Last Updated: 22 Aug 2024

HCP HEALTHCARE ASIA PTE. LTD. (UEN: 201129679E), a private limited company incorporated under the laws of Singapore and having its registered address at 150 Beach Road, #33-07/08, Gateway West, Singapore 189720 (hereinafter the “Company”, “we” or “us”) operates the website at https://urgomedicalapac.com/ (hereinafter the “Site”).

This privacy policy (hereinafter the “Privacy Notice”) applies only to your use of the Site.

We recognise that your privacy is important to you. We are committed to ensuring that your personal data is treated with care and integrity.

Our Privacy Notice tells you what personal data we collect and how we collect it. It explains what we use your personal data for and how we protect and safeguard your personal data. Please note that other information may be collected from you by third party applications (including Google Analytics, Matomo, SemRush, HubSpot and Adobe Analytics) as you use our Site; such information are generally not identifiable as your personal data. We have no control or influence over how these third party applications use the information they collect from you. For more information on how these third parties use the information collected or may be collected from you, please refer to their respective terms of use on their websites.

Please note that this Privacy Notice is specifically designed for the Singapore market.

1. What is a personal data?

Personal data means any information relating to an identified or identifiable natural person. It is any information, or piece of information, whether true, or not that could identify you either directly (your name, gender, age and date of birth, citizenship, language spoken) or indirectly (information on your employment with an organisation, your physical address, phone number, email address or government-issued identification number and identity verification information).

2. Who is the controller (“organisation”) of your personal data we collect from you on this Site?

HCP HEALTHCARE ASIA PTE. LTD. (UEN: 201129679E), a private limited company incorporated under the laws of Singapore and having its registered address at 150 Beach Road, #33-07/08, Gateway West, Singapore 189720, is the controller of your personal data we collect from the Singapore Site. For more information on HCP HEALTHCARE ASIA PTE. LTD., click here. HCP HEALTHCARE ASIA PTE. LTD. is the publisher and host of the Site on behalf of the URGO Group.

3. Who is the processor (“intermediary”) of your personal data we collect from you on this Site?

Your personal data which we collect from you on this Site shall, where relevant, also be processed by our Affiliates. Affiliates means entities directly or indirectly owned by us.

4. Contact information and your privacy point of contact

If you want to exercise your rights, have any questions about this Privacy Notice, need more information or would like to raise a concern, our privacy point of contact’s details: Email: dpo@group.urgo.com , Address: 184, rue de Rivoli 75001 Paris France.

5. What personal data do we collect, use and/or disclose on this Site?

The personal data we collect, process or disclose may include:

• your organisation;
• your department;
• your specialty;
• your title;
• your name;
• your phone number;
• your email;
• your country;
• your information generated when using Cookies (as hereinafter defined); and
• any other information as provided by you.

6. How do we collect your personal data on this Site?

Directly from you when you:

• Create an account and profile on our Site, or apps;
• Use your company’s sign on or other third-party authentication service (for example Microsoft, Google log in page) to gain access to our systems or apps.
• Use our Site, apps and systems;
• Share or use your social media profile to contact us;
• Sign up with us to receive promotional material;
• Enter a contest or competition organised by us;
• Engage with one of our sales representatives;
• Get in touch for support or to provide feedback;
• Attend an online event such as a webcast;
• Respond to any surveys that you may choose to participate in;
• Share adverse events or medical information enquiries with us; and
• Attend offline meetings, such as advisory boards or conferences.

From other sources:

• Publicly accessible sources;
• Joint marketing partners;
• Marketing vendors;
• Healthcare provider directories;
• Events management agencies;
• Social media platforms; and
• When you talk about us online, like when you mention one of our products in a social media platform.

If you connect your social media account to our Site, or apps, you will share certain personal data from your social media account with us. This may include your name, email address, photo, list of social media contacts, and any other information you make accessible to us when you connect your social media account to our websites, or apps. For more information, please read section 14 below about our cookie policy and section 15 below about social media platforms.

We also combine information about you from various sources, including the information you provide to us and personal data, which is collected during your relationship with us.

7. For what purposes do we collect, use and/or disclose your personal data?

Your personal data may be collected, used and/or disclosed by us to manage our relationship with you.

