We at Ativ Medical Pte Ltd (hereinafter referred to as “ATIV”) respect the privacy of each user which includes the use and protection of any information submitted by our visitors and is committed to protecting your privacy in accordance with the applicable laws, including the Personal Data Protection Act 2012 (“PDPA”).
We request that you read our Privacy Policy carefully as it contains important information about how we will process and use the Personal Data provided by you in the course of our business, including our websites, digital services and products such as mobile applications, technical platforms, and other online or offline offerings otherwise indicated.
By interacting with us and submitting your Personal Data to us, you agree and consent to ATIV as well as our related companies, respective agents, authorised service providers and relevant third parties to processing your Personal Data in the manner set forth in this Privacy Policy.
If you have any queries related to this Privacy Policy, please contact the Data Protection Officer(s) identified at the end of this Privacy Policy.
This Privacy Policy supplements but does not supersede nor replace any other consents which you may have previously or specifically provided to us nor does it affect any rights that we may have at law in connection with the collection, use and/or disclosure of your Personal Data.
We may from time to time update this Privacy Policy to ensure that this Privacy Policy is consistent with our future developments, industry trends and/or any changes in legal or regulatory requirements. As and when the contents of this Privacy Policy are updated or amended, the changes will be uploaded on to our website at [ativ.jp].
Each time you use our websites and/or mobile and web-based applications, and any updates, upgrades, new versions, documentation and content and services provided by or through the websites and/or mobile and web-based applications (collectively referred to as “ATIV Platforms”), or contact, interact or transact with us, you acknowledge and agree that the latest version of this Privacy Policy shall apply.
It is your duty to keep yourself updated as to the latest version of this Privacy Policy.
This Privacy Policy was last updated on [15 September 2025].
1. Privacy
We recognize that the protection of your Personal Information is very important in building trust with you.
This Privacy Policy may also be supplemented by additional policies and terms used in connection with particular purposes or on various forms which we may identify to be applicable.
2. Personal Information
“Personal Data” or “Personal Information” refers to any data, whether true or not, about an individual who can be identified
(a) from that data; or
(b) from that data and other information to which we have or are likely to have access to, including data in our records as may be updated from time to time.
The exact type of Personal Data that may apply in your case will vary depending on how you have interacted with us.
Some examples of such Personal Data you may provide to us include (depending on the nature of your interaction with us):
(a) personal details (e.g. name, NRIC, FIN, passport or other identification number, contact details, residential address, personal email address, nationality, age, gender, marital status, race, nationality, religion, and/or income levels);
(b) medical history and background which includes:
(1) the individual’s health or health care history;
(2) the provision of health care to the individual; or
(3) the payment for health care provided to the individual; and includes;
• the “Medical Record Number” and any other identifying number, symbol or particular assigned to an individual; and
• any identifying information about the individual that is collected in the course of, and is incidental to, the provision of healthcare or payment for healthcare.
(c) images and biometrics (e.g. photographs, voice and video recordings of you, including our conversations with you);
(d) your personal opinions made known to us (e.g. through feedback or surveys); and
(e) other electronic data or information relating to you through your usage of our products and services or as part of their delivery to you (e.g. location data, IP address, activity logs, cookies, device carrier/operating system and connection type).
Personal data does not include data about a data subject which has been anonymised.
Anonymisation is the process of removing identifying information such that the remaining data does not identify any particular individual.
3. Purposes and Use of Personal Information
ATIV may use your Personal Data:
(a) for the purposes identified below or separately communicated to you;
(b) to fulfil legitimate business interests and/or contractual and legal obligations; and
(c) to comply with applicable laws, regulations and/or requirements from government agencies, regulatory bodies, statutory boards or other relevant bodies in Singapore.
