PRIVACY AND DATA PROTECTION POLICY ("PRIVACY POLICY")

This Privacy Policy sets out the basis on which Doctor Anywhere Pte. Ltd. and our related companies ("DA", "we", "us", or "our") may collect, use, disclose or otherwise process your personal data when you use our website at http://doctoranywhere.com, https://marketplace.doctoranywhere.com, https://soda.insure or https://provider.da-care.com (collectively, "Website") and/or the Doctor Anywhere mobile applications ("Application") , visit any of the clinics owned or operated by DA and/or participate in any health screenings, vaccinations or any other programmes, activities or events which DA organises, sponsors or is otherwise involved in, or otherwise use any services provided by DA (collectively, "Platforms") in accordance with the Personal Data Protection Act 2012 ("PDPA"). This Privacy Policy applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose or process personal data for our purposes.

If you do not agree to this Privacy Policy and our Terms and Conditions, please do not use any of the Platforms. By communicating, engaging with DA or using our products or services, you acknowledge that you have read and understood this Privacy Policy and agree and consent to the use, processing, disclosure and transfer of your personal data by DA as described in this Privacy Policy.

Where you access, register for or use any of the Platforms, or provide personal data to us, duly authorised to act on behalf of an organisation (including your employer, or any entity, association or group (an "Organisation") whose employee, member or other individuals are covered collectively under that Organisation's arrangement, or policy with us (each, a "Member"), (a) all references to "you" or "your" in this Privacy Policy shall be read as referring to each Member; and (b) the Organisation shall procure that each Member is made aware of, acknowledges and consents to the collection, use, disclosure and processing of their personal data in accordance with this Privacy Policy.

PERSONAL DATA

• 1. As used in this Privacy Policy:

"customer" means an individual who (a) has contacted us through any means (such as through any of the Platforms) in relation to the goods or services available on the Platforms, or (b) may, or has, entered into a contract with us for the supply of any goods or services by us.

"personal data" means 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 we have or are likely to have access.

• 2. Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include:

• a. Personally-identifiable information that you or your Authorised Representative provide to us including your name, identification numbers such as NRIC, Passport Number, FIN, residential address, email address, telephone number, nationality, gender and date of birth;

• b. Personally-identifiable medical and health-related information which you provide to us (including information or records relating to your medical or health history, medical claims, health status, laboratory testing results, diagnostic images, photographs);

• c. Personally-identifiable medical and health information about you prepared by healthcare professionals/treatment providers/diagnostic and medical laboratories or such other third party who provide services and products to you via the Platforms (including medical records, treatment and examination notes, laboratory testing results or diagnostic images);

• d. Billing information that you provide us (e.g. credit card or online payment system account information);

• e. Information about the computer or mobile device you are using;

• f. Geographical location or address; or

• g. Other information which you may input into the Platforms or related services.

• 3. Other terms used in this Privacy Policy shall have the meanings given to them in the PDPA (where the context so permits).

COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA

• 4. We generally do not collect your personal data unless (a) it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your personal data to us (your "Authorised Representative", which could include your employer or your insurer if they process your claims for medical care and any clinicians, specialists, diagnostic and medical laboratories and other healthcare professionals and providers involved in your medical care or such other persons engaged by you) for the purposes set out in this Privacy Policy, or (b) collection and use of personal data without consent is permitted or required by the PDPA or other laws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorised by law).

• 5. You shall accept and consent, (and shall procure that each Authorised Representative) to our collection and use of your Personal Data for purposes set out in this Privacy Policy. You agree to grant us the right to verify the legitimacy of consent for sensitive data such as medical reports, provided by You or your Authorised Representatives. You further agree that we reserve the right to suspend or cease to process any such Personal Data if there are reasonable grounds to believe it was provided without proper consent or valid authorisation from you or Authorised Representative with the associated liability for any breach stemming from such invalid provision resting solely with You.

• 6. We may collect and use your personal data for any or all of the following purposes:

• a. performing obligations in the course of or in connection with our provision of the goods and/or services requested by you (including the provision of any medical or healthcare services, the delivery of products purchased by you);

• b. verifying your identity;

• c. responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;

• d. managing your relationship with us;

• e. processing or facilitating the processing of your claims;

• f. processing payment or credit transactions;

• g. improving the quality of medical or healthcare services through the performance of quality reviews and similar activities;

• h. creating de-identified information which is information which is not used or intended to be used to personally identify an individual (e.g. aggregate statistics relating to the use of the services on the Platforms);

• i. developing, training, testing, validating, operating and improving our products, services, systems, processes, algorithms and machine learning and artificial intelligence models ("AI Systems"), including to improve the quality, accuracy, safety and functionality of the Platforms and the services offered on them;

• j. notifying you when Platform updates are available;

• k. marketing and promoting the Platforms, and the services and products offered on the Platforms to you;

• l. conveying operational updates, health and wellness information to you;

• m. complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;

• n. converting the personal data to anonymised data for the purposes of analytics and market research;

• o. any other purposes for which you have provided the information;

• p. transmitting to any unaffiliated third parties including our third party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes; and

• q. any other incidental business purposes related to or in connection with the above.

