PRIVACY POLICY

Redwood Psychology (by Redwood Ventures Pte. Ltd.) (“we”, “us”, “our” or “Redwood Psychology”) recognises the importance of protecting the privacy and the rights of individuals (such persons hereon referred to as “you” or “yours”) which include any minor on whose behalf you are acting for in relation to their personal data.

This privacy policy (“Privacy Policy”) tells you how we will collect, use, disclose or otherwise process your personal data.

1 Collection of your information

1.1 Depending on the nature of your interaction with us, we may collect the following types of personal data about you;

1.1.1 general information about you such as your name; residential address; email address; gender; nationality; personal identification number (e.g. identity card, NRIC, FIN or passport number); telephone contact number; date of birth; marital status;

1.1.2 next of kin information (e.g. emergency contact name, relation to client and contact details);

1.1.3 bank account and credit card details;

1.1.4 data related to your insurer, employer or other payor, if these parties are paying for the service; and

1.2 We do not collect your personal data unless: (a) it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your personal data to us, after: (i) you (or your authorised representative) have been notified of the purposes for which the data is collected; and (ii) you (or your authorised representative) have provided written consent to the collection and usage of your personal data for those purposes; or (b) collection and use of your personal data without consent is permitted or required by the Personal Data Protection Act 2012 (“PDPA”) or other laws.

1.3 If you provide personal data of a third party with us (e.g. next-of-kin information), you confirm that you are duly authorised by that third party to do so for the purposes for which you have provided that personal data to us. Where collection of children’s personal data is made through persons claiming to be parents or guardians, we may (but are not obliged to) require proof to verify such claims.

1.4 Personal data may be collected by us via any form of interaction with you, including:

1.4.1 when you submit any form, including but not limited to customer inquiry forms or other forms relating to any of our services;

1.4.2 when you enter into any agreement or provide other documentation or information in respect of your interactions with us, or when you use our services;

1.4.3 when you interact with our staff, including our therapists and administrative team, for example, via telephone calls (which may be recorded), letters, fax, face-to-face meetings, social media platforms (including Facebook, WhatsApp) and emails;

1.4.4 when you interact with us via our websites or use services on our websites;

1.4.5 when you request that we contact you or request that you be included in an email or other mailing lists;

1.4.6 when you respond to our request for additional personal data;

1.4.7 when your images are captured by us via CCTV cameras while you are within our premises, or via photographs or videos taken by us or our representatives when you attend our events;

1.4.8 when you are contacted by, and respond to, our marketing representatives, administrative team and customer service officers.

1.5 If you do not provide us with the personal data described above, we may not be able to provide the requested services to you, either to the same standard as if you had provided the personal data or at all.

2 Purpose of Collection and Use

2.1 We collect, use, process and disclose your personal data for the following purposes:

2.1.1 setting up your client account with our clinic;

2.1.2 providing services to requested by you;

2.1.3 updating client records and sharing client records with other health related service providers;

2.1.4 providing a reply to other healthcare organisations or providers who have referred clients to us;

2.1.5 further developing our products and services;

2.1.6 communicating with insurance companies and other payors relating to your claims;

2.1.7 processing and responding to any complaints or enquiries made by you;

2.1.8 uploading onto computer systems operated or managed by third parties client health records for record keeping purposes;

2.1.9 carrying out research, planning, and statistical analysis and for the purposes of product development, outcome evaluation and operational needs;

2.1.10 complying with any law, rule, regulation, lawful and binding determination, decision or direction of a regulator, or to co-operate with any governmental authority; and

2.1.11 sending clients newsletters, email reminders, text messages and other electronic means of communication.

2.2 We will not be sharing, selling, renting or disclosing your personal data other than as described in this Privacy Policy.

3 Disclosure of Personal Data

3.1 We may disclose your personal data to:

3.1.1 our affiliates, contractors or third party services providers for the purposes set out in paragraph 2.1;

3.1.2 health related service providers and other healthcare institutions upon referral to provide healthcare services (whether that is upon our referral of a client or another party’s referral to us);

3.1.3 websites, publications or scientific forums for the purposes of publishing research results and outcomes (your data will be aggregated and anonymised);

3.1.4 insurers, employers and other payors in relation to client claims;

3.1.5 the purchaser (or prospective purchaser) of any business or asset which Redwood Psychology (by Editing Ventures Pte Ltd) is (or is contemplating) selling;

3.1.6 law enforcement agencies or regulatory authorities where we are required to do so by law;

3.1.7 relevant parties where it is necessary for legal proceedings; or

3.1.8 any other organisations for any authorised purpose with your expressed consent.

3.2 The purposes listed in the above clauses may continue to apply even in situations where your relationship with us has been terminated or altered in any way, for a reasonable period thereafter (e.g. to allow for the transfer of your records to another health service provider).

4 Access, Correction and Withdrawal of Consent

4.1 If you, at any time, have any enquiries, requests and feedback relating to your personal pata or this Notice, please submitting your request to our Data Protection Officer at the contact details provided in Clause 8 of this Notice. This includes any request:

for a copy of your personal data in our possession or control (in which case we may charge an administrative fee);
to withdraw your consent for the collection, storage, use and disclosure of your personal data by us; or
to correct your personal data in our possession or control.

4.2 In respect of your right to access or correct your personal data, we have the right to take steps to verify your identity before fulfilling your request. Please be aware that it may take up to 30 days from the date which your request was sent for any change to be reflected in our systems. Therefore, you may still receive marketing or promotional materials/communication during this period of time.

4.3 We may however choose not to provide you with access to or correct such information, in accordance with the exceptions under the PDPA. This would include cases where:

We are satisfied on reasonable grounds that the correction should not be made;
The request for access is frivolous or the information requested is trivial;
The personal data is related to a prosecution and all the proceedings related to the prosecution have not been completed;
The personal data, if disclosed, would reveal confidential commercial information that could, in the opinion of a reasonable person, harm our competitive position.

4.4 Please also note that we are not required to correct information relating to clinical observations or opinions made in good faith. Do also note that upon your withdrawal of consent, we may not be in a position to continue to provide our products or services to you.

5 Security

5.1 We take reasonable steps to ensure your personal data is protected from misuse or loss, and unauthorised access, modification or disclosure.

5.2 Access to personal data is limited to internal employees, our authorised third-party service providers and agents only on a need-to-know basis, and to those otherwise authorised by law. We provide personal data to health care providers acting on your behalf, on the understanding that they are also bound by law and ethics to safeguard your privacy. 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.

6 Retention of Personal Data

6.1 We retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required by applicable laws. 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.

7 Transfers of Personal Data Outside of Singapore

7.1 We generally do not transfer your personal data to countries outside of Singapore. However, if we do so, we will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.

8 Contacts

If you have any questions in relation to this Privacy Policy or your personal data, please contact our Data Protection Officer at dpo@redwood.sg.

9 Changes to this Privacy Policy

9.1 This Notice applies in conjunction with any other policies, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us. We may update this Notice from time to time to ensure that our standards and practices remain relevant and comply with the applicable laws and guidelines. The latest version of this Notice supersedes earlier versions and will apply to personal data provided to us previously. We encourage you to review this page periodically to keep up to date with any changes to this Notice. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.