Eagle Eye Centre Pte Ltd (“EEC”)
Data Privacy Notice

Overview:

This Data Privacy Notice is applicable to Eagle Eye Centre Pte Ltd’s subsidiary companies in
Singapore including the subsidiary companies which may be established from time to time
(“EEC”).

Your privacy is important to us at EEC. We are committed to handling your Personal Data
under our control with care.

This document serves to inform you of practices at EEC on Personal Data management. You
should read this Data Privacy Notice to know and understand the purposes for which EEC
collect, use and disclose your Personal Data. It supplements any other consents which you
may have previously provided to EEC on your Personal Data.

From time to time, we may update/amend this Data Privacy Notice to be consistent
with EEC’S internal practices and to stay abreast with future developments in the industry
and/ or changes in legal and regulatory requirements without prior notice. All your
interactions with EEC shall be subject to the latest version of the Data Privacy Notice in force
at the relevant time.

By continuing to communicate with EEC or by continuing to use EEC’s services following the
modifications, updates or amendments to this Data Privacy Notice, such action shall signify
your acceptance of such modifications.

1. Personal Data

In this Data Privacy Notice, “Personal Data” 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 EEC have or are likely to have access, including data in our records as
may be updated from time to time .For the context of this Data Privacy Notice, examples of such
Personal Data you may provide, include (depending on the nature of your interaction with us)
your name, NRIC, passport or other identification number, telephone number(s), mailing address,
email address and any other information relating to any individuals which you have provided to EEC
in any forms you may have submitted, or via other forms of interaction with you.

2. Collection of Personal Data

In this Data Privacy Notice, “Personal Data” 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 EEC has or is likely to have access, including data in EEC’s records as may be
updated from time to time.

2.1 Generally, EEC collects Personal Data in the following ways:

a) when you submit any form, including but not limited to customer inquiry forms or
other forms relating to any of EEC’s services;
b) when you enter into any agreement or provide other documentation or information
in respect of your interactions with us, or when you use EEC’s services;
c) when you interact with EEC’s staff, including customer service officers, for example,
via telephone calls (which may be recorded), letters, fax, face-to-face meetings, social
media platforms and emails;
d) when you interact with EEC via our websites or use services on EEC’s websites;
e) when you request to be contacted or request that you be included in an email or other
mailing list;
f) when you respond to EEC’s promotions, initiatives or to any request for additional
Personal Data;
g) when you submit an employment application or when you provide documents or
information including your resume and/or CVs in connection with any appointment as
an officer, director, representative or any other position;
h) when your images are captured via CCTV cameras while you are within EEC’s premises,
or via photographs or videos taken by EEC or its representatives when you attend
EEC’s events;
i) when you are contacted by, and respond to, EEC’s marketing representatives and
customer service officers;
j) when EEC seeks information about you and receives your Personal Data in connection
with your relationship with EEC, including for EEC’s products and services or job
applications, for example, from business partners, public agencies, your ex-employer,
referral intermediaries and the relevant authorities;
k) when you registered with EEC as a patient, employee, business associate and other
related party; and/or
l) when you submit your Personal Data to EEC for any other reasons.

2.2 When you browse EEC’s website, you generally do so anonymously but please see
paragraph (6) below for information on cookies and other technologies which we
have implemented on EEC website(s).

2.3 If you provide any Personal Data relating to a third party (e.g. information of your
spouse, children, parents, and/or employees), by submitting such information to EEC, you
represent that you have obtained the consent of the third party to provide EEC with their
Personal Data for the respective purposes.

2.4 You should ensure that all Personal Data submitted to us is complete, accurate, true and
correct. Failure on your part to do so may result in EEC’s inability to provide you with the
products and services you have requested, or delays in providing you with products and
services you have requested, or processing your applications.

3. Purposes for the Collection, Use, Process and Disclosure of Your Personal Data
3.1 Generally, EEC collects, uses and discloses your Personal Data for the following purposes:
a) If you are a prospective, current or former patient or customer of EEC:

