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Doctor On-line

Privacy and Data Protection Policy (“Privacy Policy”) 

This Privacy Policy sets out the basis on which Dytan Health On-line Sdn Bhd and our related companies (“Doctor On-line”, “we”, “us”, or “our”) may collect, use, disclose or otherwise process personal data of our customers when you use our website at  https://www.doctor-online.io/ (“Website”) and/or the Doctor On-line mobile application (“Application”) (collectively, “Platforms”) in accordance with the Personal Data Protection Act 2010 (“PDPA”). In order to protect your private information, we have established this Privacy Policy in accordance with the best practices in the industry and applicable laws and regulations. This Privacy Policy applies to personal data in our possession or under our control, including personal data in the possession of organizations in which we have engaged to collect, use, disclose or process personal data for our purposes.

By signing up, accessing or using any of our Platforms constitutes your unconditional agreement to be bound by these terms and conditions. If you do not agree to these terms and conditions or any of its revisions, please do not proceed and immediately discontinue your access and/or the use of our Platforms immediately.

This Privacy Policy is incorporated as part of our Platforms’ Terms of Use. Your use of our Platforms and/or Service is subject to the Terms of Use and this Privacy Policy. Unless specifically defined in this Privacy Policy, the defined terms shall have the same meaning as defined in the Terms of Use.

  1. To process, administer and/or manage your relationship with us, we will necessarily need to collect, use, disclose and/or transfer your personal data. This Privacy Policy applies to personal data about you (our users/ members, our business/marketing partners, solicitors, agents, vendors, distributors, suppliers, contractors, service providers, etc), possessed by us or that we obtain about you, whether now or in the future. We will only process your personal data pursuant to PDPA and other relevant applicable laws.
  2. If you are a company, or an organisation, references to the term “you” and “your” shall also include your employees, representatives and agents.
  3. By accessing, browsing, downloading and/or using our Platforms and/or Services, or by dealing with us, you acknowledge that you have read and understood this Privacy Policy and agree to us processing your personal data in accordance with the manner as set out in this Privacy Policy, amended from time to time.
  4. We may revise and/or update this Privacy Policy at any time by posting a revised/an updated version on our Platforms. Unless stated otherwise, any revision or update takes effect immediately. Your continued access and/or use of our Platforms and/or Service or dealing with us after a revision or update to this Privacy Policy constitutes your binding acceptance of the revised or updated Privacy Policy.
  5. It is necessary for us to collect and process your personal data. If you do not provide us with your personal data, or do not consent to this Privacy Policy or any amendments to this Privacy Policy, you may be required to stop accessing or using our Platforms and/or Services.

By accepting the Privacy Policy and our Terms of Use, you expressly consent to our collection, storage, use and disclosure of your personal information as described in this Policy. This Policy is effective immediately upon acceptance by new users.

 

A. PERSONAL DATA

  1. As used in this Privacy Policy:

“customer” means an individual who (a) has contacted us through any means (such as through any of the Platforms) in relation to the goods or services available on the Platforms, or (b) may, or has, entered into a contract with us for the supply of any goods or services by us; and

“personal data” means data, whether true or not, about a customer who can be identified: (a) from that data; or (b) from that data and other information to which we have or are likely to have access.

  1. You can browse our Platforms without telling us who you are and/or revealing any personal information about yourself. Once you give us your personal information, you are not anonymous to us.
  2. We may collect and store the following personal information:

(a) Your name, identification numbers such as NRIC, Passport Number, identification number, residential address, email address, telephone number, nationality, gender and date of birth;

(b) Personally-identifiable medical and health-related information which you provide to us (including information or records relating to your medical or health history, medical claims, health status, laboratory testing results, diagnostic images);

(c) Personally-identifiable medical and health information about you prepared by healthcare professionals/treatment providers who provide medical or healthcare services and products to you via the Platforms (including medical records, treatment and examination notes);

(d) Billing information that you provide us (e.g. credit card or online payment system account information);

(e) Information about the computer or mobile device you are using;

(f) Geographical location or address;

(g) Other information which you may input into the Platforms or related services;

(h) Other terms used in this Privacy Policy shall have the meanings given to them in the PDPA (where the context so permits);

(i) Transactional information based on your activities on our Platforms (such as your purchases and content you generate or that relates to your account);

(j) Community discussions, chats, dispute resolution, correspondence through our Website, and correspondence sent to us;

(k) other information from your interaction with our Website, services, content and advertising, including computer and connection information, statistics on page views, traffic to and from the Website, ad data, IP address and standard web log information; and/or

(l) Other supplemental information from third parties (for example, if you incur a debt to the Company, we reserve the right to conduct a credit check by obtaining additional information about you from a credit bureau, as permitted by Malaysian laws).

