PRIVACY
POLICY
PSPhere
is operated by DKSH Singapore Pte Ltd. (“DKSH”). At DKSH, we are
committed to respecting and safeguarding your privacy by handling your personal
data responsibly and in accordance with applicable laws. By accessing or using the
PSPhere service offerings and features on http://pspherehome.dkshpsp.com.sg (the
“Site”), and any components that support the functionality of the
services (the “Services”), as further defined in our Terms and
Conditions http://pspherehome.dkshpsp.com.sg, you expressly consent to the collection,
processing, use and disclosure of your personal data according to this Privacy
Policy. DKSH may share your personal data with our affiliates, group companies,
subsidiaries and other authorized third parties solely for the purposes
described herein. This Privacy Policy is aimed at giving you transparency about
how we collect, use, and keep your personal data safe, and what your rights are
under the Personal Data Protection Acts.
1.
What personal data about you
do we collect?
DKSH collects and uses certain
types of personal data about you, depending on the relationship that you have
with us as well as applicable laws. In order to access the Site and to use PSPhere,
you will be asked to provide certain personal data. We may collect the
following personal data about you:
Personal data category |
Types of personal data |
General
information |
Your full name (including prefixes and suffixes
which may indicate your gender); date of birth and age; job information; educational,
training, licensing and certification information; professional membership
information; marital status; national identification number and passport
number; Site account details such as username and online identifiers. |
Contact
information |
Your address, telephone, mobile phone, fax, e-mail,
social network information and other relevant contact details, as well as
information about the preferred way and time of communication. |
Financial
information |
Information collected in connection with sales and
promotional activities; financial information including transaction details,
bank and debit/credit card details, payment methods and terms; income and
salary information; insurance information and claims history. |
Sensitive
information |
Ethnicity and race; hereditary information and
health records including but not limited to your medical history, height,
weight, disability, blood type and allergies, drug prescription history, your
healthcare professional’s name and contact information; biometric identifiers
including but not limited to facial recognition, retina recognition,
fingerprint recognition, voice recognition for the purposes of verifying and
confirming your identity for the use of our products and services. |
Usage
information |
Information regarding your mobile telephone, your
computer, your IP address, the type of Internet browser you are using, the
location from which you are visiting the Site, or the areas of the Site you
visited and the actions you performed on the Site. |
Other
information |
Information provided in connection with assessing,
recording and reporting adverse events; information necessary to provide
product recalls and product safety notification; records of sample medicines
provided to healthcare professionals; information about your attendance at
programs organized or supported by DKSH; information about your interactions
with sales representatives; information in relation to complaints that you
have made; information about your calendar for appointment scheduling and
reminders. |
2.
How we collect your personal
data.
We may collect your personal
data through the following methods:
Collection method |
Description |
Directly
from you |
Including when you communicate with us over the
telephone, in person, through the Site, forms, surveys, or by email; when you
make an inquiry, complaint or report an actual or suspected adverse event;
when you use our information services; when you attend a DKSH event; when you
agree to other specific terms, privacy policies and/or consent forms required
by DKSH, |
Through
your use of the Site |
Including through the use of “cookies” that store information
on your computer, mobile phone or other device, and though other tracking
technologies like tags, pixels, clear pixels, gifs, bugs, beacons, and other
similar technologies. |
Through
third parties |
Including from organizations carrying out functions
on our behalf such as event management organizations and data analytics
organizations; pharmaceutical companies and medical device companies;
hospitals and other healthcare service providers or professionals; government
authorities and regulators; professional membership bodies; online
directories; insurers, banks and financial institutions. |
3.
Why do we collect, use and
disclose your personal data?
