1. WHAT PERSONAL DATA WE COLLECT

“Personal Data” means any identified or identifiable information about you as listed below. In order to offer you with our products and services, we may collect Personal Data directly (e.g. through our representatives, officers, relationship manager, salesperson, staff, call center, application) or indirectly from you or other sources (e.g. social media, third party’s online platforms, and other publicly available sources) or through our parent company, affiliates, subsidiaries, business partners, official authorities, or third parties. The specific type of data collected will depend on the context of your interactions with us, and the services or products you need or want from us and within AMI Healthcare Group.

“Sensitive Data” means Personal Data classified by law as sensitive data. We will only collect, use, disclose and/or cross-border transfer Sensitive Data if we have received your explicit consent or as permitted by law.

2. THE PURPOSE OF COLLECTION, USE OR DISCLOSURE OF YOUR PERSONAL DATA

We may collect, use, disclose and/or cross-border transfer your Personal Data and Sensitive Data for the following purposes.

2.1 Purpose for which consent is required
We rely on your consent for the following purposes:

1. Marketing and Communications: To provide marketing communications, sales, special offers, promotions, notices, news, and information about products and services from us, AMI Healthcare Group, our affiliates, subsidiaries, third parties and/or business partners which we cannot rely on other legal bases;
2. Analytic services: To conduct data analytic services on your personal data within AMI Healthcare Group, our affiliates, subsidiaries, or to third parties; and/or
3. Sensitive Data: We may use your sensitive data for the following purposes:
   1. Sensitive data as shown in the identification document (e.g. religion, racial or ethnic origin): for verification and authentication purpose;
   2. Biometric data (e.g. fingerprints, facial recognition, retinal scans) for providing access our premises, security purposes and providing elevator access control system;
   3. Health data and disability for coordinating with medical service providers;
   4. Criminal records for security purpose.

2.2 The purposes we may rely on and other legal grounds for processing your Personal Data
We may also rely on (1) contractual basis, for our initiation or fulfilment of a contract with you; (2) legal obligation, for the fulfilment of our legal obligations; (3) legitimate interest, for the purpose of our legitimate interests and the legitimate interests of third parties; (4) vital interest, for preventing or suppressing a danger to a person’s life, body, or health; and/or (5) public interest, for the performance of a task carried out in the public interest or for the exercising of official authorities.

3. TO WHOM WE MAY DISCLOSE OR TRANSFER YOUR PERSONAL DATA

We may disclose or transfer your Personal Data to the following third parties who collects, uses and discloses Personal Data in accordance with the purpose under this Policy. These third parties may be located in the United States and areas outside the United States. You can visit their privacy policy to learn more details on how they collect, use and disclose your Personal Data as you are also subject to their privacy policies.

3.1 AMI Healthcare Group ‘s data ecosystem
As AMI Healthcare, Inc. is part of AMI Healthcare Group, AMI Healthcare Asia Co., Ltd., (Thailand) and AMI Healthcare Co. Ltd. (collectively referred to as “AMI Healthcare Group”) which all collaborate and partially share customer services and systems including website-related services and systems, we may need to transfer your Personal Data to, or otherwise allow access to such Personal Data by other companies within AMI Healthcare Group for the purposes set out in this Privacy Policy. This will allow other companies within AMI Healthcare Group to rely on consent obtained by AMI Healthcare.

3.2 Our service providers
We may use other companies, agents or contractors to perform services on behalf or to assist with the provision of products and services to you. We may share your Personal Data to our service providers or third-party suppliers including, but not limited to (1) computer program developer, software developer, IT service providers and IT support company; (2) marketing, advertising media, designer, creative, and communications agencies; (3) campaign, event, and market organizers, and CRM agency; (4) data storage and cloud service providers; (5) property management service provider; (6) sale agencies; (7) logistic and courier service providers; (8) payment and payment system service providers; (9) research agencies; (10) analytics service providers; (11) survey agencies; (12) call center; (13) telecommunications and communication service providers; (14) outsourced administrative service providers; (15) printing service providers.