Generally, ATIV may process your Personal Data for the following purposes:
(a) Onboarding of information on relevant data subjects necessary to establish patient records and to commence treatment and care of the patient, including setting up the patient’s account with us and managing the patient’s use and access of the ATIV Platforms;
(b) Managing your relationship with us, and providing medical treatment, services and advice, including and without limitation to facilitating your use of our services offered via our ATIV Platforms such as telemedicine consultations and/or transactional e-services like e-appointments and e-payments;
(c) Contacting family members and/or next-of-kin and/or representatives for purposes of providing patient location (e.g. for visiting), medical updates, and seeking consent from them in emergency/incapacity situations;
(d) Ensuring proper and complete diagnosis and appropriate treatment including and without limitation to identifying health and/or treatment risks (e.g. collecting, identifying and communicating vulnerabilities, conditions, allergies, potentially adverse reactions, adverse events, device failures and/or issues, etc.) and monitoring appropriateness of medication usage, specimen testing and reporting recording patient infection data;
(e) Prescribing and dispensing appropriate medication;
(f) Referring and/or collaboration with and/or transferring patients to other institutions, healthcare professionals, caregivers, persons, organisations for procedures, additional support on treatment, specialist assistance, the procurement or provision of follow up care or as part of care arrangements;
(g) Conduct medical reviews to better address your medical risks and improve patient care;
(h) Monitor and facilitate the post treatment transition of patients’ care to partners (including community partners, allied health professionals, step-down care, home care and the like);
(i) To complete transactions with you and to administer and to manage/verify you with our preferred client services;
(j) To understand and analyze our services to cater to your needs and preferences;
(k) To develop, enhance, market and provide products and services to match your needs;
(l) To enable you to participate in any of our events, promotions and/or contests (if any);
(m) To enable us to personalize our services;
(n) To improve the quality of our services;
(o) To enable us to respond to any enquiries and/or request and/or complaints (if any);
(p) Carrying out security and health and safety measures and services (including, for example, performing network or service enhancement, protecting ATIV Platforms from unauthorised access or use and advising you of a product or drug recall);
(q) Verifying your identity and such other information provided by you, including but not limited to the relationship between yourself and a third party dependent or the relationship between yourself and a third party caregiver;
(r) Internal auditing, managing medical records, including facilitating patient merge processing and answering requests for medical records, producing medical reports and associated administrative documents;
(s) Facilitating business asset transactions (which may extend to any mergers, acquisitions or asset sales);
(t) Carrying out due diligence in accordance with legal and regulatory obligations or our risk management procedures and policies such as conducting audits to prevent, detect and investigate crime or offences or uncover non-conforming processes;
(u) In connection with any claims, actions or proceedings (including but not limited to the drafting and reviewing of documents, transaction documentation, obtaining legal advice, and facilitating dispute resolution), and/or protecting and enforcing our contractual and legal rights and obligations;
(v) To bill and receive payment for services that we or others provide to you; and
(w) Any other purpose reasonably related to the aforesaid.
We may disclose your Personal Information if we are required to do so by law or requirement by any competent authority or ministries.
To conduct our operations more smoothly, we may disclose the Personal Data you have provided to us to our third-party services providers (such as translators and courier services), agents and/or affiliates or related corporations (“External Parties”) for such External Parties to process your Personal Data based on your requested services for one or more of the above stated reasons or purposes.
An External Party may be sited locally or outside Singapore.
We may handle Personal Data (such as telephone number and email address) to contact you to remind you of appointments at clinics operated under ATIV. Telephone calls may also be made as part patient care and follow up (including but not limited to phone triage, or consultation).
We may also disclose Personal Data in emergency situations affecting (or causing serious threats to) the health, life, safety of any individual (e.g. to notify appropriate authorities where we believe a person has been the victim of abuse, neglect or domestic violence). Such disclosures will be made to such persons as may be necessary to address or respond to the situation.
If we need to use your Personal Data for any other purposes, we will notify you and obtain your consent beforehand in accordance with the requirements of applicable data protection laws.
4. Information Collection
We communicate with you through a variety of means and channels, through the internet and whether by email, post, phone or fax on your phone.
Such communications may involve giving as well as receiving information from you.
Some of the information received is personally identifiable information such as those defined in Section 2 above.
Generally, depending on the situation, ATIV may collect your Personal Data in the following ways:
(a) when you submit forms, including but not limited to medical consent forms, applications, requests or feedback to us;
(b) when you use our ATIV Platforms or interact with us via any of our ATIV Platforms or use the services on any of our ATIV Platforms which may utilise various technologies to collect data (which may include Personal Data) automatically either by us or by third parties on behalf of us;
(c) when, as a patient, you are examined by our staff or medical equipment, or when you are subject to or participate in a medical examination, including but not limited to various forms of screening (which may include the taking of biological samples or matter), or when, as a patient, you are engaged in medical procedures (which may result in notes or records being made);
(d) where medical monitoring devices and equipment are supplied to you as part of treatment and/or diagnostics, when we receive personal data from those devices as part of the device or equipment’s operation;
(e) 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 or the ATIV Platforms;
(f) when you interact with our staff (including customer service officers, nurses, doctors, residents, allied health service professionals, and other representatives), for example, via our ATIV Platforms, telephone calls, letters, face-to-face meetings, social media platforms and/or emails;
(g) when you respond to our request(s) for additional Personal Data;
(h) when we receive your Personal Data from referral parties, government ministries or agencies, regulators, statutory boards, Public Healthcare Institutions, public agencies, your employer and/or other third parties;
(i) when your images are captured by our CCTV cameras while you are within our premises, or when you attend or participate in our events or activities (e.g. public forums or events) and your voice and/or image data is captured on cameras, audio and/or video recordings;
(j) when you respond to our initiatives (e.g. promotions, market research or surveys);
(k) from third parties, including social networks (such as Facebook, LinkedIn or YouTube), when you consent to such third parties disclosing information about you to us that those third parties have collected, whether by logging into or through the social plug-ins on our websites or mobile or web-based applications or otherwise;
(l) when you make payment or provide details to facilitate payment, or secure or administer the application of funding, benefits and/or subsidies;
(m) when we seek information from third parties about you in connection with your relationship with us, including from next-of-kin and caregivers;
(n) from publicly available sources including public social media or information you make available to the public; and
(o) when you submit your Personal Data to us for any other reason.
