At PULSE we want you to be confident that your information is kept safe and secure with us and understand how we use it to provide great care and a more personalised experience. This Privacy Policy seeks to highlight the rights and obligations, as well as the conditions for the collection, use, processing and disclosure of any personal data you provide to us. “Personal Data” shall be as defined in the Personal Data Protection Act 2019 of Thailand.

By continuing to use the Clinic’s services and website, you shall be deemed to always accept and agree to this Privacy Policy. If you do not accept this Privacy Policy and any amendment thereof, or withdraw your consent to any or all use of your personal data, the Clinic 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 the Clinic, and your being in breach of your contractual obligations or undertakings. The Clinic’s legal rights and remedies in such event are expressly reserved.

What types of personal data is being collected?

In order to perform the required services and features, the Clinic needs to collect and process the following personal data from you:

• Directly identifiable personal information such as name, age, nationality, gender, date of birth, passport number or other numbers that can be used to identify personal identity;
• Contact information such as address, phone number and e-mail address;
• Payment information such as payment transaction information, bank account information and credit card information;
• Information of healthcare services, such as doctor appointment details, personal information of relatives, personal requirement for accommodation, food and other services;
• Information on your personal health and wellbeing, treatment and care such as your marital status, sexual orientation, drug usage, history of allergic reactions, general medical history, physical health and mental health reports, scans, laboratory results and diagnostic results;
• Information collected from our website such as your username and password, IP address and web browser status and setting that you have used to connect to the website; and
• Your personal feedback and contribution to our client questionnaires and surveys.

How do we collect your personal data?

Generally, the Clinic collects personal data in the following ways:

• when you submit any form, including but not limited to customer inquiry forms or other forms relating to any of our services;
• when you enter into any agreement or provide other documentation or information in respect of your interactions with us, or when you use our services;
• when you interact with our staff, including receptionists, for example, via telephone calls (which may be recorded), letters, fax, face-to-face meetings, social media platforms and emails;
• when you interact with us via our mobile app, website or use services on our website;
• when you request that we contact you or request that you be included in an email or other mailing list;
• when you respond to our promotions, initiatives or to any request for additional personal data;
• when you submit an employment application or when you provide documents or information including your resume in connection with any staff appointment;
• when your images are captured by us via CCTV cameras while you are within our premises, or via photographs or videos taken by us or our representatives when you attend our events;
• when you are contacted by, and respond to, our marketing representatives and any member of our staff;
• when we seek information about you and receive your personal data in connection with your relationship with us, including for our products and services or job applications, for example, from business partners, public agencies, your ex-employer, referral intermediaries and the relevant authorities; and/or
• when you submit your personal data to us for any other reasons.

When you browse the Clinic’s website, you generally do so anonymously but please refer to the paragraph below on ‘What are Cookies that the Clinic is using on the Platform?’ for information on cookies and other technologies which the Clinic has implemented on our website. The Clinic does not automatically collect personal data through our website unless you provide such information to us.

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

You should ensure that all personal data submitted to the Clinic is complete, accurate, true and correct. Failure on your part to do so may result in the Clinic’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 the processing of your applications.

Disclosure of personal data

Generally, the Clinic collects, uses and discloses your personal data for the following purposes:

• The Clinic needs to process your personal data to manage our services, to carry out our obligations arising from any contracts entered into between us and you, to provide you with information or services you have requested and to help you with any payments or refunds you may require.
• To ensure that you receive the best possible care, your health record will also contain more sensitive information and reports about your health including details of any appointments, illness, tests and other treatments you receive. This may be shared with those who have a legal and legitimate need to see it to support your care.
• The Clinic uses cookies and similar technologies on our website to improve your experience (please see our cookie section for more information) and ensure that the content is presented in the most effective and helpful way for you.
• The Clinic may share minimal and relevant non-medical information within other organisations in order to provide effective information technology, financial, legal and governance support.
• The Clinic uses personal or anonymised data to monitor how effective our services are and to make sure that the treatments and services we provide are meeting the needs of our clients.
• The Clinic uses your personal data to send you our newsletters and information about products and services, which you may be interested in if you have given us consent to do so. You can opt out of this at any time.
• The Clinic may use your personal contact details to notify you about changes to our service.
• The details you provide during the purchasing process are collected for the sole purpose of processing and delivery of your products and services. Additionally, the Clinic may contact you after your products and services have been delivered to ask you to review your experience. You will not be added to any mailing lists without your permission, and the Clinic will not send you any correspondence that is not related to your order.
• You will also be required to provide some personal information in the course of completing a booking or form. This information is collected for the sole purpose of processing your booking or enquiry. Again, you will not be added to any mailing lists without your permission, and we will not send you any correspondence that is unrelated to your reason for getting in touch.

