Privacy Policy

AWAKEN PRIVACY POLICY

31 January, 2021

 

  1. INTRODUCTION

 

Asia Assistance Network (M) Sdn Bhd (“Asia Assistance”, “we”, “us”, “our”) is committed to maintain the privacy of Personal Data obtained in the course of our business activities and comply with the applicable laws regarding the processing of personal and sensitive personal data. Our privacy policy regarding the collection and use of your information via the AWAKEN platform (either website or mobile app) is set forth below.

AWAKEN is a digital solution that allows you to measure your health and wellbeing. AWAKEN consists of several tailored plan that carries various range of services including but not limited to health assessment, health coaching, reward program and other personalized health recommendations (“Services”). Use of the AWAKEN (either through website of mobile app) including use of any products or services available in AWAKEN will be governed by this Privacy Policy.

  1. AGREEMENT TO PRIVACY POLICY & CONSENT

By accessing or using the AWAKEN platform (either website or mobile app), you expressly agree to the terms and conditions stated herein and you shall be deemed to have consented to the collection and use of your Personal Data by the Asia Assistance. In the event you do not agree with the terms and conditions of this Privacy Policy, please do not proceed to access and use the AWAKEN platform (either website or mobile app) for any purposes.

  1. PROCESSING OF YOUR PERSONAL DATA

 

For the purpose of this Privacy Policy, “Personal Data” means any data relating to a person who can be identified either from the data, or from the data together with other information that is available, or from the data together with other information that is likely to be available. Personal Data covers any information that can identify an individual such as identification numbers or characteristics such as physical, physiological, mental, economic, cultural, or social identity.  Examples include: name, pseudonyms, address, telephone number, identity card number, occupation, salary/compensation, health or personnel records, birth date, financial/bank account information, physical characteristics, etc. Personal Data is each piece of information related to the individual, regardless of the form in which it is expressed and the format in which it is kept in or on the information holder (storage media, paper, tape, film, electronic media, etc).

When you access or use the Services, we will collect and process your Personal Data such as your email address and other relevant information in order to provide the Services to you.

We also reserve the right to share your information with third parties to the extent permitted by applicable laws including but not limited to the requirements under Personal Data Protection Act 2010. Asia Assistance maintains full rights to any information collected, and may freely collect, use and disclose such information unless prohibited by this Privacy Policy or applicable law as stated above.

 

 

 

  1. PURPOSE OF PROCESSING YOUR PERSONAL DATA

Your personal data will be processed for the following purposes:

 

  • Management of registration in order for you to access AWAKEN platform (either website or mobile app);
  • To provide you the Services to ensure you can enjoy the Services, its advantages and benefits;
  • Delivery of commercial correspondence or newsletters, whether or not personalised, on health, healthcare, wellbeing, physical exercise, nutrition, healthy lifestyles;
  • Personal profiling based on your 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;
  • Profiling and completion of surveys and check-ups in order to provide you 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 platform (either website or mobile app) for surveys and medical check-ups (to be filled in voluntarily).

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.

  1. SHARING AND DISCLOSURE OF YOUR PERSONAL DATA

 

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 and or outside of Malaysia which is operating the AWAKEN platform (either website or mobile app) including third-parties provider(s) or supplier(s), or any person under a duty of confidentiality to which has undertaken to keep your personal data confidential which we have engaged to discharge the Services to you.

We will only use your Personal Data to the extent appropriate and necessary. We shall not sell, share or disclose your Personal Data to third party in ways that differ from what is discussed in this Privacy Policy.

However, we may share your Personal Data to the following third parties and or purposes:

  • Our affiliates or related companies either in Malaysia or outside of Malaysia;
  • Any person or third-party provider(s) or supplier(s) service provider engaged to provide the Services who are under a duty of confidentiality to keep your Personal Data confidential;
  • To third parties for the purpose of statistical purposes to understand trends or traffic patterns. In doing so, we shall not include any Personal Data that identifies individuals;
  • Professionals working on behalf Asia Assistance e.g. auditors, accountant or financial adviser, lawyers and/or other third parties as required or permitted by law or as we may determine to be necessary or appropriate;
  • Data centres, servers including cloud storage located within or outside of Malaysia for data storage purposes;
  • Government agencies, law enforcement agencies, regulatory bodies, statutory agencies or bodies if required to do so, to satisfy any applicable law or order of a court or attending queries from the relevant authorities.

