As leaders in healthcare, each SingHealth Institution1 (collectively, "SingHealth", "we", "us", "our" or similar expression) takes its responsibility to protect personal data seriously. Your privacy is important to SingHealth and we are committed to complying with applicable law, including the Singapore Personal Data Protection Act (No. 26 of 2012) (the "PDPA").
1 Namely, Singapore Health Services Pte Ltd ("Corp Office") and its applicable related corporations, affiliates, subsidiaries and their respective charities and funds, including , Singapore General Hospital Pte Ltd ("SGH"), KK Women's and Children's Hospital Pte. Ltd ("KKH"), Bright Vision Hospital ("BVH"), National Cancer Centre of Singapore Pte Ltd ("NCCS"), National Dental Centre of Singapore Pte Ltd ("NDCS"), National Heart Centre of Singapore Pte Ltd ("NHCS"), National Neuroscience Institute of Singapore Pte Ltd ("NNI"), Singapore National Eye Centre Pte Ltd ("SNEC"), Singapore Eye Research Institute ("SERI"), SingHealth Polyclinics ("SHP"), Sengkang Health Pte Ltd ("SKH"), SingHealth Fund ("SHF"), Changi General Hospital Pte Ltd ("CGH"), Changi Health Fund (Ltd.) ("CHF") and Homecare Enterprises Ltd ("HEL").
1. The purpose of this document ("Data Protection Policy", or "DPP") is to inform you of how SingHealth collects, uses, discloses, processes or otherwise handles ("Handles") your personal data, and to let you know how you can exercise your rights in respect of your personal data.
2. You may have seen or been referred to shorter summaries of this DPP which were formatted and edited to meet specific purposes, formats or to provide an easy-at-a-glance look at the key or relevant points of the DPP. This is the full DPP and is the authoritative statement of our policy on the handling of personal data.
3. The portion of the DPP that applies to your personal data will depend on the nature of your transactions, agreements or interactions with us.
4. Please note that though we make an effort, as per legal requirements, to provide reasonably adequate information concerning our policies as it pertains to personal data, this DPP is not an exhaustive list of all the situations or scenarios concerning personal data. Feel free to approach your SingHealth Institution's Data Protection Officer (see
Contacting Us – Withdrawal of Consent, Access and Correction of your Personal Data below) if you need clarification about any specific situation.
We update the DPP from time to time - this version of the DPP was last updated as at 31 July 2019.
5. We update the DPP from time to time to ensure that our standards and practices remain relevant, are up to date, comply with applicable laws and guidelines, and remain applicable to industry trends. The latest version of the DPP supersedes and replaces the earlier versions.
6. The public website at http://www.singhealth.com.sg/pdpa contains the latest links and most updated editions of the DPP or resources.
7. We encourage and ask all individuals who interact with SingHealth, including any person to whom personal data relates (each a "data subject") to check back to the publicly posted / circulated copies of the DPP.
8. The DPP is an integral part of your journey with us. It applies to and forms part of the terms and conditions governing your transactions, agreements or interactions with us, whenever your personal data is Handled by us.
9. We bring it to your attention and make it a part of or complementary to your transactions, agreements or interactions with us, in addition to the website and making the copies of this DPP available as mentioned above, by:
11. This DPP supplements but does not supersede nor replace any other consents you may have previously or specifically provided to any SingHealth Institution in respect of your personal data, and your consents here are in addition to any consents by you or rights given at law to any of the SingHealth Institution to Handle your personal data.
12. We ask and require that each of the following parties / persons to abide by this DPP:
13. SingHealth Institutions are subject to the PDPA, as well as specific legislation or regulations concerning relevant aspects of healthcare, and your transactions, agreements or interactions with us. More information about the PDPA can be found at the website of the Personal Data Protection Commission ("PDPC") at www.pdpc.gov.sg
14. The PDPA is a baseline law that ensures a common standard of protection for individuals' personal data across organisations in Singapore.
15. For the healthcare sector, existing laws such as Human Organ Transplant Act (HOTA), Termination of Pregnancy Act, the Infectious Diseases Act etc will continue to apply concurrently with the PDPA. SingHealth Institutions will need to ensure that they comply with current sectoral laws and regulations as well as the PDPA.