We
may collect, use and disclose your personal data for the following reasons, and
any other reasons which corresponds or are similar to these reasons:
Reason |
Description
|
Provision
of the Site |
This includes the provision of our services to you
based on our contractual obligations, to process and respond to your
applications, requests, comments, inquiries, reports, complaints, and other
forms you submit through the Site. |
Facilitating
our interactions with you |
This includes maintaining our business relationship
by providing you with information related to our products and services, sales
and delivery of products, performing any contract with you or as agreed by
you. If you are a healthcare professional, we may also use our personal data
to provide information to you on educational opportunities relevant to your
field, and to invite you to educational events that are relevant to your
field. |
Managing our relationship |
This includes managing our product and service
delivery, related financial transactions including invoicing for services,
and carrying out quality reporting concerning our products. |
Complying with legal requirements and DKSH policies
|
This includes processing your personal data for
income tax and national insurance deductions, record-keeping and reporting
obligations, conducting audits, complying with inspections and other requests
from law enforcement or other public authorities; ensuring pharmaceutical
business and pharmacovigilance compliance; reporting adverse events; responding
to legal processes such as subpoenas and court orders; pursuing legal rights
and remedies; enforcing or applying our Terms and Conditions and other
agreements; defending litigation and managing any internal complaints or
claims, etc. |
Sale and acquisition |
This includes when we become involved in a
transaction involving the sale of our assets, such as a merger or
acquisition, or if DKSH is transferred to another company, we may disclose
and/or transfer your personal data as part of the transaction. If the
surviving entity is not DKSH, your personal data may be used pursuant to the
surviving entity’s privacy policies, which may be different from this Privacy
Policy. |
Research and insights |
This includes strategic internal research and data
analytics. Your personal data may be combined with the information collected
from other individuals in order to generate aggregated and anonymized data
that does not contain identifying information, for commercial and non-commercial
purposes. We also use your personal data to enhance our understanding of our
users’ preferences and to improve our Site accordingly. |
Other legitimate interests |
This includes when such collection, use and
disclosure is permitted under the Personal Data Protection Acts such as when
it is necessary for the performance of a contract to which you are a party,
or in order to take steps as requested by you, when it is for our lawful
interests or for other parties’ lawful interests which override your fundamental
rights, when it is for the prevention or suppression of danger to a person’s
life, body or health, when it is necessary for the completion of our tasks in
the public interest, when preparing historical documents or archives for
public and education interest or for purposes relating to research or
statistics, and for the compliance of applicable laws. |
4.
Who may have access to your
personal data?
We may share, or otherwise
disclose your personal data to the following parties:
Parties |
Our group companies, business partners and/or other
persons that we have a legal relationship with, including our directors,
employees, third party contractors, authorized representatives, and advisors. |
Local and international governmental authorities
and/or supervisory or regulatory authorities, credit bureaus, fraud
prevention agencies, courts, health authorities, professional organizations
or any persons whom we are required or permitted by laws, regulations, or
orders to share personal data. |
Our suppliers, agents and other entities including
pharmaceutical companies, medical device companies and health service
providers where the disclosure of your personal data has a specific purpose
and is done under a lawful basis, including third parties providing services
to us. |
Any relevant persons as a result of activities
relating to selling rights of claims and/or assets, restructuring or
acquisition of any of our entities, where we may transfer their rights to,
and any persons with whom we are required to share data for a proposed sale,
reorganization, transfer, financial arrangement, asset disposal or other
transaction relating to our business and/or assets held by our business. |
Insurers, banks, financial institutions, and third
parties where required by law. |
Attorneys, authorized persons or legal representatives
who have lawfully authorized power. |
To the extent permitted under
applicable laws, we have contracts in place with these parties to ensure that
personal data is processed based on our instructions and in compliance with
this Privacy Policy and any other appropriate confidentiality and security
measures. We only share your personal data with the parties mentioned above and
other third parties, as far as this is reasonably necessary for the purposes as
outlined in this Privacy Policy.
Please note that DKSH
companies and subsidiaries, as well as authorities, customers and suppliers to
whom we may disclose your personal data, may be located outside of your country
of domicile, whose data protection laws may differ from those in the country in
which you are located. In such cases, we will ensure that appropriate
safeguards are in place to protect your personal data by implementing
appropriate legal mechanisms, such as EU Standard Contractual Clauses. For more
information, please contact us as described in the section “How to contact
us”.
5.
How long will your personal
data be stored?
DKSH will store your personal
data as long as necessary for the purposes outlined in this Privacy Policy,
unless a longer or shorter retention period is required or permitted by law.
6.
How is your personal data
secured?