In the event we do contact you for any of the above purposes, you agree that we may contact you via email or text or by call at your email address or telephone number provided to us by you or your Authorised Representative.

• 7. We may rely on the permitted exception under the PDPA to collect, use and disclose personal data without your consent including but not limited to the "legitimate interests" exception for the purposes of detecting and preventing fraud and misuse of our services. Such disclosures may be made to your insurer or your employer, where relevant for such purposes.

• 8. Collection, Use & Disclosure of Images: Without prejudice to any other provision of this Privacy Policy, please note that the Platforms may collect certain images such as diagnostic images or photographs or images of claims-related documents. Such images may be collected when you upload such images on the Platforms or are provided by relevant third parties. We will only use the images for the purposes as set out in Clause 6 above, such as processing or facilitating the processing of your claims. Such images may also be disclosed to our subsidiaries, related companies, affiliates, partners or other relevant parties in accordance with Clause 11 below and will be retained in accordance with our retention policy as set out below.

• 9. Giving Consent on behalf of Dependents: Where applicable, you agree and confirm that you have the requisite authority and can validly give consent on behalf of your dependents for the collection, use, disclosure and processing of their personal data, including but not limited to, the personal data of any child/ward under your care or custody.

• 10. As you use the Platforms, its services, or purchase or arrange for the delivery of products, certain information may be passively collected:

• a. Site Activity Information: We may keep track of some of the actions you take on the Platforms, such as the content of searches you perform;

• b. Access Device and Browser Information: When you access the Website from a computer or other device, we may collect anonymous information from that device, such as your Internet protocol address, browser type, connection speed and access times;

• c. Cookies (i.e. small pieces of information that a site sends to your browser while you are viewing a website): We may use both session Cookies (which expire once you close your web browser) and persistent Cookies to make the Website and services easier to use, to improve our algorithm for personalization and show you advertisements tailored to your interests and preferences, and to protect both you and DA. You can instruct your browser, by changing its options, to stop accepting Cookies or to prompt you before accepting a Cookie from the websites you visit. If you do not accept Cookies, however, you will not be able to stay logged in to the Website.

• d. Real-Time Location: Certain features of the Platforms use GPS technology to collect real-time information about the location of your device so that the Platforms can connect you to a healthcare professional/treatment provider near your location.

• e. Device information: We may also collect non-personal information from your mobile device or computer. This information is generally used to help us deliver the most relevant information to you. Examples of information that may be collected and used include how you use the application(s) and information about the type of device or computer you use. In addition, in the event our application(s) crashes on your mobile device we will receive information about your mobile device model software version and device carrier, which allows us to identify and fix bugs and otherwise improve the performance of our application(s).

• f. Web Analytics: We may use Google Analytics to help analyse how users use the Platforms. Google Analytics uses Cookies to collect information such as how often users visit the Platforms, what pages they visit, and what other sites they used prior to coming to the Platforms. We use the information we get from Google Analytics only to improve our Platforms and services. Google Analytics collects only the IP address assigned to you on the date you visit the Platforms, rather than your name or other personally identifying information. Although Google Analytics plants a persistent Cookie on your web browser to identify you as a unique user the next time you visit the Platforms, the Cookie cannot be used by anyone but Google. Google's ability to use and share information collected by Google Analytics about your visits to the Platforms is restricted by the Google Analytics Terms of Use and the Google Privacy Policy.

• 11. We may disclose your personal data where: (i) such disclosure is required for performing obligations in the course of or in connection with our provision of the goods and services requested by you; or (ii) for any of the purposes described in clause 6 above:

• a. To our subsidiaries, related companies, affiliates, or partners;

• b. To the relevant parties who may process your claims for your medical care (which may include your employer or your insurer if you are making claims under your employee or insurance benefits scheme or policy). In such circumstances, we may disclose your medical diagnosis/information to such parties for the purposes of claims processing and/or verification of utilisation, if required by such parties;

• c. To contractors (including specialists, diagnostic and medical laboratories and other healthcare providers), service providers and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them (including logistics service providers, data service providers);

• d. As required by law, which can include providing information as required by a court order;

• e. When we believe in good faith that disclosure is necessary to protect your safety or the safety of others, to protect our rights, to investigate fraud, or to respond to a government request;

• f. To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of DA's assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal data maintained on the Platforms is among the assets transferred;

• g. To any other person or organisation disclosed by us when you provide the information.

