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Privacy Policy

This Policy sets out the manner in which Canaan Dental Surgery Pte Ltd collects, uses, manages and protects Personal Data (as defined below) in compliance with the provisions of the Personal Data Protection Act 2012.

This Policy applies to all Individuals (as defined below) who provide Canaan Dental Surgery Pte Ltd with Personal Data or whose Personal Data is otherwise collected, used and/or disclosed by Canaa Dental Surgery Pte Ltd in connection with and/or for the purposes of its operations.

Definitions

“Data Protection Officer” means the person designated to be responsible for ensuring that Canaan Dental Surgery Pte Ltd complies with the PDPA;

“Individuals” means natural persons, whether living or deceased, and “Individual” means any of them;

“PDPA” means the Personal Data Protection Act 2012 as may be amended from time to time;

“Personal Data” means data (whether true or not) that is capable of identifying a natural person, whether on its own or in conjunction with other data that is accessible to Canaan Dental Surgery Pte Ltd. Such Personal Data shall also refer to data which is already in the possession of Canaan Dental Surgery Pte Ltd or that which shall be collected by Canaan Dental Surgery Pte Ltd in the future; and

“Platforms” mean the websites, Applications, computer systems, computer networks and any other digital platforms operated by or on behalf of Canaan Dental Surgery Pte Ltd from time to time.

How Canaan Dental Surgery Pte Ltd collects Personal Data

Generally, Canaan Dental Surgery Pte Ltd may collect Personal Data about an individual in one or more of the following ways:

  1. through application forms submitted by the Individual;
  2. through correspondence, emails, electronic messages or other forms of written communications in such manner as may be submitted by the Individual to Canaan Dental Surgery Pte Ltd or its Personnel or posted on the Platforms;
  3. through an Individual’s verbal (including voice or video calls or face-to-face interactions) communications;
  4. through the Individual’s access to and/or use or navigation of the Platforms and the use of cookies;.*
  5. through recordings taken via security cameras or other forms of photography or video or sound recording at Canaan Dental Surgery Pte Ltd premises;
  6. through third party business partners or associates of Canaan Dental Surgery Pte Ltd and
  7. when the Individual submits his/her Personal Data to Canaan Dental Surgery Pte Ltd for any other reason related to Canaan Dental Surgery Pte Ltd ordinary course of operations.

* When you visit our Platforms, we send one or more cookies to your computer and/or other devices. The information obtained from such cookies may be used by us for storing user preferences and to enable Canaan Dental Surgery Pte Ltd or third party advertising partners to display targeted advertisements which may be of interest to you. We also collect information which is sent to us by your web browser. When you browse our Platforms, we automatically receive your computer’s Internet protocol (IP) address which provides us with information that helps us learn about your browser and operating system, such as the name of your operating system and the name and version of your browser.

Purposes for which Canaan Dental Surgery Pte Ltd may collect, use and/or disclose Personal Data

Generally, Canaan Dental Surgery Pte Ltd may collect, use and/or disclose Personal Data about an Individual for one or more of the following purposes:

Consent Required

Canaan Dental Surgery Pte Ltd shall not collect, use or disclose your personal data unless:

  1. you give, or are deemed to give, consent to the collection, use or disclosure of your personal data; or
  2. The collection, use or disclosure of your personal data without your consent is required or authorised under the PDPA or written law.

Provision of Consent

Canaan Dental Surgery Pte Ltd shall not, as a condition of providing a product or service to you, require you to consent to the collection, use or disclosure of your personal data beyond what is reasonable to provide the product or service to you.

Canaan Dental Surgery Pte Ltd shall not obtain or attempt to obtain your consent for collecting, using or disclosing personal data by providing false or misleading information with respect to the collection, use or disclosure of your personal data, or use deceptive or misleading practices

Deemed Consent

You are deemed to consent to the collection, use or disclosure of your personal data for a purpose if:

  1. you voluntarily provide your personal information to Canaan Dental Surgery Pte Ltd for that purpose, albeit without actually expressly providing your consent; and
  2. It is reasonable that you would voluntarily provide the data.

Withdrawal of Consent

  1. On providing reasonable notice to Canaan Dental Surgery Pte Ltd you may at any time withdraw any consent given, or deemed to be given, in respect of Canaan Dental Surgery Pte Ltd collection, use or disclosure of your personal data for any purpose.
  2. You may submit the withdrawal of consent via email dpo@canaan.com.sg and submit to Canaan Dental Surgery Pte Ltd DPO.
  3. On receipt of such notice, Canaan Dental Surgery Pte Ltd shall inform you of the likely consequences of withdrawing your consent.
  4. Please allow up to 30 days for Canaan Dental Surgery Pte Ltd to process and update your request. You may continue to receive marketing messages and other product information from Canaan Dental Surgery Pte Ltd within these 30 days.
  5. Canaan Dental Surgery Pte Ltd shall not prohibit you from withdrawing your consent to the collection, use or disclosure of your personal data.
  6. If you withdraw your consent, then Canaan Dental Surgery Pte Ltd shall cease (and cause its data intermediaries and agents to cease) collecting, using or disclosing your personal data unless otherwise required under the PDPA or other written law.
  7. Although you may have withdrawn consent for the collection, use or disclosure of your personal data, Canaan Dental Surgery Pte Ltd may retain your personal data for purpose of administering your policy with Canaan Dental Surgery Pte Ltd and in accordance with Canaan Dental Surgery Pte Ltd Records and Retention Policy.

