Privacy Policy
We, Allegory Counselling (referred to as “us” or “our” or “we”), recognise the importance of the collection, storage, use and disclosure of Personal Data (defined in Paragraph 1) of persons interacting with us (such persons hereon referred to as “you” or “yours”, which include any minor on whose behalf you are acting for the purpose of this Privacy Notice (“this Notice”).
1. Personal Data
Personal Data is defined in the Personal Data Protection Act 2012 to mean any data, whether true or not, about an individual who can be identified from that data or from that data and other information to which we have or are likely to have access. This generally includes your name, identification information, contact information such as your address, email address, telephone number, mobile, nationality, gender, date of birth, marital status, employment information, financial information such as credit card numbers, debit card numbers or bank account information, current medication or treatments used by you, previous/current medical history, including, where relevant, a family medical history, and the name of any health service provider or medical specialist from whom you may have been referred or to whom you may be referred.
2. Collection of Personal Data Consent
When you provide your Personal Data to us, you have consented by your action to the collection, storage, use and disclosure of your Personal Data by us in accordance with this Notice. If you provide Personal Data relating to a third party (e.g. information of your child, dependent, spouse, parent, ward or employees) to us, by submitting such information to us, you represent that the consent of that third party has been obtained for the collection, storage, use and disclosure of the Personal Data by us in accordance with this Notice and you hereby indemnify us against any liability arising from such representation being false. Where collection of children’s Personal Data is made through persons claiming to be parents or guardians, we may (but are not obliged to) require proof to verify such claims.
3. Personal Data Collection
Personal Data may be collected by us via any form of interaction with you, including:
when you submit any form, including but not limited to customer inquiry forms or other forms relating to any of our services;
when you enter into any agreement or provide other documentation or information in respect of your interactions with us, or when you use our services;
when you interact with our staff, including our therapists and administrative team, for example, via telephone calls (which may be recorded), letters, fax, face-to-face meetings, social media platforms (including Facebook, WhatsApp) and emails;
when you interact with us via our website or use services on our website;
when you request that we contact you or request that you be included in an email or other mailing lists;
when you respond to our request for additional Personal Data;
4. Refusal to provide personal data or withdrawal of consent
All Personal Data is provided voluntarily. You may refuse to do so or withdraw your consent in respect of our collection, storage, use or disclosure of your Personal Data at any time by submitting your request to info@allegorycounselling.com. However, if you limit, or do not provide, the requested Personal Data, it may result in us being unable to:
process the relevant enquiry, request or application;
provide the products or services to you in a continuous manner;
provide the products or services to the extent stated in our promotional materials; or
provide new products or services that may be offered by us from time to time.
Kindly note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.
5. Use of Personal Data
We may collect, store, process, disclose, access, review and/or use personal data (including sensitive personal data) about you, whether obtained from you or from other sources, for the purposes set out below and/or any other administrative or operational purposes and/or the purpose of managing your relationship as a client with us:
verification and identification purposes;
providing medical services to you and meeting your healthcare needs;
to avail the services which we provide, including, where necessary, the transferring to or sharing of your personal data with third party medical service providers such as psychiatrists, specialists, or other allied health professionals such as occupational therapists, speech therapists, etc.;
where there is a serious and imminent threat to an individual’s life, health, or safety;
where there is a serious threat to public health or public safety;
conducting feedback surveys;
resolving complaints and dealing with enquiries made by you;
maintenance and updating of the data;
administrative or operational purposes;
processing credit notes and processing refunds;
collection of fees, charges and expenses for services provided;
collecting payments by cheque, bank transfers or other means,
carrying out billing, accounting, auditing and the maintenance of proper book keeping for our operations and business;
complying with 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;
any other purposes for which you have provided the information;
transmitting to any unaffiliated third parties including our third party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes; and
any other incidental business purposes related to or in connection with the above; or
where you have subscribed for our marketing communications (by providing us with your telephone number or email address and have indicated to us that you consent to receiving marketing communications via these channels). You may choose whether you wish to continue receiving such marketing communications from us.
You may withdraw your consent by following the steps stipulated in Clause 7 of this Notice.
The purposes listed in the above clauses 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).
Kindly note that where we disclose your Personal Data to third parties in connection with one or more of the above-stated purposes, we will use best efforts to require such third parties to protect your Personal Data.
6. Protection of Personal Data
We maintain personal data in either physical or electronic files. We protect your personal data with appropriate administrative, physical and security measures to prevent misuse, loss and unauthorised access, modification and disclosure. Access to personal data is limited to internal employees, our authorised third-party service providers and agents only on a need-to-know basis, and to those otherwise authorised by law. We provide personal data to health care providers acting on your behalf, on the understanding that they are also bound by law and ethics to safeguard your privacy. 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.
7. Request for Access, Corrections and Withdrawal of Consent
If you, at any time, have any enquiries, requests and feedback relating to your Personal Data or this Notice, please submitting your request to us. This includes any request:
for a copy of your Personal Data in our possession or control (in which case we may charge an administrative fee);
to withdraw your consent for the collection, storage, use and disclosure of your Personal Data by us; or
to correct your Personal Data in our possession or control.
In respect of your right to access or correct your Personal Data, we have the right to take steps to verify your identity before fulfilling your request. We may however choose not to provide you with access to or correct such information, in accordance with the exceptions under the PDPA. This would include cases where:
We are satisfied on reasonable grounds that the correction should not be made;
The request for access is frivolous or the information requested is trivial;
The personal data is related to a prosecution and all the proceedings related to the prosecution have not been completed;
The personal data, if disclosed, would reveal confidential commercial information that could, in the opinion of a reasonable person, harm our competitive position.
Please also note that we are not required to correct information relating to clinical observations or opinions made in good faith. Do also note that upon your withdrawal of consent, we may not be in a position to continue to provide our products or services to you.
8. Accuracy of Personal Data
We generally rely on personal data provided by you (or your authorised representative). While all reasonable efforts are made to keep your personal data accurate, you are kindly requested to disclose all relevant information, inform us of any change and to ensure that all your personal data that is submitted to us is current, complete, accurate, true and correct. Please note that we will not be responsible for relying on inaccurate or incomplete Personal Data provided by you or arising from your failure to update your Personal Data.
9. Retention of Personal Data
We retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required by applicable laws. We will cease to retain your personal data or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected and is no longer necessary for legal or business purposes.
10. Effect of Notice or Changes to Notice
This Notice applies in conjunction with any other policies, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us. We may update this Notice from time to time to ensure that our standards and practices remain relevant and comply with the applicable laws and guidelines. The latest version of this Notice supersedes earlier versions and will apply to personal data provided to us previously. We encourage you to review this page periodically to keep up to date with any changes to this Notice. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.