Personal Data Protection Act (PDPA) Policy
We at Thrive Healthcare take our responsibilities under the PDPA seriously. We also recognize the importance of the personal data you have entrusted to us and believe that it is our responsibility to properly manage, protect and process your personal data.
INTRODUCTION TO THE PDPA
1.1. “Personal Data” is defined under the PDPA to mean data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which an organisation has or is likely to have access. Common examples of personal data could include names, identification numbers, contact information, medical records, photographs and video images.
1.2. We will collect your personal data in accordance with the PDPA. We will notify you of the purposes for which your personal data may be collected, used, disclosed and/or processed, as well as obtain your consent for the collection, use, disclosure and/or processing of your personal data for the intended purposes, unless an exception under the law permits us to collect and process your personal data without your consent.
1.3. Types of Personal Data Collected :
For the purpose of carrying on the Company's business, including registration and administration of the Company's related products and services (including relevant online services), you may be requested to provide personal data such as, but not limited to, the following, without which it may not be possible to satisfy your request:
1.3.1. Your name;
1.3.2. Correspondence address, and/or billing address;
1.3.3. Payment details, including credit card and banking information;
1.3.4. Contact details, including contact name and telephone number and email address;
1.3.5. Your image taken at our premises with a web cam (or like equipment) for visual identification.
1.4. In some instances, you may also be requested to provide certain data that may be used to further improve our products and services and/or better tailor the type of information presented to you. In most cases, this type of data is optional although, where the requested service is a personalised service, or provision of a product or dependant on your providing all requested data, failure to provide the requested data may prevent us from providing the service to you. This type of data includes, but is not limited to:
1.4.1. Your age;
1.4.3. Salary range and employment details;
1.4.4. Education and Profession;
1.4.5. Health condition, hobbies and leisure activities;
1.4.6. Other related products and services subscribed to; and
1.4.7. Family and household demographics.
PURPOSES FOR COLLECTION, USE, DISCLOSURE AND PROCESSING OF PERSONAL DATA
2.1. We may collect, use, disclose and/or process your personal data for one or more of the following purposes:
2.1.1. considering and/or processing your membership application with us, including to require you to fill in relevant forms which sets out your health and lifestyle to ascertain your fitness level at the point of application with us;
2.1.2. Facilitating and managing your membership with us, including, without limitation;
a) granting you access into the facility and clubs according to the terms of your membership;
b) providing and arranging your training programmes and other lessons provided by Thrive Healthcare
c) providing you with service or Thrive Healthcare status updates;
d) administering your personal training and other training/fitness packages;
e) processing the payment of your membership fees and / or any other relevant charges that may be incurred by you;
f) operating Thrive Healthcare’s members’ database;
g) providing you with any benefits as indicated by the terms of your membership, including to administer the relevant referral programs applicable to your membership;
h) providing you with our Class Booking application for you to making booking(s) for classes;
i) facilitating the payment and provision of private locker rentals;
j) managing your access to online services provided by Thrive Healthcare;
m) managing your access to our apps (including the SugarWOD and PushPress app) and online services provided by the Company;
n) where your image is captured on any Thrive Healthcare facilities/events, to be used for publicity purposes; or
2.1.3. carrying out your instructions or responding to any enquiry given by (or purported to be given by) you or on your behalf;
2.1.4 contacting you or communicating with you via phone/voice call, text message and/or fax message, email and/or postal mail for the purposes of administering and/or managing your membership with us such as but not limited to communicating information to you related to:
a) The status of your membership;
b) any Thrive Healthcare-related status updates;
c) reminders for appointments and / or sessions that you have booked with Thrive Healthcare, whether through email or a notification through our Class Booking application;
d) outstanding payments or membership fees;
e) any of the purposes as indicated in paragraphs 2.1.1 and 2.1.2 above; or
2.1.5 carrying out due diligence or other screening in accordance with any legal or regulatory obligations or our risk management procedures that may be required by law or that may have been put in place by us;
2.1.6 to prevent or investigate any fraud, unlawful activity or omission or misconduct, whether relating to your membership with us or any other matter arising from your membership with us, and whether or not there is any suspicion of the aforementioned;
