PSPhere is operated by DKSH Singapore Pte Ltd. (“DKSH”). At DKSH, we are committed to respecting and safeguarding your privacy by handling your personal data responsibly and in accordance with applicable laws. By accessing or using the PSPhere service offerings and features on http://pspherehome.dkshpsp.com.sg (the “Site”), and any components that support the functionality of the services (the “Services”), as further defined in our Terms and Conditions http://pspherehome.dkshpsp.com.sg, you expressly consent to the collection, processing, use and disclosure of your personal data according to this Privacy Policy. DKSH may share your personal data with our affiliates, group companies, subsidiaries and other authorized third parties solely for the purposes described herein. This Privacy Policy is aimed at giving you transparency about how we collect, use, and keep your personal data safe, and what your rights are under the Personal Data Protection Acts.

1. What personal data about you do we collect?

DKSH collects and uses certain types of personal data about you, depending on the relationship that you have with us as well as applicable laws. In order to access the Site and to use PSPhere, you will be asked to provide certain personal data. We may collect the following personal data about you:

Personal data category	Types of personal data
General information	Your full name (including prefixes and suffixes which may indicate your gender); date of birth and age; job information; educational, training, licensing and certification information; professional membership information; marital status; national identification number and passport number; Site account details such as username and online identifiers.
Contact information	Your address, telephone, mobile phone, fax, e-mail, social network information and other relevant contact details, as well as information about the preferred way and time of communication.
Financial information	Information collected in connection with sales and promotional activities; financial information including transaction details, bank and debit/credit card details, payment methods and terms; income and salary information; insurance information and claims history.
Sensitive information	Ethnicity and race; hereditary information and health records including but not limited to your medical history, height, weight, disability, blood type and allergies, drug prescription history, your healthcare professional’s name and contact information; biometric identifiers including but not limited to facial recognition, retina recognition, fingerprint recognition, voice recognition for the purposes of verifying and confirming your identity for the use of our products and services.
Usage information	Information regarding your mobile telephone, your computer, your IP address, the type of Internet browser you are using, the location from which you are visiting the Site, or the areas of the Site you visited and the actions you performed on the Site.
Other information	Information provided in connection with assessing, recording and reporting adverse events; information necessary to provide product recalls and product safety notification; records of sample medicines provided to healthcare professionals; information about your attendance at programs organized or supported by DKSH; information about your interactions with sales representatives; information in relation to complaints that you have made; information about your calendar for appointment scheduling and reminders.

2. How we collect your personal data.

We may collect your personal data through the following methods:

Collection method	Description
Directly from you	Including when you communicate with us over the telephone, in person, through the Site, forms, surveys, or by email; when you make an inquiry, complaint or report an actual or suspected adverse event; when you use our information services; when you attend a DKSH event; when you agree to other specific terms, privacy policies and/or consent forms required by DKSH,
Through your use of the Site	Including through the use of “cookies” that store information on your computer, mobile phone or other device, and though other tracking technologies like tags, pixels, clear pixels, gifs, bugs, beacons, and other similar technologies.
Through third parties	Including from organizations carrying out functions on our behalf such as event management organizations and data analytics organizations; pharmaceutical companies and medical device companies; hospitals and other healthcare service providers or professionals; government authorities and regulators; professional membership bodies; online directories; insurers, banks and financial institutions.