As a website or app, the ATIV Platforms may also use some of the following technologies in the services and functionalities in the ATIV Platforms.
Examples of some of the technologies which may be used (either by us or by third parties on behalf of us) by or in our electronic services, websites and mobile and web-based applications to collect, use and/or disclose Personal Data include the following:
(a) Authentication confirmations from biometric data services.
We do not store biometric data, but may interface with third party biometric data services to authenticate your identity when you seek to access the ATIV Platforms services.
(b) Click-stream data.
A visit to one of our websites or use of our mobile or web-based applications results in data that is transmitted from your browser to our server being automatically collected and stored by us or by third parties on behalf of us.
This data can include:
(1) the visitor’s IP address;
(2) the date and time of the visit;
(3) the referral URL (the site from which the visitor has come);
(4) the pages visited and action taken on our website or mobile or web-based applications; and
(5) information about the device, mobile carrier and browser used (browser type and version, operating system, etc).
(c) Cookies.
A number of places on our website and our mobile and web-based applications make use of cookies.
Should you wish to disable the cookies associated with these technologies, you may do so by changing the setting on your browser.
However, you may not be able to enter certain part(s) of our website or enjoy full access to all of our applications.
(d) Web beacons and tracking links.
Web beacons (also known as pixel tags and clear GIFs) involve graphics that are not apparent to the user.
Tracking links and/or similar technologies consist of a few lines of programming code and can be embedded in our emails, website or mobile or web-based applications.
In conjunction with cookies, these are primarily used for statistical analysis purposes.
This technology can also be used for tracking traffic patterns on websites, as well as finding out if an e-mail has been received and opened and to see if there has been any response.
(e) Web analytics.
Web analytics is the term given to a method for collecting and assessing the behaviour of visitors to websites and mobile or web-based applications.
This includes the analysis of traffic patterns in order, for example, to determine the frequency of visits to certain parts of a website or mobile or web-based application, or to find out what information and services our visitors are most interested in.
For these purposes, we primarily make use of click-stream data and the other techniques listed above.
Web analytics are carried out by the Content Management Systems, Google Analytics and/or other selected parties (as we may inform you from time to time) (“Web Analytics Providers”).
When you visit or use our ATIV Platforms, Personal Data may (unless you have refused the processing of your Personal Data via such cookies and technologies) be sent to the Web Analytics Providers for analysis for and on behalf of us for the purposes described in this Privacy Policy.
Please note that if you have created an online profile at any of our ATIV Platforms and if you are logged in on this profile, a unique number identifying this profile may also be sent to the Web Analytics Providers in order to be able to match the web analytics data to this profile.
If you do not wish information about your behaviour at any of our ATIV Platforms to be collected and assessed by Google Analytics, you can install the Google Analytics opt-out browser add-on.
Please refer to Google Analytics Opt-out Browser Add-on page for more information on downloading the add-on and opting out.
(f) Unique application numbers.
Certain services include a unique application number.
This number and information about your installation of the application (for example, the operating system type and application version number) may be sent to us when you install or uninstall that service or when that service periodically contacts our servers, such as for automatic updates.
(g) Local Storage.
We may collect and store information (including Personal Data) locally on your device using mechanisms such as browser web storage (including HTML 5) and application data caches.
Such information may include your self-added medication list and medication reminders.
(h) Retargeting Technologies.
Our ATIV Platforms may use retargeting technologies within the Internet.
Retargeting technologies analyse your cookies and past surfing behaviour, including clicking of advertisements, so that where you have visited or used any of our ATIV Platforms or clicked on our advertisements before, we can serve you our advertisements on our partner websites.
We may also work with Web Analytics Providers, who use tracking technologies to serve our advertisements to you across the Internet.
