Privacy Policy

This Privacy Policy sets out how we, Columbia Asia, collect, use and disclose your Personal Data.

1. “Personal Data” means data (such as name, date of birth, gender, photographs, address, email address, telephone numbers, mobile numbers, government-authorised identity card information, financial and bank account details health information or biometric information), whether true or not, about an individual who can be identified from that data, or can be linked with such other data and information in order to identify that individual.

2. By providing us with your Personal Data, you consent to our collection, use, disclosure (including transfer) of your Personal Data in accordance with this Privacy Policy. Please do not provide us with any Personal Data if you do not agree to us using your Personal Data in this manner.

3. We may use “cookies”, where a small data file is sent to your browser to store and track information about you when you use the Platform. The cookie is used to track information such as the number of users, their profiles, frequency of use and preferred sites. While this cookie can tell us when you use the Platform and which pages you visit, it cannot read data off your hard disk or mobile device. You can set your browser to refuse all or some cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the Platform may become inaccessible or not function properly.

4. Collection, use and disclosure of your Personal Data. We may collect, use and disclose the Personal Data received from you for the purposes listed below and any other related or associated purposes (“Purposes”):

(a) Setting up your account with us and managing your use and access of the Platform.

(b) Sending you a one-time password to your mobile phone to verify your identity.

(c) Providing you and/or your Dependant and/or a Third Party with the services or function of the Platform.

(d) Enabling you and/or your Dependant and/or a Third Party to pay outstanding medical bills through the Platform.

(e) Managing you and/or your Dependant’s and/or a Third Party’s relationship with us.

(f) Assisting you and/or your Dependant and/or a Third Party with enquiries from you and/or your Dependant and/or a Third Party.

(g) Obtaining feedback from you and/or your Dependant and/or a Third Party.

(h) Accounting, risk management and record keeping.

(i) Informing you about service upgrades and updates.

(j) Performing network or service enhancement.

(k) Carrying out research, planning and statistical analysis, including satisfaction surveys to improve and personalise our Platform to you and/or your Dependant and/or a Third Party, and develop new products and services.

(l) Personalising our Platform and recommending content related to our services and the health of you and/or your Dependant and/or a Third Party.

(m) Offering you and/or you Dependant and/or a Third Party with rewards and loyalty programmes which you and/or your Dependant and/or Third Party may qualify for; and

(n) Sending you and/or your Dependant and/or Third Party advertisements, information on promotions by our partners and invitations to events.

5. Sharing of your Personal Data. You consent to us sharing your Personal Data with:

(a) External third parties:
  • We may share your Personal Data with our business partners and third parties who perform functions on our behalf and who also provide services to us, including IT service providers, cloud service providers, data storage providers, professional advisors, IT consultants carrying out testing and development work on our business technology systems, and companies that we use to serve you marketing or advertising online.
  • We may also share your Personal Data with third parties to comply with an order under the law for the time being in force; at the request of government authorities conducting an investigation; to verify or enforce our contractual rights or other applicable policies; to detect and protect against fraud, or any technical or security vulnerabilities; to respond to an emergency; or otherwise to protect the rights, property, safety, or security of third parties, visitors to the Platform, our business or the public.

(b) Internal third parties: We also share your Personal Data with Columbia Asia group companies for internal reasons, primarily for business and operational purposes. For example, our medical advisors in Indonesia may obtain health records stored by our group company in Malaysia, or vice versa.

(c) Sale or transfer to third parties: As we continue to develop our business, we may sell or purchase assets. If another entity acquires us or merges with us your Personal Data will be disclosed to such entity. Also, if any bankruptcy or reorganisation proceeding is brought by or against us, all such information will be considered an asset of ours and as such it is possible they will be sold or transferred to third parties.

6. Consent for international transfers. You consent to us transferring your Personal Data out of your country for the Purposes set out above. When we send your Personal Data outside of your country, we will make sure that your information is protected to at least the same standard as that which is required in your country. For example, we will always ensure that there is a proper legal agreement that covers the data transfer.

7. Security measures to protect your Personal Data. We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality.

8. If you have any questions about our privacy policy, you can direct them at compliance.officer@columbiaasia.com if you:

(a) have any enquiries or feedback on this clause as well as our data protection policies and procedures; need more information on or access to data which you have provided to us in the past or if you wish to correct such data; or

(b) wish to withdraw your consent to or limit our collection, use or disclosure of your Personal Data at any time.

9. For India Users Only: We have appointed Sreevathsa C S as our Grievance Officer. If you have any grievances and discrepancies with respect to our processing of your Personal Data, you can contact our Grievance Officer at sreevathsa.cs@columbiaasia.com.