 

 

 

  1. RETENTION OF YOUR PERSONAL DATA

 

  1. SECURITY

We are committed to ensuring that your Personal Data is stored securely. We endeavour, where practicable, to implement appropriate physical, administrative, electronic, technical and procedural security measures to safeguard your Personal Data as required by applicable law. We use industry standards, such as Secure Socket Layers (“SSL”) technology, to help safeguard against such occurrences. In certain cases, the information passed between your browser and our system is encrypted with SSL technology to create a protected connection between you and the AWAKEN platform (either website or mobile app) to ensure confidentiality.

Our data centre is both physically and electronically secured. Our servers are protected from open access to the internet by using firewall and we conduct penetration test. We limit access to Personal Data to our employees and third parties including the third-parties provider(s) or supplier(s), who we reasonably believe need to have access to your Personal Data.

  1. TRANSFER OF YOUR PERSONAL DATA OUTSIDE OF MALAYSIA

For the purpose of the Services, our storage facilities, servers and or cloud storage may be located in other jurisdictions outside of Malaysia, where your Personal Data will be stored. In addition, your Personal Data may be disclosed or transferred to our affiliates located outside Malaysia or where you access the AWAKEN platform (either website or mobile app) from countries outside Malaysia.

You hereby expressly consent to us transferring your Personal Data outside of Malaysia for the purpose of the Services and your access on the AWAKEN platform (either website or mobile app). We endeavour to ensure the appropriate measures are taken to procure that all such third parties outside of Malaysia shall protect the confidentiality and privacy of your Personal Data.

  1. COOKIES

We may use “cookie” technology on and off the AWAKEN platform (either website or mobile app). “Cookies” are small pieces of information that are stored by your browser on your computer’s hard drive. They enhance your online experience by saving your preferences while you are visiting a particular website. When you use the AWAKEN platform (either website or mobile app), we may place a cookie on your computer, which may be either temporary or permanent.

Temporary cookies are used to complete transactions with AWAKEN platform (either website or mobile app) and for other purposes such as counting the number of visits to certain web pages. These temporary cookies are eliminated when you exit your browser. A permanent cookie may also be stored on your computer by your browser. When you log in, this type of cookie tells us whether you’ve visited us before or if you are a new visitor. The cookie does not obtain any information about you or provide us with any way to contact you, and the cookie does not extract any information from your computer.

In addition, if you visit the AWAKEN platform (either website or mobile app) again after deleting a cookie, a new cookie may be activated. Since third parties may use their own cookies when you click on a hypertext link to their site or service, you should carefully review the privacy policy of other sites you link to, if any, from the AWAKEN platform (either website or mobile app).

  1. IP ADDRESSES

We may also log and track IP addresses for systems administration purposes and for reporting usage trends. Your IP address is usually associated with the physical place from which you enter the internet, the name of the domain and host from which you access the internet, the browser software you use and your operating system, and the date and time you access the AWAKEN platform (either website or mobile app). IP addresses are not used to track an individual user’s session. This information only helps us determine how often different areas of the AWAKEN platform (either website or mobile app) are visited.

We may combine non-identifiable information collected automatically (such as through IP addresses, cookies or click-stream monitoring) with any previously submitted Personal Data that we may have received.

  1. GEOGRAPHICAL LOCATION

We may collect your geographic location based on your IP address and other location-based data.

  1. YOUR DATA PRIVACY RIGHTS

 

11.1     Right of access to your personal data

Subject to the exception provided under the Personal Data Protection Act 2010, 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. 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 and your relationship with us will have to be terminated.

