1. Our Commitment to Privacy

• SilverJoy Medicare & ServicesPte. Ltd. (“SilverJoy Medicare”) knows that protecting the privacy and confidentiality of your personal information is important. SilverJoy Medicare shall therefore only use your name and other information that relates to you in the manner set out in this Privacy Policy. SilverJoy Medicare will only collect information where it is necessary for SilverJoy Medicare to do so and if it is relevant to SilverJoy Medicare’s dealings with you, in the manner set out in this Privacy Policy. SilverJoy Medicare will only keep your information for as long as SilverJoy Medicare is either required to by law or as is relevant for the purposes for which it was collected.
• The collection, use and disclosure of personal information (see Clause 2.1 for a definition) by SilverJoy Medicare are governed by the Personal Data Protection Act 2012 (the “Act”). This Privacy Policy explains what personal information is collected from users of SilverJoy Medicare’s website and/or other online platforms (collectively, the “Platforms”) and services and how such personal information is used and disclosed to other parties. It also explains how you can ask questions, make suggestions, and complain about SilverJoy Medicare’s privacy practices.
• This Privacy Policy applies to personal information collected by SilverJoy Medicare. Note that SilverJoy Medicare may contain links to other websites provided and maintained exclusively by third parties not subject to this Privacy Policy. Please review the privacy policies on any third party websites to determine their information handling practices. SilverJoy Medicare will not be liable under any circumstances for any damages whatsoever, direct or indirect, resulting from any use of SilverJoy Medicare or any other third party website linked to SilverJoy Medicare, whether or not SilverJoy Medicare is advised of the possibility of such damages. This Privacy Policy is available to the public in electronic form at https://www.silverjoymedicare.sg/privacy-policy. If you have any additional concerns or questions, you are encouraged to contact SilverJoy Medicare and SilverJoy Medicare will address your concerns to the best of its ability. Please read this Privacy Policy carefully and check back periodically as SilverJoy Medicare updates it from time to time. By submitting your personal information to SilverJoy Medicare and by visiting SilverJoy Medicare, you signify your agreementto the terms and conditions of this Privacy Policy, and expressly consent to the collection, use and disclosure of your personal information in the manner and for the purposes set out in this Privacy Policy.
• If you have any comments, suggestions or complaints, you may contact SilverJoy Medicare (and SilverJoy Medicare’s Data Protection Officer) by email at feedback@sjm.sg

2. What is personal information?

• “Personal information” refers to data, whether true or not, about an individual who can be identified (a) from that data; or(b) from that data and other information to which the organisation has or is likely to have access, whether stored in electronic or non-electronic form. “Personal information” does not include the name, title, business address or telephone number of an employee of an organisation. Information used solely for journalistic purposes is exempted from the Act.

3. What personal information does SilverJoy Medicare collect, and why?

• SilverJoy Medicare collects your personal information for specific, limited purposes, as set out in this Clause 3. Information is collectedby fair and lawful means.
  1. SilverJoy Medicare collects contact information (for example, name, address, email address, and telephone numbers) when you register at any of the platforms. This information is used to complete your SilverJoy Medicare bookings and respond to your inquiries.
  2. SilverJoy Medicare also collects credit card and bank account information as needed to process payments for SilverJoyMedicare’sservices. SilverJoy Medicare does not permanently store your credit card and bank account information.
  3. If you enter a contest or other promotion, SilverJoy Medicare collects your personal contact information to administer the contest or promotion, including for the purposes of contacting, announcing and promoting prize winners.
  4. SilverJoy Medicare collects booking history and a list of promotions offered to you (“History”) in order to gain a betterunderstanding of your interests so that SilverJoy Medicare may develop better services and to determine eligibility for SilverJoy Medicare’s services.
  5. SilverJoy Medicare collects and stores your location history to establish your location, improve your experience and from time to time to send you information, such as promotional offers, that are most relevant to your geographic location.
  6. SilverJoy Medicare keeps notes and special instructions in respect of your personal information on file to help SilverJoy Medicare fulfil your care service requirements and care bookings, and provide customer service.
  7. SilverJoy Medicare also collects your personal information to help SilverJoy Medicare improve the services provided by SilverJoy Medicare (including the types of services offered by SilverJoy Medicare, the quality of the Care Providers used to provide the services, SilverJoy Medicare’s internal care operations, customer service and support, and outreach services).
  8. If you wish to apply for a job on any of the Platforms, SilverJoy Medicare will collect personal information such as your name, email address, phone number and additional information such as resume and gender. SilverJoy Medicare uses the information,collected through the Platforms to register and process your application, to determine your qualifications for the position for which you have applied and to contact you.
  9. If you choose to opt out of any use of your personal information in accordance with Clause 6, SilverJoy Medicare keeps your contact information on a list so that your request can be honoured.
  10. If you complain to any of SilverJoy Medicare’s departments for any reason, SilverJoy Medicare collects your contact information and the nature of your complaint for the purpose of investigating your complaint and responding to you.
  11. If you are a service provider, SilverJoy Medicare collects your personal and/or business identification details for tax reporting purposes and your contact information in order to pay you through SilverJoy Medicare’s third-party payment agent. SilverJoy Medicare may also collect financial information (for example, banking details and credit history) from SilverJoy Medicare’s service providers to assess credit risk, sales data to prepare commission reports and other information to help SilverJoy Medicare evaluate its services.
  12. Additional purposes for the collection, use or disclosure of personal information, which are not set out in this PrivacyPolicy, will be set out at the time of collection. SilverJoy Medicare will obtain your consent to such additional purposes no later than at the time of such collection.
  13. 13. Collection of Computer Data: SilverJoy Medicare may use cookies, web beacons, and other similar technologies for storing information to help provide you with a better, faster, safer and personalised experience when you use SilverJoy Medicare’s services and/or access any of the Platforms. When you visit SilverJoy Medicare’s website, SilverJoy Medicare’s servers will automatically record information that your browser sends whenever you visit a website. This data may include:

