Data Protection Policy
CAPSULE PHARMA PTE LTD
Data Protection Policy
Last Revision Date: 03 March 2015
Capsule Pharma Pte Ltd and the websites under it’s management (such as the BELVEA.COM site) (herein known collectively as “the Company”) will routinely collect personal data, including name, email address, contact details (collectively known as “Data”), from individuals as it strives to fulfill its service as a marketer, seller, distributor and wholesaler.
Adequate policies and procedures have been put in place by the Company to protect the confidentiality of the Data that it has collected and to safeguard the interests of the individuals.
Collection of Data
The Company will generally seek an individual’s expressed or implied consent for the collection, use and disclosure of the individual’s Data. The granting of consent will not be a condition for the supply of any service. An individual is also entitled, at any time after having granted his consent, to write in to inform the Company’s Quality Service Manager of the withdrawal of his consent. The Company will, after being so informed, continue to maintain the relevant Data in its custody, but will not use or disclose the Data to any other party except in an aggregate1 form.
The Company may, in the following situations, collect, use or disclose Data without an individual’s consent:
- The Data is generally available to the public.
- The Data is necessary to render a service that the individual has applied for.
- The Data is required by law.
- The Data is for research or statistical purposes, and that the results of the research or statistical processing would lead to an aggregate or de-identified2Data and would not lead to identification of an individual by any reasonably foreseeable means.
- The collection, use or disclosure of Data is clearly in the individual’s interest.
- It is impracticable to obtain the individual s consent at the point of collection, use or disclosure, and if it were practicable for the individual to grant such consent, the individual would be likely to give it.
Processing and maintenance of Data
The Company has procedures in place to protect the confidentiality of collected Data. Data stored in the Company’s computer systems are protected from unauthorised access by appropriate security technologies. Only the authorised staff of the Company will have access to Data on a need-to-know basis.
Use and disclosure of Data
The Company will use collected Data in accordance with the purposes authorised by an individual or in those certain specific situations described in the aforesaid section titled “Collection of Data“.
The Company will not consider any request for Data, submitted by external researchers. All requests for Data for research purposes will be rejected outright, by the Company.
Further, the Company will not release any Data to any requesting party unless that party agrees to maintain the confidentiality of the Data supplied and to use the said Data only for the specific purposes approved by the Company.
The Company will not release collected Data to any commercial businesses or companies.
Access to and correction of Data
An individual may, at any time, requests details of the Data that the Company has collected from him, or information relating to the Company’s use and disclosure of his Data, from the relevant Division of the Company or the Quality Service Manager.
The Company has the discretion to decide whether to provide the requested information and the terms on which the said information is provided to the said individual. The Company has the discretion to refuse to provide the requested information in the following situations:
- Information requested would reveal Data that cannot be disclosed by the Company on the grounds of public policy, legal, security or commercial proprietary reasons;
- The request would be too costly for the Company to comply with; or
- The request is frivolous or vexatious.
An individual may also, at any time, contact the relevant Division of the Company that has collected the information from him, or the Company’s Quality Service Manager, to amend his Data on the basis that the Data collected or maintained by the Company is inaccurate or incomplete. Satisfactory evidence must be provided to prove the inaccuracy or incompleteness of the Data. The Company will correct its records after the request has been verified and approved.
Amendments
The Company reserves the right to amend its data protection policy and the information it has published in relation to the said policy from time to time. While the Company takes reasonable care to ensure that information published about its said policy is up-to-date, the Company does not guarantee the accuracy or completeness of such information.
Feedback
The Company welcomes all feedback in relation to its data protection policy. All feedback should be addressed to the Company s Quality Service Manager.
Quality Service Manager
Tel: +65-6481 2886
Email: cps<at>capsulepharma<dot>com
Please indicate subject header as: PDPP Feedback
1 Data obtained from different persons and/or from multiple sources that have been processed in a summary form, and which does not reveal the identity of any person from whom the individual Data is collected.
2 Data with all particulars concerning the identity of a person or any other particulars in relation to a person removed or concealed by a technical process.