HEARLIFE PTE. LTD. (“hearLIFE” or as appropriate in the context, “we”, “us” or “our”) respects the protection of the Personal Data of individuals and value the relationship we have with you. This Personal Data Policy (“Policy”) describes the types of Personal Data we may collect from you, how we may use that information, and the parties with whom we may share it. Our Policy also describes the measures we take to protect the security of the information you provide to us, including without limitation through the hearLIFE Language Rehab Application (the “App”). We also tell you how you can reach us to update your Personal Data, ask questions you may have about our Personal Data protection practices and provide feedback on our Personal Data protection practices.
“Personal Data” in this Policy means data that can identify an individual.
1. Personal Data that we collect
The types of Personal Data that we collect from you include:
Information you provide for App registration and payment
- Full name
- Date of birth
- Ethnic group
- Personal email address
- Telephone number
- Home or other contact addresses
- Country of residence
- Credit card information
Where you give us Personal Data about other individuals e.g. emergency contact information, you confirm that you are authorized to disclose and consent, on their behalf, to the processing of such Personal Data for the purposes described in Section 2, or other purposes for which your consent has been sought and obtained.
When you use the App, you may submit information and content to your profile such as Hearing Implant or Hearing Assisted Listing Device data or your clinical notes and data.
When you take a test or survey on the App, we may record the results and retain them.
2. Purposes for which we collect and use Personal Data
We collect and use the Personal Data that you provide to us for the following purposes
- complete your requested registrations, transactions or subscriptions on the App and make available the App’s content and features to you based on your registrations, transactions or subscriptions;
- contact you in connection with your registration, transactions or subscriptions on the App, requested services through the App or other additional services that hearLIFE may make available to you including updates of the App or similar;
- contact you to respond to your customer service requests and feedback or take other actions to address your inquiries;
- personalize the content and features you see when you use the App including providing Results (information that the App automatically records during the training and practising exercises) to you if you have chosen to purchase the option of having Results sent to you;
- improve the content and functionality of the App, including troubleshooting, functionality testing and addressing issues regarding the App and its functionalities;
- improve our products and services, including improving the quality of the tests on the App;
- internal research purposes;
- inform you of our promotions and new products and services (which may not be related to the App);
- track users’ demographics, interests, and behaviours; and
- track the total number of users of the App and to each feature of the App.
We only collect and use Personal Data in accordance with Singapore’s Personal Data Protection Act and for purposes which you have consented to and for which we have been authorized. If we need to use your Personal Data for any purpose which you have not previously consented to for which your consent is required, we will seek your consent prior to using your Personal Data for the new purpose.
You are able to indicate in the Customer Consent Form the methods by which you prefer for us to contact you (e.g. Email, Phone, etc.) and indicate if you are interested in receiving news and information from us on promotions and new products.
3. Disclosure, sharing and transfer of Personal Data
We do not sell or rent Personal Data that we collect from individuals. We may share your Personal Data with companies, vendors and service providers that we contract with to provide services on our behalf, such as social media services, programming, marketing and promotions, data processing, sending out information and communications, processing credit card and other types of payment transactions, and analyzing various aspects relating to the App such as usage, functionality etc. Some of the content on the App, such as advertisements, are served by third parties, including advertisers, ad networks and servers, content providers, and technology and application providers. We may share information (including, without limitation, the number of times an advertisement has been serviced, click information, and geographic limitations) with such third parties as necessary so that they may provide the services for which they have been engaged.
We require that the parties to whom we transfer Personal Data and our service providers implement adequate levels of protection in order to protect Personal Data. We also require that these parties only process Personal Data strictly for purposes which we engage them and that are consistent with the purposes described in Section 2 above, or other purposes for which consent has been sought and obtained.
In addition, we may disclose Personal Data in the following circumstances:
- where required to do so by law;
- in response to a request from law enforcement authorities or other government officials;
- to comply with a court order or direction from a government agency or regulatory authority ordering the disclosure of the Personal Data; and
- where necessary for investigations or legal proceedings.
We may anonymize, de-identify and/or aggregate the test and survey information that we collect through the App (“Anonymized Data”) and use such Anonymized Data for commercial, statistical and market research purposes, including sharing it with affiliates and business partners. The Anonymized Data is not tied to your Personal Data in any way and cannot identify you as an individual.
4. Protection and security of Personal Data
We employ a range of technological and physical security arrangements and maintain safeguards to protect against the accidental or unauthorized access, collection, use, disclosure, copying, modification, disposal, deletion and other similar risks to Personal Data.
5. Retention of Personal Data
We only retain Personal Data for as long as the retention is required for the purposes for which we collected the Personal Data, the purposes described in this Policy and for our business and legal purposes. Generally, we do not retain Personal Data for more than seven (7) years after the original purposes for which the Personal Data was collected have ceased to be applicable, unless otherwise required by law or other mandatory directions by court or government authorities or for legal proceedings or other similar proceedings or investigations.
6. How to contact us
If you have any questions or comments about this Policy and our policies and practices on our collection, use, disclosure or retention of Personal Data, you may contact our Data Protection Officer:
Email address: DPO@hearlife.com.sg
Data Protection Officer
hearLIFE Pte. Ltd.
304 Orchard Road
05-22 Lucky Plaza Building
- wish to update or correct your Personal Data;
- wish to request for information on what Personal Data of yours we have and how we have used and shared your Personal Data during the last one year before the date of your request;
- wish to withdraw your consent to our use, collection, sharing or processing of your Personal Data; or
- have any concerns, feedback or complaints about the use and/or sharing of your Personal Data, please contact our Data Protection Officer in writing at the above contact information.
7. Updates to this Policy
We may change or update portions of this Policy at any time and without prior notice to you. Please review this Policy from time to time so you are aware of any changes or updates to the Policy. We will indicate the effective date of the Policy. If you do not agree with any of the changes or updates to the Policy, you have the option of withdrawing your consent to our collection, use, disclosure and processing of your Personal Data (please refer to Section 6 above). Otherwise, your continued use of the App will continue to.
Effective date: 21 April 2021