2.1.7 complying with or as required by any applicable law, governmental or regulatory requirements of any relevant jurisdiction, including meeting the requirements to make disclosure under the requirements of any law binding on us and/or for the purposes of any guidelines issued by regulatory or other authorities, whether in Singapore or elsewhere, with which we are expected to comply;
2.1.8 complying with or as required by any request or direction of any governmental authority; or responding to requests for information from public agencies, ministries, statutory boards or other similar authorities. For the avoidance of doubt, this means that we may/will disclosure your personal data to the aforementioned parties upon their request or direction;
2.1.9 conducting research, analysis and development activities (including but not limited to data analytics, surveys and/or profiling) to improve our services and facilities in order to enhance your membership with us or for your benefit, or to improve any of our products or services for your benefit;
2.1.10 storing, hosting, backing up (whether for disaster recovery or otherwise) of your personal data, whether within or outside Singapore;
2.1.11 providing and sending you marketing, advertising and promotional information, materials and/or documents relating to your membership with us which we think may be of benefit or interest to you, via (i) postal mail to your postal address(es) and/or electronic transmission to your email address(es), and (ii) if so consented by you, via telephone calls, SMS/MMS and/or facsimile to your telephone number(s);
2.1.12 if you have used our clubs as a guest or trial pass user, or have signed up with us during our promotional events, providing and sending you marketing, advertising and promotional information, materials and/or documents relating to our membership and clubs, via (i) postal mail to your postal address(es) and/or electronic transmission to your email address(es), and (ii) if so consented by you, via telephone calls, SMS/MMS and/or facsimile to your telephone number(s) provided by you;
(collectively, the “Purposes”)
2.2. As the purposes for which we may/will collect, use, disclose or process your personal data depend on the circumstances at hand, such purpose may not appear above. However, we will notify you of such other purpose at the time of obtaining your consent, unless processing of your personal data without your consent is permitted by the PDPA or by law.
2.3. In order to conduct our business operations more smoothly, we may also be disclosing the personal data you have provided to us to our third-party service providers, agents and/or our affiliates or related corporations, and/or other third parties whether sited in Singapore or outside of Singapore, for one or more of the above-stated Purposes. Such third-party service providers, agents and/or affiliates or related corporations and/or other third parties would be processing your personal data either on our behalf or otherwise, for one or more of the above-stated Purposes. Examples of service providers include companies that provide web hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, marketing, auditing, debt recovery and other services
By submitting personal data to us, you undertake and warrant that;
(a) you have the authority to provide that personal data to Thrive Healthcare;
(b) the personal data provided is accurate and true;
(c) you have informed the individual about the purposes for which his/her personal data is collected, used and disclosed as well as the parties to whom such personal data may be disclosed or transferred by Thrive Healthcare, as set out; and
(d) the individual has consented to the collection, use and disclosure of his/her personal data for such purposes.
SPECIFIC ISSUES FOR THE DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES
3.1. We respect the confidentiality of the personal data you have provided to us.
3.2. In that regard, we will not disclose your personal data to third parties without first obtaining your consent permitting us to do so. However, please note that we may disclose your personal data to third parties without first obtaining your consent in certain situations, including, without limitation, the following:
3.2.1. cases in which the disclosure is required or authorized based on the applicable laws and/or regulations;
3.2.2. cases in which the purpose of such disclosure is clearly in your interests, and if consent cannot be obtained in a timely way;
3.2.3. cases in which the disclosure is necessary to respond to an emergency that threatens the life, health or safety of yourself or another individual;
3.2.4. cases in which the disclosure is necessary for any investigation or proceedings;
3.2.5. cases in which the personal data is disclosed to any officer of a prescribed law enforcement agency, upon production of written authorisation signed by the head or director of that law enforcement agency or a person of a similar rank, certifying that the personal data is necessary for the purposes of the functions or duties of the officer;
3.2.6. cases in which the disclosure is to a public agency and such disclosure is necessary in the public interest; and/or
3.2.7. where such disclosure without your consent is permitted by the PDPA or by law.