3. Why do we collect, use and disclose your personal data?

We may collect, use and disclose your personal data for the following reasons, and any other reasons which corresponds or are similar to these reasons:

Reason	Description
Provision of the Site	This includes the provision of our services to you based on our contractual obligations, to process and respond to your applications, requests, comments, inquiries, reports, complaints, and other forms you submit through the Site.
Facilitating our interactions with you	This includes maintaining our business relationship by providing you with information related to our products and services, sales and delivery of products, performing any contract with you or as agreed by you. If you are a healthcare professional, we may also use our personal data to provide information to you on educational opportunities relevant to your field, and to invite you to educational events that are relevant to your field.
Managing our relationship	This includes managing our product and service delivery, related financial transactions including invoicing for services, and carrying out quality reporting concerning our products.
Complying with legal requirements and DKSH policies	This includes processing your personal data for income tax and national insurance deductions, record-keeping and reporting obligations, conducting audits, complying with inspections and other requests from law enforcement or other public authorities; ensuring pharmaceutical business and pharmacovigilance compliance; reporting adverse events; responding to legal processes such as subpoenas and court orders; pursuing legal rights and remedies; enforcing or applying our Terms and Conditions and other agreements; defending litigation and managing any internal complaints or claims, etc.
Sale and acquisition	This includes when we become involved in a transaction involving the sale of our assets, such as a merger or acquisition, or if DKSH is transferred to another company, we may disclose and/or transfer your personal data as part of the transaction. If the surviving entity is not DKSH, your personal data may be used pursuant to the surviving entity’s privacy policies, which may be different from this Privacy Policy.
Research and insights	This includes strategic internal research and data analytics. Your personal data may be combined with the information collected from other individuals in order to generate aggregated and anonymized data that does not contain identifying information, for commercial and non-commercial purposes. We also use your personal data to enhance our understanding of our users’ preferences and to improve our Site accordingly.
Other legitimate interests	This includes when such collection, use and disclosure is permitted under the Personal Data Protection Acts such as when it is necessary for the performance of a contract to which you are a party, or in order to take steps as requested by you, when it is for our lawful interests or for other parties’ lawful interests which override your fundamental rights, when it is for the prevention or suppression of danger to a person’s life, body or health, when it is necessary for the completion of our tasks in the public interest, when preparing historical documents or archives for public and education interest or for purposes relating to research or statistics, and for the compliance of applicable laws.

4. Who may have access to your personal data?

We may share, or otherwise disclose your personal data to the following parties:

Parties

Our group companies, business partners and/or other persons that we have a legal relationship with, including our directors, employees, third party contractors, authorized representatives, and advisors.

Local and international governmental authorities and/or supervisory or regulatory authorities, credit bureaus, fraud prevention agencies, courts, health authorities, professional organizations or any persons whom we are required or permitted by laws, regulations, or orders to share personal data.

Our suppliers, agents and other entities including pharmaceutical companies, medical device companies and health service providers where the disclosure of your personal data has a specific purpose and is done under a lawful basis, including third parties providing services to us. Third party service providers which may in the future support/manage the service offering after informing you who this third-party service provider is and allowing you to reject such transfer.

Any relevant persons as a result of activities relating to selling rights of claims and/or assets, restructuring or acquisition of any of our entities, where we may transfer their rights to, and any persons with whom we are required to share data for a proposed sale, reorganization, transfer, financial arrangement, asset disposal or other transaction relating to our business and/or assets held by our business.

Insurers, banks, financial institutions, and third parties where required by law.

Attorneys, authorized persons or legal representatives who have lawfully authorized power.

To the extent permitted under applicable laws, we have contracts in place with these parties to ensure that personal data is processed based on our instructions and in compliance with this Privacy Policy and any other appropriate confidentiality and security measures. We only share your personal data with the parties mentioned above and other third parties, as far as this is reasonably necessary for the purposes as outlined in this Privacy Policy.

Please note that DKSH companies and subsidiaries, as well as authorities, customers, third-party service providers, and suppliers to whom we may disclose your personal data, may be located outside of your country of domicile, whose data protection laws may differ from those in the country in which you are located. In such cases, we will ensure that appropriate safeguards are in place to protect your personal data by implementing appropriate legal mechanisms, such as EU Standard Contractual Clauses. For more information, please contact us as described in the section “How to contact us”.

5. How long will your personal data be stored?

DKSH will store your personal data as long as necessary for the purposes outlined in this Privacy Policy, unless a longer or shorter retention period is required or permitted by law.