Access to personal data

Individuals whose personal data are kept by Canaan Dental Surgery Pte Ltd shall be allowed to access to their personal data. Canaan Dental Surgery Pte Ltd shall disclose such information, including the usage and disclosure history of the personal data that has occurred within a year of the date of request. Individuals may make request from Canaan Dental Surgery Pte Ltd for such disclosure and correction by writing to Canaan Dental Surgery Pte Ltd.

Correction of personal data

Canaan Dental Surgery Pte Ltd is committed to ensure that all personal data kept are accurate and up-to-date. To achieve this, Canaan Dental Surgery Pte Ltd recognizes individual’s participation in informing Canaan Dental Surgery Pte Ltd of any changes, error or omission in their personal data is essential. Canaan Dental Surgery Pte Ltd shall provide facilities and processes to allow individual to submit corrections to their personal data.

Canaan Dental Surgery Pte Ltd shall notify all other organisations of such corrections, if the individual’s personal data was disclosed by Canaan Dental Surgery Pte Ltd to that organization one year prior to this correction. Such notification shall take place except if Canaan Dental Surgery Pte Ltd deems the personal data is no longer relevant or needed by the organization for the purpose that Canaan Dental Surgery Pte Ltd disclosure was made earlier.

Access and correction process

The DPO will have oversight of all personal data access or correction requests and ensures that they are processed in accordance with this Policy. Request for personal data access or correction by individuals, including any enquires and complains shall be submitted to Canaan Dental Surgery Pte Ltd in writing to the DPO at the following contact information:

Data Protection Officer
Email address: dpo@canaan.com.sg

All Canaan Dental Surgery Pte Ltd staff shall forward any personal data access or correction request to the DPO in a timely manner.

Canaan Dental Surgery Pte Ltd may request for additional information from the requestor to aid in the investigation. The DPO shall verify the identity of the individual before responding to the request for access or correction. Canaan Dental Surgery Pte Ltd may respond to the requestor via telephone call, written note or electronic mail. In any case, the DPO shall make a record of such requests and responds for future reference and verification.

Verification of Personal Data & Notification of Changes

Where feasible, Canaan Dental Surgery Pte Ltd will take reasonable steps to verify the accuracy of Personal Data received at the point of collection but Individuals remain primarily responsible and liable to ensure that all Personal Data submitted by them to Canaan Dental Surgery Pte Ltd is complete and accurate. Information provided voluntarily by an Individual to Canaan Dental Surgery Pte Ltd shall prima facie be deemed complete and accurate.

Canaan Dental Surgery Pte Ltd will also take reasonable steps to periodically verify Personal Data in its possession, taking into account the exigencies of its operations, but Individuals are nonetheless required to notify Canaan Dental Surgery Pte Ltd time to time, of any applicable changes to such Personal Data.

Canaan Dental Surgery Pte Ltd shall not be held liable for any inability on its part to provide services to an Individual who fails to ensure that his/her Personal Data submitted to Canaan Dental Surgery Pte Ltd is complete and accurate or who fails to notify Canaan Dental Surgery Pte Ltd of any relevant changes to such Personal Data. In this regard, you should ensure that the Personal Data provided by you to Canaan Dental Surgery Pte Ltd is at all times correct, accurate and complete; and you agree to update Canaan Dental Surgery Pte Ltd in a timely manner of all changes to your Personal Data.

Protection of Personal Data

Canaan Dental Surgery Pte Ltd shall make reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks to Personal Data in its possession.

If Canaan Dental Surgery Pte Ltd transfers or hosts Personal Data outside Singapore, Canaan Dental Surgery Pte Ltd  will take reasonable steps to ensure that such Personal Data transferred receives a standard of protection comparable to the protection received under the PDPA.

Canaan Dental Surgery Pte Ltd will ensure that third parties who receive Personal Data from Canaan Dental Surgery Pte Ltd protect such Personal Data in a manner consistent with this Policy and not use such Personal Data for any purposes other than those specified by Canaan Dental Surgery Pte Ltd, by incorporating appropriate contractual terms in its written agreements with these third parties.

Canaan Dental Surgery Pte Ltd is not responsible in any way for the security and/or management of Personal Data shared by Individuals with third party websites or links accessible via the Platforms.