• to facilitate your access to the Site;
• to produce statistical analyses, particularly of Site traffic;
• to monitor usage and activity trends;
• to manage and improve the Site for optimal user browsing;
• to manage and send emails, newsletters and any other marketing documents (including without limitation brochures) to users who gave their consent;
• to manage, process and respond to users’ questions, requests, enquiries and complaints;
• to manage, process and respond to enforcement action and take-down requests;
• to further develop our products and services;
• to ascertain your identity in connection with fraud detection purposes;
• to conduct our business and to comply with the applicable legal and regulatory obligations;
• for any proposed purchase, merger or acquisition of any part of our business; and
• for any other purpose to which your consent has been obtained by us in compliance with the applicable law.
• Provide our products and services to you;
• Provide you with a prize if you enter a prize draw or competition;
• Provide online services such as webcasts, employment opportunities and financial results;
• Manage your account on our websites, and apps;
• Identify you and authenticate your access rights access to our websites, systems and apps;
• To respond to your queries and provide you with information when you request it or when we believe our products and services may be of interest to you. If we intend to share electronic marketing with you, we will ask for your consent where required and you can opt out at any time;
• Invite you to provide feedback, participate in research, surveys or attend events;
• Personalise your experience when interacting with us;
  • Report the adverse events you notify us about; and
• Perform analytics, market research and segmentation to understand your preferences, improve our products and services and our communications to you.

Your personal data may also be collected, used and/or disclosed by us to manage and improve our processes and our business operations:

• Manage our network and information systems security;
• Manage our workforce effectively;
• Respond to reports you make of a possible side effect associated with one of our products and to monitor the safety of our products;
• Keep records related to our relationship with healthcare professionals;
• Monitor and analyse trends, usage and activities in connection with our products and services to understand which parts of our products and services are of the most interest and to improve them accordingly; and
• Prepare and perform management reporting and analysis, including analytics and metrics.

To achieve other purposes such as:

• To follow applicable laws and regulations;
• To respond to requests from competent public authorities;
• To tell you about changes to our terms, conditions and policies;
• To exercise or defend against potential, threatened or actual litigation;
• To investigate and take action against illegal or harmful behaviour of users.
• To protect us, your vital interests, or those of another person;
• To gain insights and feedback on our products and services in order to correct or improve them, by analysing information from external sources such as Google, Instagram, Facebook, LinkedIn (and others);
• To deliver services to you via your smart device and our mobile apps; and
• When we sell, assign or transfer all or part of our business.

8. What are the legal bases for the collection, use and/or disclosure of your personal data?

Our legal bases to collect, use and disclose your personal data are:

• with your consent: we will ask for your permission to collect, use and/or disclose your personal data when it is mandatory and once you have specifically given us your permission, it means you have consented for us to collect, use and/or disclose your personal data. You can withdraw your consent at any time, and we will usually need your consent in the following cases:
  • i. Placing cookies on your device to find out how you use our websites so we can personalise what you see by tailoring content and notifications to the things you are interested in;
  • ii. Certain situations where you share sensitive information about yourself, such as your health;
  • iii. Before we send you certain electronic marketing communications; and
  • iv. In any other situation where personal data processing relies upon your consent.
• without your consent: in some cases, we can collect, use and/or disclose your personal data without your consent in accordance with the applicable laws/regulations (e.g. our legitimate interest, where matters affecting the public and/or your vital interests are concerned); and
• as part of our legal obligation: we may need to collect, use and/or disclose your personal data to comply with applicable laws/regulations (e.g. record-keeping regulatory monitoring and reporting obligations including those related to an adverse reaction to the products of any of the URGO Group companies or complying with anti-corruption and transparency obligations).

9. To whom is your personal data we collect on the Site disclosed or transferred to?

User’s personal data that we collect will only be accessible by a limited list of recipients on a need-to-know basis in accordance with the purposes described in this Privacy Notice or where required by law, including but not limited to:

• the departments and personnel of HCP and/or its Affiliates, and/or any entity who may acquire us or part of our business or brands;
• The suppliers and service providers of HCP and/or its Affiliates, for example:
  • Event agencies;
  • Marketing agencies;
  • Employment and recruitment agencies;
  • Technology suppliers who work with us to develop and improve our websites, digital forums and apps;
  • Media services providers who work with us
  • Suppliers managing adverse event reports
  • Insurances;
• Local or foreign regulators, courts, governments and law enforcement authorities; and
• Professional advisors, such as auditors, accountants and lawyers.