 

B. DATA IN CONNECTION WITH SIMILAR TECHNOLOGIES

  1. We may also use cookies, web beacons and similar technologies to collect data while you use our services on our Platforms. We collect this data from the devices (including mobile devices) that you use our services with. The data collected includes the following usage- and device-related information that may include, but not limited to:

(a) Data about your activities and interactions with our advertising partners and merchants (if applicable) including data about the advertisements you were shown, how often they were shown, when and where they were shown, and whether you took any action, such as clicking on an advertisement or making a purchase.

(b) Your user segment.

(c) Model or device type, operating system and version, browser type and settings, device ID or individual device identifier, advertisement ID, individual device token, and cookie-related data (e.g. cookie ID).

(d) Site Activity Information: We may keep track of some of the actions you take on the Platforms, such as the content of searches you perform on the Platforms. Data about the pages you visit, the access time, frequency and duration of visits, the links on which you click and other actions you take as part of your use of our services and in advertising and email content.

(e) Access Device and Browser Information: When you access the Website from a computer or other device, we may collect anonymous information from that device, such as your Internet protocol address, browser type, connection speed and access times;

(f) Cookies (i.e. small pieces of information that a site sends to your browser while you are viewing a website): We may use both session Cookies (which expire once you close your web browser) and persistent Cookies to make the Platforms and services easier to use, to make our advertising better, and to protect both you and DA. You can instruct your browser, by changing its options, to stop accepting Cookies or to prompt you before accepting a Cookie from the websites you visit. If you do not accept Cookies, however, you will not be able to stay logged in to the Platforms. We presently do not honour “Do Not Track” requests across all parts of our Platforms.

(g) Real-Time Location: Certain features of the Platforms use GPS technology to collect real-time information about the location of your device so that the Platforms can connect you to a healthcare professional/treatment provider near your location. Please note that most mobile devices allow you to manage or disable the use of location services for all applications in the settings menu.

(h) Device information: We may also collect non-personal information from your mobile device or computer. This information is generally used to help us deliver the most relevant information to you. Examples of information that may be collected and used include how you use the application(s) and information about the type of device or computer you use. In addition, in the event our application(s) crashes on your mobile device we will receive information about your mobile device model software version and device carrier, which allows us to identify and fix bugs and otherwise improve the performance of our application(s).

(i) Web Analytics: We may use Google Analytics to help analyze how users use the Website. Google Analytics uses Cookies to collect information such as how often users visit the Website, what pages they visit, and what other sites they used prior to coming to the Website. We use the information we get from Google Analytics only to improve our Website and services. Google Analytics collects only the IP address assigned to you on the date you visit the Website, rather than your name or other personally identifying information. Although Google Analytics plants a persistent Cookie on your web browser to identify you as a unique user the next time you visit the Website, the Cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to the Website is restricted by the Google Analytics Terms of Use and the Google Privacy Policy.

  1. Furthermore, please take notice that a few pertinent points you should be aware regarding cookies include, but not limited to:

(a) We offer certain features that are available only through the use of cookies.

(b) We use cookies to help identify you and maintain your signed-in status.

(c) Most cookies are “session cookies,” meaning that they are automatically deleted from your hard drive at the end of a session.

(d) You are always free to decline our cookies if your browser permits, although doing so may affect with your use of some of our sites or services.

(e) You may encounter cookies from third parties on certain pages of the Website that we do not control. (For example, if you view a web page created by another user, there may be a cookie placed by that web page).

 

C. MARKETING

  1. We don’t sell or rent your personal information to third parties for their marketing purposes without your explicit consent. We may combine your information with information we collect from other companies and use it to improve and personalise our services, content and advertising. If you don’t wish to receive marketing communications from us or participate in our ad-customisation programmes, simply indicate your preferences on our website and/or by following the directions provided with the communication and/or advertisement.

 

D. COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA

  1. Our primary purpose in collecting personal data is to provide you with a safe, smooth, efficient, and customized experience. You agree that we may collect and use your personal data for any or all the following purposes:

(a) performing obligations in the course of or in connection with our provision of the goods and/or services requested by you (including the provision of any medical or healthcare services, the delivery of products purchased by you);

(b) verifying your identity;

(c) responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;

(d) resolving disputes, payment collection and managing your relationship with us;

(e) processing or facilitating the processing of your claims;

(f) processing payment or credit transactions;

(g) improving the quality of medical or healthcare services through the performance of quality reviews and similar activities;

(h) creating de-identified information which is information which is not used or intended to be used to personally identify an individual (e.g. aggregate statistics relating to the use of the services on the Platforms);

(i) notifying you when Platform updates are available;

(j) send you targeting marketing, service updates and promotional offers, if applicable, and promoting the Platforms, and the services and products offered on the Platforms to you;

(k) complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;

(l) converting the personal data to anonymized data for the purposes of analytics and market research;

(m) any other purposes for which you have provided the information without disclosing information about identifiable individuals;

(n) transmitting to any unaffiliated third parties including our third-party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Malaysia or abroad, for the aforementioned purposes;

(0) Prevent potentially prohibited or illegal activities and enforcing our Terms of Use; and

(p) any other incidental business purposes related to or in connection with the above.

