Privacy Policy

DATA PRIVACY POLICY  

Asia Assistance Network (M) Sdn Bhd (“Asia Assistance”, “we”, “us” or “our”) is committed to maintaining the privacy of personal data obtained in the course of its business activities and comply with the Personal Data Protection Act 2010, the aplicable regulations, guidelines, orders made under the Personal Data Protection Act 2010 (collectively referred to as the “PDPA”) regarding the processing of personal and sensitive personal information. Our Data Privacy Policy regarding the collection and use of your personal data is set forth below. Who is your personal data Controller?

You are hereby informed that your personal data will be processed by Asia Assistance and/or its affiliates, sub-contractors, third-party service provider in Malaysia which is operating the platform or any person under a duty of confidentiality to which has undertaken to keep your personal data confidential which we have engaged to discharge our services to you.

By providing your personal data including sensitive personal data to us and by accessing the AWAKEN platform whether through website or mobile app, you declare that you have read and understood this Data Privacy Policy and agree to us processing your personal data in accordance with the manner as set out in this Policy.

In order to ensure that your personal data are processed lawfully and transparently,  Asia Assistance has a Data Protection Officer, who may be reached at the following e-mail address:legal@asia-assistance.com

User registration

When you register in the AWAKEN, you should keep your user name and password  confidential. If you choose to share your user name and password, you understand that those individuals to whom you share that information will have access to your personal data and will be able to add, delete or amend your personal data as though they were you. You shall bear sole responsibility for all activities by users resulting from sharing or not maintaining the confidentiality of your user name or password.

What are the purposes of your data processing?

Your personal data will be processed for the following purposes:

  • Management of registration on the AWAKEN , , to include relations between the AWAKENand its users, in order to ensure that the latter enjoy its advantages and benefits, contents and services, for which a user may be reminded of his/her appointments by SMS or e-mail. If minimum data are not provided for registration, the latter may not be completed.
  • Delivery of commercial correspondence or newsletters, whether or not personalised, on health, healthcare, wellbeing, physical exercise, nutrition, healthy lifestyles
  • Personal profiling based on browsing behaviour, sociocultural factors and the use of big data processing techniques, for market analysis purposes and to inform users on health services, wellbeing, healthcare, physical exercise, nutrition and healthy lifestyles, which may be of interest. This profiling may only be carried out if authorised by the user.
  • Profiling and completion of surveys and check-ups in order to provide the user with personalised recommendations on health and lifestyles. This profiling will only be carried out if, after your registration as a user, the relevant sections are completed on the AWAKEN  for surveys and medical check-ups (to be filled in voluntarily). This profiling may only be carried out if authorised by the user.

In any case, all personal data will be treated confidentially and will be adequate, pertinent and not excessive for each one of the purposes indicated and authorised at all times by the user.

Lawfulness of your personal data processing

We will process your data lawfully, on the following grounds:

  • Consent for the management of your registration on the AWAKENand the maintenance and provision of contents and services offered by AWAKEN constitute our main lawful grounds for the processing of any personal data requested.
  • Consent to delivery of commercial correspondence and newsletters.
  • Consent to personal profiling, for market analysis and adequate delivery to the user of personalised commercial correspondence, based on the information and profiling available at all times.
  • Consent to personal profiling, based on health surveys and medical check-ups in various sections of the AWAKEN platform, voluntarily completed by the user.

 Disclosure of your personal data

Your personal data will not be sold, rented, transferred or disclosed to third parties, except in the following cases and always subject to  your prior acceptance:

  • To SENDINBLUE, with registered address in 55 rue d’Amsterdam, 75008 Paris, in order to forward you transactional e-mails related to the AWAKEN , and other e-mails with tips on health and healthy lifestyles.
  • We may use your identifiable health information or other information that you voluntarily provide us in order to provide you with information, products or services that you may request from the us. We may share your information only with our service providers and/or vendors to the limited extent permitted by the applicable data protection laws. We will require those service providers and vendors to comply with all applicable data privacy laws and regulations.
  • Aggregate data is information that describes the habits, treatment plans, usage patterns, other medical record data and/or demographics of users as a group but does not reveal the identity of particular users. The data will not identify you but will be used as statistical information to determine such things as user demographics and usage patterns of the Awaken. We may use aggregate data to understand the needs of our clients or health care service providers and determine the best programs and services we can help to provide.
  • Other third-party service or product providers as may be determined by us to be necessary or appropriate who shall be under a duty of confidentiality to which has undertaken to keep your personal data confidential.

Transfer of your personal data outside of Malaysia

The storage facilities and servers for AWAKEN may be located outside of Malaysia. For this purpose, you hereby consent to us transferring your personal data outside of Malaysia. We ensure that reasonable steps are taken to procure that. all such third parties outside of Malaysia that we engaged or appointed shall not use your personal data other than for the purpose of the content and services offered by AWAKEN.

For how long will we store your personal data once you have de-registered?

Your personal data will be blocked when they are no longer necessary for the purpose for which they were gathered and destroy your personal data from our records and system in accordance with our data retention policy except that your personal data is required to be retained to satisfy longer retention period for operational, legal, regulatory, tax or accounting requirement.

What are your data processing rights?

Your data protection rights are:

  • Right of access to your personal data

Subject to the exception provided under the PDPA, you are entitled to request for access to, request for a copy of, a request to update or correct, your personal data held by us. Small fee may be charged as permitted under the PDPA. Nevertheless, we have the right to refuse your request to access or correct your personal data if providing such access is perceived to be harmful to the risks of your privacy or the rights of other may also be violated.

  • Withdrawal of consent and total or partial objection to the processing.

You are entitled to revoke your consent and to challenge the processing at any time, for reasons related to your individual situation, should the processing be based on our legitimate interest or that of a third party (including any processing aimed at direct marketing and profiling). In this case, we  will cease its processing andyour relationship with us will have to be terminated.

For any doubt or additional issue related to the exercise of your rights or, in general, the processing of your personal data, you may contact our Data Protection Officer at  legal@asia-assistance.com