Privacy Policy

This privacy policy for CURBSIDE PTE. LTD., its predecessors or successors in interest, and any of te affiliates or related corporations ("Company," "we," "us," or "our"), describes how and why we might collect, store, use, protect and/or share ("process") your information when you use our services ("Services"), such as when you: (1) access and/or use any website, electronic application, application programming interface, product and/or feature owned and/or maintained by us, including our mobile application known as "Curbside Academy" and our website at https://www.curbside.academy ("Sites"); and (2) engage with us in other related ways, including any sales, marketing, or events.

If you do not agree with our policies and practices, please do not access and/or use our Services or Sites. If you have any questions or concerns, please contact us at admin@curbside.academy.

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

We collect personal information that you voluntarily provide to us when you register for an account or profile on the Services and/or Sites, express an interest in obtaining information about us or our Services and/or Sites, when you participate in activities or submit on the Services and/or Sites, or otherwise when you contact us through e.g. user support and surveys and personal information from third party sources.

Personal Information Provided by You

The personal information that we collect depends on the context of your interactions with us and the Services and/or Sites accessed and/or used, and the choices you make. The personal information we collect may include the following: (1) full names; (2) email addresses; (3) usernames; (4) passwords; (5) occupations; (6) contact details; (7) MCR number; (8) identification number; and/or (9) educational qualifications such as school attended, year of graduation, specialisation, sub-specialisation, clinical and professional interests, languages spoken, profile photo, medical group and hospital affiliations, and internship, residency, fellowship, employment, speaking engagement, publication, usership and board certification history. We also collect other information such as comments, searches, information about you provided by other users, contacts, schedule details, resume, survey responses, and details about your communications when you interact with us and/or through the Services and/or Sites.

Application Data

If you use our Service(s) and/or Site(s), we also may collect the following information if you choose to provide us with access or permission: Push Notifications We may request to send you push notifications regarding your account or certain features of the application(s). If you wish to opt out from receiving these types of communications, you may turn them off in your device's settings. All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information. You may also be required to verify the information from time to time. You may also be asked to update or supplement the information you have provided from time to time. We do not guarantee that users on our Services and/or Sites are healthcare providers they claim to be and make no guarantee as to their respective identities, credentials, and licensure status.

Information automatically collected

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, browsing history, ISP and mobile career, advertising ID, country, location, information about how and when you access and/or use our Sites and/or Services such as data and time and whether you access and/or interacted with the Sites and/or Services, including articles, advertisements, and communicated via the Sites and/or Services and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes. Like many businesses, we also collect information through cookies and similar technologies. The information we collect through cookies and similar technologies includes: Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called "crash dumps"), and hardware settings).

Information from Third Parties

We also collect information from third parties, including government and regulatory agencies, public data sources, professional associations, publications, employers, our business partners, service providers, customers, and other users, some of which we may add to your professional profile (and to be verified by you from time to time). We may also obtain information for promotional and advertising purposes.

2. HOW DO WE PROCESS YOUR INFORMATION?

We process your information to provide, improve, and administer our Sites and/or Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

(1) to customise, personalise and improve our Sites and/or Services to make your experience more secure and convenient (including improving the quality of our Sites and/or Services through the performance of quality reviews and similar activities, and creating de-identified or anonymised information which is not used or intended to be used to personally identify an individual for the purposes of data analytics and research). These may include processing your information to tailor your newsfeed to content relevant to you and your profile, e.g. targeting advertising and other content provided by third parties such as pharmaceutical companies advertising certain products and services;

(2) to provide and support our Services to meet your needs (including by facilitating account creation and authentication and otherwise managing user accounts and developing new products, services, and features). We may process your information so you can create and log in to your account, as well as keep your account in working order;

(3) to respond to user inquiries / offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested Sites and/or Services;

(4) to send administrative information to, or otherwise communicate with, you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information. The information may also include your personal information to be verified, external engagements such as professional opportunities and events, and other content such as educational information, and marketing materials;

(5) to enable user-to-user communications. We may process your information if you choose to use any of our offerings that allow for communication with another user and store and transmit your communications through the Sites and/or Services; and

(6) to save or protect vital interest. We may process your information when necessary to save or protect an individual’s such as a user, and our vital interest, such as to prevent harm. Such harm may include detection, investigation and prevention of fraud, or other activities which we deem in our absolute discretion to be harmful, illegal or authorised.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?

We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

Consent

We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time.

Performance of a Contract

We may process your personal information when we believe it is necessary to fulfil our contractual obligations to you, including providing our Sites and/or Services or at your request prior to entering into a contract with you.

Legal Obligations

We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.

Vital Interests

We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party as elaborated above.

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

We may need to share your personal information in the following situations:

(1) business transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or disposal or acquisition of all or a portion of our business or equity in Curbside or our corporate affiliates to another third party;

(2) integration of your personal information on other applications and/or platforms owned and/or managed by us. However, prior to such integration, your consent shall be sought by us;

(3) business partners and service providers. We may share your information with our trusted business partners and service providers to provide the Sites and/or Services so that we are able to increase professional opportunities for our users and also maintain the Sites and/or Services;

(4) research and educational institutions. We may share your information with research and educational institutions which share similar missions to Curbside, e.g. to support the medical profession. We will require such institutions to agree to only process the data as needed for the purpose as approved by us and that any research findings must be de-identified and anonymised. Such activities may result in publishing which must be approved by us in our sole discretion;

(5) clients. We provide our clients with search and communication features as part of our talent and marketing services businesses. They use these tools to select users that may be interested in their information. We also provide our clients with user information for their advertising and other sponsored content programs delivered via the Sites and/or Services. If you express interest in their content, we may share with them limited information from your profile, along with details about your interaction.