      1. your computer’s IP address;

      2. browser type;

      3. webpage you were visiting before you came to SilverJoy Medicare’s website;

      4. the pages within SilverJoy Medicare’s website which you visit; and

      5. the time spent on those pages, items and information searched for on SilverJoy Medicare’s website, access times and dates, and other statistics.

      This information is collected for analysis and evaluation in order to help SilverJoy Medicare improve SilverJoy Medicare’s website and the services and products SilverJoy Medicare provides.
  14. Internet Cookies: An internet cookie is a small piece of information that a website stores on your internet browser. SilverJoy Medicare uses cookies to better understand how you use SilverJoy Medicare’s website and to improve your experience. For example, a cookie may recall a set of preferences you have set for SilverJoy Medicare’s website. Storing cookies on your web browser allows SilverJoy Medicare to present you with custom web pages and other content that are tuned with your preferences. These activities are invisible to you, and are generally intended to improve your internet surfing convenience. Unless you have set your preferences so that you will be alerted when a cookie is being stored on your computer, you will not know about it.
  15. If you are concerned about cookies, you may disable them by adjusting the privacy and security settings of your web browser. However, please be aware that by disabling cookies, you may not be able to use allportions of SilverJoy Medicare’s website and may not have the optimal experience.
  16. SilverJoy Medicare may place advertising or other links on any of the Platforms that originate from outside advertisers. If you view these ads, the advertisers may assign a cookie. SilverJoy Medicare does not control these cookies, nor is it responsible for any marketing or other use of your name by these advertisers.

4. Market Research

• Occasionally, SilverJoy Medicare asks its users to complete market research surveys. Survey results are aggregated and shared with SilverJoy Medicare’s advertisers, sponsors and related corporations in a manner that does not disclose personal information.

5. To whom does SilverJoy Medicare disclose personal information, and why?

• SilverJoy Medicare may use or disclose your personal information under the following circumstances:
  1. SilverJoy Medicare may use the contact information and History collected from you to send you promotional offers and information from SilverJoy Medicare, its related corporations and from selected sponsors or advertisers (“Marketing Offers”). SilverJoy Medicare may disclose your personal contact information to related corporations and selected sponsors and advertisers in order to provide you with Marketing Offers. If you do not wish to receive Marketing Offers, you may opt out at any time by following the procedure set out in Clause 6.
  2. SilverJoy Medicare may transfer your personal information to service providers acting on its behalf in order to perform processing and other specialised services, for example, prize fulfilment of SilverJoy Medicare’s contests, collection of overdue accounts, service delivery, credit card or bank transfer processing.
  3. SilverJoy Medicare may disclose your personal information to any legal, regulatory, governmental, tax, law enforcement or other authorities or the relevant right owners pursuant to Clause 13.
  4. SilverJoy Medicare may disclose your personal information to parties connected with the contemplated or actual financing,insuring, sale, assignment or other disposal of all or part of its business or assets, including for the purposes of determining whether to proceed or continue with such transaction or business relationship or fulfilling any records or other reporting requirements to such parties. SilverJoy Medicare will require such parties to treat your personal information in accordance with this Privacy Policy and to use and disclose it only for the purposes for which it was collected.
• In disclosing or transferring your personal information to third parties and/or SilverJoy Medicare’s related corporations locatedoverseas, SilverJoy Medicare will ensure that the receiving jurisdiction has in place a standard of protection accorded to personal information that is comparable to the protection under or up to the standard of the Act.