16. Where there are inconsistencies between the PDPA and existing sectoral laws and regulations in respect of the collection, use or disclosure of personal data, the provisions of the other written laws shall prevail. For example, the requirements under the Private Hospitals and Medical Clinics Act, the Singapore Medical Council Ethical Code and Ethical Guidelines (ECEG), the Human Organ Transplant Act and the Infectious Diseases Act in respect of disclosure of information will prevail over the PDPA, while for the donation of a deceased person's organs, consent must be obtained from the next-of-kin (i.e. the "Authorised Persons" in the Schedule to The Medical (Therapy, Education and Research) Act (MTERA)) before harvesting the organ.
17. This DPP applies to "personal data", which, in this DPP and in line with the PDPA, refers to any data, whether true or not, about an individual (i.e. the data subject) 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 to, including data in our records as may be updated from time to time.
18. The exact type of personal data that may apply in your case will vary depending on the how you have interacted with us. Examples of such personal data you may provide to us 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 us in any forms you may have submitted to us (including in the form of biometric data), or via other forms of interaction with you.
19. In some situations, personal data may include tissue specimen, organic materials provided by a data subject (whether as a patient, donor, research participant, or volunteer etc.), but only where such materials are linked with data that can lead to the identification of the data subject.
20. Personal data does not include data about a data subject which has been anonymised. Anonymisation is the process of removing identifying information such that the remaining data does not identify any particular individual. Techniques can include pseudonymisation2, aggregation, replacement, data reduction3, data suppression4, data shuffling5, or masking6.2 Replacing identifiers with other references. For example, replacing an individual's name with a tag or reference number.3 Removing values that are not required for the purpose. For example, removing 'Ethnicity' from a data set of individuals' attributes.4 Banding or hiding the value within a given range. For example, replacing age '43' with the range '40-50'.5 Mixing up or replacing values with those of the same type so that the information looks similar but is unrelated to the actual details. For example, the surnames in a customer database could be sanitised by replacing them with those drawn from another database.6 Removing certain details while preserving the look and feel of the data. For example, representing a full string of numbers on a credit card as 4346 XXXX XXXX 5379 instead of '4346 6454 005379.
21. SingHealth practices and undertakes reasonable safeguards to anonymise personal data in appropriate situations, balancing both the need to rely on and use sufficiently accurate and complete personal data to protect life and health, and avoid mistakes, injury or accidents.
22. By applying this DPP, you:a. consent to the relevant SingHealth Institution(s) and the relevant person(s) (see "Who will comply with this DPP" above) Handling your personal data in ways which enable us to serve you, provide you with the relevant services, attend to the relevant transaction, or to facilitate our interactions with you;b. enable the exercise of your rights under the PDPA in an operative and applicable framework, including securing the right to access your personal data, withdraw (or manage) your consents and preferences as to your personal data.
23. Your consent may not be necessary or required in some situations as there may be applicable law or regulation which renders this unnecessary, or where certain permissions or rights or duties have been accorded to the SingHealth Institution which enable / require us to Handle the personal data. Where such law or regulation applies, we will act in accordance with those other laws and regulations.
24. You are entitled under applicable law to withhold / withdraw consent to the collection, use or disclosure of personal data, and SingHealth will respect your choices in this regard. You may withhold consent at any juncture that you are asked for consent, and you may also apply the process / method to withdraw consent as stated in this DPP (see
Contacting Us – Withdrawal of Consent, Access and Correction of your Personal Data below).
25. However, as is recognised by and provided for under the PDPA, it may be that any choice you make to withhold or withdraw consent may impact our ability to proceed with your transactions, agreements or interactions with us, and in particular:
28. Generally, depending on the situation, we may collect personal data in the following ways:
29. We may also collect personal data about you from third parties such as:
30. If you provide us with any Personal Data relating to a third party (e.g. information of your next-of-kin, spouse, children, parents, and/or employees), by submitting such information to us, we rely on you and will assume that you are representing to us that you have obtained the consent from the third party to provide us with their personal data for the respective purpose for which we are collecting this personal data.
31. We also rely on you and will assume that you have ensured that all personal data submitted to us is complete, accurate, true and correct.
