HealthPass by OCBC Data Protection Policy

1.1 This HealthPass by OCBC ("Platform") Data Protection Policy ("PDPP") applies to users ("user", "you", "your", or "yours" as the context requires) accessing and/or using services offered by Third Party Providers (as defined in the Platform's Terms of Use) on or through the Platform owned by Oversea-Chinese Banking Corporation Limited ("OCBC", "we", "our"or "us"as the context requires) and/or engaging Third Party Providers.

1.2 By accessing and/or using the Platform, you agree and consent to be unconditionally bound by the PDPP which may be updated by us in our sole discretion from time to time without notice to you. If you do not agree to any of the terms of the PDPP, please discontinue your access immediately. You agree that your continued access of the Platform after such update will constitute your acceptance of and agreement to be bound by the updated terms.

1.3 This PDPP is supplementary to and does not supersede the terms in OCBC's Data Protection Policy, and which users agree and consent to be bound by. This PDPP sets out further purposes for which the Personal Data of users may be collected, used, disclosed or processed when accessing and/or using the Platform. Unless otherwise indicated, the definitions of terms defined in the Platform's Terms of Use, and OCBC's Data Protection Policy shall also apply to this PDPP.

1.4 In this PDPP "Disclosees" shall mean (i) OCBC related corporations; (ii) Operator and/or Third Party Providers (including medical practitioners and wellness experts); (iii) agents, contractors or third party service providers who provide operational services to OCBC, such as courier services, telecommunications, information technology, payment, payroll, processing, training, market research, storage, archival, customer support investigation services or other services to OCBC; (iv) vendors or other third party service providers in connection with marketing promotions and services offered by OCBC; (v) analytics, search engine providers or other third party service providers that assist us in delivering our products, services, websites and platforms as well as improving and optimising the same; (vi) any business partner, investor, assignee or transferee (actual or prospective) facilitating business asset transactions (which may extend to any merger, acquisition or any debt or asset sale) involving any of the companies in the OCBC Group; (vii) external banks, credit card companies and their respective service providers; (viii) third party referrers; (ix) our co-brand and other business partners; (x) our professional advisors such as our auditors and lawyers; (xi) relevant government regulators, government ministries, statutory boards or authorities and/or law enforcement agencies, whether local or overseas, including the Monetary Authority of Singapore, the Accounting and Corporate Regulatory Authority, and the Insolvency and Public Trustee Office, the Singapore Exchange Limited and/or any other relevant securities exchange; and/or (xii) any other party to whom you authorise us to disclose your Personal Data to.

1.5 You agree and consent to the following:

  1. the terms of OCBC's Data Protection Policy, available at or upon request;
  2. OCBC's, its Related Corporations' and Representatives' ("OCBC Group"), Third Party Providers', as well as their respective agents' and authorised service providers' collection of Users' Personal Data (as well as Personal Data of any other individuals disclosed by each User) when Users submit any forms on the Platform, including but not limited to application forms and/or referral forms;
  3. OCBC Group, Disclosees as well as their respective agents and authorised service providers collecting, using and disclosing Users' Personal Data (as well as Personal Data of any other individuals disclosed by each User), and sharing this data between themselves and their business partners to:
    1. respond to, process and handle User's complaints, queries, feedback, customer service requests and/or suggestions relating to the Platform;
    2. verify your identity;
    3. request for feedback or participation in surveys, as well as to conduct market research and/or analysis for statistical, profiling or other purposes for OCBC to improve User experience on the Platform;
    4. provide media announcements and responses;
    5. organise promotional events;
    6. meet or comply with any applicable rules, laws, regulations, codes of practice or guidelines issued by any legal or regulatory bodies which are binding on OCBC (including but not limited to disclosures to regulatory bodies, conducting audit checks, surveillance and investigation or customer due diligence);
    7. process Users' payment to Third Party Providers;
    8. facilitate business asset transactions (which may extend to any mergers, acquisitions or asset sales) involving any of the companies in the OCBC Group;
    9. in connection with any claims, actions or proceedings (including but not limited to drafting and reviewing documents, transaction documentation, obtain legal advice, and facilitating dispute resolution), and/or protect and enforce OCBC Group's contractual and legal rights and obligations;
    10. manage and prepare reports on incidents and accidents; and/or
    11. comply with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities.
  4. OCBC Group disclosing Personal Data of Users (as well as Personal Data of any other individuals disclosed by each User) to Disclosees, for Disclosees to:
    1. provide products, platform consultations and/or services made available by the Disclosees including without limitation –
      1. platform consultations with medical practitioners and/or wellness experts;
      2. scheduling platform consultation appointments with Users;
      3. in-clinic registration for Users who have not made an appointment with the relevant medical practitioners and/or wellness experts;
      4. provision and delivery of medication;
      5. issuance of digital medical certificates;
      6. conducting of preventative health screening;
      7. providing of lab diagnostic reports;
      8. generation of any invoices;
      9. booking of health and wellness offerings;
      10. provision of health and lifestyle monitoring functionalities on the Platform;
      11. digital concierge consultations;
    2. improve User experience on the Platform in relation to products, platform consultations and/or services made available by Disclosees;
    3. facilitate Users' platform consultations e.g. digital registration and/or appointment bookings at clinics;
    4. respond to, process and handling any claims arising out of or in connection with Users' use of products, platform consultations and/or services; and/or
    5. any other purposes which are reasonably related to any of above.
  5. In addition, where permitted under the Personal Data Protection Act (Act No. 26 of 2012), OCBC Group may also collect, use and disclose your Personal Data for the following purposes (which we may describe in our documents and agreements as "Additional Purposes" for the handling of Personal Data:
    1. tailoring information and product / service offerings to User;
    2. customising promotions and also offering products or services that may be of interest to User, based on User's Platform preferences and transaction history;
    3. evaluating your financial and banking needs and providing recommendations to you as to types of products and services suited to your needs; and/or
    4. using cookies, online advertising and other technologies in connection with the above.

1.6 Users are to be responsible for the security of their devices. To the maximum extent permissible under applicable laws, OCBC shall not be liable for medical information and other information relating to the Platform which are stored on Users' devices.

1.7 OCBC Group does not collect, use, disclose, process, store and/or process any medical records submitted by Users to Third Party Providers. Any medical information provided by Users are encrypted locally on Users' devices.

1.8 If you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, OCBC may not be in a position to continue to provide its products or services to you, administer any contractual relationship already in place. This may also result in the termination of any agreements you have with OCBC, and your being in breach of your contractual obligations or undertakings. OCBC's legal rights and remedies in such event are expressly reserved.

1.9 You represent, warrant and undertake that in relation to any Personal Data of any other individuals provided to OCBC Group by you via or in connection with the Platform, you have secured all necessary consents for the collection, use or disclosure of such Personal Data by OCBC Group in accordance with this PDPP.