11.3     Data Privacy inquiries

If you have any questions about this Privacy Policy or the use of your information by, please call us at +603-7628 3888 from 9am to 5pm, Monday to Friday or email us at legal@asia-assistance.com. Please enter Data Protection Enquiry as the email subject.

 

 

  1. MODIFICATION

Asia Assistance reserves the right, at its own discretion to revise this Privacy Policy at any time without prior notice to you. If you continue using the Services after we made any changes or modification to this Privacy Policy, it shall be deemed that you agree and accept of such changes. This Privacy Policy is not a contract, nor does it create any legal or suggest any obligation on our part with another party or on behalf of another party.

 

Realise Health Privacy Notice

INTRODUCTION

 

Realise Health Sdn Bhd (Company No. 201901046372) a private limited company incorporated in Malaysia and its related corporations as defined in the Companies Act 2016 (which include the holding company, subsidiaries, jointly-controlled entities, associate companies), and its officers, directors, employees and agents (“Realise Health “Realise Health Group” or ”LiveSmart”, or “We”/“Us”/“our”/“ours”) is committed to protecting and respecting your privacy in compliance with the applicable personal data protection laws and regulations of Malaysia.

 

This Privacy Notice shall apply to any user (“user”, or “you”/“your”/“yours”) who visit our website (www.realise.my) (“Site”) and/or use the Realise Health Services.

 

A full description of the Realise Health Services can be found in the Terms of Service on our website. Unless the context requires otherwise, the capitalised terms shall have the same meaning ascribed to them in the Terms of Service.

 

This Privacy Notice is to help you understand and provide you notice of:

  • Type of personal information we collect and how we collect them
  • The purpose of collecting, processing and disclosing your personal information
  • To whom do we disclose your personal information
  • Storage and retention policy of Realise Health Group
  • Your choice in granting consent and your right of access
  • Impact of non-provision of your personal information

 

  1. TYPES OF DATA AND HOW WE COLLECT THEM

In the provision of Realise Health Services, we may collect and process the following data about you:

 

  • Personal Data: data which relate to an individual who can be identified from such data when registering for or logging into an account with us (either through registration made by you directly or by an authorised person within your organisation who handles the registration on your behalf), subscribing to our emailing lists, purchasing or using the Realise Health Services (either online or offline). Personal Data includes but is not limited to:

 

1.1.1    information to establish user’s identity and/or the identity of user’s family member, relative or other third party as the alternate contact person, such as full name, age, date of birth, gender, nationality, identification card number (e.g. NRIC or passport) and contact information (e.g. phone number, address and email address);

 

1.1.2    payment information provided directly to us during and/or after registering with us, such as details of user’s banking account, credit card/debit card or other available mode of payment; or

 

1.1.3    information obtained through biometric system other than data which contain Sensitive Personal Data.

 

  • Self-Reported Health Data: information about data subjects’ physical and mental health conditions (either past or present) such as any diseases and allergies, medical conditions, family history, behavioural or personal traits or such other health-related information that a user provided directly to us verbally or in written form (print or electronically), as and when required for the provision of Realise Health Services, particularly Health Assessment and Health Coaching;

 

  • Diagnosis Data: information generated from the processing of Pathology Samples by Realise Health or by our appointed laboratory and/or third-party service providers for analysis.

 

  • Pathology Samples: blood samples or such other bodily specimens given by the data subjects and/or user to Realise Health or to our appointed third-party laboratory for the various tests and analysis offered by Realise Health Services from time to time after registering with us;

 

  • Sensitive Personal Data: collectively, the Self-Reported Health Data, Pathology Samples, Diagnosis Data, the data subject’s ethnicity/race, religious beliefs or other beliefs of a similar nature, or identification card/document or which may contain such beliefs, and biometric information that are or linked to one or more combination of the above information.