The Clinic tries to ensure that all personal information we hold is accurate and up to date. The Clinic holds this information securely and in accordance with the relevant laws, including the Personal Data Protection Act 2019 of Thailand and the European Union General Data Protection Regulation (GDPR). The Clinic 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, to the following entities or parties, whether they are located overseas or in Thailand:

• amongst the Clinic’s group members and affiliates (including their staff and medical practitioners);
• third party doctors, clinics, hospitals and/or medical institutions;
• companies providing services relating to insurance to the Clinic;
• agents, contractors, sub-contractors or third party service providers who provide operational services to the Clinic, such as courier services, telecommunications, information technology, payment, printing, billing, debt recovery, processing, technical services, transportation, training, market research, security, or other services to the Clinic;
• vendors or third party service providers and the Clinic’s marketing and business partners in connection with marketing promotions, products and services;
• the Clinic’s corporate clients;
• 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);
• external banks, credit card companies, other financial institutions and their respective service providers;
• the Clinic’s professional advisers such as consultants, auditors and lawyers;
• 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 Public Health); and/or
• any other party to whom you authorise the Clinic to disclose your personal data to.

Data Security and Retention

The Clinic shall use the most appropriate security measures to prevent the unauthorized access, amendment or disclosure of all personal data in any form or in any circumstance by either internal or external persons.

Your personal data will be confidentially kept in our system as long as it is required, either for the purposes mentioned above or in accordance with applicable laws and regulations.

Whilst the Clinic 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. As such that, with respect to the medical records of patients, unless specific contrary instructions from the patient are received, the Clinic may (but is not obliged to) retain such medical records for as long as the Clinic 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.

Data Subject Rights

You have the following rights in relation to your personal data:

• Right to withdraw consent: you can withdraw your consent and request the Clinic to stop collecting your personal data.
• Right of access: you can obtain access to the personal data held about you, including receiving verifying copies of original documents and making a request for data transferring from the Clinic to other data controllers or yourself.
• Right to rectification: you can request an update on an inaccurate or incomplete personal data.
• Right to restrict processing: you can request that the Clinic to limit the way your personal data is used, under certain conditions.
• Right to object to processing: you can object to the processing of personal data that is collected on the grounds of legitimate interests or the performance of a task in the interest/exercise of official authority.
• Right to data portability: you are permitted to request the transfer of your personal data to another organization, or directly to you, under certain conditions.
• Right to erasure: you can request that the Clinic erase your personal data in certain circumstances, such as when the personal data is no longer necessary, was unlawfully processed or is no longer meeting the lawful ground for which it was collected. This includes the situation where you withdraw your consent.

You can contact the Clinic to make the request to exercise any above right through the appropriate channel and the Clinic will consider and notify you of the Clinic’s determination within 30 days (or within a period as stipulated by the laws of the relevant jurisdiction) after the receipt of such request. Fees may apply in accordance with the laws of the relevant jurisdiction where such request is made.

Third Party Sites

The Clinic’s website may contain links to other websites operated by third parties, including but not limited to, those of our business partners. The Clinic is neither responsible nor liable for the data protection practices of websites operated by third parties that are linked to our website. The Clinic encourages you to learn about the data protection practices of such third party. Some of these third party websites may be co-branded with the Clinic’s logo or trade mark, even though they are not operated or maintained by the Clinic. Once you have left the Clinic’s website, please check the applicable Privacy Policy of the website of such third party to determine how they handle any information they collect from you.

What are Cookies that the Clinic uses?

Cookies are text files stored on your computer browser directory or program data subfolder in order to keep data log of your internet usage, behaviour or interaction on the website and other digital platforms. For the performance of the website, the Clinic needs to use various types of cookies for the following purposes:

• Functionality cookies are used to record information about choices you have made on the website such as personal settings, languages and fonts which allows the Clinic to tailor the Clinic’s website features to match your preference settings;
• Advertising cookies are used to record your on-site behavior and history of the website visited which allows the Clinic to provide you the products and services that suit your preferences; and
• Strictly necessary cookies are essential for you to browse the website and use its features, such as accessing its secure areas.

You can disable the cookies setting under your browser, provided that you acknowledge that this may impact the efficiency and performance of the website as set out above under each type of cookie respectively.

Updates to the Privacy Policy

The Clinic may amend or revise this Privacy Policy from time to time in order to comply with the relevant laws and regulations and in relation to any updates and changes to the website and the services we provide. The Clinic aims to communicate such amendments or revisions via any reasonably practicable means and such amendments or revisions shall become effective once published anywhere on the website.

This Privacy Policy was last updated on 19 April 2021.

Contact Us

If you wish to exercise your rights in accordance with this Privacy Policy, please contact the Clinic via a written letter attached with a copy of an identification document. You may also contact us on any questions or comments: 

Pulse Silom Co., Ltd.

Address: 60/4 Silom Road, Suriyawong, Bangrak, Bangkok, Thailand 10500

Telephone: +662 652 5097

Data Protection Officer: Bhirachat Yaemin

Email address: bhirachat.y@pulse-clinic.com

Please note that if your personal data has been provided to the Clinic 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 the Clinic on your behalf.

You also have the right to lodge a complaint about us to a data protection supervisory authority.