In order to serve such advertisements, these companies may collect information about your visits to our ATIV Platforms and your interactions with us and our advertisements.
Please refer to our Web Analytics Providers’ privacy policy(ies) for more information about their data protection practices.
If you do not wish to receive such advertisements, you may adjust your browser settings for the cookies which your browser accepts.
ATIV will endeavour to limit the collection of personal data to what is reasonable or necessary for such applicable purposes as described in this Privacy Policy.
However, it should be noted that in the case of medical and/or health information, the extensiveness and completeness of information that is collected can mean the difference between saving a life, or preventing the loss of life, and can make a crucial difference between a full and proper diagnosis with appropriate treatment and incomplete or inadequate treatment.
Further, the relevance of information may not be immediately apparent at first and personal data may be collected as a matter of precaution to ensure that you or a data subject is adequately protected from or treated for illness.
It may also be good medical practice to collect information about a patient or even next-of-kin (e.g. in the case of congenital disorders, allergies, predispositions to certain risks etc), spouse, children, parents, and/or employees.
5. Accuracy of Information
We at ATIV keep Personal Information as accurate, complete and up-to-date taking into account its usage and interests of our customers.
We also rely on you and will assume that you have ensured that all Personal Data submitted to us is complete, accurate, true and correct.
To enable us to ensure the quality and accuracy of Personal Data, you have an obligation to provide accurate and up-to-date information to us.
Failure on your part to do so may result in our inability to provide you with the products and services you have requested or process your application.
Please inform us if there are any changes to your Personal Information and for ensuring that such information is accurate and relevant at any point of time when you visit us or use any of our ATIV Platforms.
6. Updating Personal Information and Withdrawal of Consent
We will amend the Personal Information contained in our database or elsewhere as required when an individual demonstrates to us the inaccuracy or incompleteness of the Personal Information.
We may require you to provide us with additional information if necessary.
You are entitled to withdraw your consent for the collection, use and disclosure of your Personal Data at any time.
However, depending on the nature of the withdrawal, it may become impossible for ATIV to provide services such as processing or providing services offered by the ATIV Platforms, and in particular:
(a) in some cases, it may be unsafe or unlawful for us to provide (or continue to provide) medical treatment without the ability to collect, use or disclose Personal Data;
(b) it may not be possible, without undue risk, cost or liability to ATIV, to proceed with a particular transaction, agreement or interaction with you, and we may be left with no choice but to cease or refrain from the same.
At the same time, it should be noted that your withdrawal of consent will not prevent us from exercising our legal rights (including any remedies, or undertaking any steps as we may be entitled to at law).
If you have any questions or feedback relating to your Personal Data or our Privacy Policy, would like to withdraw your consent to any use of your Personal Data as set out in this Privacy Policy, or would like to obtain access and make corrections to your Personal Data records, please contact our Data Protection Officer identified at the end of this Privacy Policy by way of email.
7. Security and Retention of the Personal Information
We at ATIV will take reasonable efforts to protect your Personal Information in our possession against any loss or theft as well as unauthorized access, copying, disclosure, usage or modification regardless of the way the personal information is being stored.
However, we cannot completely guarantee the security of any Personal Data we may have collected from or about you, e.g. that no harmful code (such as viruses, bugs, Trojan horses, spyware or adware) will enter our website.
We retain Personal Data as may be required for business, legal, regulatory or compliance purposes, and such purposes do vary according to the circumstances.
While we will take reasonable steps to dispose or anonymise Personal Data that is no longer needed, it is in the interests of any caregiver or person treating the patient to be able to refer to a complete set of medical records to avoid risks to health and safety of the patient.
With regard to medical data that we process, we will retain medical records in accordance with the duration stipulated by the Ministry of Health or/and in adherence with contractual agreements.
Generally, we do not transfer Personal Data out of Singapore, except to our approved third party services providers for applicable services.
Should we do so, we will ensure there is compliance with the requirements under the PDPA.
8. Third Party Sites
Our ATIV Platforms may contain links to other websites operated by third parties.
We are not responsible for the privacy practices of websites operated by third parties that are linked to our website.
We encourage you to learn about the privacy policies of such third party websites.
Some of these third party websites may be co-branded with our logo or trademark, even though they are not operated or maintained by us.
Once you have left our ATIV Platforms, you should check the applicable privacy policy of the third party website to determine how they will handle any information they collect from you.
9. Governing Law
This Privacy Policy and your use of the ATIV Platforms shall be governed in all respects by the laws of Singapore.
10. Data Protection Officer
Should you have any queries relating to your Personal Data, please contact us via the inquiry form on our website.
[Tatsuki FUJII]