32. If consents are not procured or if you fail to provide us with complete and accurate information, we may, in some situations, be prevented from providing a patient with medical treatment (or may be impaired in doing so, resulting in risks to that patient) or cause harm to a data subject.
33. SingHealth will take the approach that best safeguards us, you and others from risks, and we may well have no choice but to decline to proceed with the transaction, agreement or interaction in question to avoid causing harm or exposing us, you or others to risk.
34. SingHealth will endeavour to limit the collection of personal data to what is reasonable or necessary for such applicable purposes as described in this DPP.
35. However, it should be noted that in the case of medical / health information, the extensiveness and completeness of information that is collected can mean the difference between saving a life, or preventing the loss of life, and can make a crucial difference between a full and proper diagnosis with appropriate treatment and incomplete or inadequate treatment.
36. Further, the relevance of information may not be immediately apparent at first and personal data may be collected as a matter of precaution to ensure that you or a data subject is adequately protected from or treated for illness.
37. It may also be good medical practice to collect information about a patient or even next-of-kin (e.g. in the case of congenital disorders, allergies, predispositions to certain risks etc), spouse, children, parents, and/or employees.
38. If you withhold information, this can have the same effect as when you withdraw consent (see "Withholding / Withdrawing Consent" above), and as stated in the "Risks of relying on data we collect from you that is without consent or which is inaccurate" section above, we may well have no choice but to decline to proceed with the transaction, agreement or interaction in question to avoid causing harm or exposing us, you or others to risk.
Generally, a SingHealth Institution Handles your personal data for the purposes set out in this section. Any one or more of the listed purposes may apply to your personal data, depending on the actual situation. The following does not purport to be an exhaustive listing, although an effort is made to set out as many salient purposes as may be applicable.
40. In the sub-sections that follow we set out some of the Purposes which apply to collection or use of personal data in certain scenarios and also identify some of the relevant recipients in the disclosure of personal data. We would also highlight that while a party may be listed as a recipient or source of personal data in these sections, that same party may also be a recipient or source (albeit not listed or mentioned expressly) in other scenarios.
41. We may Handle your personal data in order to execute healthcare operations, including responding to the service needs of patients as well as other data subjects, managing the administrative and business operations of the SingHealth Institutions and conducting audits and studies for the purposes of improving the efficiency, standards and quality of the SingHealth Institutions' services and operations.
42. We may Handle your personal data, particularly if you are a patient, to provide medical and other allied health treatments, such as physiotherapy, speech and dietetics treatments and therapies.
43. The personal data may be disclosed / shared with healthcare professionals (such as doctors, physicians, residents, nurses, allied health professionals, technicians, students / trainees who are assisting on or providing medical treatment / services), other medical institutions / facilities (including labs, pharmacies, counsellors, care providers such as next-of-kin, service providers etc.), and healthcare providers. In each case the disclosure or sharing of such personal data is solely to such persons or entities which are involved in the care of the patient.
44. The purposes for which such personal data is Handled includes:
45. We may also Handle personal data (such as telephone number and email address) to contact you and/or your representatives to remind you of appointments at the SingHealth Institution.
For emergency prevention of injury or death
46. We may also disclose personal data in emergency situations affecting (or causing serious threats to) the health, life, safety of any individual (e.g. to notify appropriate authorities where we believe a person has been the victim of abuse, neglect or domestic violence). Such disclosures will be made to such persons as may be necessary to address or respond to the situation.
For healthcare operations
47. We may Handle your personal data in order to execute healthcare operations. In brief, this relates to planning, execution, administration and implementation of functions or things which are necessary to run the relevant SingHealth Institution. Your personal data may also be used to respond to the service needs of patients as well as other data subjects.Purposes under this heading include:
48. For these purposes, disclosures may be made to SingHealth's staff who have a need to know, such as administrators, doctors, nurses, allied health professionals, executive / administrative staff, as well as persons who can assist SingHealth in undertaking these purposes such as analysts, consultants, advisors, educators, or other similar persons.
49. Disclosures for this purpose can also be to affiliated institutions, other SingHealth Institutions, community health centres or polyclinics, or to the SingHealth Institution's service providers. In the case of other SingHealth Institutions, the Handling of personal data will be under the framework of intra-group agreements / policies that ensure that the standards in this DPP are followed / applied.
