps without sharing the same with anyone.
Retention and Transfer of Data
We shall not retain your personal data in our possession and/or database if your personal data is no longer required to meet the purposes for which they were collected and/or no longer serves a legal and/or business purpose.
Some of the recipients of your personal data (for example, our third-party service providers) may be based in countries outside of Cambodia. We are committed to adequately protecting your personal data regardless of where the data resides and to providing appropriate protection for your data where such data is transferred outside of Cambodia. We will use our best efforts to ensure that the third-party service providers engaged by us to provide the products and services to you will not transfer information about you to a place outside Cambodia without our prior written consent. In the event that we provide such consent, we will use our best efforts to procure that the relevant third-party service provider provides a written undertaking to us that the information about you which is transferred outside of Singapore will be protected at a standard that is at least comparable to that listed here. If the relevant third-party service provider transfers information about you to any person overseas, we will use our best efforts to procure that such third-party service provider procures the same written undertaking from such person.
Access and Correction of Data
If you have provided personal data to Khmermedical, you have the right to access, at any time, personal data we hold about you and information about the ways in which your personal data has been or may have been used or disclosed by Khmermedical within one (1) year before the date of your request.
Where permitted by law, we reserve the right to charge a reasonable administrative fee for this service. In exceptional circumstances and where permitted by the applicable laws, we reserve the right to deny you access to your personal data and may provide an explanation as required by applicable laws.
You have the right to correct any personal data held about you that is inaccurate. If you would like to inquire, make any corrections or request deletion of your personal data, please contact our Data Protection Officer (at the address stated at the end of this document below).
Accuracy of Data
We require your assistance to ensure that your personal data is accurate and complete. As such, please inform us of any changes to your personal data by contacting our Data Protection Officer (at the address stated at the end of this document below).
Social Sharing Feature and links to other websites
Our Websites and/or Apps may offer social sharing features, links to social media and other integrated tools. Depending on the settings you use with the entity that provides the social sharing feature or social media, your use of such social sharing feature or social media may enable the sharing of your information with your contacts or with the public. You are advised to visit the privacy policies of the entities that provide these social sharing feature or social media to obtain information about the way they collect, use and/or disclose your personal data.
S.I.B.S Khmer Medical Co.Ltd
Company Registration Number: 00052191
Address: No 55, 3rd Floor, St 566 Sangkat Boeung Kok 1, Khan Toul Kork, Phnom Penh, Kingdom of Cambodia