• 12. The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to your employment contract should you be hired) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under a contract with you).

• 13. This Privacy Policy applies only to information we collect through the Platforms and in email, text and other electronic communications sent through or in connection with the Platforms. This policy does not apply to information collected by any third party. When you click on links on the Platforms, you may leave our site. We are not responsible for the privacy practices of other sites, and we encourage you to read their privacy statements.

• 14. In the event that we collect and convert your personal data (particularly for sensitive medical and health related records) to anonymised data for the purposes of analytics, research, market research, and the development, training, testing, validation and improvement of our AI Systems, the Platforms and our internal processes, we undertake to adhere to recognised industry standards, best practices or specific methodologies to effectively minimise the risk of re-identification.

• 15. In the event that we disclose your personal data to contractors, service providers and other third parties under clause 11.c above, especially if such entities handle your medical and other sensitive personal data, we will ensure that agreements are in place with such third parties to hold them to data protection and security standards comparable to those required by the PDPA including breach notification requirements in the event of any security incident and to grant us the right to conduct audits or obtain verifiable assurances of their compliance.

WITHDRAWING YOUR CONSENT

• 16. The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop collecting, using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.

• 17. Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within ten (10) business days of receiving it.

• 18. Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our goods or services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in clause 16 above.

• 19. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws. For the avoidance of doubt, such withdrawal of consent shall not require us to delete any personal data that has already been collected by us from our records. Such retention shall be subject to clauses 27 to 29 below.

ACCESS TO AND CORRECTION OF PERSONAL DATA

• 20. If you wish to make (a) an access request for access to a copy of the personal data which you provided or information about the ways in which we use or disclose your personal data, or (b) a correction request to correct or update any of your personal data which we hold about you, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below. Such request shall be made in the prescribed form which we will provide, and shall include the details of the requestor, description of the personal data being requested or requiring correction and the date and time range the personal data was believed to be collected.

• 21. Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.

• 22. We will respond to your request as soon as reasonably possible. In general, our response will be within fourteen (14) business days. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).

PROTECTION OF PERSONAL DATA

• 23. To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures and privacy enhancing technologies such as up-to-date antivirus protection, encryption, and disclosing personal data both internally and to our authorised third party service providers and agents only on a need-to-know basis.

• 24. You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your personal data and are constantly reviewing and enhancing our information security measures.

• 25. In the event of a data breach incident (as defined in the PDPA), we shall comply with all applicable data breach notification obligations under the PDPA including requirements to detect, assess and to report qualifying data breaches to the relevant authorities and to you (where applicable) without undue delay.

ACCURACY OF PERSONAL DATA

• 26. We generally rely on personal data provided by you (or your Authorised Representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided below.

ACCOUNT DELETION & RETENTION OF PERSONAL DATA

• 27. If you wish to delete your account on the Application, you can do so by contacting your account manager or [email protected] or by other means as we may specify from time to time. After such termination, we will have no further obligation to provide any of its services to you, and subject to applicable law, reserves the right to retain, delete or destroy all information, communication and materials stored or posted on the Platforms pursuant to its internal record retention and/or content destruction policies.

• 28. We may retain the personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws. Please note that with respect to medical and health-related records or data of patients, there are applicable laws which require that we retain them to meet legal, regulatory and compliance purpose. The retention period required to meet these purposes could be lengthy and extend beyond general business retention policies.

• 29. We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.

TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE

• 30. We generally do not transfer your personal data to countries outside of Singapore save to our affiliate in Malaysia. However, if we do so, we will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.

DATA PROTECTION OFFICER

• 31. You may contact our Data Protection Officer if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, in the following manner:

Email Address: [email protected]

EFFECT OF PRIVACY POLICY AND CHANGES TO PRIVACY POLICY

• 32. This Privacy Policy applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.

• 33. We may revise this Privacy Policy from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Privacy Policy was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes and you agree to be bound by the prevailing terms of this Privacy Policy as may be updated from time to time.

Effective date : 1 July 2026

Last updated : 24 June 2026