PDPA Policy

In this policy, “KYAN Therapeutics” or “we” refers to KYAN Technologies Pte Ltd, a Singapore company, UEN 202226520H (together with our subsidiaries).

KYAN Therapeutics is committed to ensuring the proper protection of all information assets within our possession, and doing so in accordance with the Singapore Personal Data Protection Act (the “PDPA”), the Private Hospitals and Medical Clinics Act, the Ministry of Health’s guidelines, directives and other relevant legislation.

This Personal Data Protection Policy explains how we collect, hold, use, disclose, secure, and otherwise manage all personal information. It describes the types of information we collect and hold, as well as the reasons and methods of accessing and correcting such information.

When you provide us with your personal data, directly or indirectly, you expressly grant consent to KYAN Therapeutics to collect, use, and disclose your personal data to all relevant third parties as laid out in our Personal Data Protection Policy.

The policy herein serves as a supplement and therefore does not supersede or act as a substitute to any other prior consent that you may have provided to KYAN Therapeutics with regard to your personal data. KYAN Therapeutics also reserves all rights granted by the law to collect, use, or disclose your personal data.

What is personal data?

Personal data is any data about an identified individual or an individual who is reasonably identifiable.

Types of Personal Data that may be provided to or collected by KYAN Therapeutics include but are not limited to:

(a) Name;

(b) NRIC, passport or other personal identification number;

(c) Telephone number;

(d) Fax number

(e) Mailing address;

(f) E-mail address; and

(g) any other information relating to the individual that has been provided to KYAN Therapeutics.

How do we collect personal data?

We may collect personal data in any of the following scenarios:-

• when you submit a form, including but not limited to laboratory request forms
• when you provide us with your tissue specimens or any other organic materials such that it is linked with other data in a way that you can be identified
• when you interact with our staff, including customer service officers, phlebotomists, medical technologists and other KYAN Therapeutics representatives via telephone calls (which may be recorded), letters, fax, in-person meetings, and email
• when our CCTV cameras capture your images while you are in our premises, or when you attend events hosted or sponsored by us during which photographs or videos are taken by us or our representatives
• when you use our services provided through online platforms, such as our website, including any other online platforms
• when you request that we contact you, be included in an email or other mailing list, or when you respond to our request for additional personal data as part of our promotions or other initiatives
• when we receive your personal data from referral parties, public agencies, your employer, or any other third party
• when you interact with us on our websites, your information may be automatically recorded on our server logs from your browser. E.g. We may employ cookies in order for our server to recognise a return visitor as a unique user.
• when you submit your personal data to us for any other reasons

For what purposes do we use and disclose personal information?

KYAN Therapeutics uses the personal information it collects and holds to:

• contact individuals to respond to enquiries, to follow up, for authorisation in relation to any service provided
• enable the provision of education and training in the health profession
• effectively administer, manage, monitor and improve our services
• planning, evaluation and complaint-handling
• communicate with individuals by various means about our available services
• charging and billing
• verify an individual’s identity to proceed with sample processing
• comply with quality assurance or clinical audit activities
• undertake accreditation activities
• respond to feedback or customer query
• address liability indemnity arrangements and reporting
• compilation or analysis of statistics relevant to services provided

We may also use personal data in circumstances where we are required or authorised by law to do so or where we otherwise have consent of the individual or their representative.

To whom do we disclose personal information?

By contacting or dealing with us, you herein agreed unilaterally that we may disclose an individual’s personal information to the following third parties (including but not limited to) to other health service providers involved in the individual’s treatment or diagnostic services

How do we store and secure personal information?

We store personal and health information in electronic form.

The security of personal and health information is very important to us and we take reasonable steps to protect it from misuse, interference and loss and from unauthorised access, modification or disclosure.

Some of the ways we do this include:

• requiring our staff to maintain confidentiality
• implementing document storage security
• imposing security measures for access to our computer systems
• providing a discreet environment for confidential discussions
• allowing access to personal and health information only where the individual seeking access to their own information has satisfied our identification requirements

Personal and health information is retained for the period of time determined by KYAN Therapeutics and/or stipulated by law after which it is de-identified or disposed of in a secure manner.

How do we keep personal information accurate and up-to-date?

We take all reasonable steps to ensure that the personal information we collect is accurate, complete and up-to-date, and also when we use or disclose it, that it is relevant.

However, the accuracy of that information depends largely on the quality of the information provided to us.

How can personal information we hold be accessed?

Individuals have a right to access the personal information that KYAN Therapeutics holds about them. We will give access to an individual’s personal information in the form they request.

However, if the situation doesn’t permit us doing so, we will, with reasonable means, provide alternative means of access or discuss how access can be given through a mutually agreed intermediary.

We will disclose the personal information and give access to the individual’s Authorized representative or legal adviser whom we have been given written authority to do so.

Please be aware that if your personal data has been provided to us by a third party (e.g. your doctor or employer), you need to contact that individual or organization directly if you have any related query or complaint.

How to contact our Data Protection Officer?

If there are any questions or feedback relating to one’s Personal Data or this policy; or a party would like to withdraw one’s consent to use of one’s Personal Data as set out in this policy; or a party would like to obtain access and/or make corrections of Personal Data records, please contact our Data Protection Officer by emailing dpo@kyantherapeutics.com.