Data Privacy Statement

1. General

We at RadLink Philippines Corporation (herein referred to as RadLink PH) are committed to safeguarding your privacy. We treat all personal data provided by you in strict confidence as defined in the Data Privacy Act of 2012 and the current issuances by the National Privacy Commission and will only use your personal data in the manner set out in this Statement or in cases provided for by any applicable law. This Statement applies to all personal data that you provide to us and the personal data we hold about you. This Privacy Statement informs you about how RadLink PH collects, uses, discloses, and protects your personal data in the course of providing you our services. We treat all personal data provided by you in strict confidence, All references to “RadLink Philippines Corporation”, “RadLink PH”, “we”, “us” and “our” refer collective to RadLink PH and its related entities.

2. Amendment to this Statement

We may amend this Statement from time to time. The updated Statement will supersede earlier versions and will apply to personal data provided to us previously. The updated Statement will be made available upon request from our Data Protection Officer and on our website.

3. Our Data Protection Officer

Radlink PH is a Philippine based entity, with a Data Protection Officer responsible for ensuring the confidentiality, integrity and availability of your personal information. If you have privacy concerns or if you wish to enforce your rights to be informed, to object, to access, to correct, to erasure, to complain or to data portability, please direct your query to Radlink PH DPO as follows:

DATA PRIVACY OFFICER

dpo@radlink.com.ph

4. Personal Data We Collect

When availing our services, we may collect the following personal data from you:

Contact Information: Name, address, phone number, email address, next of kin information.
Photo or videos captured through our platforms and/or CCTVS installed in our premises
Medical Information: Medical history, diagnoses, medications, allergies, immunizations, lab results, treatment notes, physician reports.
Financial Information: Billing and payment information, insurance or HMO information.
Demographic Information: Age, gender, ethnicity, language.
Call Recordings when you call our hotlines;
Usage, viewing, technical, and device data when you visit our sites, use our applications on third-party sites or platforms, or open emails we send, or connect with our wireless Internet access services and other similar technologies, including your browser or device type, unique device identifier, and IP address;
Public Forum Information posted about us by you made available to all.
Personal data is collected when you:
register for or use any services or products we provide;
respond to or register for any of our initiatives or events;
visit our website;
send us an email;
request to be included in our mailing list;
interact with our staff, including customer service officers, for example, via telephone calls (which may be recorded), letters, fax, face-to-face meetings, social media platforms and emails;
call us to fix an appointment;
when your images are captured by us via CCTV cameras while you are within our premises, or via photographs or videos taken by us or our representatives when you attend our events;
request that we contact you;
and/or submit your personal data to us for any other reason.

5. Purposes for Collection, Use or Disclosure of your Personal Data

Primary purposes we collect and use your personal data for the following purposes:

To manage your relationship with us;
To provide you with the services that you have requested;
To provide you with customer service and support and assist you with your enquiries;
To verify your identity;
To manage your appointments and billing.;
To administer medical care, including dispensing medication and treatment, liaising with health professionals, Insurers and Health Maintenance Organisations (HMO) in relation to your medical care where necessary (including by providing them with access to your medical records);.
To personalize your experience at our touchpoints and improve our service offerings;
To keep you updated on our events and services;
To comply with legal and regulatory requirements

Business purposes: Radlink PH needs to process your personal data to fulfill our role as your provider of medical services, with all the attendant benefits Radlink PH provides. Sometimes Radlink PH has a legitimate interest in processing data to better understand the needs, concerns, and interests our patients and other customers so we can operate optimally as a business and to use your personal data for purposes connected or relevant to our business.

Marketing purposes. If you have consented, we may collect, use and/or disclose your personal data for the purposes of marketing our products and services and those of our strategic partners and business associates e.g. informing you of our latest events and services. In order for us to market products and services which are of special interest and relevance to you in order to collect, use and/or disclose your personal data for these marketing purposes, we may analyse and rely on your overall interaction with us (such as but not limited to your medical and treatment history as well as your other interactions with us). You have a choice to withdraw your consent for receiving marketing or promotional materials/communication. You may contact us using the contact details found below. Please be aware that once we receive confirmation that you wish to withdraw your consent for marketing or promotional materials/communication, you may still receive marketing or promotional materials/communication during the period it takes us to process your withdrawal of marketing consent. Please note that even if you withdraw your consent for the receipt of marketing or promotional materials, we may still contact you for other purposes in relation to the services that you have requested or purchased from us.

