Your privacy is important to us.
Data Protection Policy (“Policy”)
1.1. At Dementia Singapore Ltd (“Dementia Singapore”, “us”, “we”, “our”), we understand the importance of your Personal Data. We are committed to protecting the confidentiality and privacy of your Personal Data.
1.2. This Policy helps you understand how we deal with (such as collecting, using, disclosing and/or processing) your Personal Data on the CARA mobile application and our website
(at www.cara.sg) (the CARA mobile application and our website shall becollectively referred to as “the platform”). Please feel free to contact our Data Protection Officer at [email protected] if you have any queries.
1.4. Definitions and key terms
To help explain things as clearly as possible in this Policy, the words below shall bear the following meanings:
Device: any internet connected device such as a phone, tablet, computer, or any other device that can be used to visit the platform and use the services.
Personal Data: refers to data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which an organisation has or is likely to have access as defined under the Personal Data Protection Act (No. 26 of 2012) (“PDPA”). This includes personal data provided by you and collected by Dementia Singapore. Examples include but are not limited to names, identification numbers, email addresses, home addresses, telephone numbers, medical records, lifestyle preferences, personal interests, work-related information, photographs and video images. For the avoidance of doubt, the phrase “your Personal Data”, as used in this Policy, refers to all personal data provided by you, and include your own personal data, as well as personal data of a person living with dementia or a caregiver of a person living with dementia (whether your relationship to the person is next-of-kin, family member, caregiver, representative or legal guardian).
Third-party service providers refers to advertisers, contest sponsors, promotional and marketing partners, and others who provide content on the platform or whose products or services we think may interest you.
You: a person who is registered or intends to register with Dementia Singapore and the platform.
2. Consent and Changes to this Policy
2.1. By using the platform, you hereby agree to this Policy, and expressly consent to us dealing with your Personal Data (such as collecting, using, disclosing and/or processing) in accordance with and as set out in this Policy. If you do not agree with this Policy please do not use the CARA mobile application.
2.2. We reserve the right to modify or change this Policy at any time. Any updated version of this Policy shall take effect immediately and shall supersede all earlier versions but shall continue to apply to all data provided to us by your use of the platform previously. Subject to your rights under the PDPA, you hereby agree to and consent to the prevailing terms of any updated version of this Policy.
2.3. We encourage you to periodically reread this Policy to see if there have been any changes that may affect you. Any changes to this Policy shall be made available on the CARA mobile application and shall be published on this page.
3. Collecting, Using, Disclosing and Processing Personal Data
3.1. We may collect, use, disclose and process your Personal Data for various purposes as listed below:
(a) To administer any form that you submit via the platform including but not limited to registration, application forms and contest entry forms. We shall do so in a manner to help you complete the usage of our services and to render our services more efficiently. This includes contacting you, collecting your financial information to process payment for
our services or to process application of grants/subsidies, and promoting and announcing contest winners.
(b) To provide our services to you when you request and/or use our services and/or enter into an agreement with us. This includes our screening process (to check if you are eligible for CARA membership) and contacting you (for example, when you request to be contacted either in response to your queries or to be placed on a mailing list, when we need to contact you and for keeping notes to fulfill our services to you). For the CARA safe return function, if you are a caregiver of a person living with dementia registered on the CARA mobile application, we may also (through the CARA mobile application) disclose your Personal Data to members of public who are trying to assist the person living with dementia you are caring for. In addition, your Personal Data may be disclosed to third party printing service providers for the printing of the physical CARA card. We also use cloud services to process and store Personal Data; we only use cloud service providers who comply with the PDPA.
(c) To improve our services to you. This includes collecting and storing history of our interactions with you (for example, the types of services and promotions offered to and/or used by you), generating statistics and research results (such as tracking user behaviour and preferences on the CARA mobile application), and your location history which shall
enable us to enhance your customer experience. You may also be prompted to complete market research surveys. While we may collect and use Personal Data
from these surveys, survey results are aggregated and shared with advertisers, sponsors and related corporations in a manner that does not disclose Personal
(d) To comply with any law, regulation or governmental requirement as may be applicable to us from time to time. These include any record-keeping and statutory reporting requirements.
3.2. Any purpose not listed in this Policy shall be notified to you at the time of collection and your consent shall be sought no later than at the time of collection.
3.3. In the event that you provide Personal Data of a person living with dementia or a caregiver of a person living with dementia (whether your relationship to the person is next-of-kin, family member, caregiver, representative or legal guardian), you undertake and warrant that you have such person’s consent to disclose their Personal Data to us and that the Personal Data provided is true and accurate. Dementia Singapore shall not be in any way liable for any loss arising from your failure to obtain such consent.