i. providing customer service and support (including but not limited to customer
relationship management, processing your admissions, processing and
settlement of bills, facilitating, arranging and providing reminders of your
appointments, medical examinations, screenings or check-ups, applying for
visas on your behalf, contacting you regarding medical reports and results,
providing follow-up calls, providing you with administrative support, and
administering insurance coverage and processing insurance claims);
ii. administering and processing your requests including creating and maintaining
profiles of EEC’s customers in EEC’s system database for administrative
purposes (including tracking your attendance at various EEC facilities and/or
events);
iii. personalising your experience at EEC’s various touchpoints and conducting
market research, understanding and analysing customer behaviour, location,
preferences and demographics in order to improve EEC’s service offerings;
iv. administering medical care (including keeping patient case and procedure
records, providing medication, ordering medical tests, reports and biological
samples;
v. liaising with third party specialist doctors, clinics, hospitals and/or medical
institutions in relation to your medical care (including by providing them with
access to your medical records);
vi. if you use EEC’s mobile applications or online registration and payments
systems, displaying your medical data, sending you health-related notifications,
and facilitating the provision of EEC services to you;
vii. if you use EEC’s tele-consultation services, you will be referred to the TeleConsultation
Privacy Policy for further information on how your Personal Data may be used;
viii. administering debt recovery and debt management;
ix. disclosing of your Personal Data whenever and to whomever the law or a court
order may require;
x. disclosing of your Personal Data to EEC’s suppliers/vendors if it is required by
the law and/or authorities that the end-user consuming the
medicine/drug/equipment must be recorded or if it is required for them to
carry out their duties;
xi. enabling a response to a request for Personal Data which may include your
Personal Data, in compliance with the Personal Data Protection Act 2012 and
its regulations; and/or
xii. any other purposes which are reasonably related to the aforesaid.

b) If you are a nominated caregiver or next-of-kin of a patient or customer of EEC:

i. informing you of the patient’s medical status and whereabouts;
ii. the disclosing of your Personal Data whenever and to whomever the law or a
court order may require; and/or
iii. any other purposes which are reasonably related to the aforesaid.

c) If you are an employee, officer or owner of an external service provider or vendor
outsourced or prospected by EEC:

i. assessing your organisation’s suitability as an external service provider or
vendor for EEC;
ii. managing project tenders and quotations, processing orders or managing the
supply of goods and services;
iii. creating and maintaining profiles of EEC’s service providers and vendors in
EEC’s system database;
iv. processing and payment of vendor invoices and bills;
v. managing facilities (including but not limited to issuing visitor access passes
and facilitating security clearance);
vi. disclosing your Personal Data whenever and to whomever the law or a court
order may require;
vii. administering debt recovery and debt management; and/or
viii. any other purposes which are reasonably related to the aforesaid.

ci) If you submit an application to EEC as a candidate for employment, internships or
scholarships:

i. conducting interviews;
ii. processing your application (including but not limited to pre-recruitment
checks involving your qualifications and facilitating interviews);
iii. obtaining references and for background screening;
iv. assessing your suitability for the position applied for;
v. enrolling successful candidates as EEC’s employees and facilitating human
resource planning and management (including but not limited to preparing
letters of employment, name cards and building access passes); and/or
vi. any other purposes which are reasonably related to the aforesaid.

cii) If you are an existing employee of EEC:

i. providing remuneration, reviewing salaries and bonuses, conducting salary
benchmarking reviews, staff appraisals and evaluation, as well as recognising
individuals for their services and conferring awards;
ii. staff orientation and entry processing;
iii. administrative and support processes relating to your employment, including
its management and termination, as well as staff benefits, including travel,
manpower, business continuity and logistics management or support,
processing expense claims, medical insurance applications, medical screenings
and immunisations, leave administration, long-term incentive plans, training,
learning and talent development, and planning and organising corporate
events;
iv. providing you with tools and/or facilities to enable or facilitate the
performance of your duties;
v. facilitating professional accreditation and complying with compliance audits;
vi. compiling and publishing internal directories and emergency contact lists for
business continuity;
vii. managing corporate social responsibility projects;
viii. conducting analytics and research for human resource planning and
management, and for EEC to review, develop, optimise and improve
work-related practices, environment and productivity;
ix. ensuring that our administrative and business operations function in a secure,
efficient and effective manner (including but not limited to examining or
monitoring any computer software and/or hardware installed within EEC’s
premises and facilities, your work emails and personal digital and storage
devices);
x. compliance with any applicable rules, laws and regulations, codes of practice
or guidelines or to assist in law enforcement and investigations by relevant
authorities (including but not limited to disclosures to regulatory bodies,
conducting audit checks or surveillance and investigation);
xi. administering cessation processes;
xii. disclosing your Personal Data whenever and to whomever the law or a court
order may require;
xiii. administering debt recovery and debt management; and/or
xiv. any other purposes which are reasonably related to the aforesaid.

3.2 Furthermore, where permitted under Personal Data Protection Act 2012, EEC may also
collect, use and disclose your Personal Data for the following “Additional Purposes”:

a) taking or filming photographs and videos for corporate publicity or marketing
purposes, and featuring your photographs and/or testimonials in EEC’s articles and
publicity materials;
b) providing or marketing services and benefits to you, including promotions, service
upgrades, loyalty, reward and/or membership programmes and sending of
healthcare-related updates, event invitations, newsletters and marketing and
promotional information to you;
c) organising roadshows, tours, campaigns (including health check or vaccination
campaigns) and promotional or events and administering contests and competitions;
d) matching your Personal Data with other data collected for other purposes and from
other sources (including third parties) in connection with the provision or offering of
services;
e) sending you details of services, clinic updates, health-related information and rewards,
either to EEC’s customers generally, or which have been identified may be of interest
to you;
f) conducting market research, aggregating and analysing customer profiles and data to
determine health-related patterns and trends, understanding and analysing customer
behaviour, location, preferences and demographics for EEC to offer you other
products and services as well as special offers and marketing programmes which may
be relevant to your preferences and profile; and/or
g) any other purposes which are reasonably related to the aforesaid.

