Personal Data Protection Act

The protection of your personal data is important to Lucence. This Privacy Policy outlines the management of Personal Data (as defined herein) by Lucence Diagnostics Pte. Ltd. and its related entities (“Lucence”) in compliance with the requirements of the Personal Data Protection Act 2012 (“PDPA”) and the Regulation (EU) 2016/679 (General Data Protection Regulation)(“GDPR”) (where applicable) in respect of the collection, use and disclosure of your personal data. We may amend this Privacy Policy from time to time and such amendments will be reflected on this website.

(A)   By interacting with Lucence, submitting information to Lucence or using any products or services offered by Lucence, you agree and consent to Lucence collecting, retaining, processing, using, disclosing and transferring your Personal Data to Lucence’s authorised service providers and relevant third parties in the manner set out in this Privacy Policy.

(B)   This Privacy Policy supplements and does not supersede nor replace any other consents you may have previously provided to Lucence in relation to your Personal Data.  Your consents shall be valid and effective notwithstanding any current or future registration made by you on the Do-Not-Call-Registry and are additional to any rights that Lucence may have at law to collect, retain, process, use, disclose or transfer your Personal Data.

(C)   Lucence may from time to time update this Privacy Policy to ensure that this Privacy Policy is consistent with its future business, industry trends and/or any changes in legal or regulatory requirements.  Subject to your rights at law, you agree to be bound by the prevailing terms of this Privacy Policy as may be updated by Lucence from time to time.

  1. Personal Data
  • 1.1  In this Privacy Policy, “Personal Data” means any data about an individual who can be identified:
    • (a)    from that data; or
    • (b)   from that data and other information to which Lucence has or is likely to have access to, including data in Lucence’s records as may be updated from time to time.
  • 1.2  Types of Personal Data that may be provided to or collected by Lucence include but are not limited to:
    • (a)    name;
    • (b)   NRIC, passport or other personal identification number;
    • (c)    telephone number;
    • (d)   fax number;
    • (e)    mailing address;
    • (f)     e-mail address; and
    • (g)    any other information relating to you or other individuals that you have provided to Lucence.


  1. Collection of Personal Data
  • 2.1 Lucence may collect your Personal Data in the following ways:
    • (a)    when you submit any form relating to Lucence’s products and/or services, including but not limited to order forms and customer inquiry forms
    • (b)   when you use Lucence’s services or purchase Lucence’s products
    • (c)    when you interact with Lucence’s officers, employees, representatives and agents via telephone calls, letters, fax, face-to-face meetings, events, workshops, seminars, social media platforms and e-mails;
    • (d)   when you request for Lucence to contact you or include you in its e-mail mailing lists or other mailing list in connection with updates to Lucence’s products and services;
    • (e)    when you respond to Lucence’s marketing promotions or initiatives or when you are contacted by and respond to Lucence’s officers, employees, representatives and agents;
    • (f)     when you enter into any agreement or provide other documentation or information in relation to your interactions with Lucence;
    • (g)    via Lucence’s website, which does not automatically collect your Personal Data unless you provide such information to Lucence;
    • (h)   when you respond to Lucence’s request for additional information to supplement your Personal Data;
    • (i)     when Lucence requests for your information and receive your Personal Data in connection with your relationship with Lucence, for example, from your business partners, public agencies and relevant authorities;
    • (j)     when your images are captured by Lucence on its CCTV cameras installed on its premises or photographs or videos taken by Lucence when you attend its events, workshops or seminars; and/or
    • (k)    when you submit or disclose your Personal Data to Lucence for any other reasons.
  • 2.2  If you provide Lucence with any Personal Data relating to a third party, you represent to Lucence that you have obtained the consent of that third party to provide Lucence with its Personal Data.
  • 2.3  You shall make reasonable efforts to ensure that all Personal Data provided to Lucence is complete, accurate, true and correct.  Further, you shall give Lucence notice in writing as soon as reasonably practicable should your Personal Data be updated or changed after such disclosure, in accordance with Clause 7 below.  Failure to do so may result in Lucence’s inability to provide to you with any products and services as requested.


