Effective date: 14 Dec 2018
- Matching tool: facilitating Users in their search for clinical trials that may be suitable for an oncology patient;
- Feasibility marketplace: facilitating the matching of Trial Sites with Trial Sponsors for the conduct of clinical studies.
Given the nature of the information we work with, which includes without limitation, personal data and disease related information, we pledge to protect your privacy and keep your personal data secure and confidential. The personal data you share with Oncoshot is kept strictly confidential and fully secure unless you, the User, specifically request otherwise.
1. Privacy Officer
Note that for purposes of compliance with the requirements of the General Data Protection Regulation (“GDPR”), the Oncoshot Privacy Officer also serves as the Data Protection Officer.
2. Information We Collect
We collect and retain information from you in the following manner:
- through your activity on and use of the Site, and of the Services (as defined above), including the sites that you exit to;
- through your registration and/or creation of an account on the Site;
- through your logins as Users of the Site;
- Through Cookies (as defined below);
- through your responses to questions in Build Profile;
- through your requests to be contacted by us and your interaction with our Medical Professionals;
- through your IP address, web browser type and version and/or operating system; and
- through any other data and information you provide us with by whatever means of communication or in whatever medium, and whether provided to our employee or a Medical Professional (pursuant to the second opinion service), or otherwise.
All data that we collect from you shall hereinafter be referred to as “Collected Data”. Collected Data may include “personal data”, as defined under the Singapore Personal Data Protection Act 2012 (“PDPA”). This is information that identifies you specifically, and examples may include:
- your name, age, date of birth, occupation, gender, mailing address, email address, details of your identification document(s), and telephone or mobile number;
- medical and health information that you provide us, which may include information or records relating to your medical or health history, health status and laboratory testing results, diagnostic images, and other medical and health related information; and
- billing information that you provide us, for example credit card or online payment system account information.
3. Purpose and Use of Collected Data
We require the Collected Data to provide you with the best possible service and experience when using our Services and the Site. The Collected Data may be used by us for the following reasons, including with limitation:
- to operate the Site and Services, and to provide the Services to you;
- to enable us to contact you;
- to improve the content and quality of our Services; and
- for our internal account handling, business and administrative purposes.
4. How We Protect Your Information
Oncoshot keeps all your Collected Data confidential in our secure system. No other User can view or change your Collected Data without your Username and Password. Oncoshot puts you, the User, in control of your personal data. You can edit, update or delete information that you have provided by sending an email to firstname.lastname@example.org.
Oncoshot controls all personal data gathered via our Sites. All data is secured in a top-tier secure hosting facility. Oncoshot shall promptly discard or delete Personal Information, etc. if it has achieved the purpose of use thereof and the period of storage prescribed by governing laws and regulations has expired. Your Personal Data is retained to the extent one or more of the purposes for which it was collected remains valid and for other legal or business purposes for which retention may be necessary.
Only authorized Oncoshot employees (with special system access controls and passwords) are permitted or able to access your personal data. All Oncoshot employees must abide by our code of conduct, security and privacy policies and those who violate this policy are subject to disciplinary action, up to and including termination.
No method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee the absolute security of your Collected Data. If a breach of your personal data occurs, we will provide notifications as per regulatory requirements. In that event, Oncoshot would no longer have the ability to protect your information. By using our Site and Services, you acknowledge that there is risk that the information you share with us may be compromised, despite our efforts to protect it.
5. How to Request, Update or Delete Your Information
By default, personally identifying information is maintained in our system for three (3) years from your last interaction with our Site or our Services. We will also take reasonable steps to securely destroy or permanently de-identify your personally identifiable information when we no longer need it.
You may delete your account via the Delete Profile link provided on your user dashboard. You may alternatively delete your account at any time by sending an email to email@example.com with the subject “Delete My Account”. The latter option will remove your personally identifying information from our database. It will also remove or detach any Personal Profiles you created from identifying information that was in your account.
Existing Users can log into their account to review, correct, update or delete inaccuracies to the information in their user account (including updating email address and changing password) and in any saved Personal Profiles. If you are unsure of how to update any of your previously provided information, write to firstname.lastname@example.org for assistance.
6. Personal Profile Information
We use the Personal Profile information that you provide us in the provision of our Services.
You may delete individual Personal Profiles at any time using the “delete” feature in the dashboard page. If you delete your account (which you can do at any time by writing to us at email@example.com), your Personal Profile will also be deleted. Deleted Personal Profiles may still be accumulated in aggregate data analysis (as set out in section 8 below).
7. Disclosure to Third Parties
Oncoshot may provide your personal data to third parties in order to provide you with the Service(s). This disclosure of personal data may include, without limitation:
- via sharing a User’s Personal Profile where Trial Sites and/or Trial Sponsors cannot be directly engaged within the Site. Once the Personal Profile has been shared, we will then contact the Trial Sites or Trial Sponsors with your consent;
- to enable Oncoshot to connect the patient to a suitable leading oncologist in Singapore in order to provide an expert second opinion. This provision of personal data is always subsequent to your own decision to connect and share your personal data with a third party involved the provision of the Service.
