Privacy policy


This Privacy Policy is issued subject to and pursuant to the Applicable Legislation and explains how Halza Pte Ltd (“Halza” or “us”) collects, uses, discloses, and protects information coming from the different types of Users on its Solution.

This Privacy Policy supplements but does not supersede nor replace any other consents you may have previously provided to Halza in respect of your Personal Data, and your consents herein are additional to any rights which to Halza may have at law to collect, use or disclose your Personal Data.

Halza may from time to time update this Privacy Policy to ensure that this Privacy Policy is consistent with future developments or any changes in legal or regulatory requirements. Subject to your rights at law, you agree to be bound by the prevailing terms of the Privacy Policy as updated from time to time on our website at: https://www.halza.com/privacy

This Privacy Policy is incorporated into and forms part of the End-User Licence Agreement (“EULA”), accessible at https://www.halza.com/en/terms . To the extent that these terms are inconsistent with the EULA, these terms shall prevail. All capitalised terms used (but not expressly defined) in this Privacy Policy shall have the same meanings ascribed to them in the EULA.

  1. Definitions and Interpretation – In this Privacy Policy, the following terms shall be taken to mean the following:

    In this Privacy Policy, unless the context otherwise requires, headings are used for ease of reference only and do not affect the interpretation of these terms;

  2. Types of Personal Data – Personal Data, which includes but is not limited to – (i) personal information that links back to an individual e.g., name, gender, date of birth, passport or other personal identification numbers, images, photographs, videos, voice recordings; (ii) contact information e.g., address, phone number, email address; (iii) payment information e.g., credit or debit card information, including the name of cardholder, card number, billing address and expiry date; (iv) health information e.g., medical records or requests; (v) technical information e.g., IP address

  3. Consent – Generally, in the course of Halza performing her contractual obligations included in the EULA, Personal Data will, by nature of the task or transaction, be provided by our Users, Subscribers, Proxy, Follower or Medical Professionals. In such instances, consent will necessarily be implied from them that they are agreeable to providing Personal Data in order for Halza to provide the requested or necessary service and/or product to them. However, where required by law, Halza will adopt an ‘opt-in’ policy for obtaining your consent, in which event, express written consent will be sought from you when collecting your Personal Data e.g., signing a form or checking a box. Should you submit Personal Data from other individuals as part of your usage of the Solution, you undertake and will ensure that the individual whose Personal Data is supplied to Halza, has authorized the disclosure, is informed and consents to the terms and conditions of this Privacy Policy.

  4. Rights to collect, use and disclose your Personal Data – By using the Solution, you consent to us using and/or disclosing Personal Data submitted through the various Solutions for the following purposes:

    For all Users / Clinic employees:


    Where you are a Subscriber:


    Where you are a Proxy or Verifying Party (or designated as one):


    Where you are a Follower:


    Where you are a Medical Professional:


    Where you are a Concierge:

    By interacting with us, or by using or submitting information to the Solution, Halza, as well as their respective agents and authorized representatives involved in the operation of the Solution (collectively, “our”, “ourselves” or “us”) may also use, collect, disclose and share your Personal Data with and to relevant third parties in order to fulfil the purposes listed above. In connection with the above, we may, from time to time, collect, disclose, transfer, and jointly use your Personal Data to and with our subsidiaries and affiliated companies.

    Halza shall use its best endeavours to ensure that its employees, officers, agents, consultants, contractors and such other third parties mentioned above who are involved in the collection, use and disclosure of Personal Data will observe and adhere to the terms of this Privacy Policy

    In addition, Halza may disclose Personal Data to our legal advisors for establishing, exercising or defending our legal rights, to our other professional advisors, or as otherwise authorised or required by law. Halza also reserves the right to share Personal Data as is necessary to prevent a threat to the life, health or security of an individual or corporate entities such as Halza. Further, Halza may disclose Personal Data, as is necessary, to investigate suspected unlawful activities including but not limited to fraud, intellectual property infringement or privacy.

  5. User statistics – User statistics gathered from the use of the Solution will be aggregated and anonymized, such that no individual can be identified or recognized from the statistics in question. You acknowledge that such statistics obtained through the use of the Solution is not Personal Data, and that Halza has the right to share and disclose such anonymized statistics with third

  6. Google Analyticsis a web analysis service provided by Google. Google utilizes the data collected to track and examine the use of the Solution, to prepare reports on its activities and share them with other Google services. Google may use the data collected to contextualize and personalize the ads of its own advertising network.

  7. Your obligations to ensure security & confidentiality– You are solely responsible for maintaining the security and confidentiality of your own Personal Data (including, without limitation any user name and password or other means used to authenticate your identity or instructions or request made through this Solution or in connection with this Privacy Policy) and where this Solution is installed on your personal device, you agree that you will safeguard the access to the use of the Solution on your device by deploying security measures such as device passwords or PINs.

  8. Processing principles – Halza processes Personal Data in line with Applicable Legislation, Data Protection Laws and in accordance with the following data protection principles:


  9. Transfers of your Personal Data / Data export– The Halza head office is based in Singapore. In submitting your Personal Data to us, the Personal Data may be transferred / exported to territories outside of your location for the purposes of data storage and processing by Data Intermediaries. We endeavour, in doing so, and in each instance in accordance with Data Protection Laws, and require such Data Intermediaries to comply with all Data Protection Laws and to provide an equivalent standard of protection for such Personal Data as such Personal Data would have received had the Personal Data remained in

  10. Inactive / Suspended / Terminated Accounts– Where your account has been suspended or terminated for any reason whatsoever in accordance with the EULA, Halza has the right to close a Subscriber’s account and permanently delete (in accordance with its security and data retention procedures) any Personal Data stored or linked to a Subscriber’s account.

  11. Queries concerning your Personal Data – If you have any queries, comments or instructions relating to your Personal Data or this Privacy Policy, or would like to withdraw your consent or make any access or correction requests, please direct them to our data protection officer at the following addresses:

    Email: dpo@www.halza.com

    If you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, Halza may not be in a position to continue to provide its products or services to you, administer any contractual relationship in place, may be considered a termination by you of any contractual relationship which you may have with Halza, and your being in breach of your contractual obligations or undertakings, and Halza’s legal rights and remedies in such event are expressly reserved.

    Updated on 10/01/2020