10. How long will your personal data be retained?

We will always retain your personal data for as long as is required by law and where we are required to do so in connection with any legal action or investigation involving us, our Affiliates, and/or any other relevant entity including any other company in the URGO Group. For the avoidance of doubt, however, where your personal data we collect on this Site must necessarily be used by such entities apart from HCP and its Affiliates, we shall notify you accordingly. Otherwise, we will keep your personal data for as long as we have a relationship with you (for example, where we have to respond to or process a question or request from you, or if we have sent you a product sample). Accordingly, the personal data as retained by us is deleted upon the occurrence of one of the following events:

• when it is no longer required for our legal or business purposes; or
• when you withdraw your consent in accordance with the applicable laws and the terms and conditions specified in the section 13 titled “What are your rights?” below.

11. How are your personal data protected?

We apply the appropriate and commercially reasonable technical and organisational security measures to keep confidential and to protect the personal data collected, used and/or disclosed by us, taking into consideration the state of art of technology and the cost of implementation.

However, we cannot and do not guarantee that these measures will prevent all risks of personal data breaches, and we shall not be held responsible for any personal data breach in the event of fraudulent behaviour by a third party and/or in the event that this personal data breach is due to the user’s own default. If you have reason to believe that your interaction with us is no longer secure, please notify us immediately using the contact details for the Data Protection Officer.

12. Where is your personal data transferred to outside of your home country?

Urgo Group, to which the Company belongs to, is an international group, so we collect and transfer personal data on a global scale, which means that we may need to transfer your personal data outside of Singapore.

If we transfer your personal data outside of Singapore, we will ensure that it is protected and transferred in accordance with the relevant applicable laws and regulations. The data protection laws in the countries to which we transfer data may not be the same as the laws in your home country but we shall ensure that the entities to which we transfer your personal data to shall minimally adhere to the data protection law, regulations, and obligations applicable under Singapore law. Law enforcement, regulatory, security or judicial authorities in the countries to which we transfer your personal data may have the right to access your personal data. However, with regard to the transfer of personal data collected by third party cookies, please refer to the section 14 titled “How do we manage Cookies” below.

13. What are your rights regarding your personal data?

The rights available to you depend on the reason we process your personal data and the law in Singapore, and there are exceptions to some rights. Depending on this, you may have the right to:

• Withdraw your consent for us to process your personal data for direct marketing purposes;
• Ask us about the processing of your personal data, including to receive copies of your personal data;
• Ask us to correct any information that you believe to be inaccurate or incomplete;
• Ask us to delete your personal data;
• Ask us to restrict the processing of your personal data;
• object to our processing of your personal data;
• Ask us to transfer information you have given us from one organisation to another or to give it to you; and
• Complain to your local data protection authority.

These rights may be exercised by the user at any time, by contacting us by e-mail at “um.apac@intl.urgo.com” or by post to “HCP HEALTHCARE ASIA PTE. LTD. (UEN: 201129679E),150 Beach Road, #33-07/08, Gateway West, Singapore 189720”.

To manage your request efficiently, please:

• indicate which collection, use and/or disclosure activity you are concerned with; and
• indicate the right(s) you wish to enforce.

In order to respond to your request, we may ask you to provide proof of your identity for verification purposes.
In the absence of a response from us or if the dispute persists, you may lodge a complaint with the competent data protection authority of your country (in Singapore, with the Singapore Personal Data Protection Commission: https://www.pdpc.gov.sg/).

For general information on Urgo Group’s data protection principles, please read through the Urgo Group’s general policy for personal data protection (https://www.urgo-group.com/personal-data/).

If we have relied on your permission to use your personal data and you later withdraw that permission, we may not be able to carry out some of the activities described in section 7 ‘For what purposes do we collect, use and/or disclose your personal data?’.

14. How do we manage Cookies?

a. What is a Cookie?

A cookie is a small computer file, a marker, which is stored and read on your computer, smartphone or tablet (hereinafter the “Devices” and each a “Device”) when you visit the Site.

In this Privacy Notice, we refer to all the cookies placed and read on your Device as “Cookies”.

b. What is the legal basis for the use of Cookies?

Necessary and/or functional Cookies: Your prior consent is not required for us to collect, store, use and/or disclose these Cookies because they do not collect any personal data.

Non-necessary and/or non-functional Cookies: You must first give your explicit consent before the Company and its partners, if any, collect, store, use and/or disclose Cookies other than those mentioned in the previous paragraph. These Cookies do not affect the quality of the service you request or the basic functionality of the Site.

You can disable and delete non-necessary and/or non-functional Cookies used by the Company and any of its partners, at any time, by deleting them from your devices, by managing your browser settings, or your “COOKIE PREFERENCES”.

c. What Cookies do we use on the Site?

We use different types of Cookies, the purposes of which are described below: