Privacy Policy

Roczen Privacy Policy
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1. Introduction

‏‎Welcome to our Privacy Policy.

Reset Health Malaysia Sdn. Bhd. (Company Registration No.: 202101028076 (1428376-K)) is a company limited by shares incorporated in Malaysia. Our registered address is at Gleneagles Hospital Kuala Lumpur, Block A & Block B, 286 & 288, Jalan Ampang, Kampung Berembang, 50450 Kuala Lumpur, Wilayah Persekutuan Kuala Lumpur.

Roczen is a trading name of Reset Health Malaysia Sdn. Bhd. In this Privacy Policy, we refer to ourselves as "Roczen", "us", "our", or "we".

Roczen is the data controller in relation to your personal data.

We respect your privacy and are committed to protecting your personal data. This Privacy Policy will inform you how and why we collect your personal data, how we look after your personal data, and about your privacy rights and how the law protects you.

This Privacy Policy explains how we collect and process your personal data when you:

visit our website or use Roczen mobile apps;
contact us directly;
use or subscribe to any of our services or products (including attending any pre-treatment or pre-enrolment screenings); and
sign-up to receive updates and newsletters from us.

This website, and the services we offer, are not intended for children. We do not knowingly collect data about children. If you become aware that we may have been given data about a child, please contact us as soon as possible.

It is important that you read this Privacy Policy together with any other privacy policy or privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements other notices and privacy policies and is not intended to override them.

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2. The data we collect about you

‏‎‎Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data: your name, title, address, telephone/mobile number, email address, date of birth and age, and gender;
Financial Data: bank account and payment card details;
Transaction Data: details and records about payments to and from you, including details of products and services that you have purchased from us;

Health Data: body measurements (e.g. weight, height, waist circumference), BMI, blood pressure, disabilities, current illnesses/conditions (e.g. Type 2 Diabetes, high blood pressure, etc), current medications (and dosages), medical information held by your GP/doctor or the NHS in your medical file, dietary and nutritional information, race and ethnicity, information about your psychological wellbeing (including information about psychiatric disorders and conditions, such as, depression, bipolar disease and eating disorders) and information about your physical wellbeing (e.g. lifestyle information, exercise habits, quality of life, personal preferences);
GP Details: contact details (e.g. name, address and phone number) of your GP/doctor.
Video Data: live video call footage (when you participate in a screening, appointment or consultation with one of our healthcare professionals through video call); video call footage of you is only viewed by the relevant Roczen professional during a screening, appointment or consultation in which you are participating, solely for the purpose of conducting that call; we do not record this footage;
Technical Data: internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website;
Profile Data: this includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses;
Usage Data: information about how you use our website, mobile apps, products and services; and
Marketing and Communications Data: your preferences in receiving marketing from us and our third party partners, and your communication preferences.

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We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Health Data with the Health Data of other customers of Roczen in order to better understand Type II Diabetes Mellitus, Metabolic Syndrome and obesity, and how to treat these conditions. This aggregated data may be used in medical publications and research showing the effectiveness of Roczen treatments in different groups and demographics of people. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

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If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

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3. How is your personal data collected?

We use different methods to collect data from and about you including thorough:

‏‎‎a) Direct interactions:

You may give us your Identity Data, Financial Data, Health Data, GP Details, Video Data and Marketing and Communication Data by using our mobile apps, filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

apply for or purchase our products or services;
download and use Roczen’s mobile apps
create an account on our website;
complete any forms or questionnaires;
attend or participate in a screening, consultation or appointment (in person or via video call);
subscribe to our publications or marketing; or
give us feedback or contact us.

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‏‏‎ ‎b) Third parties:

We may obtain your Identity Data, Health Data and GP Details from third parties that have referred you to us or who disclose your information to us, as set out below:

When you are referred to us by your GP/doctor, or other healthcare professional;
Where you provide consent for us to access your Health Data and other information directly from your GP/doctor or other healthcare professional;
Where you are referred to us by one of our corporate partners (e.g. where you are an employee / staff member of the relevant corporate partner, and you have asked that corporate partner to refer you to us); and

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c) Automated technologies and interactions:

As you interact with our website and apps, we will automatically collect Technical Data and Usage Data about your devices, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our Cookie Policy for further details.

Roczen may supplement the information that you provide to us, or which we are given, with information that we receive or obtain from other sources, such as from our professional advisors, partners, and agents of Roczen, third parties with whom we interact, and publicly available sources.

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‏‏‎ 4. Purposes for which we use your personal data

‏‏‎ ‎We have set out below, a description of all the ways we plan to use your personal data and which legal bases we rely on to do so. We have also identified what our legitimate interests are, where appropriate.

Please note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need further details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out, for the purposes below:

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a) To provide you with our products and service

We will process your personal data where you have purchased, or are enquiring about purchasing, our products and services. This is so that we can provide you with the requested product or service, or with the information you have requested about such product or service.

Our services focus mainly on providing metabolic membership programmes designed for people living with obesity, Type 2 Diabetes, and other metabolic syndrome complications. In order to provide these services we will process personal data both (i) during the assessment, triage and diagnostics stages, and thereafter (ii) during the treatment and monitoring stages.

In practice, personal data processing will occur when you use our mobile apps (as explained below), when you provide us with information about yourself as part of pre-treatment assessment and diagnostics, when you allow us to obtain your medical information from your GP or health professional, when you attend screenings, consultations and appointments with one of our professionals, and when you are completing a treatment plan or programme.

We will also process your data for the purposes of (i) managing any payments, fees and charges, and (ii) collecting and recovering monies owed to us.

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Type of data:

Identity
Financial
Transaction
Health
GP Details
Video
Usage

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Lawful basis for processing, including any legitimate interests pursued:

Performance of our contract with you.
Explicit consent (where you provide us with explicit consent to process your Health Data or access your medical records).
Necessary for our legitimate interests (to recover debts due to us).

b) Roczen Mobile Apps

We process information about you when you use our mobile apps. Our apps can be downloaded from the Apple App Store and Google Play store.

Our apps require you to provide information about your health (including your psychological and physical wellbeing). This information is used to assess your suitability for our products and services, to diagnose and inform your treatment, and to monitor progress throughout any treatment programme that you subscribe to.

Type of data:

Identity
Financial
Transaction
Health
Technical
Profile
Usage
Marketing and Communication

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Lawful basis for processing, including any legitimate interests pursued:

Performance of our contract with you.
Explicit Consent (where you provide us with explicit consent to process your Health Data);
Consent (where you use our Apps to opt-in to receive updates and promotional materials form us).

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c) Relationship management

To manage our relationship with you which may include:

communicating with you;
notifying you about changes to our terms and conditions or Privacy Policy; and
asking you to leave a review or take a survey.

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Type of data:

Identity
Profile
Marketing and Communications

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Lawful basis for processing, including any legitimate interests pursued:

Performance of our contract with you.
Necessary to comply with a legal obligation.
Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services).

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d) Administration

To administer and protect our business, this website and our apps (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).

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Type of data:

Identity
Financial
Transaction
Technical
Profile
Usage
Marketing and Communication

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Lawful basis for processing, including any legitimate interests pursued:

Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise);
Necessary to comply with a legal obligation.

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e) Online and social media advertising

Roczen uses third-parties to provide online or electronic ads on our behalf. These third parties use data about your visits to our websites and apps to send you customised ads that may be of interest to you. This information is collected using cookies and other similar technologies by Roczen and our third-party advertising partners in accordance with our Cookie Policy.

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Type of data:

Identity
Profile
Usage
Technical
Marketing and Communication

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Lawful basis for processing, including any legitimate interests pursued:

Consent (when you consent to the use of these cookies on our website and apps)

‏‎ ‎f) Improving our website, apps and products/services

To use data analytics to improve our website, apps, products and services, marketing, customer relationships and experiences.

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Type of data:

Technical
Usage

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Lawful basis for processing, including any legitimate interests pursued:

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy).

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g) Keeping you informed

To make suggestions and recommendations to you about products and services that may be of interest to you.

Please see below for further details on marketing.

Type of data:

Identity
Technical
Usage
Profile
Marketing and Communications

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Lawful basis for processing, including any legitimate interests pursued:

Consent (where you have opted-in to receive updates and promotional materials form us, for example, on our website).
Necessary for our legitimate interests (to develop our products/services and grow our business).
Marketing

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We may use your Identity Data, Technical Data, Usage Data, Profile Data and Marketing and Communication Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which updates, products, services and offers may be relevant for you (we call this marketing).

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You may receive marketing communications from us if you have requested information from us, or subscribed to or purchased products or services from us and you have not opted-out of receiving that marketing. Alternatively, you may receive marketing communications where you have specifically opted-in to receive these (for example, by signing up for updates or newsletters on our website, or by signing up whilst using our apps).

You can ask us to stop sending you marketing at any time by clicking "unsubscribe" on any email marketing sent to you, by changing your preferences in our apps, or alternatively by contacting our Data Protection Officer on the details below.