50. Disclosures may also be to agents, debt collection agencies, contractors or third party service providers who provide operational services to the SingHealth Institution, such as courier services, telecommunications, information technology, payment, payroll, processing, training, market research, storage, archival, customer support investigation services or other services to the SingHealth Institution, or other vendors or other third party service providers in connection with services offered by the SingHealth Institution.
51. For some SingHealth Institutions, it may be necessary to disclose personal data records to a shared third party service provider or vendor, or via another SingHealth Institution, in order to obtain the services of that vendor. In such instances, reasonable safeguards will be taken to ensure the confidentiality of your personal data records.
52. In the case of third party entities, the SingHealth Institution will ensure that agreements in place with such third parties to hold them to the standards in this DPP.
53. SingHealth believes that the making of decisions and taking of steps in relation to the healthcare of a patient involves great care and should be made on the basis of complete and accurate information. Should a situation develop where the lack of information about an individual (whether a patient, next-of-kin, or other person) or the lack of completeness of a particular record could result in the creation or rise in risk to the health, safety or well being an individual (e.g. through errors, or inability to validate information etc.), it is essential for our staff to be able to take steps to minimize or eliminate such risks and any personal data may be collected, used or disclosed by us for this purpose.
54. In such cases, collection, use or disclosure will be made strictly to the extent necessary and to such persons as may be necessary to achieve the minimization or elimination of such risks.
55. SingHealth Institutions are progressive and continually exploring ways to advance the seamless and efficient delivery of healthcare services, and information technology ("IT") tools and platforms are central to this drive.
56. For this purpose, SingHealth Institutions may Handle personal data using IT platforms and tools promulgated by MOH, MOHH or other like body including, but not limited to the National Electronic Health Records ("NEHR") system. SingHealth Institutions apply and require the application of reasonable and defensible security and access controls in the use of such systems, such that organisations other than the SingHealth Institution treating or transacting with you have only such access as is on a need to know basis for purposes and in a manner consistent with this DPP and/or where (and to the extent) necessary to meet your needs.
57. SingHealth Institutions also work with partners such as Integrated Health Information Systems ("IHIS") who run IT services within the SingHealth Institution. For the purposes of meeting your needs, such IT services include establishing the scope and requirements of projects, testing systems / applications, fulfilling IT support and service requests, and managing changes and configurations in IT infrastructure. Personal data is shared with IHIS under appropriate agreements which ensure that IHIS only accesses or Handles personal data as our data intermediary on a need to know basis for the purposes and in a manner consistent with this DPP.
58. As healthcare providers, SingHealth Institutions and/or its staff are subject to and regulated by various statutes and regulations such as the Private Hospitals and Medical Clinics Act, Medical Registration Act, Singapore Medical Council Guidelines etc. Additionally, special legislation may apply to certain healthcare scenarios, e.g. National Registry of Diseases Act, Infectious Diseases Act, Human Organ Transplant Act, Termination of Pregnancy Act, etc. Such legislation (collectively, "Medical Laws") may override / apply in place of the provisions / standards set by the PDPA in respect of the subject matter of such legislation. We may owe duties under such Medical Laws to Handle your personal data in certain ways, including making disclosures to appropriate government agencies, ministries, statutory bodies, or third parties in each case in accordance with and within the scope of our legal duties.
59. In addition, SingHealth may be required to collect, use or disclose personal data for the purposes of facilitating business asset transactions (which may extend to any merger, acquisition or asset sale); and in order to comply with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities.
60. Examples of such purposes include:
62. We may Handle your personal data to bill and receive payment for services that we or others provide to you.
63. The purposes connected with such Handling of the personal data include:
64. Disclosures for these purposes include submission of personal data to health insurers, or another party that pays for some or all of your healthcare (payor) including for the purposes of verifying their payment for your invoice. To process such payments, we may also disclose personal data (e.g. when addressing whether a certain prescribed treatment would be covered under a particular plan etc). For certain services, your permission may be requested to release health information to obtain payment.
65. The following section of the DPP addresses the application of the DPP and details concerning the Handling of personal data in respect of specific classes / types of data subjects.
