This Privacy Policy sets out the basis upon which Hannah Life Technologies Pte Ltd (“Hannah Life Technologies”, “we”, “us”, or “our”) may collect, use, disclose or otherwise process the personal data of our customers in accordance with the Personal Data Protection Act (“PDPA”). This Policy will provide you with a notice and overview on how your personal data is collected, intended to be used, transferred to, stored and accessed. It also covers how we amend and protect your personal data provided to us.

Here at Hannah Life Technologies Pte Ltd, we take just as much pride in providing you with data protection. We will continuously update and review our adherence to changes in PDPA as well as the steps taken to provide security and protection to your data.

PERSONAL DATA

1. As used in this Policy:
   
   “customer” means an individual who (a) has contacted us through any means to find out more about any goods or services we provide, or (b) may, or has, entered into a contract with us for the supply of any goods or services by us; and
   
   “personal data” means data, whether true or not, about a customer who can be identified: (a) from that data; or (b) from that data and other information to which we have or are likely to have access.
   
   
2. Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include name, residential address, email address, telephone number, nationality, gender, date of birth, marital status, employment information, health information, financial information, web browser, country of residence, and some of the cookies that are installed on your device.
   
   
3. Other terms used in this Policy shall have the meanings given to them in the PDPA (where the context so permits).
   
   

COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA

1. We generally do not collect your personal data unless (a) it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”) after (i) you (or your authorised representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorised representative) have provided written consent to the collection and usage of your personal data for those purposes, or (b) collection and use of personal data without consent is permitted or required by the PDPA or other laws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorised by law).
   
   
2. We may collect and use your personal data for any or all of the following purposes:
   1. performing obligations in the course of or in connection with our provision of the goods and/or services requested by you;
   2. verifying your identity;
   3. responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
   4. managing your relationship with us;
   5. processing payment or credit transactions;
   6. complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;
   7. any other purposes for which you have provided the information;
   8. transmitting to any unaffiliated third parties including our third-party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes;
      
      For example, we use Shopify to power our online store--you can read more about how Shopify uses your Personal Information here: https://www.shopify.com/legal/privacy.
      
      We also use Google Analytics to help us understand how our customers use the Site--you can read more about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.
   9. any other incidental business purposes related to or in connection with the above;
   10. when in line with the preferences you have shared with us, provide you with information or advertising relating to our goods and/or services;
   11. provide you with targeted advertisements or marketing communications we believe may be of interest to you.
       
       For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.
       
       You can opt out of targeted advertising by using the links below:
       • Facebook: https://www.facebook.com/settings/?tab=ads
       • Google: https://www.google.com/settings/ads/anonymous
       • Bing: https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads
       
       Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.
   12. providing you with regular or ad-hoc updates, information required for your services update, upgrade, enhancement and their respective applications;
   13. processing of insurance applications meant for the coverage and safety during the delivery of our respective goods and/or services;
   14. submission and application for funding and certification processes to professional bodies;
   15. screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize twoplusfertility.com (the “Site”). For example, by generating analytics about how our customers browse and interact with the Site, and to assess the success of our marketing and advertising campaigns.
   16. website visitor traffic and informatics on the Site via the following technologies:
       
       - “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, visit http://www.allaboutcookies.org.
       
       - “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
       
       - “Web beacons,” “tags,” and “pixels” are electronic files used to record information about how you browse the Site.
3. We may disclose your personal data:
   1. where such disclosure is required for performing obligations in the course of or in connection with our provision of the goods and services requested by you;
   2. to third party service providers, agents and other organisations we have engaged to perform any of the functions with reference to the above mentioned purposes; or
   3. complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority.
4. The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under a contract with you).

WITHDRAWING YOUR CONSENT

1. The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop collecting, using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.
2. Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within fourteen (14) business days of receiving it.
3. Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our goods or services to you and we shall, in such circumstances, notify you before completing the processing of your request. 
4. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.

ACCESS TO AND CORRECTION OF PERSONAL DATA

1. If you wish to make (a) an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, or (b) a correction request to correct or update any of your personal data which we hold about you, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.
2. Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.
3. We will respond to your request as soon as reasonably possible. In general, our response will be within seven (7) business days. Should we not be able to respond to your request within fourteen (14) days after receiving your request, we will inform you in writing within fourteen (14) of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).

PROTECTION OF PERSONAL DATA

1. To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as:
   • authentication and access controls (such as good password practices, need-to-basis for data disclosure, etc.),
   • encryption of data,
   • up-to-date antivirus protection,
   • regular patching of operating system and other software,
   • securely erase storage media in devices before disposal,
   • web security measures against risks,
   • usage of one time password (otp)/2 factor authentication (2fa)/multi-factor authentication (mfa) to secure access, security review and testing performed regularly,
   • credential exposure checks, and
   • device vulnerability assessment and security hardening
2. You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.

ACCURACY OF PERSONAL DATA

1. We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided below.

RETENTION OF PERSONAL DATA

1. We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.
2. We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.

MINORS

1. The Site is not intended for individuals under the age of 21.

DATA PROTECTION OFFICER

1. If you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, you may contact our Data Protection Officer by email at [email protected] or by mail using the details provided below: 2 Sims Close, #03-04 Gemini @ Sims, Singapore 387298.

EFFECT OF POLICY AND CHANGES TO POLICY

1. This Policy applies in conjunction with any other Policies, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.
2. We may revise this Policy from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Policy was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.

Last updated: 23/05/2024