6.Withdrawal of Consent and Opting Out

• SilverJoy Medicare will obtain your express consent to collect, use and disclose your personal information for any additional purposes not set out in this Privacy Policy at or prior to the time of collection.
• You may, at any time, withdraw your consent to and opt out of SilverJoy Medicare’s collection, use and/or disclosure of your personal information for any the purposes set out in Clauses 3, 4, and/or 5 by contacting SilverJoy Medicare at its email address set out in Clause 14.3 below.
• Please note that if you opt out of allowing SilverJoy Medicare to collect, use and/or disclose your personal information for any of the purposes set out in this Privacy Policy, SilverJoy Medicare may not be in a position to continue to provide SilverJoy Medicare’s services to you or perform any contract SilverJoy Medicare has with you. SilverJoy Medicare’s rights and remedies (legal or otherwise) are expressly reserved in such an event.
• If you do not wish to receive Marketing Offers, you may opt out any time by doing any of the following:
  1. follow the instructions at the bottom of any email Marketing Offer you receive;
  2. inform your telemarketer at the time you are called with a Marketing Offer; or
  3. email Client Services at feedback@sjm.sg and request that your personal information not be used for Marketing Offers.

7. Security of Your Personal Information

• SilverJoy Medicare maintains personal information in a combination of paper and electronic files. SilverJoy Medicare takes technical, contractual, administrative and physical security measures to protect your personal information. Not all SilverJoy Medicare interactions require thatcredit card and/or bank information be provided. If you provide credit card and/or bank account information to SilverJoy Medicare, SilverJoy Medicare works to help protect the security of your credit card and/or bank account information by using industry standard secure sockets layer (SSL) encryption technology.
• Please be aware that email is not a secure medium, and any personal information you send to SilverJoy Medicare by email could be intercepted. If your communication is very sensitive, or includes information such as your credit card number and/or bank account information, you should not send it electronically unless the email is encrypted or your browser indicates that the access to SilverJoy Medicare’s website is secure. Materials posted to online forums such as bulletin boards or chat rooms are public, not secure and may be viewed by anyone. Any personal information you post may be collected and used by anyone and may result in unsolicited messages from other internet users.
• If you believe your privacy has been breached by SilverJoy Medicare, please contact SilverJoy Medicare at feedback@sjm.sg.
• Your password is the key to your account. Please use unique numbers, letters and special characters, and do not share your SilverJoy Medicare password with anyone. If you do share your password with others, you will be responsible for all actions taken in the name of your account and the consequences. If you lose control of your password, you may lose substantial control over your personal information and other information submitted to SilverJoy Medicare. You could also be subject to legally binding actions taken on your behalf.

8. No Spam, Spyware, or Virus

• No spam, spyware or virus is allowed on any of the Platforms. Please set and maintain your communication preferences so that SilverJoy Medicare sends communications to you as you prefer. You are not licensed or otherwise allowed to add other users to your mailing list (email or physical mail) without their express consent. You should not send any messages which contain any spam, spyware or virus via SilverJoy Medicare. If you would like to report any suspicious messages, please contact SilverJoy Medicare at its email address set out in Clause 14.3 below.

9. How to access and correct your personal information

• SilverJoy Medicare provides you with the means to access, update, edit or delete certain subscriber and registration information you have provided at any time by going to the appropriate location at any of the Platforms, and changing or deleting such information as desired
• You undertake to treat your SilverJoy Medicare username, password and order details as confidential information and undertake not to make them available to unauthorised third parties. SilverJoy Medicare cannot assume any liability for misuse of your SilverJoy Medicareusername, password or order details, except as stated in the Terms of Use.
• If you would like to view the personal information SilverJoy Medicare has on you or inquire about the ways in which your personal information has been or may have been used or disclosed by SilverJoy Medicare within the past year, please contact SilverJoy Medicare at its email address set out in Clause 14.3 below. SilverJoy Medicare reserves the right to charge a reasonable administrative fee for retrieving your personal information records.
• If you want to close your account or have other questions or requests, please contact SilverJoy Medicare. While SilverJoy Medicare is ready toassist you in closing your account, and removing your active profile, SilverJoy Medicare cannot always delete records of past interactions and transactions. For example, SilverJoy Medicare is required to retain records relating to previous bookings on its website for financial reporting and compliance reasons.
• SilverJoy Medicare will give you access to the information SilverJoy Medicare retains about you within a reasonable time, upon written request, satisfactory identification and proof of entitlement. In some cases, SilverJoy Medicare may not provide access to personal information in SilverJoy Medicare’s possession or control. If SilverJoy Medicare denies your request, SilverJoy Medicare will advise you in writing of the reason for the refusal and you may challengeSilverJoy Medicare’s decision.