Disclosure of Personal Data to Third Party

We do not disclose personal data to third parties except when required by law, when we have your consent or deemed consent or in cases where we have engaged the third party such as data intermediaries or subcontractors specifically to assist with our firm’s activities. Any such third parties whom we engage will be bound contractually (e.g. Non-Disclosure Agreement) to keep all information confidential, but we cannot and do not assume any responsibility for any actions or omissions of third parties.

We may disclose personal data to other related companies of Canaan Dental Surgery Pte Ltd where it is necessary (i) to meet the purpose for which you have submitted the information; or (ii) to enable you to be provided with information at a later date which may be of relevance and interest to you based on the nature and purpose of your voluntary requests.

We may also transfer all data in our possession to a successor-in-interest to our business or assets.

Subject to the provisions of any applicable law, your Personal Data may be disclosed, for the purposes listed above (where applicable), to the following:

  1. Canaan Dental Surgery Pte Ltd related corporations and employees who provide content, Products and Services to you, address your questions and requests in relation to your customer accounts, subscription and billing or order arrangements with us as well as our Products and Services, to activate, deactivate, install, maintain and operate our systems and/or services;
  2. companies who provide insurance and consultancy services to Canaan Dental Surgery Pte Ltd
  3. agents, contractors or third-party service providers who provide operational services to Canaan Dental Surgery Pte Ltd, such as courier services, telecommunications, information technology, payment, printing, billing, payroll, processing, technical services, training, market research, call centre, security (CCTV) or other services to Canaan Dental Surgery Pte Ltd;
  4. vendors or third-party service providers who provide marketing promotions and services offered by Canaan Dental Surgery Pte Ltd or its preferred partners;
  5. commercial shops and retailers who provide rewards and benefits in partnership with Canaan Dental Surgery Pte Ltd;
  6. any business partner, investor, assignee or transferee (actual or prospective) who facilitates business asset transactions (which may extend to any merger, acquisition or asset sale) involving any of the companies under the Canaan Dental Surgery Pte Ltd which we are part of;
  7. our professional advisers such as auditors and lawyers;
  8. relevant government regulators, statutory boards or authorities or law enforcement agencies to comply with any laws, rules, guidelines and regulations or schemes imposed by any governmental authority; and
  9. Any other party to whom you authorise us to disclose your Personal Data to.

Transfer of Personal Data outside of Singapore

Canaan Dental Surgery Pte Ltd do not transfer Personal Data overseas. In circumstances that we do, we will ensure that any transfers of personal data to a territory outside of Singapore will be in accordance with the PDPA so as to ensure the standard of protection of personal data in the territory it is transferred to is comparable to that of the PDPA in Singapore.

Disclosure of Data to Third Parties

The personal data submitted will not be disclosed to third parties except when required by law, when we have your explicit consent or in cases where the third party is a contractor or supplier whom we have engaged specifically to assist with the company’s activities. All such contractors will be bound contractually (e.g. Non-Disclosure Agreement) to keep all information confidential, but we cannot and do not assume any responsibility for any actions or omissions of third parties.

We do not transfer any personal data across borders to overseas territories.

Transfer of Data to Overseas

Canaan Dental Surgery Pte Ltd do not transfer Personal Data overseas. In circumstances that we do, we will ensure that any transfers of personal data to a territory outside of Singapore will be in accordance with the PDPA so as to ensure the standard of protection of personal data in the territory it is transferred to is comparable to that of the PDPA in Singapore.

Contacting Canaan Dental Surgery Pte Ltd on Personal Data matters

Any Individual who:

  1. has questions or feedback relating to this Policy;
  2. would like to obtain access to his/her Personal Data held by Canaan Dental Surgery Pte Ltd;
  3. would like information about the ways in which his/her Personal Data held by Canaan Dental Surgery Pte Ltd has been or may have been used or disclosed by Canaan Dental Surgery Pte Ltd in the year preceding the request; and/o
  4. would like to update or make corrections to his/her Personal Data held by Canaan Dental Surgery Pte Ltd should contact Canaan Dental Surgery Pte Ltd Data Protection Officer at Canaan Dental Surgery Pte Ltd
  5. Individuals should note that Canaan Dental Surgery Pte Ltd is not required, under the PDPA, to provide access and correction to Personal Data in certain situations.
  6. The PDPA allows and Canaan Dental Surgery Pte Ltd reserves the right to charge a reasonable fee for the handling and/or processing of access requests by an Individual pursuant to clauses 2 or 3 above.
  7. Depending on the complexity of the request, Canaan Dental Surgery Pte Ltd may require up to 3 weeks from the date of the Individual’s request to respond and effect any change requested by the Individual, and if additional time is required, Canaan Dental Surgery Pte Ltd will notify the Individual accordingly.

Governing Law

This Policy shall be governed by and construed in accordance with the laws of Singapore.

Any dispute arising out of or in connection with this Policy including any question regarding its existence, validity or termination, shall be referred to and finally resolved by the Courts of Singapore.

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