Privacy Policy

Last Modified: 5 September 2024

Taggle Pte Ltd (“Taggle” or “we”) created this Privacy Policy to demonstrate respect for your privacy preferences and to disclose our information collection and sharing practices of personal information we receive from users of our website, accessible at portal.tagglehealth.com (the “Website”), and our mobile applications (“Health Apps” or the “Apps”) as well as use of our proprietary set of services made available through the same (“Health App Services” or the “App Services”). Regardless of whether you provide us with your Personal Information via our Website, Health Apps or Health App Services (collectively the “Taggle Services” or “Services”), we strive to honour your privacy preferences. This Privacy Policy applies to your access to and use of the Taggle Services, and by agreeing to these conditions, you agree to 1) abide by the practices described in this Privacy Policy, as may be amended from time to time, and 2) the collection, transfer, processing, storage, disclosure, maintenance and other uses of your personal and sensitive information. If you are under 21 and intend to use them, read the section OUR POLICY ON CHILDREN below carefully before using them.

As used in this policy, the terms “using” and “processing” information include without limitation using cookies on a computer, subjecting the information to statistical or other analysis and using or handling information in any way, including, but not limited to collecting, storing, evaluating, modifying, deleting, using, combining, disclosing and transferring information within our organization or among our affiliates within Singapore or internationally.

As used below, the term “Personal Information” or “Personal Data” or “Personal Identifiable Information” is used to indicate any piece of information or data that can be used to identify any individual. Personal Information may relate to you as a Member, or it may relate to the individual that is the subject of any Group that you create, if you create a Group for a child, parent or other Care Recipient.

Any other defined term that is not defined in this Privacy Policy has the meaning given that term in the respective Taggle Terms and Conditions or any Additional Terms of Service, as applicable.

CHANGES TO PRIVACY PRACTICES: From time to time, Taggle may revise its privacy practices to address changing technology, security measures and website and apps functionality. We strive to provide you with timely notice of these changes. We reserve the right, at its sole discretion, to modify this Privacy Policy, at any time and without prior notice. If we modify this Privacy Policy, we will post the modified Privacy Policy and alert you to the modified Privacy Policy on the Services or will otherwise provide you with notice of the modification. We will also update the “Last Modified Date” at the top of this Privacy Policy. By continuing to access or use the Services after we have posted a modified Privacy Policy or have provided you with notice of a modification, you are indicating that you agree to be bound by the modified Privacy Policy. If the modified Privacy Policy is not acceptable to you, your only recourse is to cease using the Services and withdrawing consent. This can be done in the privacy section of your account on the app or the online portal. Information we collect under the old Privacy Policy will remain subject to the old Privacy Policy unless and until you consent to the application of any modified Privacy Policy to such information.

THE INFORMATION WE COLLECT

PERSONAL INFORMATION: You may browse the Website and download the Services without expressly providing us any Personal Information that expressly identifies you. Depending on the type of communication or transaction you have with us, the Personal Information we collect may include, but is not limited to, your name, postal address, zip code, telephone number, organisation name, e-mail address, credit card information, bank information or billing information, surveys, demographic information (such as your age, education, occupation, gender, date of birth, personal contacts) and photographs. However, in order to make full use of the Services as made available via the Services, you will be required to register with us. When you register with us to create an account and become a Member, we will ask you for certain Personal Information. In order to set up your account, you need to provide your email address and you will need to select a password. If you elect to add any other Personal Information to your Account, we will collect that information and data and use it and share it as set forth below. When you use or interact the Services as a Member, the Services automatically collect and process data (“Health Data”) to help you to track your fitness, nutrition, activity levels, sleep etc, to provide you with feedback and recommendations.

HEALTH DATA: Health Data is data that is clearly or inherently medical data. Health Data may include, but not limited to, raw data that the Services or other third-party applications or services have obtained from sensors, which is processed by the Services or other third-party applications or services and can be used independently or combined with other data to come to a conclusion about the user’s health status or potential health risks, or data where conclusions can be drawn about the user’s health status or health risks based on information gathered by the Services or other third-party applications or services. We collect Health Data when you supply us with the data in the Services manually, when you use or interact with features in the Services that are designed to capture Health Data, when you leverage technologies that integrate/connect with our Services that share Health Data with the Services such as third-party applications, services or wearables, and when we calculate additional information from Health Data that you might supply to us. Health Data may include, but not limited to, body measurements, activities, vital signs, sleep and how you felt about your physical or mental conditions such as eczema conditions or anger level. Depending on the Services being used you can also choose to share medical records and other medical information.