10. Do-Not-Call Privacy Statement

• SilverJoy Medicare takes responsibility to protect the information you provide to SilverJoy Medicare very seriously.
• From time to time, SilverJoy Medicare and its partners may call or SMS its users to inform them about its latest services or promotional offers.
• SilverJoy Medicare will only call or SMS you after (i) ascertaining that you have not registered with the national DNC Registry administered by the Personal Data Protection Commission of Singapore and (ii) having obtained your clear andunambiguous consent for SilverJoy Medicare and/or its partners to call or SMS you about its latest services or promotional offers (including Marketing Offers).
• If you no longer wish to receive marketing calls or messages, you may withdraw your consent by contacting SilverJoy Medicare at its email address set out in Clause 14.3 below. 5. However, as SilverJoy Medicare may rely on the one-month validity period of its search results from the DNC Registry, you may inadvertently still receive marketing or promotional messages/calls. If you have received a telemarketing call from someone representing SilverJoy Medicare although you have registered with the DNC Registry or withdrawn your consent, please inform SilverJoy Medicare at feedback@sjm.sg.

11. General Provisions

• You must only submit to SilverJoy Medicare, or SilverJoy Medicare’s authorised agent, information which is accurate and not misleading and you must keep up to date and inform SilverJoy Medicare of any changes to such information. SilverJoy Medicare reserves the right to request for documentation to verify the information provided by you.
• By sharing the personal information of any third party with SilverJoy Medicare, you expressly represent and warrant to SilverJoy Medicare thatyou have obtained all required consents from the relevant third party to disclose and transfer his/her personal information to SilverJoy Medicare and for SilverJoy Medicare to collect, use and disclose such personal information for the purposes set out in this Privacy Policy. You agree to indemnify SilverJoy Medicare against any and all claims, losses, and damages arising from or in connection with any third party claims as a result of SilverJoy Medicare’s collection, use or disclosure of such personal information.
• SilverJoy Medicare may disclose or share non-personally identifiable information with partners, advertisers, current in-home personalcare businesses and/or prospective in-home personal care businesses to help explain its business and the effectiveness of SilverJoy Medicare’s business or for promotional purposes. For example, SilverJoy Medicare may disclose aggregated demographic information which does not include any personally identifiable information.

12. Changes to the Privacy Policy

• SilverJoy Medicare shall regularly review the sufficiency of this Privacy Policy. SilverJoy Medicare reserves the right to modify and change the Privacy Policy at any time. Any changes to this policy will be published on https://www.silverjoymedicare.sg/policies/.

13. SilverJoy Medicare’s Right

• You acknowledge and agree that SilverJoy Medicare has the right to disclose your personal information to any legal, regulatory, governmental, tax, law enforcement or other authorities or the relevant right owners, if SilverJoy Medicare has reasonable grounds to believe that disclosure of your personal information is necessary for the purpose of meeting any obligations, requirements or arrangements, whether voluntary or mandatory, as a result of cooperating with an order, an investigation and/or arequest of any nature by such parties. To the extent permissible by applicable law, you agree not to take any action and/or you hereby waive your rights to take any action against SilverJoy Medicare for the disclosure of your personal information in these circumstances.

14. How to challenge SilverJoy Medicare’s privacy practices

• SilverJoy Medicare encourages you to contact SilverJoy Medicare with any questions or concerns you have about SilverJoy Medicare’s privacy practices or this Privacy Policy. If you have a question concerning SilverJoy Medicare’s Privacy Policy or would like a copy, or if you have a complaint, please contact Client Services at feedback@sjm.sg
• Client Services can deal with many issues. If you prefer or if, after contacting Client Services, your concerns or questions have not been resolved to your satisfaction, you can contact SilverJoy Medicare at feedback@sjm.sg.
• If you wish to withdraw your consent to SilverJoy Medicare’s use of your personal information, wish to request access and/or correction of your personal information, have any queries, comments or concerns, or require any help on technical or cookie-related matters in relation to SilverJoy Medicare’s website, please feel free to contact SilverJoy Medicare (or SilverJoy Medicare’s Data Protection Officer, as appropriate) at feedback@sjm.sg (https://www.silverjoymedicare.sg).