  1. Purposes for the Collection, Retention, Process, Use, Disclosure and Transfer of Personal Data
  • 3.1 Lucence collects, retains, processes, uses, discloses and transfers your Personal Data for and in connection with the following purposes:
    • (a)    verifying your identity;
    • (b)   conduct of any examinations or tests and related activities by Lucence upon your request;
    • (c)    providing any of Lucence’s products and/or services to you;
    • (d)   providing marketing materials and relevant information to you, including but not limited to information and any updates on Lucence’s products and services, newsletters, healthcare-related information and any upcoming events, workshops and seminars organised by Lucence;
    • (e)    requesting feedback or participation in surveys, as well as conducting market research and/or analysis for statistical, profiling or other purposes in connection with Lucence’s business and/or to review, develop and improve Lucence’s product and service offerings;
    • (f)     providing customer service and support (including but not limited to customer relationship management, providing follow-up calls and providing you with administrative support);
    • (g)    responding to, processing and handling your queries, feedback, complaints and requests;
    • (h)   if you use Lucence’s current or future websites, mobile applications or online registration and payment systems, displaying your Personal Data on such websites, mobile applications or online registration and payment systems to facilitate the provision of Lucence’s services to you;
    • (i)     administering and processing your requests, including creating and maintaining profiles of Lucence’s customers in Lucence’s system database for administrative purposes;
    • (j)     liaising with doctors, clinics, hospitals and/or medical institutions in relation to your service requests;
    • (k)    managing and planning the administrative and business operations of Lucence and complying with its internal policies and procedures;
    • (l)     monitoring or recording telephone calls and customer interactions for quality assurance, employee training and performance evaluation and identity verification purposes;
    • (m)  in connection with any claims, actions or proceedings (including but not limited to obtaining legal advice and facilitating dispute resolution), and/or protecting and enforcing Lucence’s contractual and legal rights and obligations;
    • (n)   complying with any applicable laws, regulations, rules, codes of practice or guidelines issued by any legal or regulatory bodies which are binding on Lucence (including but not limited to responding to regulatory complaints, disclosing to regulatory bodies and conducting audit checks, due diligence and investigations);
    • (o)   administering debt recovery and debt management;
    • (p)   taking or filming photographs and videos for corporate publicity or marketing purposes, and featuring your photographs and/or testimonials in our articles and publicity materials;
    • (q)   organising roadshows, seminars, campaigns and promotional events; and/or
    • (r)    purposes which are reasonably related to the aforesaid.
  • 3.2  If you have provided Lucence with your telephone number, fax number, mailing address and/or e-mail address and indicated that you consent to receiving information from Lucence via telephone calls, SMS messages, data messages, fax, post or e-mails, Lucence may contact you from time to time using the foregoing methods for the purposes listed in this Clause 3.
  • 3.3  In relation to the provision of Lucence’s products or services to you or in your interactions with Lucence, Lucence may have notified you of other purposes for which it collects, retains, processes, uses, discloses or transfers your Personal Data, in addition to those listed in Clause 3.1 above.  Lucence may collect, retain, process, use, disclose or transfer your Personal Data for such additional purposes, unless Lucence has specifically notified you otherwise.


  1. Disclosure of Personal Data
  • 4.1 Lucence may disclose or transfer your Personal Data to the following entities or parties for the purposes listed above in Clause 3 where necessary:
    • (a)    amongst Lucence’s affiliates;
    • (b)   doctors, clinics, hospitals and/or medical institutions;
    • (c)    Lucence’s professional advisers such as consultants, auditors and lawyers;
    • (d)   companies providing insurance services to Lucence;
    • (e)    agents, contractors, sub-contractors or third party service providers who provide operational and logistics services to Lucence, such as courier services, telecommunications, information technology, payment, printing, billing, debt recovery, processing, technical services, transportation, training, market research, call centre, security or other services;
    • (f)     vendors or third party service providers and Lucence’s marketing and business partners in connection with its marketing events, promotions, products and services;
    • (g)    external banks, credit card companies, other financial institutions and their respective service providers;
    • (h)   relevant government ministries, regulatory bodies, statutory boards or authorities or law enforcement agencies to comply with any laws, rules, guidelines and regulations or directives imposed by any governmental authority; and/or
    • (i)     any other party to whom you authorise Lucence to disclose your Personal Data to.
  1. Retention of Personal Data
  • 5.1  Lucence shall retain your Personal Data as may be required for its legal or business purposes until such time that Lucence reasonably determines that such Personal Data is no longer necessary for its legal or business purposes.
  • 5.2  Lucence protects and keeps your Personal Data safe by:
    • (a)    only disclosing your Personal Data to such entities or parties listed in Clause 4 above; and
    • (b)   taking reasonable measures to protect your Personal Data from unauthorised access, use or disclosure.
  • 5.3 Lucence is committed to maintaining the confidentiality of your Personal Data, and under no circumstances shall Lucence sell, rent or share your Personal Data with any unrelated third parties.


