PRIVACY POLICY

PRIVACY POLICY

(USERS)

Dear Hero Sihat users,

This privacy policy (“Privacy Policy”) is issued to all users of this portal (including any and all websites, WhatsApp services, mobile phone applications, features, other applications and related services) (the “Portal”) which is provided by FWD Takaful Berhad (Registration No. 731530-M) (“FWD”) in collaboration with Walnut Wellness, a wellness technology services offered by LeadinHealth Sdn Bhd (Registration No.: 1166253-P) (“WW”). Both FWD and WW are referred to as “we”, “us”, “our or “Parties”, pursuant to the statutory requirements of the Personal Data Protection Act 2010 (“PDPA”).

 

What Kind Of Personal Data We Collect

Personal data means any information in our possession that relates directly or indirectly to an individual to the extent that the individual can be identified from that and from other information in our possession, which for the purpose of this Privacy Policy, includes:

  • information that you provide to WW, such as your name, telephone numbers, wellness information etc. WW may also collect information about your insurance/takaful needs, wellness parameters, lifestyle management data and any other information deemed related through programme, chat, reminder, survey, questionnaire, assessment or any other formats;
  • information collected by technology when you subscribe to our services, such as your web browser type, Internet Protocol (IP) address, domain name, user profiles, cookies, Android ID, third party analytics services (e.g. Google Analytics), etc;
  • information collected from third parties or other permissible or authorized sources, such as where you have given your consent via third parties’ website to disclose to us information relating to you.

 

For any avoidance of doubt, FWD does not collect any personal identifiable information via the Portal.

Personal data for purposes of this notice may, where applicable, include sensitive personal data which means any personal data consisting of information as to your physical or mental health or condition, religious beliefs or other beliefs of a similar nature, or any other personal data as the Minister may determine.

How We Use Your Personal Data

The personal data (including sensitive personal data) collected from you will be used to:

  • provide you wellness consultation, tips and information;
  • assess and process your application, subscription, request or order for any of the products and/or services offered on the Portal;
  • process, facilitate, administer and/or provide you with the products and/or services offered on the Portal;
  • carry out, manage and/or maintain your relationship with us, your commercial transactions and dealings with us;
  • process your payments, including providing billing to you, maintaining financial records, assessing or verifying credit/debit card details and facilitating payments of any amount due to us;
  • provide you with service support, management and optimisation, customer support and other related services, including respond to your enquiries or complaints;
  • improve and facilitate our customer services, business development initiatives;
  • profiling your usage and purchasing preferences, including by analysing how you use the products and/or services on a personalized or aggregated basis in order to gather information on demography, interests, and behaviours so that we can better understand you and can tailor the products and/or services in accordance with your preferences;
  • conduct market research or surveys, internal marketing analysis, customer profiling activities, analysis of customer patterns, behaviours and choices, planning and statistical analysis, including preparation of reports of such analysis and the use of the results of such analysis for various purposes including for the development and marketing of our and/or our selected third party providers’ products and/or services;
  • provide you with wellness information and contents via the Portal and other platforms;
  • promote our products and/or services, or promote products and/or services of third-party providers which we think may be of interest to you;
  • send you seasonal greetings and offers;
  • any other purposes that are necessary or related to your relationship with us

(collectively referred to as “Purposes”).

As part of the services offered via the Portal, we may send you promotional materials regarding our products and/or services, or products and/or services of our selected providers which we think may be of interest to you, or even any other content, information, survey, questionnaire or materials from the Parties (regarding insurance/takaful products, any of FWD agents, any of our wellness experts, any of the solution providers or any advertiser or health education information) that may be of interest you. You may at any time unsubscribe from receiving any such further materials by contacting us.

Please email to enquiry@leadinhealth.com should you are not interested to receive any promotional materials regarding our products and/or services, or products and/or services of our selected providers from the start.

Please note that we may also anonymise or aggregate your personal data by excluding information (such as your name) that make the data personally identifiable to you (“Anonymous Information“). This Anonymous Information may be used to personalize our or our products and/or services for you, including directing certain advertisements to make them more relevant to you or to analyse request and usage patterns so that we may improve our products and/or services or for any related market research purposes, either internally or through third parties.

We may also share such Anonymous Information, including data and statistics, to our group of companies, third parties including business partners who assist in performing our core operations and counterparts who perform statistical research, advertisers, insurance agencies, health services, health product distributions, medical claims management, insurance distribution and such other parties for service provision, product distribution, promotional and advertising purposes. These parties shall only use information to carry out their specific business obligations to us.

We will process your personal data in accordance with the PDPA, its applicable regulations, guidelines and/or orders, taking into account the latest amendments to the foregoing, this Privacy Policy and any privacy terms contained in your agreement(s) or terms of use with us. We may process your personal data by collecting, recording, holding, storing, using and/or disclosing it.

