Privacy Policy

Introduction

Thank you for choosing Breakthrough Mental Health Services ("we," "us," or "our"). We are committed to protecting your privacy and providing you with a positive experience while using our mental health services. The purpose of this Privacy Policy is to outline the principles and legal framework that govern the collection, processing, use, disclosure, and safeguarding of your personal information across all interactions with our services. We recognize the importance of maintaining the privacy of your personal data and have designed this policy to help you understand how we handle such information. This includes the types of personal data we collect, the purposes for which we use it, with whom we might share it, and the rights and choices available to you regarding our use of your information.

Application
This policy applies to all interactions with Breakthrough Mental Health Services, including but not limited to our website, mobile applications, patient portal, teleconsultation, and remote patient monitoring. It covers information gathered through various channels, including direct submissions, automatic data collection, third-party integrations, and other platforms. We are dedicated to complying with the legal requirements specific to the jurisdictions in which we operate. It is essential that you read and understand this policy, as your acceptance of these terms is a condition of using our services.

Ethical Considerations
We adhere to a high standard of ethics in handling personal and sensitive information. We ensure that our practices align with integrity, responsibility, transparency, and patient-centricity. Our commitment extends to continuous improvement in privacy and data protection, ensuring alignment with industry best practices and legal requirements.

Acceptance of the Policy
By accessing or using any part of Breakthrough Mental Health Services, you acknowledge and agree to the terms laid out in this Privacy Policy. If you do not agree with any part of this policy, please do not use or continue to access our services.

Scope and Applicability

General Scope
This Privacy Policy governs the collection, usage, and disclosure of personal information by Breakthrough Mental Health Services across all our services and platforms. It applies to all information collected through any interactions you may have with us.

Users and Data Subjects
The policy applies to all users and data subjects, including patients, healthcare providers, visitors, vendors, contractors, and other stakeholders who interact with our services or provide personal information to us. The term "you" in this policy refers to all individuals whose information we collect and process.

Digital Platforms
The scope includes all digital platforms operated by Breakthrough Mental Health Services, such as our website, mobile applications, self-registration kiosks, teleconsultation portals, and integrations with third-party App. Any engagement with these platforms falls under the purview of this policy.

Third-Party Interactions
This policy also extends to our interactions with third-party vendors, partners, and affiliates who may collect or process personal information on our behalf. We ensure that these entities adhere to the same stringent privacy standards as set forth in this policy.

Limitations and Exclusions
While this policy broadly covers our privacy practices, there may be specific situations, services, or products for which separate or supplementary privacy notices are provided. Such notices will be explicitly communicated to you. Please note that this policy does not apply to third-party websites or services that may be linked from our platforms. We have no control over the privacy practices of these third parties and encourage you to review their respective privacy policies. This policy also does not govern the practices of entities not owned, controlled, or managed by Breakthrough Mental Health Services, including independent healthcare providers using our solutions.

Updates and Amendments
Breakthrough Mental Health Services reserves the right to update or amend this policy at its discretion. Any substantial changes will be communicated to you, and your continued use of our services following such updates signifies acceptance of the modified policy.

Geographic Applicability
While Breakthrough Mental Health Services operates globally, this policy is crafted with particular regard to the legal and regulatory requirements of Malaysia. We adhere to applicable laws and regulations in other jurisdictions as well, tailoring our practices to meet specific regional needs.

Definitions

Personal Data
Personal Data refers to any information relating to an identified or identifiable natural person. This includes, but is not limited to, names, identification numbers, contact information, medical records, and any other information that can be directly or indirectly linked to a specific individual.

Processing
Processing encompasses any operation performed on personal data, whether automated or manual. It includes collecting, recording, organizing, structuring, storing, altering, retrieving, consulting, using, disclosing, transmitting, or erasing personal information.

Data Subject
A Data Subject is any individual whose personal data is processed by Breakthrough Mental Health Services. This term includes patients, healthcare providers, employees, partners, visitors, and other stakeholders.

Data Controller
The Data Controller is the entity responsible for determining the purposes and means of processing personal data. In the context of this policy, Breakthrough Mental Health Services is the Data Controller for all personal data collected through our services.

Data Processor
A Data Processor is an entity that processes personal data on behalf of the Data Controller. This may include third-party service providers, vendors, and partners who handle personal information under the direction of Breakthrough Mental Health Services.

Consent
Consent refers to the clear, informed, and voluntary agreement by a Data Subject to the processing of their personal data. It must be freely given, specific, informed, and unambiguous.

Third-Party
A Third-Party refers to any entity other than the Data Subject, Data Controller, or Data Processor. This includes vendors, affiliates, partners, or other external organizations interacting with Breakthrough Mental Health Services.

Sensitive Personal Data
Sensitive Personal Data includes information that reveals racial or ethnic origin, political opinions, religious beliefs, trade union membership, genetic or biometric data, health or sex life, or sexual orientation. Such data requires special protection and consent for processing.

Breach
A Breach refers to any unauthorized access, disclosure, alteration, destruction, or loss of personal data, whether accidental or intentional, that compromises the integrity, confidentiality, or availability of the data.

