SwipeRx Privacy Policy

1 Introduction 

1.1  SwipeRx is an online social network platform for pharmacy professionals, including pharmacists, pharmacy assistants, pharmacy owners and other key stakeholders in the pharmacy space. Its goal is to help promote access to information and encourage collaboration among pharmacy personnel. In doing so, SwipeRx collects and securely stores user information.

1.2 By using the SwipeRx app (“App”), accessing the SwipeRx website (“Site”) or any applications (“Services”) made available by mClinica Pte. Ltd. (“mClinica”), however accessed, you agree to be bound by this Privacy Policy. The App and Site are owned and controlled by mClinica. If you do not agree to be bound by this Privacy Policy, you are not allowed to use this App or Site.

1.3  The term User shall include any person who has registered an account on the App or Site, or has used the App or Site.

2 What information we collect 

2.1 Registration SwipeRx is a social and professional network, exclusive for pharmacy professionals. We collect the necessary information to verify that users are pharmacy professionals, including name, location, e-mail, phone number, education, pharmacist license number, work experience, professional affiliations, age, birthday and gender. Users are also encouraged to add a profile picture of themselves to improve the overall experience of the network. If you apply to use additional exclusive features in SwipeRx, we may also collect additional information for verification purposes, including but not limited to names of responsible personnel, license details, company incorporation documents, contact details and other as deemed appropriate by mClinica.

2.2 Profile Information Apart from the information provided during registration, Users can add more information about themselves, their experience, skills and interests. This information will improve the way their professional identity will be represented on the platform and improve the overall quality of the network.

2.3 Phonebook and other services that sync with SwipeRx You may use the SwipeRx tool for importing contacts via your mobile phone’s phonebook, e-mail account or other platforms (“Contacts”), where you have stored your information. We will store your information and help you find your Contacts, which are already on the SwipeRx platform, as well as invite those who are not. This will improve your SwipeRx experience. When you send an invitation to somebody in your Contacts to join SwipeRx and to connect with you, that person may have access to your email address or mobile number (for SMS invitations) since it may be displayed in the invitation. We may also remind the invitees of your invitation on your behalf if they do not accept your invitation immediately.

Any contact information that you sync with the SwipeRx platform is governed by the User Agreement and this Privacy Policy. You can remove your information at any time via contacting our Data Protection Officer at the contact details provided below.

2.4 Customer service When you contact our customer support service, we may need to access your account, activity and messages and collect the information to better address your question, respond to it and provide a solution.

2.5 Using the Services When you use the Services, either via the App or Site, we collect information about your usage activity for example when you click on ads, fill up surveys, post or engage with content, search for content, apply for jobs and other activities.

2.6 Cookies We use cookies and similar technologies to help us recognize you across multiple devices and provide higher security, as well as improve your SwipeRx user experience.

3 How we use your personal information 

3.1 Consent to SwipeRx processing information about you When you create your account and use the Services, you share personal information

with us. By providing personal information to us, you are expressly and voluntarily accepting the terms of our User Agreement as well as accepting and agreeing to our processing and transfer of your personal information as per this Privacy Policy. You can withdraw your consent at any point it time by deleting your account information or by contacting our Data Protection Officer at the contact details provided below.

3.2 User communications When you initiate communication with other users on SwipeRx or when you invite people outside the platform, your name, profile picture, e-mail and/or phone number may be shared with the other party with whom you initiate communication.

3.3 Service development and customized experience Depending on your personal information, we will make features available to you that

make your experience better. Examples include jobs, events and other content that are tailored for your work experience, location and education.

3.4 Marketing messages We may send you marketing information about our goods or services including notifying you of our marketing events, initiatives and promotions, lucky draws, membership and rewards schemes and other promotions.   

4 Sharing information with third parties

4.1  Other members of the SwipeRx network can view only your name, location, work experience, professional affiliations and education. Your e-mail, phone number, pharmacist license number, age, birthday and gender are only available to our team for contacting and verification purposes and to employers when you apply for jobs via the platform. We do not disclose your personal data to anyone, apart from the purpose of contacting you in relation to the SwipeRx App, Site, and Services you engage with, including but not limited to applying for jobs in the App or Site or verifying your CPD exam attempts. We do not sell your personal information to any third party without your consent.

4.2  We may disclose your personal information (a) to third party data processors which we have engaged to perform any of the functions set out at clause 3 above, and which may be based within or outside of the jurisdiction the User resides; (b) to third party service providers which we have partnered with to facilitate your registration for CPD events and provide you with the other functions of the App; (c) as part of or in preparation for a sale of mClinica, or as a sale of its asset, subsidiary, or division; (d) as the result of or in preparation for a change in control of mClinica or one of its affiliates. 

4.3  Any third party to which we transfer or sell our assets to will have the right to continue to use the personal and other information that you provide to us in the manner set out in this Privacy Policy.

5 Access and Correction

5.1  If the User wishes to make (a) an access request for access to a copy of the personal information which we hold about the User or information about the ways in which we use or disclose the User’s personal information, or (b) a correction request to correct or update any of the User’s personal information which we hold, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.

5.2  Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request. 

5.3  We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal information or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under applicable data protection laws).

6 Accuracy and Retention

6.1  In order to ensure that the User’s personal information is current, complete and accurate, please update mClinica if there are changes to the User’s personal information by informing our Data Protection Officer in writing or via email at the contact details provided below.

6.2  We may retain the User’s personal information for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws. 

6.3  We will cease to retain the User’s personal information, or remove the means by which the data can be associated with a particular User, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal information was collected, and is no longer necessary for legal or business purposes.

7 Transfer

7.1  The personal information which we collect from the User may be transferred out of the jurisdiction in which the User is based to be hosted on our third party data processor’s servers located in Singapore. In the event of any transfer of personal information out of jurisdiction, we will take steps to ensure that your personal information continues to receive a standard of protection that is at least comparable to that provided under the Singapore Personal Data Protection Act.

8 Changes and security

8.1 Changes to this Privacy Policy We may change this Privacy Policy from time to time. In the event of any changes to the way we treat your personal information. or to the Privacy Policy, we will provide notice to you by email within 7 days prior to the change.

8.2 Security We have created and applied security practices to safeguard and protect your personal information from unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks, at par with industry standards, including implementing physical controls, authentication restrictions and Open SSL encryption on APIs, amongst others. Access to your data is password-protected. We regularly monitor and keep our security standards up to date. However, we do not warrant the security of any information you transmit to us and we strongly advise against sharing any confidential information through our platform, messages and group discussion features. We will only disclose personal information both internally and to our authorised third party data processors and agents only on a need-to-know basis.

9 Data Breaches and Notification

9.1  In the event of a data breach, we will notify you as soon as practicable, after an assessment that such personal data being compromised results in significant harm to you, except in circumstances such as 1) remedial action has been taken that the data breach is unlikely to cause significant harm, 2) appropriate technological measures are applied to the personal data before the breach which renders the personal data inaccessible, 3) prohibition by a law enforcement agency due to ongoing investigations or waivers obtained. In the notification, we will provide relevant details of the data breach, including our data breach management and remediation plans.

10 Data Protection Officer

10.1  The User may contact mClinica’s Data Protection Officer if you have any enquiries or feedback on our personal information protection policies and procedures, or if you wish to make any request, in the following manner:

Data Protection Officer

Address: 5 Shenton Way, UIC Building #10-01 Singapore 068808

Email: [email protected] with Privacy Policy in the subject line of your email

Tel: +65 91906624

Last updated: October 13, 2021