 

  • Browsing Data: information collected during user’s visit to our Site, to provide insights into users-behaviour analysis, personalisation preferences you select as you use the Site in order for us to continually improve our service, to serve targeting advertising and monitor the marketing campaign and users-reaction, either from cookies (small text-files or tracker placed on your device), web beacon, widgets or tags (to allow a website to transfer or collect information through a graphic image request), log files and similar technologies by virtue of your use of our Site or the information input submitted via our Site including device internet protocol (IP) address; device or browser type & specification; country location; preferred language; mouse events; keypresses; log data, user ID and passwords, one-time pin (OTP) or security codes.

 

  • Anonymised Data: data pertaining to individuals that have been anonymised in any manner as to render the individual non-identifiable, or information that have been aggregated (i.e., combined with that of other users) for analytical and statistical evaluation or the results of research data such that it is unlikely that any individual may be identified through its combination;

 

  • Pseudonymised Data: information that have been pseudonymised to reduce the association between the data subject and the information during processing.

 

  • Transaction Information: user’s company name and registration number, business address, package type, order ID number, bank account of user’s business or organisation to which the user represents, transaction value and corporate documents submitted by the user.

 

  1. COOKIES POLICY

A cookie may be used in the processing of your information, such that we use it to recognise you/ your devices and collect Browsing Data during visit to our Site. If you do not wish to receive cookie, please configure your internet browser settings regarding your preference or to erase and block any cookie from your device.

 

  1. PURPOSE OF COLLECTION & PROCESSING

By accepting the terms of this Privacy Notice through the Site (or such other means as may be required by Realise Health Group), you agree that the Realise Health Group may use and disclose your Personal Data for the following purposes:

 

    • to process user’s account registration, and to manage/maintain such account on the Site or platform operated by the Realise Health Group;

 

  • to process your request/order ID number in respect of the products and/or services offered and operated by Realise Health Group;

 

  • to facilitate the administration, management and communication to give effect to the commercial transactions which relate to the products and services you have purchased or subscribed, which include to process any payments related to your requested services and render customers service support when required;

 

  • to contact you about your user account, status updates and any relevant information about Realise Health Services (including any policy change, security updates or issues);

 

  • to protect, enforce or defend our rights under the Terms of Service (or such other agreements as may be necessary);

 

  • to produce Anonymised Data and/or Pseudonymised Data to conduct internal operations and transactions within the Realise Health Group, which include but not limited to software/IT troubleshoots and diagnostics, back-end systems data transferences, records and status updates, data analytics of each transactions conducted through our technology infrastructures (both hardware or software), users’ reaction, activities and trends, and carry out quality control activities and customer services materials;

 

  • to monitor, detect or investigate into illegal behaviours or unlawful activities on the Site;

 

  • to maintain records required for internal security, preparation and submission for claims, insurance, audit checks, inspections, due diligence or other legal purposes;

 

  • to conduct marketing or promotional activities for example, market research survey, sending alerts, updates, email notifications, seasonal greetings, promotion, advertisements, vouchers, promo codes, invitations, customer loyalty or referral programme, and related updates (“Marketing and Promotions Materials”) in respect of products, services, events or privileges offered by Realise Health Group and/or in collaboration with Realise Health Group’s business partners or sponsors;

 

  • to perform internal research & development (R&D), surveys or polls, obtain testimonials, conduct marketing analysis or systems innovation activities to develop new and improved products and/or services;

 

  • to a third party acquires or offer to acquire an interest in an entity within the Realise Health Group;

 

  • to a third party with whom we have contracted to perform functions and services as required by Realise Health Group (which include the third-party laboratory, systems analysis and/or data hosting vendor or contractor, administrator operating customer database and booking system, insurance claims management or such other intermediaries) for any of the purposes as described above;

 

  • to enable Realise Health Group or a third party who performs the functions and services on behalf of Realise Health Group, to comply with any legal or regulatory obligations under the applicable laws, rules, regulations, directions, circulars, orders and guidelines that apply to Realise Health Group or such third party as required by any governmental authorities, agencies or departments, or court of competent jurisdictions;

 

  • to compile information for analysis and reports to the relevant government agencies and regulatory authorities; and/or

 

  • for any other purpose to the extent permitted by applicable law, regulations, guidelines and/or relevant regulatory authorities.

