APAC Privacy Policy

BIOTRONIK Asia Pacific

Privacy Policy

BIOTRONIK Asia Pacific Pte. Ltd. and its affiliates, employees, representatives and/or agents (collectively “BIOTRONIK”, or “we”, or “us”, or “our”) respect the privacy of your personal data. It is important for us to provide you with this explanation about our practices as they relate to the handling of your personal data in connection with your participation or registration to BIOTRONIK’s educational activities, programs, scientific meetings, trainings, e-libraries or any other events (the “Activities”) for educational purposes.

This Privacy Policy sets out the basis in which BIOTRONIK may collect, use, disclose or otherwise process your personal data, which we may obtain when you visit our website or when you interact with BIOTRONIK’s online registration forms, digital activities (including but not limited to audio or video recording), in accordance with the Singapore Personal Data Protection Act 2012 (“PDPA”). This Privacy Policy applies to personal data in our possession or under our control, including personal data in the possession of organizations which we have engaged to collect, use, disclose or process personal data for our purposes.

A. What Data is Being Collected and Processed?

For the purpose of this Privacy Policy, “personal data” means data, whether true or not, about you 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.

Depending on the nature of your interaction with BIOTRONIK, we may collect and process personal data including but not limited to your name(s), email, phone number, your employment information, bank and payment references (if required for reimbursement purposes), photographs and other audio-visual information.

B. 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 authorized by you to disclose your personal data to us (your “authorized representative”) after

(i) you (or your authorized representative) have been notified of the purposes for which the data is collected, and

(ii) you (or your authorized 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 applicable 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 authorized by law).

2. We may collect and use your personal data for any or all of the following purposes:

(a) performing obligations in the course of or in connection with our provision of the services relating to the Activities;

(b) verifying your identity;

(c) providing you with marketing information about our products, including notifying you of our marketing events, initiatives, and make suggestions and recommendations about our products or services that may interest you;

(d) dealing with any inquiries, correspondence, concerns or complaints you have sent to us;

(f) managing your relationship with us;

(g) 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;

(h) any other purposes for which you have provided the information;

(i) 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; and/or

(j) any other incidental business purposes related to or in connection with the above.

3. We may disclose your personal data:

(a) where such disclosure is required for performing obligations in the course of or in connection with our provision of services relating to the Activities; or

(b) to third party service providers, agents and other organizations we have engaged to perform any of the functions listed in Section 2 above for us.

The purposes listed in the above sections may continue to apply even in situations where your relationship with us 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 any contract with you).

C. Transfer of Personal Data Outside of Singapore

In certain cases, BIOTRONIK may transfer your personal data to one of its affiliates or third party service providers in other countries, potentially including countries which may not be considered as providing an adequate level of protection for your personal data compared with the ones provided in your country, but only in furtherance of the purposes set out in this Privacy Policy. In such cases, we will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.

D. Retention of Personal Data

BIOTRONIK will only keep your personal data for so long as necessary to fulfill the purposes for which we are allowed to use them and in compliance with specific applicable record retention requirements. Once the purpose is completed and provided that no specific legal record keeping obligations apply, we shall cease to retain your personal data.

E. Withdrawing Your Consent

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 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 us. 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. 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 the applicable laws.

F. Access to and Correction of Personal Data

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 us. We will respond to your request as soon as reasonably possible.

G. Contact Us

If you have any comments or questions about this Privacy Policy, or if you wish to report any violations of this Privacy Policy, please contact us at communications.ap@biotronik.com.

H. Effect of Privacy Policy and Changes to Privacy Policy

Where applicable, this Privacy Policy applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data to us. We may revise this Privacy 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 Privacy Policy was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.

 

Last Updated April 2021