The information we collect is important to support your care and is also a record of your relationship with the healthcare staff involved in providing your care, e.g. doctors, nurses, administration and clerical staff. This relationship is based on mutual trust and confidence and we will do everything possible to protect and maintain that trust. It is important that the details you provide are accurate and that you let us know of any changes to them.

6. Disclosure of Personal Data

We will not sell your personal data to third parties. Subject to the provisions of any applicable law, we may disclose your personal data to the following parties whether they are located overseas or in the Philippines, in the following instances:

you request or authorize it, such as providing us with consent;
the information is provided to comply with the law (for example, to comply with a search warrant, subpoena, or court order),
enforce an agreement we have with you, or to protect our rights, property or safety, or the rights, property or safety of our employees or others;
the information is provided to our affiliates within the Fullerton Health Group, agents, vendors, consultants, partners or service providers who perform functions on our behalf or provide services in relation to the delivery of care or our business operations, ;
to address emergencies or acts of God; or
to address disputes, claims, or to persons demonstrating legal authority to act on your behalf;

Third parties to whom disclosure may be made include:

Healthcare providers involved in your care, such as specialists, hospitals, and laboratories.
HMO provider and insurance companies for billing purposes.
Corporate partner or Data subject’s employer in cases where you authorize the same or when required by law
Government agencies as required by law.
Third-party service providers who assist us in operating the System, such as data storage providers and billing companies.

We will only disclose your personal data to entities for the purposes described in this Notice

7. Retention of Personal Data

Following the latest Health Privacy Code issued by the Department of Health, Radlink PH is obliged to keep your health information for a period of fifteen (15) years or such period as stipulated by the Privacy Health Code from time to time. We will retain personal data only when there is business or legal purposes to do so. Personal data will be purged when there is no longer any business or legal purposes for retention.

8. Data Security

We have implemented appropriate technical and organizational measures to protect your personal data from unauthorized access, disclosure, alteration, or loss. These measures include, but are not limited to, data encryption, access controls, and security monitoring.

We review, update and test our security procedures on an ongoing basis. We restrict access to your personal data to those employees who need to know that information to provide benefits or services to you. In addition, we train our employees about the importance of confidentiality and maintaining the privacy and security of your information. We commit to taking appropriate disciplinary measures to enforce our employees’ privacy responsibilities.

While best practice precautions will be taken to ensure that the information you provide is protected against unauthorized or unintended access, we cannot be held responsible for unauthorized or unintended access that is beyond our control.

9. Your Rights

The Data Privacy Act of 2012 provides certain rights for data subjects. A good explanation of them (in English) is available on the website of the Philippine National Privacy Commission Website (https://www.privacy.gov.ph/know-your-rights/). These rights are as follows:

Access your personal data.
Correct inaccurate personal data.
Request the deletion of your personal data.
Restrict the processing of your personal data.
Object to the processing of your personal data.
Withdraw your consent at any time.
 lodge a complaint with the appropriate data protection authority if you have concerns about how Radlink PH processes your personal data.

To exercise any of these rights, please contact our Data Protection Officer at dpo@radlink.com.ph. We will respond to your request within a reasonable timeframe.

10. Data Breaches

 Should your personal data that we control be lost, stolen or otherwise breached, where this constitutes a high risk to your rights, property and/or freedoms, we will contact you without undue delay. We will give you the contact details of the person who is dealing with the breach, explain to you the nature of the breach and the steps we are taking to deal with it.

11. Contact Us

If you have any questions, concerns of complaints about this Statement, or would like to exercise your rights, please contact our Data Protection Officer at dpo@radlink.com.ph.