Privacy Policy
Updated this 23 November 2023
1. Introduction
1.1. This Privacy Policy sets out our practices and policies with respect to your Personal Data and/or Sensitive Personal Data (defined below) including its collection, purpose and disclosure (“Privacy Policy”).
1.2. This Privacy Policy applies to RenalWorks Pte Ltd, RenalWorks Malaysia Sdn Bhd and its group of companies (“RenalWorks”, “Company”, “we”, “us”, or “our”), our dialysis and clinic management platforms (collectively referred to as “Platforms”), and websites and mobile applications (if any) operated by RenalWorks that includes, but is not limited to, sites of the following domains and sub-domains: www.renalworks.com (“Website”).
1.3. By continuing to access our Platforms and/or Website, communicating with us, opting-in when presented with choices or voluntarily providing your Personal Data to us, you warrant that you are at least 18 years of age and expressly consent to our collection, storage, use and disclosure of your Personal Data as described in this Privacy Policy. We may also require you to provide signed consent (including via electronic signing and by actively ‘checking the box’) to enable us to collect Personal Data from you or third parties. Such consent should only be given after you have read and understood this Privacy Policy. If you are under 18 years of age, the express consent of your legal guardian or parent is required to enable our collection, storage, use and disclosure of your Personal Data. We may process Personal Data of children under 18 years of age and Sensitive Personal Data.
1.4. If you are a healthcare service provider who is a user of our Platforms, you shall be solely responsible for procuring and maintaining all necessary explicit consents and approvals (statutory, contractual or otherwise) in relation to the processing of any third-party Personal Data and/or Sensitive Personal Data (as defined in paragraph 3) via our Platform and/or Website. You shall be solely responsible for any failure to procure such explicit consent, and for any unauthorised disclosure or use of such third-party’s Personal Data and/or Sensitive Personal Data.
1.5. Our Website may contain links to other sites or websites. However, please be aware that we, RenalWorks, are not responsible for the content or privacy practices of such other sites or websites.
2. Definitions
“Personal Data” is as defined in paragraph 3.2.
“processing” means collecting, recording, using, sharing, holding or storing the data or carrying out any operation or set of operations on the Personal Data and/or Sensitive Personal Data, and the terms “process”, “processed” and similar terms shall be defined accordingly.
“Sensitive Personal Data” is as defined in paragraph 3.4.
3. Information and Types of Data Collected
3.1. We understand that privacy is important to you. In the course of our business and operations, various data and information including personal information that relates directly or indirectly to you is being and/or may be collected, held, obtained, received, stored and/or processed by us or on our behalf.
3.2. Such personal information may include information pertaining to you, and/or your next of kin:
- name;
- identification/passport number;
- occupation;
- contact particulars;
- gender;
- birth date;
- addresses (including email and internet protocol addresses);
- the contact details of family members or guardian (if applicable); and
- all other personal data.
(collectively, “Personal Data”)
3.3. Where you furnish or supply us with Personal Data that relates to any other individual, we assume that you have procured, and shall procure, said individual’s agreement and explicit consent for the collection, holding, obtaining, receipt, storage, processing and/or use of said individual’s Personal Data as contemplated in this Privacy Policy.
3.4. We may also collect data that contains information on the individual’s physical or mental health which may include:
- medical data;
- health records; and
- any health-related data.
(collectively, your “Sensitive Personal Data”)
3.5 We may also collect information which your browser sends whenever you visit our Platforms or when you access Platforms by or through a mobile device (“Other Data”). These Other Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Website that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
4. Sources of Data
The Personal Data being and/or that may be collected, obtained and/or received by us are from various sources, including from the following:
4.1. From you:
- when you visit or use our Platforms and/or request for services offered by us (for example to request operational assistance);
- when you register with us;
- when you make inquiries or provide us with your feedback;
- when you visit or use our Website;
- When you subscribe to our newsletter; and/or
- when you otherwise contact, communicate or otherwise deal with us whether in person, by phone, by email, by post or via any means to make enquiries, complaints, suggestions or provide information.
4.2. From our authorised distributor(s), agents (including sales and marketing agents) and representatives when/if you contact, communicate or otherwise deal with them.
4.3. From sources where such information is available or accessible to the public.
4.4. From sources which are obtained with your consent.
5. Purposes of Data Collection
5.1. The purpose for which the Personal Data and/or Sensitive Personal Data was, is or will be collected and further processed includes but not limited to the following purposes (“Purposes”):
- to communicate with you;
- to improve our Platforms and/or our Website by conducting internal analysis and to seek to enhance your overall experience with our Platforms and/or our Website;
- to act on, process and/or respond to your complaints, inquiries, feedback, applications, interests or requests, and/or to otherwise contact/communicate with you;
- to commence, proceed with or carry out any investigation, inquiry, recovery or other proceedings;
- to carry out analysis, statistics, research and/or surveys to further develop our Platforms and/or our Website;
- for our record keeping purposes;
- to comply with the law and/or for such purpose as may be permitted by the law; and/or
- for such other purposes that are ancillary or incidental to the above.
5.2. To the extent that you use our Platforms and/or Website or read or click on an email from us, we may also collect certain data automatically or through you providing it to us even if you choose to remain anonymous unless expressly stated otherwise, such as a browser cookie.
5.3. If you do not supply us with your Personal Data or Sensitive Personal Data that we describe as obligatory or mandatory, or if you limit such obligatory or mandatory Personal Data, then we may be unable to continue to act on, respond to, process or proceed with your matter, or to provide you with access to our Platforms and/or our Website.
6. Cookies
6.1. We use cookies and similar tracking technologies to track the activity on our Platforms and/or our Website and we hold certain information.
6.2. Cookies may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device.
6.3. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some parts of our Platform and/or our Website.
7. Transfer of Data
7.1. We may transfer and/or store your Personal Data at a place outside your jurisdiction where it is necessary in the course of business for us to disclose and transfer the Personal Data.
8. Disclosure of Data
8.1. We may share, disclose and/or make available or accessible your Personal Data to the following persons/parties for the Purposes in paragraph 5 above:
- to our officers (including directors) and employees, and to companies and entities within the ‘RenalWorks’ group of companies (including our parent and subsidiary companies) and their respective officers and employees;
- to our professional advisors and/or service providers;
- to our authorised distributor(s), agents and representatives;
- to your insurers, authorised/legal representatives, legal guardians and/or any other authorised person/party;
- to our insurers; and/or
- to the government and/or such authority, body, entity, court, tribunal, person or party that we are required in law to disclose to.
- There may be occasions where we share with our authorised distributor(s), agents and representatives aggregated demographic information that is anonymous and that is not linked to any personally identifiable information.
9. Security of Data
9.1. In order to protect your Personal Data and/or Sensitive Personal Data against accidental, unlawful or unauthorised access, RenalWorks implements appropriate technical or organisational measures to protect the confidentiality and security of the Personal Data that we collect and process which may include the following:
- Data Encryption
- Access Controls
- Regular Audits and Vulnerability Testing
- Backup and Restore
- Compliance Training
- Personal Data stored on the Websites using cloud services are in encrypted form.
10. Contact Us
10.1. If you have questions, concerns, inquiries, complaints or if you require any clarification regarding this Privacy Policy, your Personal Data and/or Sensitive Personal Data, please contact us by:
- emailing to: enquiry@renalworks.com or
- writing to:
Software Manager,
RenalWorks Malaysia Sdn Bhd
B-1-18 Oasis Square,
Jalan PJU 1A/7A,
Ara Damansara 47301 Petaling Jaya,
Selangor,
Malaysia