3.3 If you have provided us with your Singapore telephone number(s)and/or email address(es)
(collectively “contact details”) and have indicated that you consent to receiving marketing or
promotional information via your contact details, then from time to time, EEC may contact
you using such contact details(including via voice calls, text, fax, email or other means) with
information about EEC’s products and services.

3.4 In relation to particular services or in your interactions with EEC, you may also have been
specifically notified of other purposes for which EEC collects, uses or discloses your Personal
Data. If so, EEC will collect, use and disclose your Personal Data for these additional purposes
as well, unless you have been specifically notified otherwise.

3.5 You have a choice to withdraw your consent for receiving marketing or promotional
materials/communication. You may contact us using the contact details found in paragraph
(8) below.

3.6 Please be aware that once EEC receives written notification that you wish to withdraw
your consent for marketing or promotional materials/communication, it may take up to 21
calendar days for your withdrawal to be reflected in EEC’s systems. Therefore, you may still
receive marketing or promotional materials/communication during this period of time.

3.7 Please note that even if you withdraw your consent for the receipt of marketing or
promotional materials, you may still be contacted for other purposes in relation to the
services that you have requested or purchased from EEC.

4. Disclosure of Personal Data
4.1 EEC will take reasonable steps to protect your Personal Data against unauthorised
disclosure. Subject to the provisions of any applicable law, your Personal Data may be
disclosed, for the purposes listed above (where applicable), to the following entities or parties,
whether they are located overseas or in Singapore:

a) amongst the EEC Group members and affiliates (including their staff and medical /
dental/ traditional and complementary medicine practitioners, registered nurses or
other healthcare staff engaged or referred to for the provision of healthcare services)
in accordance with applicable law;
b) third party medical/dental practitioners, clinics, hospitals and/or medical institutions;
c) companies providing services relating to insurance to EEC;
d) agents, contractors, sub-contractors or third party service providers who provide
operational services to EEC, such as courier services, telecommunications,
information technology, payment, printing, billing, debt recovery, processing,
technical services, transportation, training, market research, call centre, security, third party
administratoror other services to EEC;
e) vendors or third party service providers and marketing and business partners of EEC
in connection with marketing promotions, products and services;
f) EEC’s corporate clients;
g) any business partner, investor, assignee or transferee (actual or prospective) to
facilitate business asset transactions (which may extend to any merger, acquisition or asset
sale);
h) external banks, credit card companies, other financial institutions and their respective
service providers;
i) EEC’s professional advisers such as consultants, auditors and lawyers;
j) third party insurers, employers of patients, guarantors and/or credit reporting
agencies/credit data management company;
k) relevant government ministries, regulators, statutory boards or authorities or law
enforcement agencies to comply with any laws, rules, guidelines and regulations or
schemes imposed by any governmental authority (including the Ministry of Health);
l) in connection with a corporate transaction, such as merger, consolidation, or in the
unlikely event of winding up;and/or
m) any other party to whom you authorise us to disclose your Personal Data.

4.2 As far as permitted by the laws of Singapore, EEC will not be responsible for any
unauthorised use of your Personal Data by third parties which are wholly attributable to
factors beyond the control of EEC.

5. Retention of Personal Data
5.1 EEC retains such Personal Data as may be required for business or legal purposes, and
such purposes do vary according to the circumstances.

5.2 Whilst EEC will securely dispose of or anonymise Personal Data which it can reasonably
determine is no longer needed and does not generally hold on to Personal Data “just in case”,
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.

5.3 With respect to the medical records of patients, unless specific contrary instructions from
the patient are received, EEC may (but is not obliged to) retain such medical records for as
long as EEC may be potentially consulted for further follow up by (or on behalf of) the
patient even where such consultation may not occur until after a substantial period of time
or there is no current or present indication that the patient may well return for further
consultation or follow up.In addition, EEC will retain Personal Data relating to claims for a
period deemed necessary due to regulatory requirements.

6. Use of Cookies, Web Beacons, and Similar Technologies on the website
6.1 When you visit or interact with EEC’s sites and services, EEC or EEC’s authorized service
providers may use cookies, web beacons, and other similar technologies for collecting and
storing information to help provide you with a better, faster, and safer web experience.

