Effective date: August 2018
This Notice informs you of how any personal information that you share with us through your use of our website may be used and disclosed by Romlas Health Group Holdings, Inc. (hereafter “us”, “we”, or “our”). This Notice also describes the manner by which the we may collect, hold, use, share, and discard the above-mentioned information. By your use of our website, you signify your understanding and acceptance of the terms of this Notice and any collection and use of information made in accordance therewith. It is hereby understood that your continued use of our website following the posting of changes to this policy will be deemed your acceptance of those changes.
Finally, this Notice outlines how you may access your personal information and exercise your rights under the Philippine Data Privacy Act or Republic Act No. 10173 and its implementing rules and regulations (“IRR”).
I. Scope of Service
This Website is being operated by Romlas Health Group Holdings, Inc. with business address at 8G Santolan Town Plaza, 276 Col. Bonny Serrano Avenue, San Juan, Metro Manila, Philippines. We also operate the following social media accounts (collectively the “Service”):
We understand that the personal information you share with us is confidential and we are committed in holding such information in confidence. Any information you choose to share with us shall be handled with due care and in compliance with legal requirements and shall only be shared for the following purposes:
- To facilitate your treatments with us;
- To notify you about changes to our treatments and other services;
- To allow you to participate in interactive features of our treatments and other services when you choose to do so;
- To provide you customer care and support;
- To conduct our operations and render professional services to you, as may be appropriate;
- To collect payment for services we provide you;
- To improve the services we provide to you and our other clients; and
- To comply with laws and governmental regulation.
We will need to use and disclose your information to facilitate your availment of our services and treatments. This includes the sharing of information with our affiliates and partners so that they may assist us in rendering effective services and treatments to you. Our trusted affiliates, partners and third parties include, but are not limited to the following:
- Regen Med, Inc.
- Global Medical Technologies Manila, Inc.
- Skin+Nutrition, Inc.
- Facebook Inc.
- Twitter Inc.
- Instagram, LLC
- Google LLC
We may need to engage third parties that perform business services for us, such as consultants, contractors, accounting or law firms (collectively “Business Associates”). In certain instances, we may need to share the information that you have provided us with these Business Associates so it can perform a service on our behalf. To ensure your protection, we will either anonymize or encrypt your information or ensure we have a data sharing agreement or written contract in place with the Business Associate requiring protection of the privacy and security of your confidential information.
We use electronic communications platforms to facilitate the quick, prompt and efficient coordination of care and delivery of services to you. Thus, members of our team may use various messaging platforms for purposes of communications. us. Unless you notify us to the contrary, we may use the contact information you provide to communicate general information about your care such as appointment location, department, date and time, as well as for patient experience and satisfaction surveys.
We may also use information that you share for the advancement of functional medicine and other related fields. The information you share may also be used to ensure quality assurance and compliance with standards of care. We may also use information that you provide to improve on the services being offered, to determine what services are no longer needed and to assess whether certain treatments are effective. We will ensure that, as much as possible, any use of information will be secure or anonymous.
II. Information Collection And Use
We collect several different types of information for various purposes as explained above. Please find below some of the information we may collect and use.
While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Information”). Personally identifiable information may include, but is not limited to:
- Email address
- First name and last name
- Telephone or Mobile number
- Billing or Postal Address, State, Province, ZIP/Postal code, City
- Cookies and Usage Data
Sensitive Personal Information
In addition to the above, we may also collect sensitive personal information through your use of the Service such as but is not limited to the following:
- Ethnic Race and Origin
- Marital Status
- Date of Birth
- Information pertaining to your Medical History such as but not limited to:
- Previous and/or current medical conditions or ailments
- Family histories
- Occupational history
- Medications being or previously taken
Please be assured that our collection and use of Sensitive Personal Information will be on as-needed basis and in all cases with your prior consent. Rest assured that we shall safekeep all Personal and Sensitive Personal Information that you choose to share with us. We implement adequate levels of protection to ensure that the integrity of your personal information is secure as required by the Philippine Data Privacy Act and its IRR.
In exceptional circumstances, we may need to collect and use your Personal or Sensitive Personal Information if the same is necessitated in order to protect your life and health or the life and health of any other person, and that you are not legally or physically able to express your consent prior to the act of collection or use, or the the protection of your or our lawful rights and interests.
We may also collect information how you access and use our Service (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Website that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
Tracking & Cookies Data
Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Website.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.
Examples of Cookies we use are the following:
- Session Cookies. We use Session Cookies to operate our Service.
- Preference Cookies. We use Preference Cookies to remember your preferences and various settings throughout your use of our Service.
- Security Cookies. We use Security Cookies for security purposes.
III. Transfer of Information
Your information, including Personal or Sensitive Personal Information, may be transferred to — and stored in — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
If you are located outside Philippines and choose to provide information to us, please note that we transfer the data, including Personal or Sensitive Personal Information, to the Philippines and for storage and possible use there.
Your consent to this Notice followed by your submission of such information represents your agreement to that transfer.
Rest assured that we have taken steps reasonably necessary under Philippine law to ensure that information shared with us will be treated securely and in accordance with this Notice. Any information you share shall be encrypted and stored on secured servers. Said information may only be accessed by our employees or authorized representatives when it is reasonable and necessary for our performance of treatments and other services you are availing from us or as necessary for our effective delivery of treatments and services as set forth in this Notice. We will not transfer of your Personal or Sensitive Personal Information to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.
IV. Disclosure Of Data
We are firm in our policy in keeping the information collected and stored to be strictly confidential. However, we may disclose your Personal Data in the good faith belief that such action is necessary to:
- To comply with a legal obligation;
- To protect and defend our rights or property, as necessary;
- To prevent or investigate possible wrongdoing in connection with the services rendered or treatments;
- To protect your personal safety as well as that of our other Clients and the public;
- To collect payments due and owing to us for services rendered; or
- To protect against legal liability;
In addition to the above declarations, we shall not rent, sell, nor discloses your personal information with other parties.
V. Security Of Data
The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
VI. Retention of Data
When no longer needed for the purpose which it is intended, the information collected and stored shall be deleted and destroyed permanently. We may however retain and use your personal information in accordance with this Notice for as long as you wish to maintain your records with us. If we are required to retain any portion of your personal information, we are obliged to use reasonable efforts to limit the use of such personal information according to the purpose to which it is originally intended and to other lawful purposes. On the other hand, we shall also take reasonable steps to delete your information as quickly as possible upon your written request. Due to technical constraints, please take note that there may be residual data that may still be stored in our servers despite our efforts to process the deletion of your personal information.
VII. Service Providers
We may employ third party companies and individuals to facilitate our services and treatments (“Service Providers”) to provide the services and treatments on our behalf, to perform other related services or to assist us in analyzing how our services and treatments are being delivered.
These third parties have access to your Personal and Sensitive Personal Information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
We may use third-party Service Providers to monitor and analyze our rendition of services and treatments.
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en&gl=ZZ
VIII. Links To Other Sites
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
IX. Children’s Privacy
Our Service does not address anyone under the age of 18 (“Children”).
We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Children has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.
XI. Contact Us
- By email: firstname.lastname@example.org
- By address: 8G Santolan Town Plaza, 276 Col. Bonny Serrano Avenue, San Juan, Metro Manila, Philippines