As a Member, you may set up one or more Groups within the Services; the Group may be created for a child, parent or other Care Recipient. When you set up a Group, you will be asked to provide Personal Information about the individual that is the subject of the Group, whether yourself or your child, parent or other Care Recipient. When you set up a Group in Services, we will collect and store any Personal Information that you may elect to provide to us as part of the Group Content, which may include, but is not limited to, medication information, notes on symptoms and other medical information, medical treatment instructions, medical appointments, insurance information, doctor’s contact information, advance directives, and prescription information. In the event you set up a Group that relates to someone other than yourself, you are solely responsible for ensuring that you have any and all consents and permissions to share that Personal Information with us and to use that information as part of Services.

As a Member you also have the option to share information with your doctor, care givers, GP, Nursing homes, Daycare centres or other persons you choose to share your data with. It is possible to share information with 1) Individuals 2) Groups (for example a family or clinic setting) 3) External connections using FHIR connection standards for example to exchange medical records. Access of groups, individual or external connections to your personal data and health data can be managed in the app or online portal in the Privacy section.

You may provide us with Personal Information of a third party Caregiver, as contemplated by the Services Terms of Service, to access a Group that you create. If you elect to invite any third party to access a Group connected to your Account, we will ask you for such third party’s name and email address, and you should only provide this information if you had already obtained the third party’s consent for doing so. We will send the third party emails inviting him or her to register for Services. We store this information for the sole purpose of sending this one-time email. The third party may contact us at privacy@tagglehealth.com to request that we remove this information from our database. We cannot control whether such third party will elect to register for Services.

LOCATION INFORMATION: The Services, with your consent, may access your location. Our Services will only access your location services provided you have opted in to activate this feature. You may choose to allow Services to access your location by granting the Services access to your device’s location, when prompted by the Services, or through your device’s location services settings. Our Services uses the Google Maps API(s) for location searches. Pursuant to the Google Maps APIs Terms of Service, use of this location feature is also subject to the Google privacy policy, which can be found at https://www.google.com/policies/privacy/, and is incorporated with this reference.

NON-IDENTIFYING PERSONAL INFORMATION: We also collect the following information any time you visit our Services, as applicable. This information may not necessarily identify you, but if we have your Personal Information, or you otherwise set up an Account with us, we may link any of the below non-personal information with your Personal Information in our records.

BROWSER LOG DATA: When you visit the Website, whether as a Member or a non-registered user just browsing the Website, our servers automatically record information that your browser sends whenever you visit the Website (“Browser Log Data”). This Browser Log Data may include information such as your computer’s Internet Protocol (“IP”) address, browser type, operating system or the webpage you were visiting before you came to our Website, pages of our Website that you visit, the time spent on those pages, access times and dates, and other statistics. We use this information to monitor and analyse use of the Website and for the Website’s technical administration, to increase our Website’s functionality and user-friendliness, and to better tailor it to our visitors’ needs. We do not treat Browser Log Data as Personal Information or use it in association with other Personal Information, though we may aggregate, analyse and evaluate such information for the same purposes as stated above regarding other Non-Identifying Information.

COOKIES: A “cookie” is a small piece of data that is sent to your browser from Taggle’s web server and is stored on your computer’s hard drive. Cookies are used to collect non-identifying information about the user, such as Web surfing behaviour or user preferences for a specific website. Taggle uses two different types of cookies – session-based and persistent cookies. Session-based cookies enable certain features of the Website, help us understand how you interact with the Website and monitor aggregate usage by users and web traffic routing on the Website. Session-based cookies expire at the end of a browser session so the cookie simply terminates once you close your browser. Persistent cookies save your login information for future logins to the Website. Persistent cookies remain on your computer until you remove them. Persistent cookies are also used to provide internal website analytics. You can manually delete all cookies including persistent ones within your browser privacy. You can also set your browser to not accept cookies although this may prevent you from using some of the services offered by the Website. In addition, Taggle uses “pixels,” or transparent GIF files, to help manage online advertising. These pixels do not collect identifying information. The mechanisms identified here are used to improve the user experience on the Website, and are employed irrespective of “Do Not Track” requests.

APP USAGE DATA: When you use our Services, whether as a Member or a non-registered user, our servers automatically record information that your mobile device sends whenever you use an Internet service (“App Usage Data”). This App Usage Data may include information such as your computer’s IP address, device model and version, device identifier, operating system, time zone, name of your mobile operator or Internet service provider (ISP), application performance measurements, and error conditions. It may also include a record of when specific features of the Services are used. We use this information to monitor and analyse use of the Services and for their technical administration, to increase their functionality and user-friendliness, and to better tailor them to our visitors’ needs. Except in response to a customer support request or after registering for Member Services, we do not treat App Usage Data as Personal Information or use it in association with other Personal Information, though we may aggregate, analyse and evaluate such information for the same purposes as stated above regarding other Non-Identifying Information.

WHERE AND WHEN WE COLLECT PERSONAL INFORMATION: You will be asked to provide your personal information when making purchases at our online Store, requesting communications, applying for a job with Taggle and/or in connection with other Taggle business (whether it is via the Website, Services, email, direct mail or telephone communications).