 

  1. In the event, the user is not the data subject of the Personal Data and the Sensitive Personal Data, Realise Health Group will ask for the user to cooperate and assist Realise Health with the procurement of such consent of each data subject in the appropriate form required by Realise Health Group. Realise Health Group will only use and share Sensitive Personal Data and/or the corresponding Anonymised Data with any third parties as set out in Paragraph 5 (whether within and outside of Malaysia) in accordance with the manner set out in this Privacy Notice, as follows:

 

  • Pathology Samples of a data subject will only be collected by Realise Heath Group or by its appointed laboratory or third-party service providers contracted with Realise Health Group if the explicit consent of such data subject is obtained;

 

  • Sensitive Personal Data may be used and processed by Realise Health Group or by its appointed third-party laboratory or related service providers for the purposes of:
  • analysing and generating the testing results;
  • providing healthcare recommendation to the data subject;
  • storing and performing internal administrative matters and data management procedures;

 

  • Sensitive Personal Data and Anonymised Data which may be used for research and development purposes by Realise Health Group or our qualified research collaborators (within or outside of Malaysia) if the explicit consent of the relevant data subject is obtained.

 

  1. DISCLOSURE OF DATA

There may be situations where Personal Data, Sensitive Personal Data, Pseudonymised Data or Anonymised Data are processed by and disclosed to other entities. The categories of third party include but not limited to:

 

    • Entities within Realise Health Group;

 

  • Law enforcement agencies, such as:
  • federal and state governments, ministries and government agencies
  • courts of law; or
  • local police;

 

  • Companies or organisations that have been appointed to act as our agents, our independent contractors, vendors, suppliers, service providers or business partners (including but not limited to pathology testing laboratories, electronic payment gateway, qualified logistic services provider, advertisers, marketing consultants, researchers, administrators, auditors, consultants, lawyers, business advisors);

 

  • Customers or potential customers;

 

  • Actual or prospective successor, assignee, transferee, joint venture parties or participants of the rights, interests or business of Realise Health Group;

 

  • such other parties in respect of whom the data subject has expressed consent for us to disclose (such as your immediate family members, emergency contact person as may be notified to us from time to time.

 

  1. TRANSFER OF PERSONAL DATA OUTSIDE OF MALAYSIA
    • In the event where it may be necessary for us to transfer any information/data as described under this Privacy Notice outside Malaysia, or if any of Realise Health Group, service providers or business partners that are involved in providing part of the Company’s products and services are located in countries outside Malaysia, you hereby consent to us transferring any Personal Data and Sensitive Personal Data outside Malaysia in these instances.

 

  • Reasonable steps will be taken to safeguard the Personal Data and Sensitive Personal Data whereby these service providers and business partners will not use the data for any reason other than to provide the services they are contracted to provide.

 

  • We will take reasonable steps to comply with the legal and regulatory obligations in respect of Personal Data and Sensitive Personal Data and ensure that the recipient is obliged to protect Personal Data and Sensitive Personal Data at the standard comparable to the protection under the applicable laws.

 

  1. MARKETING & PROMOTIONS

We may communicate and send Marketing and Promotions Materials to you by post, phone calls, messaging services, push notifications, emails or other mode of communications. Where you have indicated your consent to receiving Marketing and Promotions Materials, you may opt-out from receiving such Marketing and Promotions Materials at any time by contacting us at the details provided in Paragraph 13 below.

 

  1. HOW LONG CAN WE KEEP YOUR PERSONAL DATA
    • We may keep the Personal Data and the Sensitive Personal Data for as the duration of your relationship with realise Health Group, or for such period as may be necessary for us to carry out any purpose as detailed in the above sections, or as it is required by the applicable law.

 

  • For Transaction Information, Browsing Data and Pseudonymised Data, we would retain the relevant materials or documents for approximately 7 years from the point we obtained such data unless otherwise required by the applicable laws.

