- access or use our Ubie AccountUbie Account (mobile, web-based, or otherwise) (“Ubie Account”), and services; and/or
- provide us with your Personal Data, regardless of the medium through which such Personal Data is provided.
1. Information You Give Us
1.1 For the purposes of this Policy, “Personal Data” shall mean data, whether true or not, about an individual 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, including but not limited to name, identification number, birth date, address, postal code, and contact information. Such Personal Data shall also refer to that which is already in our possession or that which shall be collected by us in the future.
1.2 We may collect your Personal Data directly or indirectly, through various channels, such as when:
- (a) you access or use the Ubie Account;
- (b) you use our services or enter into transactions with us;
- (c) you contact us by telephone, email or any other means;
- (d) we seek information about you and receive your Personal Data in connection with your relationship or business dealings with us;
- (e) you register for and/or attend events organized by us; and/or
- (f) you provide us with your Personal Data for any other reason.
1.3. The information we obtain from you may include:
- (a) name, telephone number, e-mail address, external app’s ID connected with the Ubie Account, and other information that can identify the specific individual;
- (b) contents that user used in the Ubie Account, history of use, frequency, online action when using the Ubie Account, usage or browsing related information, including Cookie (defined in clause 2.9 below), access log, device, OS, location, browser, browser language, and other user’s communication related information;
- (c) account related information including login ID and password;
- (d) any such information as we deem necessary or appropriate from time to time in connection with the Ubie Account to be provided to you.
2. Collection, Use, Transfer and Disclosure of Personal Data
2.1. We generally do not collect your Personal Data unless (a) it is provided to us voluntarily by you directly or via a third party (including your doctors and healthcare providers) 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 Personal Data is collected, and (ii) you (or your authorized representative) have provided 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 any 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).
2.2. We may collect, use and store your Personal Data for any or all of the following purposes:
- (a) offer the service of the Ubie Account and conduct user verification;
- (b) provide users with reference information, which means the information that we provide for users’ reference, including health-related information;
- (c) provide users with information in relation to medical/healthcare institutions;
- (d) facilitate users’ information sharing with medical/healthcare institutions which is necessary for medical examinations;
- (e) enable viewing users’ information in the Ubie Account;
- (f) facilitate users inputting information to other connected services or information sharing between services;
- (g) carry out research, improvement and development of our services, including new services;
- (h) carry out marketing or business development of our products and services and/or those of our partners and business associates;
- (i) provide our business partners or customers (including pharmaceutical companies and insurance companies) with our services;
- (j) enable user to connect the Ubie Account with other services requested by users;
- (k) facilitate sales, promotion, and purchase of our goods and services and/or those of our partners and business associates;
- (l) provide user support and respond to queries;
- (m) inform users of the changes of the terms or conditions of the services we offer;
- (n) display our or third party’s advertisements, carry out measurement of advertising effectiveness;
- (o) any other purposes for which you have provided the information; and/or
- (p) any other purposes directly related to and/or required to achieve the above.
2.3. We may disclose or transfer your Personal Data:
- (a) where such disclosure or transfer is necessary for performing obligations in the course of or in connection with our provisions of the services requested by you;
- (b) where such disclosure or transfer is required by 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; and
- (c) to any third parties such as below, whether in your country or abroad, for the purposes listed in clause 2.2 above;
- i. any related and associated companies, affiliates, and subsidiaries of Ubie, including those established in the future and those in your country;
- ii. any data intermediaries processing your Personal Data on our behalf;
- iii. where applicable, third parties who provide related services or products in connection with our business such as our vendors, business partners, pharmaceutical companies, insurance companies, and any party assisting us in carrying out the purposes above;
- iv. our business parties (including pharmaceutical companies and insurance companies) which conduct sales, marketing, and business development;
- v. our business partners (including pharmaceutical companies and insurance companies);
- vi. any agent, contractor, or service provider who provides administrative, order processing, payment clearing, credit reference, debt collecting, or other services necessary to the operation of our business;
- vi. organizations including professional service providers and relevant regulatory authorities whether within or outside your country, in connection with the acquisition, disposition, and/or intended acquisition or disposition of Ubie‘s assets and/or Ubie itself whether directly or indirectly;
- vii. any party or organization who are bound by confidentiality agreements with us;
- viii. any person to whom we are, in our belief in good faith, under an obligation to make disclosure as required by any applicable law; including, but not limited to government agencies, statutory authorities, and industry regulators; and
- ix. our auditors, consultants, accountants, lawyers, or other financial or professional advisers.
2.4. The third parties set out above may be situated in your country or elsewhere. You fully understand and unambiguously consent that we may transfer your Personal Data to any location outside of your country for the purposes set out above. We are committed to safeguarding your Personal Data when it is transferred across jurisdictions. We will ensure that your Personal Data receives an adequate level of protection regardless of the jurisdiction to which it is transferred.
2.5. The purposes listed in clauses 2.2 and 2.3 above may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) 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).