WITHDRAWING YOUR CONSENT

The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you. You may withdraw consent and request us to stop using and/or disclosing your personal data in the privacy section of the app or online portal or by sending the request by email to our Data Protection Officer at the contact details provided below.

Upon receipt of your request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed. Following the request the data will be anonymized by deleting any identifying information. The personal data will be deleted after withdrawing consent or ending our membership Services. The rest of the data will be anonymized using the Safe Harbour principles.

CONSEQUENCES OF WITHDRAWING CONSENT.

Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our goods or services to you and we shall notify you before completing the processing of your request. As a consequence of de-identifying the data we will also not be able to retrace the use, processing and disclosure of the data related to this person. Please note that withdrawing consent does not affect our right to continue to use and disclose personal data where such use and disclose without consent is required under applicable laws.

ACCESS TO AND CORRECTION OF PERSONAL DATA. If you wish to request a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, or to correct or update any of your personal data which we hold about you, you can go to the privacy section of the app or online portal.

We will respond to your request as soon as reasonably possible. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so.

ACCURACY OF PERSONAL DATA. We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, please update your personal information in the app or the online portal if there are changes to your personal data.

RETENTION OF PERSONAL DATA. We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws. We will cease to retain your personal data, or remove the means by which the data can be associated with you, when you withdraw your consent or end the Membership.

INTERNATIONAL CROSS-BOUNDARY TRANSFER OF PERSONAL DATA. We generally do not perform international cross-boundary transfer of data. 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.

DATA PROTECTION OFFICER. You may contact our Data Protection Officer by email if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request: privacy@tagglehealth.com

INFORMATION SECURITY — HOW WE PROTECT YOUR DATA: Taggle has a layered security in our systems and only designated employees have access to hard copies of your personal information. All online transactions are done on a secure server. This means that information entered on the transaction page is encrypted using SSL (Secure Socket Layer) before transmission. On secure pages, a “closed” lock symbol is displayed in the bottom part of your browser screen and the website address in the address bar at the top of the browser screen starts with an “https” instead of an “http”. Online Payment pages are verified by Verisign and transactions are processed using a Verisign merchant account. We use reasonable measures to protect personally identifiable information that is stored within our database, and we restrict access to such information to those employees and agents who need access to perform their job functions, such as our customer service personnel and technical staff. However, please note that we cannot guarantee the security of this information. Unauthorised entry or use, hardware or software failure, and other factors may compromise the security of member information at any time. In the event we become aware of a security incident, we will notify you to the extent required under applicable law.

HOW WE USE THE INFORMATION COLLECTED: We do not sell your Personal Information.

As applicable, the Personal Information you provide to us, as well as any Group Personal Information to provide App Services, may also be used to:

contact you about the Services;
contact you relating to your membership or user status;
confirm or fulfill an order you have made;
inform you of a prize you have won;
monitor or improve the use of the Services;
customise the content you see on the Services;
monitor compliance with the Terms of Use for the Services;
maintain Services security;
enhance navigation;
To connect the health data in the portal or app with medical records if the data subject chooses to use those services

Additionally, we may request for your consent via other means if we need to :

send or offer you a newsletter; and
send you promotional material or special offers on behalf of our partners and/or affiliates;
For communication between Members within a Group;
For communication with a treating doctor or other healthcare providers;

TAGGLE MAY SHARE YOUR PERSONAL INFORMATION: Your Personal Information will also be used to provide you access to the various sections of the Services that have been personalised for your needs. Except in the limited circumstances outlined below, Taggle will never intentionally share your email addresses, phone numbers or financial information.

EXCEPTIONS: Taggle reserves the right to share your personal information in certain situations:

SPONSORS: If you register with us through the Services that is co-branded with a sponsor or care association, we will disclose your name and email address to that sponsor or association. We do not and cannot control how that sponsor or association uses your information. You must contact the sponsor or association directly with respect to such third party’s use of your Personal Information or other information.

CAREGIVERS: Caregivers register for access to the Services pursuant to an invitation issued by the primary Caregiver for a Group. For example, the primary Caregiver creates a Group for a child, parent or other Care Recipient, and adds a professional Caregiver into the Group. All Group Members of a Group will have access to all Group Member Profiles related to the Group. Taggle cannot control how any Caregiver may use or disclose or otherwise exploit any Personal Information or other Group Content that you may elect to make available to such third party. Taggle will warn and share the types of information that will be disclosed to Caregivers. You release Taggle from any responsibility and liability resulting from any third party access to any Personal Information or Group Content that you may permit. Any information you choose to provide and make available to third parties via Services should reflect how much you want others to know about you and the individual(s) whose information is in your Group.