6.2 The information collected by EEC or EEC’s authorised service providers may recognise a
visitor as a unique user and may collect information such as how a visitor arrives at EEC’s
sites, 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).

6.3 The use of cookies, web beacons and similar technologies by EEC on the website(s) has
different functions. They are either necessary for the functioning of EEC’s services, help in
improvement of EEC’s performance, or serve to provide you with extra functionalities. They
may also be used to deliver content that is more relevant to you and your interests, or to
target advertising to you on or off EEC’s sites.

Cookies – Small text files (typically made up of letters and numbers) placed in the memory of
your browser or device when you visit a website or view a message. Cookies allow a website
to recognize a particular device or browser. There are several types of cookies:

• Session cookies expire at the end of your browser session and allow EEC to link your
  actions during that particular browser session.
• Persistent cookies are stored on your device in between browser sessions, allowing us
  to remember your preferences or actions across multiple sites.
• First-party cookies are set by the site you are visiting
• Third-party cookies are set by a third party site separate from the site you are visiting.

Cookies can be disabled or removed by tools that are available in most commercial browsers.
The preferences for each browser you use will need to be set separately and different
browsers offer different functionality and options.

Web beacons – Small graphic images (also known as “pixel tags” or “clear GIFs”) may be
included on our sites and services. Web beacons typically work in conjunction with cookies to
profile each unique user and user behaviour.

Similar technologies – Technologies that store information in your browser or device utilizing
local shared objects or local storage, such as flash cookies, HTML 5 cookies, and other web
application software methods. These technologies can operate across all of your browsers.
Similar technologies – Technologies that store information in your browser or device utilizing
local shared objects or local storage, such as flash cookies, HTML 5 cookies, and other web
application software methods. These technologies can operate across all of your browsers.

6.4 EEC offers certain site features and services that are available only through the use of
these technologies. You are always free to block, delete, or disable these technologies if your
browser so permits. However, if you decline cookies or other similar technologies, you may
not be able to take advantage of certain site features or services tools. For more information
on how you can block, delete, or disable these technologies, please review your browser
settings.

7. Third-Party Sites
EEC’s website(s) may contain links to other websites operated by third parties, including for
example business partners of EEC. EEC will not be responsible for the data protection
practices of websites operated by third parties that are linked to EEC’s website(s). You are
encouraged to learn about the data protection practices of such third party websites. Some
of these third party websites may be co-branded with EEC’s logo or trade mark, even though
they are not operated or maintained by EEC. Once you have left EEC’s website(s), you should
check the applicable Data Privacy Notice/Policy of the third party website to determine how
they will handle any information they collect from you.

8. Contacting Us – Withdrawal of Consent, Access and Correction of your Personal Data 8.1
If you:

a) have any questions or feedback relating to your Personal Data or this Data Privacy
Notice;
b) would like to withdraw your consent to any use of your Personal Data as set out in this
Data Privacy Notice;
c) would like to obtain access and make corrections to your Personal Data records; or
d) would like to lodge a complaint regarding the collection, use, process and disclosure
of your Personal Data;

Please contact us as follows:

• • Call: +65 64651000
  • Email:email@eagleeyecentre.com.sg
  • Write to our Data Protection Officer at:
    Eagle Eye Centre Pte Ltd
    159 Sin Ming Road,
    #05-07, Lobby 2 Amtech Building,
    Singapore 575625

8.2 Please note that it may take up to 21 calendar days for the requested changes under
paragraph 8.1 above to be reflected in EEC’s systems. Also, a minimal fee may be charged to
attend to any data access requests as permitted by the relevant applicable personal data
protection laws.

8.3 Please note that if your Personal Data has been provided to us by a third party (e.g. a
general practitioner or your employer), you should contact that organisation or individual to
make such queries, complaints, and access and correction requests to EEC on your behalf.

8.4 If you withdraw your consent to any or all use of your Personal Data, depending on the
nature of your request, EEC 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 EEC, and your being in breach of your
contractual obligations or undertakings. EEC’s legal rights and remedies in such event are
expressly reserved.

8.5 Unless notice of your withdrawal of consent is received by EEC as described in this
paragraph, EEC reserves the right to assume that you consent and agree to the trems set out
in this Notice.

9. Transfer of Personal Data
Your Personal Data may be transferred to, stored, used and processed in a jurisdiction other
than Singapore, in order that EEC can duly perform the agreed services and fulfill its
contratual obligations with you. In such case, EEC shall ensure that the recipient organisation
is obliged to comply with a standard of protection which is comparable to the protection
required under the Singapore Personal Data Protection Act 2012.

10. Governing Law
10.1 This Data Privacy Notice shall be governed in all respects by the laws of Singapore .

Date: 25th Mar 2022