 

E. WITHDRAWING YOUR CONSENT

  1. The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop collecting, using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.
  2. Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within fourteen (14) business days of receiving it.
  3. Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our goods or services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in clause E.2 above.
  4. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.

 

F. SHARE YOUR INFORMATION

  1. We may share your personal date with:

(a) Third-party service providers under contract who help with our business operations: We employ other companies and individuals to perform functions on our behalf. Examples include removing repetitive information from product lists, analysing data, providing marketing assistance, providing search results and links (including paid listings and links), processing credit card payments, investigating frauds and providing customer service. They have access to personal information needed to perform their functions, but may not use it for other purposes.

(b) Third parties giving promotional offers: Sometimes we send offers to selected groups our users on behalf of other businesses. When we do this, we do not give that business your name and address. If you do not want to receive such offers, please adjust communication preferences in our Platforms.

(c) Other third parties to whom you explicitly ask us to send your information (or about whom you are otherwise explicitly notified and consent to when using a specific service).

(d) Law enforcement and/or other governmental officials, in response to a verified request relating to a criminal investigation or alleged illegal activity. In such events, we will disclose information relevant to the investigation, such as name, city, postal code, telephone number, email address, User ID history, IP address, fraud complaints, and purchasing history; and

(e) Other business entities, should we plan to merge with or be acquired by that business entity, if applicable. (Should such a combination occur; we will require that the new combined entity follow this privacy policy with respect to your personal information. If your personal information will be used contrary to this policy, you will receive prior notice)

  1. For the avoidance of doubt, if we have reasonable grounds to believe that any of our guest(s) or registered user(s), merchants, are in breach of any of the terms of this Privacy Policy, we reserve the right, in its sole and absolute discretion, to cooperate fully with governmental authorities, all the rightful owner(s) or interest holder(s) and/or injured third parties in the investigation of any potential or ongoing criminal or civil wrongdoing. Further, we may disclose the guest(s) and/or the register user(s) identity and contact information, or such other transaction-related data, if requested by a government and/or law enforcement body, rightful owner and/or interest holder and/or any injured third party or as a result of a subpoena or other legal action, or if we are of the view, in its sole and absolute discretion, that it would be in its best interest to do so. We shall not be liable for damages or results arising from such disclosure, and guest(s) and/or register user(s) agrees not to indemnify us for such disclosure.

 

G. ACCESS TO AND CORRECTION OF PERSONAL DATA

  1. If you wish to make (a) an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, or (b) a correction request to correct or update any of your personal data which we hold about you, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below. Such request shall include the details of the requestor, description of the personal data being requested and the date and time range the personal data was believed to be collected.
  2. Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.
  3. We will respond to your request as soon as reasonably possible. In general, our response will be within fourteen (14) business days. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).

 

H. PROTECTION OF PERSONAL DATA

  1. To safeguard your personal data from unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as up-to-date antivirus protection, encryption, and disclosing personal data both internally and to our authorized third party service providers and agents only on a need-to-know basis.
  2. You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.
  3. We will never ask for your password by phone or e-mail, so if you receive such an inquiry, please contact us immediately at hello@doctor-online.io

     

  4. If you access our Platforms from a shared computer or a computer in an internet cafe, or a library, certain information about you, such as your user ID, activity or reminders from our Platforms, may also be visible to other individuals who use the computer after you. To protect your personal information or communication from being disclosed to others, you should log out and close the web browser after using our Website.

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I. ACCURACY OF PERSONAL DATA

  1. We generally rely on personal data provided by you (or your authorized representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided below.

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J. RETENTION OF PERSONAL DATA

  1. We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.
  2. We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.

 

K. RETENTION OF PERSONAL DATA

  1. We treat data as an asset that must be protected and use lots of tools (encryption, passwords, physical security, etc.) to protect your personal information against unauthorised access and disclosure. However, as you probably know, third parties may unlawfully intercept and/or access transmissions or private communications, and other users may abuse or misuse your personal information that they collect from the site. Therefore, although we work very hard to protect your privacy, we do not promise, and you should not expect, that your personal information or private communications will always remain private.

 

L. THIRD PARTIES

  1. We do not control the privacy policies of third parties, and you are subject to the privacy policies of those third parties where applicable. We encourage you to ask questions and to review their privacy policies before you disclose your personal information to others.

 

M. DATA PROTECTION OFFICER

  1. You may contact our Data Protection Officer if you have any inquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, in the following manner:

Email Address : hello@doctor-online.io

 

N. EFFECT OF PRIVACY POLICY AND CHANGES TO PRIVACY POLICY

  1. This Privacy Policy applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.
  2. We may revise this Privacy Policy from time to time by posting the amended terms on our Platforms. All amended terms automatically take effect fourteen (14) days after they are initially posted. Kindly take note that you are advised to check this Privacy Policy each time you access our Platforms so as to be aware of the most recent applicable version of the Policy as per PDPA.

 

Effective date : 12th September 2023

Last updated : 12th September 2023