DKSH has implemented technical
and organizational measures to protect your personal data against accidental or
unlawful destruction, loss or alteration and unauthorized disclosure or access
to your personal data. These measures include training of our personnel who may
have access to your personal data.
7.
What rights do you have in respect
to your personal data?
You
can exercise the rights relating to your personal data below:
Your right |
Description
|
Right
to withdraw consent |
You have the right to withdraw your consent that
has been given to us at any time pursuant to the methods and means prescribed
by us, unless the nature of consent does not allow such withdrawal. Please
note that the withdrawal of consent will not affect the lawfulness of the
collection, use, or disclosure of your personal data based on your consent
before it was withdrawn. |
Right to access and obtain copy |
You have the right to access and obtain copy of
your personal data held by us, or to request the disclosure of details on how
your personal data was acquired, unless we are entitled to reject your
request under applicable laws or court orders, or if such request will
adversely affect the rights and freedoms of other individuals. |
Right to data portability |
You have the right to receive your personal data
where we have arranged such personal data in a format which is readable or
commonly used by ways of automatic tools or equipment, and which can be used
or disclosed by automated means. you also have the right to request us to
send or transfer your personal data to a third party, or to receive your
personal data which we have sent or transferred to a third party, unless it
is impossible for us to do so because of the technical circumstances, or if
we are entitled to lawfully reject your request. |
Right to object |
You have the right to object to the collection, use
or disclosure of your personal data at any time where such personal data was
collected, used, or disclosed on a lawful basis, or for the purpose of direct
marketing, or for the purpose of scientific, historical or statistic
research, unless we have legitimate grounds to reject your request according
to applicable laws. |
Right to erasure |
You have the right to request us to delete, destroy
or anonymize your personal data, unless we have legitimate grounds to reject
your request according to applicable laws. |
Right to restrict |
You have the right to request us to restrict the
use of your personal data under certain circumstances, such as when we are processing
your request to rectify your personal data. |
Right to rectification |
You have the right to rectify your inaccurate
personal data and to update your incomplete personal data. |
Right to lodge a
complaint |
You have the right to make a complaint with the
Personal Data Protection Committee according to the Personal Data Protection
Act B.E. 2562 (2019) if you believe that we are not in compliance with
applicable laws. |
To exercise any of your rights above, please contact us as
described in the section “How to contact us” below. After receiving your proof
of identity, we will respond to your requests within one month.
8.
Cookies.
The
Site uses cookies for your convenience to collect and store information that your
browser makes available when you visit the Site, so that you do not have to
reenter your data upon each visit. This information includes your IP address,
browser type, browser language, and the date and time of your query, which
enables us to better understand and improve the usability, performance and
effectiveness of the Site. This information is transmitted to and stored on DKSH’s
servers in Singapore. If you do not want DKSH to analyze your use of the Site, you
can set your browser options to reject cookies or select the privacy mode
setting on your individual internet browser. Rejecting cookies or selecting
privacy mode may affect your ability to use some features of the Site.
9.
Privacy of minors.
DKSH is committed to protecting the privacy of minors. We
do not knowingly collect, use or disclose any personally identifiable
information from minors under 20 years old. Minors are not permitted to use PSPhere.
For any minor to access the Site, the parent or legal guardian of that minor
must contact us on their behalf. If a minor has provided DKSH with personally
identifiable information, the parent or legal guardian of that minor should
contact us immediately at custcare.spore@dksh.com
to delete this information from our files.
10. Changes
to this Privacy Policy.
DKSH
may update this Privacy Policy. We will notify you about significant changes in
the way we treat personal data by sending a notice to the primary e-mail
address specified in your PSPhere account or by placing a notice on the Site.
11. How
to contact us?
If you have any questions,
comments or concerns about this Privacy Policy, or want to request access to
your personal data or exercise your privacy rights, please contact us at:
Contact |
|
Contact information |
DKSH Singapore Pte Ltd. |
|
DKSH
Singapore Pte Ltd. +65 6471 1466 custcare.spore@dksh.com |
|
|
|
Last
updated: August 2021.
© 2021
DKSH Singapore Pte Ltd.