OTHER THIRD PARTIES: If you elect to use or otherwise take advantage of some of the other third party services that we may provide and make available to you, we will share certain of your information with such third party and will disclose to you at the time what information would be necessary to share with such third party.

AGGREGATE INFORMATION AND NON-IDENTIFYING INFORMATION: We may aggregate and combine information that may include all Personal Information that we receive through your Member Accounts and your Groups with the information of other Members and Groups and we may otherwise disclose non-Personal Information with third parties for industry analysis, demographic profiling and other purposes. We use this anonymous information to attempt to improve the quality and value of our services, to provide a better user experience and to analyse and understand the usage behaviour of our Services.

CREDIT CARD TRANSACTIONS, ELECTRONIC FUND TRANSFERS, PAYMENTS BY CHEQUE OR MONEY, ORDER AND ONLINE TRANSACTIONS. Taggle uses third parties to provide credit card, bank, payment and information processing services and order fulfilment services. If you choose to make an application for employment, make an online transaction, by phone, through the mail or by other means, or make a purchase from our online Store, we will share your Personal Information with our processing service providers. We make an effort to require all third party service-providers to hold personal information in strict confidence. While we believe these other companies are upstanding and will treat your Personal Information responsibly, we do not own or control them and cannot guarantee your privacy.

REQUESTING COMMUNICATIONS: We share information provided by our Website visitors with third parties that provide services on our behalf to make the Services available – for example, to send communications. These service providers are not authorised by us to use or disclose the information except as necessary to perform services on our behalf or to comply with legal requirements.

NECESSITY: If we have reason to believe that there has been some inappropriate interference with or use of our website, communications, products, services or personal or real property, or if we have reason to believe that one of the Taggle service users, employees or other related parties may have been injured or may have harmed some other party, we will disclose, without notice to you, personal information as we deem appropriate or if compelled by a legal or regulatory authority.

MERGER, ACQUISITION OR OTHER CORPORATE RESTRUCTURE: We also may sell, transfer or otherwise share some or all of your Personal Information to a third party successor in interest if we are involved in an acquisition, merger or other transfer of control or sale of assets or in the event of bankruptcy.

TRAFFIC MEASUREMENT SERVICES: The Services may use a third party traffic measurement service to analyse the traffic on the Services. Audience and Traffic Measurement Services allow us to collect anonymous traffic and behaviour information from our Services by monitoring anonymous visitor activity. Our current policy is that we permit the Services’ traffic measurement services to set and access their own cookies on your computer.

WEBSITE LINKS: In order to provide certain services and goods at our Services, we contract with other companies and individuals. These additional services and goods may include “links” to other websites. Taggle’s privacy practices may not be applicable at any third-party sites. The fact that we link to a website is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. Anytime you leave the Services, we have no control regarding what information may be collected about you, nor do we control what third-parties might do with the information. For example, when you click on a merchant’s name at the Website, you will be connected with the third-party merchant’s website (even if the Taggle name/logo is on the screen). This merchant website should have its own privacy policy applying to transactions at their website. It is important that you review any privacy policies on third-party sites carefully, BEFORE you use any services or programs offered.

OUR POLICY TOWARD CHILDREN: The Member Services are not directed to persons under 18. We do not knowingly collect or solicit personal information from anyone under the age of 18 or knowingly allow such persons to provide us with their personal information without parent or guardian consent. If you are under 18, do not send any information about yourself to us, including your Personal Information, unless you have your parent’s or guardian’s permission. If you have created a Group for a minor Care Recipient or Care Giver under the age of 18, you represent and warrant to Taggle that you are the parent or legal guardian for that minor with a right to provide us the Personal Information of that minor. In the event we learn that we collected Personal Information from anyone under the age of 18, and do not have a parent or guardian’s consent, we will delete that information as quickly as possible. If you believe that we might unrightfully have any information from or about anyone under the age of 18, please contact us at privacy@tagglehealth.com.

CHANGING OR DELETING YOUR PERSONAL INFORMATION: All Members may review, update, correct or delete their Account information and any associated Personal Information or Group Content in the Privacy section of the app or online portal. If you would like to close your Account, delete any Group from your Account or change your privacy preferences you can go to the Privacy section of the app or online portal.

DO NOT TRACK SIGNALS AND AD NETWORKS: Our Website does not have the capability to respond to “Do Not Track” signals received from various web browsers. At this time, we do not participate in any third party service that tracks users across websites and over time.

IDENTITY THEFT: Identity theft is of great concern to Taggle. Safeguarding information to help protect you from identity theft is a top priority. We will not, at any time, request your login information, passwords, credit card information or identification numbers in a non-secure or unsolicited e-mail or telephone communication.

REPORTING A PROBLEM: If you feel your account may have been compromised, or you discover abuse or misuse of the Services, please report it immediately on our support page or send an email to privacy@tagglehealth.com and we will investigate.