3.3. The instances listed in the above paragraph are not intended to be exhaustive. For more information on the exceptions, you are encouraged to peruse the Second, Third and Fourth Schedules of the PDPA which is publicly available at http://statutes.agc.gov.sg.
3.4. Where we disclose your personal data to third parties with your consent, we will employ our best efforts to require such third parties to protect your personal data.
4.1.1. To improve your user experience on this website;
4.1.2. to remember your preferences;
4.1.3. to help us understand how this website is performing;
4.1.4. to monitor traffic to the website;
4.1.5. to enable this website to function properly;
4.3. Personal data (if any) that we collect from you through cookies may be passed to our third party service providers, whether located in Singapore or elsewhere, for one or more of the Purposes, for managing and/or administering our website, or for the purpose of data hosting/storage/backup.
ACCURACY OF PERSONAL DATA
Where possible, we will validate data provided using generally accepted practices and guidelines. This includes the use of check sum verification on some numeric fields such as account numbers or credit card numbers. In some instances, we are able to validate the data provided against pre-existing data held by the Company. In some cases, the Company is required to see original documentation before we may use the personal data such as with identity cards and/or proof of address.
The Company will honour an individual's request not to use his or her personal data for the purposes of direct marketing. Any such request should clearly state details of the personal data in respect of which the request is being made. Specifically, we request that you include the corresponding Company assigned account numbers which are printed on the Company's statements/invoices. Please also state clearly the authority under which you are authorized to make such a request. Unless otherwise instructed as per the above, the Company may use any of the data collected in the normal course of its business for the purposes as set out in paragraph 2.1 above.
REQUEST FOR ACCESS AND/OR CORRECTION OF PERSONAL DATA
9.1. You may request to access and/or correct the personal data currently in our possession or control by submitting a written request to us. We will need enough information from you in order to ascertain your identity as well as the nature of your request, so as to be able to deal with your request. Hence, please submit your written request via email at email@example.com.
9.2. For a request to access personal data, once we have sufficient information from you to deal with the request, we will seek to provide you with the relevant personal data within 30 days. Where we are unable to respond to you within the said 30 days, we will notify you of the soonest possible time within which we can provide you with the information requested. Note that the PDPA exempts certain types of personal data from being subject to your access request.
9.3. For a request to correct personal data, once we have sufficient information from you to deal with the request, we will:
9.3.1. correct your personal data within 30 days. Where we are unable to do so within the said 30 days, we will notify you of the soonest practicable time within which we can make the correction. Note that the PDPA exempts certain types of personal data from being subject to your correction request as well as provides for situation(s) when correction need not be made by us despite your request; and
9.3.2. subject to paragraph 9.4, we will send the corrected personal data to every other organisation to which the personal data was disclosed by Thrive Healthcare within a year before the date the correction was made, unless that other organisation does not need the corrected personal data for any legal or business purpose.
9.4. Notwithstanding paragraph 9.3(b), we may, if you so consent send the corrected personal data only to specific organisations to which the personal data was disclosed by us within a year before the date the correction was made.
9.5. We will also be charging you a reasonable fee for the handling and processing of your requests to access your personal data. We will provide you with a written estimate of the fee we will be charging. Please note that we are not required to respond to or deal with your access request unless you have agreed to pay the fee.
REQUEST TO WITHDRAW CONSENT
You may withdraw your consent for the collection, use and/or disclosure of your personal data in our possession or under our control by submitting your request via email at firstname.lastname@example.org.
We will process your request within a reasonable time from such a request for withdrawal of consent being made, and will thereafter not collect, use and/or disclose your personal data in the manner stated in 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.
13.1. 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 from time to time.
13.3. 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.
Thrive Healthcare reserves the right to alter any of the clauses contained herein in compliance with local legislation, to meet its global policy requirements, and for any other purpose deemed necessary by the Company.