Oncoshot may also enclose personal data in a message sent to you through email or regular mail at your request. These messages -- which may take the form of a general update or a specific response to your questions -- will be sent to the email address or physical location you specify.
Except as provided in this section, Oncoshot will not disclose to unrelated persons or entities any personal data that you provide to us. Please note that you are responsible for taking all reasonable steps to ensure that no unauthorized person shall have access to your username and password or Personal Profile. It is your sole responsibility to:
- control the dissemination and use of usernames and passwords;
- authorize, monitor, and control access to and use of your usernames and passwords; and
- promptly inform Oncoshot of any need to deactivate a username or password.
In the following limited circumstances we will consider, and may release personal data to third parties:
- as required by law, such as to comply with a subpoena, or similar legal process;
- when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;
- if Oncoshot is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our site of any change in ownership or uses of your personal data, as well as any choices you may have regarding your personal data;
- where third party companies perform services for us, including but not limited to email delivery, hosting and payment processing, or for the purpose of providing you with the Services that you request from us. However, these parties will only be entitled to use your personal data in order to provide the services requested by us or as may be required by law; or
- your consent has been obtained for disclosure.
8. Anonymous Statistics
We may use anonymise your Collected Data in a non-personally identifying manner, in aggregate, for internal analysis and statistics to help us improve the Site, our Services and/or for research purposes (“Anonymous Information”). We may share this Anonymous Information with third parties.
For example, we might inform third parties about the number of Users of our Site who are interested in information about a particular disease category, or information about the number of Users who live in a particular geographic region. We may also provide aggregate information to entities for the purpose of determining whether additional clinical trials are needed in a particular disease area. Depending on the circumstances, we may or may not charge third parties for the right to access this Anonymous Information.
9. Cookies Policy
We use “cookies” on our Site. Cookies are text files that we put on your computer and/or other electronic device used to access the Site, which stores and records information about your visit to and use of the Site (“Cookies”). Cookies can compile information about your browsing habits and can also enhance your browsing experience. For more information on Cookies, please refer to www.aboutcookies.org. We have carefully chosen these Cookies and had taken steps to ensure that your privacy is protected and respected at all times. We set out more details about the Cookies we use below. You can also choose to disable Cookies.
- to improve your user experience on the Site and to improve the efficacy of our Services;
- to remember your preferences;
- to help us understand how this Site is performing;
- to monitor traffic to the Site; and
- to enable the Site to function properly; (collectively, the “Cookie Purposes”).
Personal Data (if any) that we collect from you through Cookies may be passed to our third-party service providers or third-party data intermediaries, whether located in Singapore or elsewhere, for one or more of the Cookie Purposes, for managing and/or administering our Site, or for the purpose of data hosting, storage and/or backup.
Your use of our Site and/or Services constitutes your consent to our use of the Cookies and to the matters set out in this clause 9.
10. Privacy of Children
Oncoshot does not collect, maintain, store, or disclose personal data about children under the age of 13.
11. Marketing Communications
If you should consent, from time to time you may receive from us a variety of communications, including but not limited to newsletters, emails and text messages (the “Marketing Communications”), that will include service updates, product advertising and offers related to our Services which we believe you may be interested in.
At any time, you may change your Marketing Communications preferences, either by:
- electing to opt out from the Marketing Communications sent to you by following the ‘unsubscribe’ link which can be found at the bottom of the emails; or
- contacting our team directly using the ‘Contact Us’ option, found either in the email we sent or on the Website.
Aside from Marketing Communications, please note that from time to time, you may receive some important service information that we believe is critical to the use of our Services. In these exceptional circumstances, such information will be sent to you regardless of your Marketing Communications preferences.
If you send us a request (for example via a support email or via one of our feedback mechanisms), we reserve the right to publish it in order to help us clarify or respond to your request or to help us support other users.
12. Your Consent
By creating a username and password (registering) and filling out a Profile, accessing the Site or using the Services, you grant Oncoshot the right to receive, transmit, monitor, retrieve, store and use your personal data, including information that may be privileged and confidential under applicable state and federal laws, in connection with the operation or maintenance of the Site, the Services and features.
Oncoshot cannot and does not assume any responsibility or liability related to the accuracy or inaccuracy of the information you provide to us. Oncoshot also cannot and does not assume any responsibility or liability related to your use or misuse of information transmitted or received on the Site or through the Services, or third parties' use or misuse of information transmitted or received using Oncoshot.
If Oncoshot decides to materially change how we use personal data or your personal health information, we will notify you by posting a notice on the Site, homepage or by sending you an email if you consented to receive email communications from us prior to the changes taking effect.
12. PDPA and GDPR