For general practitioners, healthcare professionals, students (including student radiographer), trainee doctors and nurses, resident, house officer, medical officer, or a person on clinical attachment with SingHealth Institution
66. We will Handle your personal data to:
For sureties of trainee doctors and nurses
66A. We will handle your personal data to
For shoppers at our retail malls/ retail pharmacies
67. We may sometimes collect your information when you participate in our market surveys, lucky draws, contests, free sample giveaways, when you reserve items with us or fill in device warranty cards. We may use your personal data to:
For our donors and sponsors
68. SingHealth works with various donors and sponsors, and we, together with our respective charitable funds and other funds as may be set up from time to time, handle personal data for the following purposes:
69. Recipients include government authorities such as IRAS, Development offices, Charities, publicity/ outreach organisations including those that facilitate or work with media outlets.
For volunteers and research volunteers
70. SingHealth Institutions engage and work with volunteers, if you are a volunteer, we Handle your personal data for the following purposes:
71. We may disclose your personal to related organisations such as VWOs, charitable foundations or to beneficiaries.
For visitors to a SingHealth Institutions/research facilities or a SingHealth Institution corporate event
72. We welcome many visitors to SingHealth Institutions, whether this is a visit to see a patient, or if you are on SingHealth premises / campus for any specific transaction, event or other interaction with us. The personal data Handled in this regard are purposes such as :
73. For visitors to the SingHealth Institutions visiting patients, meeting with healthcare professionals, or otherwise attending meetings with SingHealth staff as part of delivery of services, the recipients of such information include SingHealth Institutions operations, administrative offices, facilities and security, law enforcement, ward staff, nurses and other healthcare professionals. At the same time, we may also maintain a log or track your attendance at a SingHealth Institution's premises or event for subsequent reference including addressing event hosting reviews.
For participants in a SingHealth Institution's events, courses, contests, and training workshops
74. SingHealth Institutions also host, and arrange educational activities (for a more in-depth look at our Data Protection Policy section on Education please see section 9. In addition to the information in the other sections, we would apply the personal data Handled for the following purposes:
75. Recipients for this type of data include event organisers / vendors, vendors of course content, social media platforms, including Facebook.
76. This category of persons includes suppliers, trainers and interpreters, tenants of SingHealth's relevant retail mall, business contacts in the stakeholder's exercise.
77. We would apply the personal data Handled for the following Purposes:
78. SingHealth makes an effort to remain connected with the community it serves and will collate and Handle personal data sometimes with a view to the following purposes:
79. Such personal data is only Handled with appropriate consents where legally required, and will be used for these stated purposes.
80. SingHealth recognizes that the care of a patient may well involve or impact more than 1 individual, and the persons who must be kept informed, or who could have a say in such matters may well extend beyond the patient.
81. The PDPA places an emphasis on the rights of the data subject, and obligates SingHealth to respect that data subject's wishes. SingHealth seeks always to balance the need to respect the interests of the data subjects as required by law, with the rights of such persons connected to the data subject.
82. Where the data subject is a caregiver, next-of-kin, representative (including an executor or administrator to a deceased patient) to a patient and/or former patient (including a deceased patient), or where the data subject is a the legal guardian or parent of a minor / disabled individual who are either patients or former patients of a SingHealth Institution (collectively a "Patient's Representative"), the purposes for the Handling of your personal data include:
83. SingHealth will accept any notification from a court or competent legal authority as to the identification of any individual appointed under applicable law, regulation or court order as a Patient's Representative and SingHealth will grant any such person access to the personal data of the patient where required by such law, regulation or court order.
84. Where the patient is a minor, we will, unless otherwise alerted with due proof of contrary authorisation / order, make the reasonable assumption that each parent (meaning both parents, whether married, separated or divorced) has full rights of access to the minor patient's personal data unless otherwise alerted with due proof of contrary authorisation / order, or where our staff (including any doctor, counsellor, or administrator) take the view that such access could jeopardize the health, safety or well being of any person.
85. Every patient who is of majority age (i.e. above 18 years old) and with full legal capacity, is entitled to exercise his / her legal rights to identify any persons who are to act as a Patient's Representative. In such instances, we will,
unless otherwise instructed by the patient, or alerted with due proof of contrary authorisation / order, make the reasonable assumption that any immediate next-of-kin (i.e. parents, siblings, and children) may be contacted in respect of emergencies or in situations where contact is needed to safeguard to preserve the health, safety or well being of the patient.