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

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‏‏‎‎Cookies

You can refuse all non-essential cookies when you visit our website, by clicking the ["Reject"] button on the cookie banner that displays when you visit our website. You can also set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

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Change of purpose

We will only process your personal data for the purposes for which we collect it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

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‏‏‎5. Disclosure of your personal data

‏‎‎We may share your personal data with the third parties set out below, for the purposes set out in Section 4 (Purposes for which we use your personal data) above:

‎where you are purchasing and products or services from us, we may share your personal data with or medical and healthcare professionals (e.g. doctors, nurses, dietitians / nutritionists, and psychologists) where this is necessary in order to provide the products or services to you. This is so they can provide the products or services requested, communicate with you for this purpose, and provide you with feedback and updates on the provision of the products and services (e.g. how you are progressing with your chosen treatment option, and what further actions require to be taken);
we will share your personal data (including Health Data) with EMIS Health, through the clinical management software that we use to access your summary care records. Any data we share will be used by EMIS Health to update your summary care records held by NHS Spine;
vendors who will process your personal data on our behalf and under our written instructions to carry out their services during the course of our business, such as IT service providers, financial institutions, customer relationship management vendors and other cloud-based solutions providers that are used by us in conducting our business. We contract with such vendors to ensure that they only process your personal data under our instructions and ensure the security and confidentiality of your personal data by implementing the appropriate technical and organisational measures for such processing;
our professional advisors (e.g. lawyers and accountants);
third parties to whom we are required to transfer personal data by law, such as law enforcement bodies, governmental and regulatory bodies, the courts and other competent authorities that may request personal data in connection with any inquiry, court order, or other legal or regulatory procedures which we would need to comply with. We may also share personal data to establish or protect our legal rights, property or safety, or the rights, property or safety of others, or to defend against legal claims; and
we may transfer your personal data to third parties, in connection with a reorganisation, restructuring, merger, acquisition, or transfer of our business or assets, provided that the receiving party agrees to treat your personal data in a manner consistent with data protection law.

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6. International transfers

Whilst we store (and endeavour to ensure that our vendors store) your personal data in Malaysia, we may transfer your personal data to organisations located outside of the Malaysia. This is primarily to allow us to receive IT services (e.g. cloud storage services, email/webmail services and customer relationship management services) from vendors located jurisdictions outside of Malaysia. However, we will only transfer your personal data to a vendor outside of Malaysia where:

such countries have been deemed to provide an adequate level of protection for personal data by the Personal Data Protection Department or the relevant authorities in Malaysia or;

where we have in place a valid data transfer agreement with the data recipient; or

where we are otherwise permitted to make the transfer under data protection law.

Please contact us if you would like further information on the specific mechanism used by us when transferring your personal data out of Malaysia.

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7. Data security

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.

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We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

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8. Data retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect of our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

When we no longer need to use your personal data, we will remove it from our systems and records, and or take steps to anonymise it so that you can no longer be identified from it (unless we need to keep your information to comply with legal or regulatory obligations we are subject to).

In some circumstances you can ask us to delete your data (please see "Your legal rights" below for further information).

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9. Your legal rights

Under data protection law, you have certain rights in relation to your personal data:

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Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with applicable law. Please note however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: a) if you want us to establish the data's accuracy; b) where our use of the data is unlawful but you don’t want us to erase it; c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent (including explicit consent) to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

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No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

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What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data, or access someone else's personal data on their behalf (or to exercise any of the other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

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Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

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‍10. Third-party links

‎This website and our mobile apps may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website or apps, we encourage you to read the privacy policy of every website you visit.

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11. Contact us

‎We have appointed a Data Protection Officer who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions in relation to this Privacy Policy, including any requests to exercise your legal rights (or someone else's legal rights on their behalf), please contact the Data Protection Officer using the details below.

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FAO Data Protection Officer
Roczen Limited & Roczen Clinics Limited
83 Baker Street
London
W1U 6AG

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Email: dataprotection@resethealth.clinic

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You also have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would however appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

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12. Keeping your information up to date

‎‎To help Roczen keep accurate information, you must tell the Data Protection Officer about changes to information or personal details relating to you, in particular, any changes to contact or financial details, or to any health information you have provided us with. If you know that Roczen holds any personal details about you that are out of date or inaccurate, you must tell us as soon as possible.

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13. Notification of changes

Roczen may update this Privacy Policy from time to time as our privacy practices change, or as required by applicable legal or regulatory requirements. Where it is practicable, we will notify you of any significant changes. However, the last update date is given at the start of this Privacy Policy, and we encourage you to review this Privacy Policy periodically so you remain informed of how we use your personal data.