 

  • When data is no longer required for its purpose, we shall use reasonable efforts to ensure data is protected whilst in our possession and irrevocably deleted from our system.

 

 

  1. SECURITY

All Personal Data and the Sensitive Personal Data provided to us is stored on our secure servers. We have given user a password which enables access to our Site, we ask that you keep the password confidential and do not share with unauthorised person. As you are aware, data transmission through the internet is not completely secured. Whilst we shall use strict procedures and reasonable security features to safeguard the Personal Data and Sensitive Personal Data transmitted to and from our Site, we neither represent nor warrant that the Personal Data and Sensitive Personal Data would be free from breach of security, unlawful interception or unauthorised access that is out of our control.

 

  1. THIRD PARTY WEBSITES

Our Site may contain links to other sites provided for your convenience and information. These sites may have their own privacy policy (which we encourage you to review if you visit any of the linked sites) and we are not responsible for the privacy policies or practices of such other sites linked to us.

 

  1. WHEN CAN YOU ASK US TO STOP USING YOUR DATA
    • We rely on the data subject’s consent to collect and use Personal Data and Sensitive Personal Data to provide the products and services we offer and to communicate with you about the status of your orders.

 

  • You may withdraw your consent or ask us to stop using your Personal Data and Sensitive Personal Data at any time, however in doing so we will be unable to continue providing the service. In order to request that we stop using your data, you can send us an email to info@realise.my stating that you wish for us to stop using your data immediately.

 

  1. WHAT HAPPENS IF YOU DON’T GIVE US SOME OF YOUR DATA

It is entirely your choice as whether to provide consent for us to collect and process your Personal Data and/or Sensitive Personal Data, however where you do not provide the Personal Data and/or Sensitive Personal Data we need in order to provide the requested Realise Health Services or if such data are incomplete, we will not be able to deliver the full range of services or benefits, or perform our obligations under any potential or existing contracts with you.

 

  1. HOW TO CONTACT US ABOUT THIS PRIVACY NOTICE

You may contact us at any time via email or post, if you have questions, comments, suggestions regarding this Privacy Notice or if you would like to make a complaint in respect of your Personal Data and/or Sensitive Personal Data collected and used under this Privacy Notice.

Email: info@realise.my

Post: Att: Operations. Realise Health Sdn Bhd. Common Grounds, G.016, The Square Jaya One, 72A, Jalan Universiti, Seksyen 13, 46200 Petaling Jaya, Selangor

 

  1. YOUR RIGHTS

You have the right to access and view your Personal Data and/or Sensitive Personal Data. You may contact us via the addresses set out in Paragraph 13 above if you would like to exercise your rights as follows:

  • make corrections to your Personal Data and/or Sensitive Personal Data stored by us;
  • withdraw consent to any use of your Personal Data and/or Sensitive Personal Data;
  • request us to limit the use of your Personal Data and/or Sensitive Personal Data;
  • opt out from Marketing and Promotions Materials; or
  • access, view details request us to provide you with your Health Data stored by us.

 

  1. CHANGES TO THIS PRIVACY STATEMENT

We may amend or update this Privacy Notice from time to time by posting the amended version on our Site or by email to the email address of the user. All amended provisions shall take effect immediately upon being published or in accordance with the effective date prescribed therein.

 

  1. GENERAL

This Privacy Notice is issued in both English and Bahasa Malaysia. In the event of any inconsistency or discrepancies between the English and Bahasa Malaysia version, the English version shall prevail.

 

 

[Consent Wordings]

 

I acknowledge that I have read and understood the Privacy Notice in its entirety. I further acknowledge that under the terms Privacy Notice, Realise Health may transmit my Personal Data and Sensitive Personal Data to selected third parties and/or parties located outside of Malaysia.

 

I hereby consent to the collection, processing, storage and use of my Personal Data and Sensitive Personal Data as set out in the terms of the Privacy Notice.

 

I further consent to allow Realise Health to transmit my Personal Data and Sensitive Personal Data to selected third parties and/or to parties located outside of Malaysia as per the terms of the Privacy Notice