Postura Wellness (“Postura Wellness”, “we”, “us” or “our”) respects your privacy and is committed to protecting your personal data in accordance with the Personal Data Protection Act 2012 of Singapore (“PDPA”) and applicable regulations and guidelines.
This Privacy Policy explains how we collect, use, disclose, store and protect personal data when you visit or use our website, contact us, submit an enquiry, book an appointment, visit our clinics, receive chiropractic, physiotherapy or wellness services, purchase a treatment, package or programme, communicate with our staff or practitioners, or otherwise interact with Postura Wellness.
By using our website or providing personal data to us, you acknowledge that you have read and understood this Privacy Policy.
1. ABOUT POSTURA WELLNESS
Postura Wellness provides chiropractic, physiotherapy and wellness services in Singapore.
Website: www.posturawellness.com
For privacy and data protection enquiries:
Data Protection Officer
Postura Wellness
Email: hello@posturawellness.com
Telephone: +65 8399 1262
2. PERSONAL DATA WE COLLECT
Depending on your interaction with us, we may collect:
A. Identity and contact information
- Name
- Date of birth
- Age
- Gender, where relevant
- Mobile number
- Email address
- Address
- Emergency contact information
B. Healthcare and treatment information
Where reasonably necessary for the provision of our services, we may collect:
- Medical history
- Symptoms and areas of pain
- Previous injuries
- Previous surgeries
- Existing medical conditions
- Medication information
- Treatment history
- Physical examination findings
- Postural assessment information
- Musculoskeletal assessment results
- Mobility and functional assessment results
- X-rays and other diagnostic images provided to us
- Treatment records
- Clinical notes
- Rehabilitation plans
- Exercise programmes
- Treatment progress
- Other information relevant to your care
Healthcare information may be particularly sensitive. We therefore apply additional safeguards appropriate to the nature of such information.
C. Appointment and transaction information
- Appointment dates and times
- Practitioner information
- Treatment packages
- Treatment history
- Payment information
- Transaction information
- Invoice information
- Insurance information
- Cancellation and attendance records
D. Communications
We may retain information contained in communications with us, including:
- Telephone communications
- WhatsApp messages
- Emails
- Website enquiries
- Online forms
- Feedback
- Reviews
- Customer service communications
E. Website and technical information
When you visit our website, we may collect:
- IP address
- Browser type
- Device type
- Operating system
- Approximate geographical information
- Pages visited
- Time and duration of visits
- Referring websites
- Clicks and interactions
- Website events
- Cookies
- Advertising identifiers
- Similar technical or tracking information
3. ANALYTICS, COOKIES AND ADVERTISING TECHNOLOGIES
We use analytics, advertising and measurement technologies provided by third parties to understand how visitors use our website, measure advertising performance, improve our website and services, and deliver or measure relevant advertising.
These technologies may include Google, Meta and TikTok technologies, including Google Analytics, Google Tag Manager, Google Ads conversion tracking, Google advertising/measurement technologies, Meta Pixel, Meta advertising and measurement tools, TikTok Pixel, TikTok advertising and measurement tools, cookies, web beacons, tracking pixels and similar technologies.
The exact technologies deployed may change from time to time.
These technologies may collect information such as IP address, browser and device information, operating system, website pages visited, referring URL, approximate location, date and time of website activity, advertisement interactions, website events, button clicks, campaign information, cookie identifiers and advertising identifiers.
We use this information to understand website traffic, improve website performance, measure advertising effectiveness, measure conversions, improve campaigns, understand which marketing channels generate enquiries, create or optimise advertising audiences, reduce ineffective advertising and improve user experience.
Important limitation regarding healthcare information:
Postura Wellness does not intentionally transmit identifiable patient medical records, clinical notes, diagnoses, treatment details, X-ray information or other sensitive healthcare information to Google, Meta, TikTok or other advertising platforms through our website analytics or advertising technologies.
We take reasonable steps to configure our website, analytics and advertising systems to prevent healthcare information and unnecessary personally identifiable information from being included in analytics or advertising events.
This restriction does not prevent those platforms from independently receiving technical information about a visitor’s interaction with our website through their respective technologies, subject to their own policies and applicable law.
4. WHY WE COLLECT AND USE PERSONAL DATA
We may collect, use and disclose personal data for:
Healthcare and treatment:
- Providing consultation and treatment
- Conducting assessments
- Understanding health history
- Developing treatment plans
- Monitoring treatment progress
- Maintaining healthcare records
- Coordinating relevant care
- Reviewing diagnostic information
- Providing rehabilitation recommendations
- Communicating regarding care
Administration:
- Processing appointments
- Sending appointment reminders
- Managing cancellations and rescheduling
- Processing payments
- Issuing invoices
- Managing treatment packages
- Processing refunds
- Responding to enquiries
- Providing customer service
Business operations:
- Managing clinics
- Improving services
- Internal quality assurance
- Staff training
- Managing complaints
- Preventing fraud or misuse
- Maintaining business records
- Complying with legal and regulatory requirements
- Protecting legal rights
Marketing and advertising:
Where permitted and where appropriate consent has been obtained, we may use contact information to send promotions, educational content, event invitations, offers and other direct marketing communications.