We do not otherwise sell or commercially make available personal-identifiable information about our users (other than in the form of Anonymous Information) to any third party, unless otherwise authorized by law enforcement bodies in complying with legal process and in regards to content violations or violations of applicable laws.

 

Disclosure of Your Personal Data

We will not disclose any of your personal data to any third party without your consent, whether within or outside Malaysia, except to:

  • the Parties group of companies (including the Parties’ subsidiaries, related and/or associated companies);
  • FWD’s agents, agencies and consultants;
  • WW’s selected providers, i.e. product brand companies (which provide you wellness related products), service-based companies (any wellness related service providers); including third party service providers who personalize the types of information that we receive from you and to customize, improve and develop content and functionality to help us provide you with better products and/or services;
  • successor in title to us;
  • any governmental agencies, regulatory authorities and/or statutory bodies;
  • parties (including but not limited to its advisers/representatives) in connection with any corporate exercises, e.g. any proposed or actual mergers and/or acquisitions, joint venture, funding exercise, asset sale or for any other matter of such nature which relates to the Company;

and where necessary, to any party who undertakes to keep your personal data confidential in carrying out the Purposes mentioned above or to persons whom we are compelled or required under the law to make such disclosure to.

 

What If Personal Data Provided By You Is Incomplete?

It is necessary for us to collect and process your personal data. If you do not provide us with your personal data (which are required for the purpose of the products and/or services offered on the Portal), we will not be able to effectively provide products and/or services to you or process your personal data for any of the Purposes, if at all. We will indicate to you if the personal data which we request from you is optional, in which case you have the option not to provide such personal data.

 

Your Rights to Access and Correct Your Personal Data

We are committed to ensuring that your personal data is stored securely and will store your personal data only for such duration as necessary and/or as per the PDPA permits. You have the right to request for access to, request for a copy of and request to update or correct, your personal data held by us by editing your profile through your account in the Portal. You also have the right at any time to request us to limit the processing and use of your personal data (for example, requesting us to stop sending you any marketing and promotional materials or contacting you for marketing purposes), subject to our right to rely on any statutory exemptions and/or exceptions to collect, use and disclose your personal data.

Your written requests or queries should be addressed to:

[Personal Data Protection Officer/Legal Officer/Customer Service Officer] Email Address : [enquiry@leadinhealth.com]

By providing your personal data to us, you consent to us transferring, storing and processing your personal data in accordance with this Privacy Policy, and you confirm that all personal data provided by you is accurate and complete, and that none of it is misleading or out of date. You will promptly update us in the event of any change to your personal data.

To the extent that you have provided (or will provide) personal data about your family members, spouse, other dependents (if you are an individual), directors, shareholders, employees, representatives, agents (if you are a corporate entity/an organisation) and/or other individuals, you confirm that you have explained (or will explain) to them that their personal data will be provided to, and processed by, us and you represent and warrant that you have obtained their consent to the processing (including disclosure and transfer) of their personal data in accordance with this Privacy Policy.

In respect of minors (i.e. individuals under 18 years of age) or individuals not legally competent to give consent, you confirm that you are the parent or guardian or person who has parental responsibility over them or the person appointed by court to manage their affairs or that they have appointed you to act for them, to consent on their behalf to the processing (including disclosure and transfer) of their personal data in accordance with this Privacy Policy.

 

Personal Data Storage Location

Please note that we are entitled to transfer any personal data that we process to any country or territory outside Malaysia in accordance with Section 129 of the PDPA.

 

Personal Data Handled by Our Selected Providers

Please note that our selected providers which provide you with products and/or services via the Portal (e.g. dietitian, fitness trainer, insurance/takaful agents etc.) are strictly bound by professional privilege or patient confidentiality and are bound by the relevant codes of conduct of their professions as governed by their respective professional bodies. We do not, and will not, accept any obligations of confidentiality with respect to any communications other than those expressly stated in our Terms of Use and Privacy Policy.

 

Information which You Provide via the Portal

Your use of the services via the Portal and publication or posting of questions, answers, comments, discussion or other features are private between you and WW. You should consider carefully before disclosing any kind of individual-specific and personally-identifiable information in any public feature as it may be seen and collected by third parties who may use such for other purposes, of which we do not have control of. Kindly exercise discretion in publication or posting of any sensitive information.

 

Amendments to This Privacy Policy

We reserve the right to update and amend this Privacy Policy from time to time. We will notify you of any amendments to this Privacy Policy via announcements on our website or other appropriate means. If we amend this Privacy Policy, the amendment will only apply to personal data collected after we have posted the revised Privacy Policy.

 

Language of this Privacy Policy

In accordance with Section 7(3) of the PDPA, this Privacy Policy is issued in both English and Bahasa Malaysia. In the event of any inconsistencies or discrepancies between the English version and the Bahasa Malaysia version, the English version shall prevail.

 

Last update: [9.10..2019]