PRIVACY POLICY (Cloud Clinic Pte. Ltd.)

Effective Date: March 2, 2026

1. INTRODUCTION

Cloud Clinic Pte. Ltd. (“Cloud Clinic,” “we,” “our,” or “us”) is committed to protecting your privacy. This Privacy Policy describes how we collect, use, and disclose information when you visit our websites (thesire.sg), use our mobile applications (“Apps”), or use our telehealth services (collectively, the “Services”). This policy is designed to comply with the Singapore Personal Data Protection Act 2012 (PDPA) and the Health Information Act 2026 (HIA).

2. THE INFORMATION WE COLLECT

We collect information necessary to provide safe medical care and a seamless digital experience:

Identity & Contact Data: Name, NRIC/FIN (required for medical verification), date of birth, gender, and contact details.
Health Data: Medical history, symptoms, laboratory results, prescriptions, and physician notes.
Financial Data: Billing addresses and payment card details (processed securely via third-party providers).
Technical & Automated Data: IP addresses, browser types, device IDs, and “pixel” data regarding your interaction with our Sites.
Device Permissions: With your consent, we access your camera and microphone (for video calls) and photo library (for document uploads).

3. PURPOSES FOR HOW WE USE YOUR INFORMATION

We use your information for the following business and clinical purposes:

Clinical Care: Facilitating medical consultations and pharmacy fulfillment.
Identity Verification: Ensuring the person receiving care matches the NRIC provided, as mandated by the Healthcare Services Act (HCSA).
AI Integration: We utilize Artificial Intelligence for clinical transcription and administrative triage. These tools process data to assist practitioners but do not replace human medical judgment.
Analytics: To improve our platform’s performance and user experience.

4.NATIONAL ELECTRONIC HEALTH RECORD (NEHR) AND MEDICAL CONFIDENTIALITY

As part of our commitment to your safety and the continuity of care, Cloud Clinic participates in the National Electronic Health Record (NEHR) system. This is a secure, centralized system managed by the Ministry of Health (MOH) that allows authorized healthcare professionals in Singapore to view your key medical records.

Mandatory Contribution: In accordance with the Health Information Act, licensed healthcare providers are required to contribute relevant health information to the NEHR to ensure a holistic view of a patient’s medical history.
Medical Confidentiality: Your medical information remains strictly confidential. Access to your NEHR records is restricted to authorized healthcare professionals directly involved in your care.
Patient Preferences: You have the right to manage your NEHR access preferences. While health information will still be uploaded to the system by law, you may choose to “opt-out” of having your records viewable by healthcare providers via the official MOH / NEHR portals.
Data Protection: All NEHR data is encrypted and managed under the highest security standards, exceeding the general requirements of the Personal Data Protection Act (PDPA).

5. ONLINE ANALYTICS AND ADVERTISING

We use third-party tools (e.g., Google Analytics, Meta Pixels) to understand user behavior.

Marketing Transparency: We do not share identifiable health data (e.g., your specific diagnosis) with social media platforms for advertising.
Opt-Out: You may manage your cookie preferences through your browser settings or device-based “Opt-out of Ads Personalization.”

6. HOW WE SHARE AND DISCLOSE YOUR INFORMATION

We share your data only in the following circumstances:

Healthcare Partners: With licensed doctors, laboratories, and pharmacies to fulfill your care.
NEHR Contribution: In accordance with the Health Information Act 2026, Cloud Clinic contributes key health data to the National Electronic Health Record (NEHR) to ensure continuity of care across Singapore’s healthcare system.
Legal Requirements: When required by law, such as responding to a lawful request from the Ministry of Health (MOH) or law enforcement.
Business Transfers: In the event of a merger or sale of Cloud Clinic assets.

7. HOW WE PROTECT YOUR INFORMATION

We implement industry-standard technical and organizational measures, including:

Encryption: Data is encrypted at rest (AES-256) and in transit (SSL/TLS).
Access Control: Only authorized clinical and administrative staff have access to your health records.
Jailbreak Prevention: We monitor for “jailbroken” devices to prevent data leaks from compromised hardware.

8. RETENTION OF YOUR INFORMATION

We retain medical records for a minimum of six (6) years from the date of your last consultation, or as otherwise mandated by the Ministry of Health (MOH) Singapore. Non-medical personal data is deleted when it is no longer necessary for business or legal purposes.

9. YOUR RIGHTS AND CHOICES

Under the PDPA, you have the right to:

Access: Request a copy of the personal data we hold about you.
Correction: Request that we correct any inaccuracies in your data.
Withdrawal: Withdraw consent for marketing communications at any time.

10. REVISIONS TO OUR PRIVACY POLICY

We may update this policy periodically. Material changes will be notified via the Sites or email. Your continued use of the Services after such updates constitutes acceptance of the revised policy.

11. CONTACTING US / DATA PROTECTION OFFICER (DPO)

If you have questions regarding your privacy, please contact our Data Protection Officer at:
Email: hello@cloudclinic.cc
Address: SIRE- 18 Sin Ming Lane, #07-38 Midview City Singapore 573960