In the course of providing such services, the service providers may have access to your Personal Data. However, we will only provide our service providers with the information that is necessary for them to perform the services, and we ask them not to use your information for any other purposes. We will ensure that the service providers we work with will keep your Personal Data secure as required under the laws.

3.3 Our business partners
We may disclose your Personal Data to companies that we have partnered with to offer or enhance products and services for our customers or prospective customers, for example, financial institution partner, access solution company, telecommunication company, sponsors, co-branded partners and other third parties that we conduct joint marketing and cross promotion with.

3.4 Third parties required by law
In certain circumstances, we may be required to disclose or share your Personal Data in order to comply with a legal or regulatory obligations. This includes any law enforcement agency, court, regulator, government authority or other third party where we believe it is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights, the rights of any third party or individuals’ personal safety, or to detect, prevent, or otherwise address fraud, security, or safety issues.

3.5 Professional advisors
This includes asset management service providers, lawyers, technicians and auditors who assist in running our business, and defending or bringing any legal claims.

3.5 Assignee of rights and/or obligations
Third parties as our assignee, in the event of any reorganization, merger, business transfer, whether in whole or in part, sale, purchase, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock or similar transaction; will comply with this Privacy Policy to respect your Personal Data.

4. INTERNATIONAL TRANSFERS OF YOUR PERSONAL DATA

We may disclose or transfer your Personal Data to third parties or servers located overseas, which the destination countries may or may not have the same data protection standards. We take steps and measures to ensure that your Personal Data is securely transferred and that the receiving parties have in place suitable data protection standards or other derogations as allowed by laws. We will request your consent where consent to cross-border transfer is required by law.

5. HOW LONG DO WE KEEP YOUR PERSONAL DATA

We keep your Personal Data only for so long as we need the Personal Data to fulfil the purposes we collected it for, and to satisfy our business and/or our legal and regulatory obligations. How long we keep your Personal Data depends on the nature of the data. Some information may be retained for longer, where we are required to do so by law.

6. YOUR RIGHTS AS A DATA SUBJECT

Subject to applicable laws and exceptions thereof, you may have the following rights to:

1. Access: You may have the right to access or request a copy of the Personal Data we are collecting, using and disclosing about you. For your own privacy and security, we may require you to prove your identity before providing the requested information to you.
2. Rectification: You may have the right to have incomplete, inaccurate, misleading, or or not up-to-date Personal Data that we collect, use and disclose about you rectified.
3. Data Portability: You may have the right to obtain Personal Data we hold about you, in a structured, electronic format, and to send or transfer such data to another data controller, where this is (a) Personal Data which you have provided to us, and (b) if we are processing such data on the basis of your consent or to perform a contract with you.
4. Objection: You may have the right to object to certain collection, use and disclosure of your Personal Data such as objecting to direct marketing.
5. Restriction: You may have the right to restrict the use of your Personal Data in certain circumstances.
6. Withdraw Consent: For the purposes you have consented to our collecting, using and disclosing of your Personal Data, you have the right to withdraw your consent at any time.
7. Deletion: You may have the right to request that we delete or de-identity Personal Data that we collect, use and disclose about you, except we are not obligated to do so if we need to retain such data in order to comply with a legal obligation or to establish, exercise, or defend legal claims.
8. Lodge a complaint: You may have the right to lodge a complaint to the competent authority where you believe our collection, use and disclosure of your Personal Data is unlawful or noncompliant with applicable data protection law.

7.  OUR CONTACT DETAILS

If you wish to contact us to exercise the rights relating to your Personal Data or if you have any queries about your Personal Data under this Privacy Policy, please contact us at:

AMI Healthcare
44 Bear Foot Rd, Suite 200,
Northborough, MA 01532

Phone: +1 (617) 600 7760
Email: info@amihealthcare.com