  1. Use of Lucence’s Website
  • 6.1  When you visit Lucence’s website <>, you generally do so anonymously but the following information is automatically tracked and collected by Lucence:
    • (a)    IP address;
    • (b)   domain server;
    • (c)    type of computer used to access Lucence’s website;
    • (d)   type of web browser used to access Lucence’s website;
    • (e)    the previous website which directed you to Lucence’s website; and
    • (f)     other information associated with the interaction of your browser and Lucence’s website.
  • 6.2  When you visit or interact with Lucence or its authorised service providers’ websites, Lucence or its authorised service providers may use cookies, web beacons and other similar technologies for collecting and storing information to provide you with a better, faster, and safer web experience.
  • 6.3  The information collected by Lucence or its authorised service providers may recognise a visitor as a unique user and may collect information including but not limited to how a visitor arrives at its websites, what kind of browser a visitor is on, what operating system a visitor is using, a visitor’s IP address and a visitor’s click stream information and time stamp (for example, which pages they have viewed, the time the pages were accessed and the time spent per web page).  By visiting or interacting with Lucence or its authorised service providers’ websites, you are deemed to have consented to the collection of the aforesaid information.
  • 6.4  Lucence may use the terms “cookies” or “similar technologies” interchangeably in its policies to refer to all technologies that it may use to collect or store information in your browser or device or that collect information or assist in identifying you as a unique user in the manner described above.
  • 6.5  Lucence offers certain site features and services that are available only through the use of these technologies.  You may block, delete, or disable these technologies if your browser permits.  However, if you decline cookies or other similar technologies, you may not be able to use certain site features or services tools on Lucence’s websites.
  • 6.6  Lucence’s website may contain links to other websites operated by third parties, including but not limited to Lucence’s service providers or business partners.  Lucence shall not be responsible for the data protection practices of such third party websites that are linked to its website.


  1. Withdrawal of Consent, Access and Correction of Personal Data
  • 7.1  You may withdraw your consent for Lucence to use your Personal Data for the purposes listed in Clause 3 above, in accordance with this Clause 7.  Upon receiving such notice from you, Lucence may require up to thirty (30) days to process the withdrawal of your consent and securely dispose your Personal Data.  During this period, Lucence shall be entitled to continue using your Personal Data for the purposes listed in Clause 3 above.  Notwithstanding any withdrawal of consent by you, Lucence may contact you for other purposes in relation to the existing products and/or services that you have requested or purchased from Lucence.
  • 7.2  If you:
    • (a)    have any questions or feedback relating to your Personal Data or this Privacy Policy;
    • (b)   would like to withdraw your consent to use of your Personal Data as set out in this Privacy Policy; or
    • (c)    would like to obtain access and/or make corrections to your Personal Data records,
  • please contact our Data Protection Officer as follows:
    • (a)    Telephone No.: +65 6909 0390
    • (b)   Fax No.: +65 6725 0590
    • (c)    E-mail: [email protected]
    • (d)   Address: 211 Henderson Road, #04-02 Henderson Industrial Park, Singapore 159552
  • 7.3  If your Personal Data has been provided to Lucence by a third party, you should contact that organisation or individual to make such queries, complaints, and access and correction requests to Lucence on your behalf.
  • 7.4  If you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, Lucence may not be in a position to continue to provide its products and services to you, or administer any contractual relationship in place, which in turn may also result in the termination of any agreements with Lucence, and your being in breach of your contractual obligations or undertakings.  Lucence’s legal rights and remedies in such event are expressly reserved.


  1. Indemnity
  • 8.1  You shall indemnify Lucence and its officers, employees, representatives and agents against all actions, claims, demands, losses, damages, expenses and costs arising out of any of your acts, omission or negligence that cause or result in Lucence to be in breach of the PDPA or other applicable laws.


  1. Governing Law
  • 9.1  This Privacy Policy shall be governed by and construed in accordance with the laws of Singapore.


10. GDPR Addendum

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