6. How is your personal data secured?

DKSH has implemented technical and organizational measures to protect your personal data against accidental or unlawful destruction, loss or alteration and unauthorized disclosure or access to your personal data. These measures include training of our personnel who may have access to your personal data.

7. What rights do you have in respect to your personal data?

You can exercise the rights relating to your personal data below:

Your right	Description
Right to withdraw consent	You have the right to withdraw your consent that has been given to us at any time pursuant to the methods and means prescribed by us, unless the nature of consent does not allow such withdrawal. Please note that the withdrawal of consent will not affect the lawfulness of the collection, use, or disclosure of your personal data based on your consent before it was withdrawn.
Right to access and obtain copy	You have the right to access and obtain copy of your personal data held by us, or to request the disclosure of details on how your personal data was acquired, unless we are entitled to reject your request under applicable laws or court orders, or if such request will adversely affect the rights and freedoms of other individuals.
Right to data portability	You have the right to receive your personal data where we have arranged such personal data in a format which is readable or commonly used by ways of automatic tools or equipment, and which can be used or disclosed by automated means. you also have the right to request us to send or transfer your personal data to a third party, or to receive your personal data which we have sent or transferred to a third party, unless it is impossible for us to do so because of the technical circumstances, or if we are entitled to lawfully reject your request.
Right to object	You have the right to object to the collection, use or disclosure of your personal data at any time where such personal data was collected, used, or disclosed on a lawful basis, or for the purpose of direct marketing, or for the purpose of scientific, historical or statistic research, unless we have legitimate grounds to reject your request according to applicable laws.
Right to erasure	You have the right to request us to delete, destroy or anonymize your personal data, unless we have legitimate grounds to reject your request according to applicable laws.
Right to restrict	You have the right to request us to restrict the use of your personal data under certain circumstances, such as when we are processing your request to rectify your personal data.
Right to rectification	You have the right to rectify your inaccurate personal data and to update your incomplete personal data.
Right to lodge a complaint	You have the right to make a complaint with the Personal Data Protection Committee according to the Personal Data Protection Act B.E. 2562 (2019) if you believe that we are not in compliance with applicable laws.

To exercise any of your rights above, please contact us as described in the section “How to contact us” below. After receiving your proof of identity, we will respond to your requests within one month.

8. Cookies.

The Site uses cookies for your convenience to collect and store information that your browser makes available when you visit the Site, so that you do not have to reenter your data upon each visit. This information includes your IP address, browser type, browser language, and the date and time of your query, which enables us to better understand and improve the usability, performance and effectiveness of the Site. This information is transmitted to and stored on DKSH’s servers in Singapore. If you do not want DKSH to analyze your use of the Site, you can set your browser options to reject cookies or select the privacy mode setting on your individual internet browser. Rejecting cookies or selecting privacy mode may affect your ability to use some features of the Site.

9. Privacy of minors.

DKSH is committed to protecting the privacy of minors. We do not knowingly collect, use or disclose any personally identifiable information from minors under 20 years old. Minors are not permitted to use PSPhere. For any minor to access the Site, the parent or legal guardian of that minor must contact us on their behalf. If a minor has provided DKSH with personally identifiable information, the parent or legal guardian of that minor should contact us immediately at custcare.spore@dksh.com to delete this information from our files.

10. Changes to this Privacy Policy.

DKSH may update this Privacy Policy. We will notify you about significant changes in the way we treat personal data by sending a notice to the primary e-mail address specified in your PSPhere account or by placing a notice on the Site.

11. How to contact us?

If you have any questions, comments or concerns about this Privacy Policy, or want to request access to your personal data or exercise your privacy rights, please contact us at:

Contact	Contact information
DKSH Singapore Pte Ltd.	DKSH Singapore Pte Ltd. +65 6471 1466 custcare.spore@dksh.com

Last updated: August 2021.