2.6. As the accuracy of your Personal Data depends largely on the information you provide to us, you warrant and represent that Personal Data which you disclose to us shall be accurate and complete. If you provide us with Personal Data relating to a third party, you warrant and represent to us that you have obtained the consent of the third party and are authorized by the third party to do so. Please kindly update us as soon as possible if there are any errors or if there have been any changes to your Personal Data by informing our Data Protection / Grievance Officer in writing or via email at the contact details provided below.
2.7. If you have provided us with your consent, we may use your Personal Data for the purposes of marketing our products and services and those of our partners and business associates (e.g. informing you of our latest activities, special offers, and promotions). In order for us to market products and services which are of special interest and relevance to you, we may analyse and rely on your overall interaction with us (such as but not limited to your participation in promotions or events and your interactions with us).
2.8. The decision to provide us with your Personal Data is solely yours to make, but you acknowledge that we require certain types of Personal Data so that we can provide our services to you and if you decline to provide us with such Personal Data, or request us to delete it, we may not be able to provide our services to you.
Google Analytics Terms of Services:
- Google Analytics: https://marketingplatform.google.com/about/analytics/terms/us/
2.11. Please be informed that when you use the Ubie Account, we may acquire information such as your location, device identification details, as well as mobile device information. If you do not wish to provide us with such information, you may activate the function to disable location on your mobile device. However, this may affect the functionality of the Ubie Account.
3. Withdrawing Your Consent
3.1. 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 in clauses 2.2 and 2.3 above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.
3.2. Upon receipt of your 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. In general, we shall seek to process your request within ten (10) business days of receiving it.
3.3. Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our goods or services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in clause 3.1 above.
3.4. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose Personal Data where such collection, use and disclosure without consent is permitted or required under applicable laws.
4. Retention of Personal Data
4.1. We retain your Personal Data for as long as we need the Personal Data to fulfil the purposes we collected it for, and to satisfy our business and/or legal purposes, including audit, accounting, or reporting requirements.
4.2. In some circumstances, we may anonymise your Personal Data so that it can no longer be associated with you, in which case we are entitled to retain and use such data without restriction.
5. Protection of Personal Data
5.1. While precautions will be taken to ensure that the Personal Data you provide is protected against unauthorized or unintended access, we cannot be held responsible for unauthorized or unintended access that is beyond our control.
5.2. To safeguard your Personal Data from unauthorized access, collection, use, disclosure, or similar risks, we, to the extent required by relevant laws, have introduced appropriate administrative, physical, and technical measures such as up-to-date antivirus protection and disclosing Personal Data both internally and to our authorized third-party service providers and agents only on a need-to-know basis. You have reviewed our information security policy and agree that such security practices and measures are reasonable.
5.3. You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.
6. Use of Statistical DataYou acknowledge that Ubie may use the Personal Data obtained from you to create statistical data based on which individuals cannot be identified. Given the nature of such statistical data not being able to identify individuals, Ubie may use such statistical data without restriction including, without limitation, to provide them to any third parties (including pharmaceutical companies and insurance companies).
- (a) check whether we hold or use your Personal Data and request access to such data;
- (b) request that we correct any of your Personal Data that is inaccurate, incomplete, or out-of-date;
- (c) request that we limit the processing of your Personal Data;
- (d) request for information concerning the ways your Personal Data has been or may have been used or disclosed by us within a year before the date of your request;
- (e) request the transfer of certain of your Personal Data to another party under certain conditions;
- (f) request that we specify or explain our policies and procedures in relation to Personal Data and the categories of Personal Data collected, used, and disclosed by us; and/or
- (g) withdraw, in full or in part, your consent given previously, in each case subject to any applicable legal restrictions, contractual conditions, and a reasonable time period.
8. Minor’s Personal DataIf and to the extent required under the applicable laws and regulations of your country, we do not knowingly collect, process, use, disclose, store, transfer, and/or otherwise deal with Personal Data of children under the age prescribed in the relevant laws and regulations of your country (“Minor”) without advance parental or guardian’s consent. In the event that such Personal Data is provided to us by the Minor, you, as the parent or guardian hereby consent to the collection, processing, use, disclosure, storage, transfer and other dealing of the Minor’s Personal Data and personally accept and agree to be bound by this Policy and take responsibility for the Minor’s actions.
9. Data Protection / Grievance Officer
If you have any grievances, inquiries or wish to make any request relating to your Personal Data, you may contact our Data Protection / Grievance Officer at:
- Name: Naoto Shimazu
- Address: 1460 Broadway, New York, NY 10036
- Email: firstname.lastname@example.org
10. Changes of This PolicyWe will give you prior notification of any changes to the Policy. Your continued access to or use of the Ubie Account after the date of the updated Policy constitutes your acceptance of the updated Policy. If you do not agree to the updated Policy, you must stop accessing or using the Ubie Account.
Last Updated: 17 November 2022