Prior to sharing the above-mentioned information, we require our clients to agree to restrict their use of information to purposes authorised by us in our sole discretion. We do not share your personal contact information with our clients without your consent.

(6) affiliated companies. We may share personal information with our corporate affiliates for use consistent with this policy;

(7) regulatory authorities and agencies. We may share your information with third parties, as required or permitted by applicable law, if we believe it is reasonably necessary to comply with applicable laws and regulations, law enforcement instructions and orders, or other legal process served on us. If you provide us information about an adverse event relating to a pharmaceutical product or medical device, we may be required to report this information along with your contact information to the manufacturer so it can comply with legally required reporting obligations;

(8) other users. When you share personal information (for example, by posting comments, contributions, or other content to the Services) or otherwise interact with public areas of the Sites and/or Services, such personal information may be viewed by all users and may be publicly made available outside the Sites and/or Services in perpetuity. Similarly, other users will be able to view descriptions of your activity, communicate with you within our Services, and view your profile.

We may also share information if we deem in our sole and absolute discretion that it is reasonably necessary or appropriate to investigate, prevent or take action regarding suspected fraudulent, harmful, or illegal activities, or any violation of our Terms of Service or to protect and defend the legal rights, safety, and property of Curbside, our employees, agents and contractors (including to enforce our agreements) or in connection with any safety or security concerns, including the personal safety of our users and the public.

We may also share your personal information with third parties that run loyalty programs, advertising campaigns, contests, or other events or activities on behalf of Curbside or in connection with our Sites and/or Services.

We may also share de-identified and anonymised information for compliance of various reporting obligations and/or to get an understanding of our users’ interests, habits, and usage patterns for certain programs, content, services, advertisements, promotions, and/or functionality available through the Services and/or Sites; and

(9) consent. We may share your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time.

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information, promote trust and security, help analyse our web page flow and measure promotional effectiveness.

Cookies are small files placed on your hard drive that assist us in providing the Sites and/or our Services. We may offer features that are only available through the use of a cookie. We also use cookies to reduce the number of times you need to enter your password. Cookies can also help us provide you with information that is targeted to your interests. You are always free to decline our cookies (if your browser permits you to do so), although in that case you may not be able to use certain features on the Sites and you may be required to enter your password more frequently during a session on the Sites.

6. HOW LONG DO WE KEEP YOUR INFORMATION?

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this policy will require us keeping your personal information for longer than the period of time in which users have an account with us.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

7. HOW DO WE KEEP YOUR INFORMATION SAFE?

Your privacy is important to us. We have put in place reasonable security arrangements (which shall at least be equivalent to industry standard practices) to protect your privacy and personal data, in such manner and to such extent as we deem reasonably appropriate in our sole discretion to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks. However, there is no such thing as “perfect security” and we do not guarantee in any way, and you should not expect, that your personal data or private communications will always remain private and/or safe from any abuse or misuse by third parties.

Your personal data to be used by Curbside is stored on Curbside’s servers located within its premises or those of its data service providers. We will use such procedural and technical safeguards as we deem reasonably necessary in our sole discretion to protect your privacy and protect your personal data against loss, theft and unauthorised access, collection, use, disclosure, copying, modification or disposal. We will also employ such security techniques deemed appropriate at our sole discretion, to reasonably protect data against loss, theft, and unauthorised access, collection, use, disclosure, copying, modification or disposal by users inside and outside Curbside. If we transfer any data outside Singapore, we will take appropriate steps to ascertain whether, and ensure that, the recipient of your transferred personal data is bound by legally enforceable obligations to provide to the transferred personal data a standard of protection at least comparable to the Singapore Personal Data Protection Act 2012 (No. 26 of 2012).

Curbside’s employees are required, as a condition of their employment, to treat personal data held by Curbside as confidential, and to maintain the confidentiality of that personal data.

As “perfect security” does not exist, each of Curbside and its affiliates, related companies, and third party service providers and their respective officers, directors, employees and agents do not represent or warrant that there will not be, and hereby disclaim any responsibility or liability directly or indirectly arising out of or in connection with, any loss, theft, or unauthorised access, collection, use, disclosure, copying, modification, disposal or similar actions with regard to any data held or maintained by any of the aforesaid entities or persons.

8. DO WE COLLECT INFORMATION FROM MINORS?

We do not knowingly solicit data from or market to children under 18 years of age. By using the Sites and/or Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Sites and/or Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at admin@curbside.academy.

9. WHAT ARE YOUR PRIVACY RIGHTS?

Withdrawing your Consent

If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS POLICY?" below or updating your preferences. However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent. In addition, if you remove any personal data, which is necessary for us to provide you with Services, our provision of our Services to you may become impossible, impeded or deficient.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can: (1) contact us using the contact information provided; (2) log in to your account settings and update your user account; and (3) upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

Cookies and similar Technologies

Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. To opt out of interest-based advertising, please contact us using the contact information provided. If you have questions or comments about your privacy rights, you may email us at admin@curbside.academy.

10. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

11. DO WE MAKE UPDATES TO THIS NOTICE?

We may update this privacy policy from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.

12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at admin@curbside.academy or by post to: CURBSIDE PTE. LTD. 201 Henderson Rd, #05-11, Singapore 159545 Singapore 159545

13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please visit: https://www.curbside.academy

This privacy policy is governed by and shall be construed in accordance with Singapore law, without giving effect to any principles of conflicts of law. By accessing and/or using the Sites and/or our Services and providing personal data or information requested, you agree to submit to the exclusive jurisdiction of the Singapore courts.