86. Should any patient of legal age of majority, with full legal capacity, wish for any SingHealth Institution to instruct us to limit access to his / her personal data or include only certain named persons in the handling / administration of any personal data or matters concerning the individuals healthcare, we will respect these decisions, subject to appropriate verifications / processes to ensure that such instructions are properly given.
87. For this reason, notice is given to all individuals that even if they identify themselves as a Patient's Representative, such identification may not match our latest records / instructions from the patient, or such records / instructions may limit access to the patient's personal data. In such cases, SingHealth reserves the right to decline access, pursuant to our obligations under the PDPA.
Contacting persons in emergencies / safeguarding of health, safety & well being
88. Notwithstanding the above, SingHealth has a right under the PDPA to contact such persons or execute such steps involving the Handling of personal data as may be reasonably necessary to address emergencies or in situations where contact is needed to safeguard and preserve the health, safety or well being of the patient, or to comply with our legal obligations.
89. At SingHealth, we are committed to serving the needs of all our patients by constantly pushing the frontiers of medicine through research. We have committed a significant amount of resources into our research processes so that the outcome of our research studies may offer better clinical care and outcomes to all our patients today and for generations to come.90. Depending on which specific class of data subjects you belong to and subject always to the requirements under the PDPA, including where we may have obtained your consent where legally required, we may use your personal data for research purposes which include:
If you are a patient or a volunteer research subject
92. In order to deliver better services and care to our patients, SingHealth actively engages in the sharing and teaching of medical knowledge with our healthcare interns and students. In order to train and inspire future generations of medical professionals, it is important for us to let them gain experience through first-hand patient contact and involvement in our core hospital operations.93. As such, depending on which specific class of data subjects you belong to and subject at all times to the requirements of the PDPA, we may use your personal data for education purposes which include:
f you are a patient/volunteer/next-of-kin of patient
96. If you have provided your Singapore telephone number(s) and have indicated that you consent to receiving marketing or promotional information via your Singapore telephone number(s), then from time to time, the SingHealth Institution may contact you using such Singapore telephone number(s) (including via voice calls, text, fax or other means) including, among other things, with information about our products and services (including discounts and special offers).
97. In relation to particular products or services or in your interactions with us, we may also have specifically notified you of other purposes for which we collect, use or disclose your personal data. If so, we will collect, use and disclose your personal data for these additional purposes as well, unless we have specifically notified you otherwise.
99. Each SingHealth Institution retains such personal data as may be required for business or legal purposes, and such purposes do vary according to the circumstances.
100. Whilst each SingHealth Institution 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.
101. As such that, with respect to the medical records of patients, unless specific contrary instructions from the patient are received, the relevant SingHealth Institution may (but is not obliged to) retain such medical records for as long as the SingHealth Institution 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.
102. While we strive to protect your personal data, we cannot ensure the security of the information you transmit to us via the Internet, and we urge you to take every precaution to protect your personal data when you are on the Internet. We recommend that you change your passwords often, use a combination of letters and numbers, and ensure that you use a secure browser.
103. If applicable, you undertake to keep your username and password secure and confidential and shall not disclose or permit it to be disclosed to any unauthorised person. Please inform us as soon as reasonably practicable if you know or suspect that someone else knows your username and password or believe the confidentiality of your username and password has been lost, stolen or compromised in any way or that actual or possible unauthorized transactions have taken place. We are not liable for any damages resulting from any security breaches, on unauthorised and/or fraudulent use of your username and password.
104. When you interact with us on our websites, we automatically receive and record information on our server logs from your browser. We may employ cookies in order for our server to recognise a return visitor as a unique user including, without limitation, monitoring information relating to how a visitor arrives at the website, 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).
105. Cookies are small text files placed in the 'Cookies' folder on your computer's hard disk and allow us to remember you. The cookies placed by our server are readable only by us, and cookies cannot access, read or modify any other data on a computer. All web-browsers offer the option to refuse any cookie, and if you refuse our cookie then we do not gather any information on that visitor.
106. Should you wish to disable the cookies associated with these technologies, you may do so by changing the setting on your browser. However, you may not be able to enter certain part(s) of our website.
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