Direct marketing consent is handled separately from consent required to provide healthcare services.
5. CONSENT
Where required by the PDPA, we will obtain consent before collecting, using or disclosing personal data.
Consent may be obtained through registration forms, electronic forms, website forms, appointment processes, treatment consent forms, marketing consent forms or other legally recognised methods.
Where permitted under the PDPA, personal data may be collected, used or disclosed without express consent where a statutory exception or other lawful basis applies.
Consent for healthcare treatment does not automatically constitute consent for marketing. Consent for marketing does not automatically constitute consent for healthcare treatment.
6. DIRECT MARKETING
Where we send direct marketing communications, we will comply with applicable requirements under the PDPA and Do Not Call (“DNC”) provisions.
Marketing consent may be provided through an explicit opt-in.
Marketing communications may include SMS, WhatsApp, email, telephone, social media-related communications and other permitted electronic communications.
You may withdraw marketing consent at any time. Withdrawal of marketing consent does not prevent us from sending essential administrative or healthcare-related communications.
7. DISCLOSURE OF PERSONAL DATA
We do not sell your personal data.
We may disclose personal data where reasonably necessary to our chiropractors, physiotherapists, healthcare personnel, administrative staff, payment providers, appointment and booking providers, IT providers, cloud service providers, website providers, analytics providers, advertising and measurement platforms, marketing service providers, professional advisers, insurers, healthcare professionals involved in your care, government agencies, regulators or law enforcement authorities.
Where third parties process personal data on our behalf, we take reasonable steps to ensure appropriate contractual and security safeguards are in place.
8. OVERSEAS DATA TRANSFERS
Certain service providers used by Postura Wellness may process or store information outside Singapore.
Where personal data is transferred outside Singapore, we will take reasonable steps to ensure that the recipient provides a standard of protection comparable to that required under the PDPA, where applicable.
9. PROTECTION OF HEALTHCARE INFORMATION
We recognise that patient information may be particularly sensitive.
Access to healthcare information is restricted to authorised personnel who reasonably require the information for legitimate clinical, administrative, operational or legal purposes.
We may implement safeguards including access controls, authentication, password protection, restricted system permissions, staff confidentiality obligations, secure electronic systems, vendor controls, data security procedures and staff training.
10. DATA RETENTION
We retain personal data only for as long as reasonably necessary for the purposes for which it was collected or where retention is required or permitted by law.
Healthcare records may be retained for longer periods where required for clinical, legal, regulatory, professional, accounting or other legitimate purposes.
When information is no longer required, we will take reasonable steps to delete, anonymise or securely dispose of it.
11. ACCESS AND CORRECTION
You may request access to personal data held by us about you.
You may also request information about how your personal data has been used or disclosed within the applicable period under the PDPA.
You may request correction of inaccurate or incomplete personal data.
We may require identity verification before processing a request.
Certain requests may be subject to applicable legal exceptions or reasonable administrative fees where permitted by law.
12. WITHDRAWAL OF CONSENT
You may withdraw consent by contacting our Data Protection Officer.
Withdrawal of consent does not affect any collection, use or disclosure carried out before withdrawal.
Where information is necessary for us to provide healthcare or contractual services, withdrawal may affect our ability to continue providing those services.
13. DATA BREACHES
If we become aware of a suspected or actual personal data breach, we will assess the incident and take appropriate measures.
Where required under the PDPA, we will notify the Personal Data Protection Commission and affected individuals in accordance with applicable requirements.
Our response may include containing the breach, assessing affected information, identifying affected individuals, assessing potential harm, taking remedial measures, implementing additional security controls and making regulatory or individual notifications where required.
14. THIRD-PARTY WEBSITES
Our website may contain links to third-party websites and platforms, including booking platforms, payment providers, Google services, Meta services, TikTok, social media platforms and other third-party services.
We are not responsible for the privacy practices of third-party websites.
15. CHILDREN AND MINORS
Where services are provided to minors, we may require consent or involvement from a parent or legal guardian where appropriate.
We do not knowingly use children’s healthcare information for advertising or remarketing purposes.
16. CHANGES TO THIS POLICY
We may update this Privacy Policy from time to time. The latest version will be published on our website.
17. CONTACT
Data Protection Officer
Postura Wellness
Email: hello@posturawellness.com
Telephone: +65 8399 1262
18. GOVERNING LAW
This Privacy Policy is governed by the laws of Singapore.