3.4. We may also disclose your Personal Data to our subsidiaries, affiliates, officers, employees, agents, partners, legal advisors, and other third parties including but not limited to third-party service providers who would process your Personal Data for the above purposes, and they shall be required to treat your Personal Data in accordance with this Policy and the PDPA. The aforesaid parties help us to make our business more efficient and effective. Where we disclose Personal Data to third parties, we shall take reasonable steps to protect the security of your Personal Data. In the event that any of the aforesaid parties are located outside Singapore, we shall comply with the requirements under the PDPA in doing so and we shall ensure the same standard of Personal Data protection in the relevant jurisdiction as required under the PDPA.
3.5. We may also disclose your Personal Data to our legal advisors, law enforcement officials such as the Singapore Police Force, and/or government authorities/agencies and/or their linked applications who would process your Personal Data for the purpose of the CARA safe return function or where it is necessary to respond to an emergency that threatens the life, health or safety of a person or where it is necessary in the public interest (e.g. in a public health crisis, for contract tracing purposes and safeguarding our community). For this purpose, we may disclose your Personal Data to OneService, a Singapore government-owned and operated application.
3.6. We may disclose your Personal Data without your consent strictly only as provided under and in accordance with the PDPA.
4. Contacting Us
4.1. All queries, requests, and feedback on this Policy and/or regarding Personal Data can be directed to our Personal Data Protection Officer at: [email protected] or 20 Bendemeer Rd, #01-02 BS Bendemeer Centre, Singapore 339914. This includes any request from you to withdraw your consent to the use of any of your Personal Data, correcting your Personal Data or accessing your Personal Data.
4.2. In the event that you seek to withdraw your consent, correct or access your Personal Data, please note that we shall carry out a verification process to ascertain your identity. We may also require more information for clarification before we can process your request. Upon you contacting us, we shall use our best efforts to get back to you within a reasonable period. In the event that we are unable to perform your request substantively, we shall inform you of the rejection within a reasonable period.
4.3. In the event that you withdraw your consent for the collection, use, disclosure and processing of your Personal Data, you may no longer be able to access and use the CARA mobile application.
5. Managing your Personal Data
5.1. We take reasonable steps to ensure the accuracy and completeness of your Personal Data. Should you provide us inaccurate and/or incomplete Personal Data or fail to update us of any change in your Personal Data, we are not responsible for relying on any of the aforesaid Personal Data.
5.2. We also retain records of your Personal Data only for a reasonable period of time for the above-stated purposes and in accordance with the PDPA. In the event that your Personal Data is no longer required, we shall anonymise and/or destroy the Personal Data in our control as soon as reasonably possible
5.3. We also use reasonable efforts to ensure the security of your Personal Data and have reasonable security processes/arrangements to protect your Personal Data. We regularly review our security practices to consider appropriate new technology and methods. However, please be aware that despite our best efforts, no security measures are perfect or impenetrable.
6.1. When you visit the platform, we may use “cookies” and other technologies such as pixel tags and web beacons (“Tracking Technologies”). These technologies are used to track information such as the number of users, their frequency of use, and which parts of the platform they have visited. Tracking Technologies may also identify your browser and store information on your Device about you such as your language preference or CARA mobile application login information.
6.2. By accessing and using the platform, you agree to our use of Tracking Technologies.
6.3. We currently use Tracking Technologies on the platform for various purposes, including but not limited to improving your user experience on the platform, remembering your preferences, targeting advertising that might be of interest to you, helping us understand how the platform is performing, measuring the overall effectiveness of our online content, advertising campaigns, and the products and services we offer through the platform, monitoring traffic to the platform, detecting your web browser’s multimedia capabilities, tracking promotional advertisements that have been displayed to you and maintaining current login and purchase information on secured portions of the platform (the “Tracking Technologies Purposes”).
6.4. Information that we collect from you through the Tracking Technologies may be passed to our third-party service providers, whether located in Singapore or elsewhere, for one or more of the Tracking Technologies Purposes, for managing and/or administering the platform, or for the purpose of data hosting/storage/backup.
6.5. Third-parties may also use Tracking Technologies when you use the platform. Third parties, such as our social media (including Facebook), advertising, analytics and business partners, may use Tracking Technologies to collect information about your online activities while you are on the platform. This information may be used to measure the usage of the platform and personalise advertising content on the platform. We do not have access to or control over Tracking Technologies or other features these third parties may use, and the information practices of these third-parties are not covered by this Policy. Please refer to the policies of those third-parties to better understand their activities and practices.
6.6. Most browsers automatically accept cookies, but you can modify your browser settings to decline cookies. Generally, you can remove these cookies by following directions provided in your Internet browser’s “help” file. If you choose not to allow us to place a cookie on your Device, you may be restricted from some services and some of the interactive features offered on the platform may be similarly restricted or rendered inoperable.
7. Governing Law
7.1. This Policy and your use of the platform shall be governed in all respects by the laws of the Republic of Singapore.