Cookies
Cookies are small text files stored on a user's device when visiting a website. They are used to track user activity and preferences to enhance user experience.

Information We Collect

General Information
Breakthrough Mental Health Services collects various types of personal data to provide, enhance, and personalize our services. This information helps us to understand your needs, comply with legal obligations, and foster a seamless user experience.

Types of Data Collected

Identifiable Information
This category includes data that can directly identify an individual, such as name, identification number, address, phone number, email address, and user credentials. We may collect this information through various channels, including registration forms, account creation, and direct communication.
Health Information
Health Information encompasses appointment bookings, vital signs, medical records, medications, and other health-related details. We obtain this information through our medical devices integration solutions, teleconsultation services, patient portal, and other related platforms.
Financial Information
We may collect financial data, such as credit card numbers, bank details, and billing information, for payment processing and other financial transactions within our services.
Information from Third Parties
We may obtain information from third-party sources, including healthcare providers, government entities, partners, and other organizations that align with our services. This may include demographic data, health records, or other information relevant to our offerings.

Purpose of Collection
We collect personal data to facilitate and improve our services, conduct research and development, comply with legal and regulatory requirements, engage in marketing and communication, manage customer relationships, and ensure the overall security and integrity of our platforms.

Consent and Choice
Your consent plays a central role in our data collection practices. We seek explicit consent where required and provide options for you to opt-out or manage preferences. You may withdraw your consent at any time, subject to legal or contractual obligations.

Children's Information
Breakthrough Mental Health Services does not knowingly collect personal information from children under the age of 13 without parental consent. If we discover that we have collected such information, we will take appropriate steps to obtain parental consent or inform third-party if any potential danger involved.

Purpose of Processing

Provision of Services
Breakthrough Mental Health Services processes personal data to deliver, maintain, and enhance our mental health services. This processing is essential to facilitate online appointments, teleconsultations, patient monitoring, and other services that constitute the core functionalities of our offerings.

Compliance with Legal and Regulatory Obligations
We are committed to adhering to legal and regulatory requirements in all jurisdictions where we operate. Processing of personal data may be necessary to comply with laws, regulations, court orders, or other legal obligations. This includes our compliance with the Personal Data Protection Act.

Research and Development
We may use personal data for research, analysis, and development purposes. This enables us to innovate, enhance, and personalize our products, identify trends, and create new features that align with the needs and expectations of healthcare providers and patients. Anonymization or pseudonymization techniques may be employed to ensure privacy.

Marketing and Communication
Processing of personal data may be undertaken for marketing, advertising, and communication objectives. This includes informing users about new services, updates, promotions, events, and other relevant information. Data subjects have the option to opt-out of such communications at any time.

Security and Fraud Prevention
We process personal data to safeguard the integrity, availability, and confidentiality of our platforms. This includes implementing measures to prevent unauthorized access, detect fraudulent activities, protect against malware, and ensure the overall security of the personal data we handle.

Customer Support and Relationship Management
We process personal information to provide customer support, handle inquiries, resolve issues, gather feedback, and foster a responsive and collaborative relationship with our users, clients, and partners.

Consent-based Processing
In some cases, we may process personal data based on explicit consent from data subjects for specific purposes not covered above. This consent can be withdrawn at any time, in accordance with our procedures and applicable laws.

Consent

Obtaining Consent
Breakthrough Mental Health Services recognizes the importance of consent in personal data processing and commits to obtaining clear, informed, and unambiguous consent from data subjects. This includes providing detailed information about what data is collected, how it's used, and why it's necessary. Consent is sought through transparent mechanisms like checkboxes, consent forms, and explicit agreements. We ensure that consent is freely given, specific to the intended purpose, and easy to withdraw at any given time.

Managing and Withdrawing Consent
Data subjects have the right to manage or withdraw their consent at any stage. We provide accessible options to change preferences, opt-out of specific data processing activities, or entirely withdraw consent. Withdrawal of consent does not affect the legality of processing based on consent before its withdrawal.

Disclosure of Personal Information

To Whom We Disclose
Breakthrough Mental Health Services may disclose personal information to various parties, including but not limited to, healthcare providers, governmental authorities, legal entities, subcontractors, third-party vendors, and partners. This disclosure is aligned with the defined purposes and adheres to applicable laws and regulations. Disclosures to third parties are carefully assessed to ensure compliance with our privacy standards and legal obligations.

Third-Party Compliance Guidelines
When disclosing information to third parties, we follow stringent third-party compliance guidelines that stipulate the requirements and obligations to safeguard personal data. This includes formal agreements, monitoring, audits, and necessary legal protections.

International Transfers
If personal data is transferred outside the jurisdictions where we operate, we ensure that adequate safeguards, legal frameworks, and contractual obligations are in place to protect the data in accordance with applicable laws.

Your Rights

Right to Access
Data subjects have the right to request access to the personal data. This includes information on how the data is processed, the purpose of processing, and with whom it may have been shared.

Right to Erasure ('Right to be Forgotten')
Data subjects may request the deletion of personal data, where applicable, under certain conditions. This includes when the data is no longer necessary for the original purpose or when consent has been withdrawn.

Right to Restriction of Processing
Individuals have the right to request a restriction on the processing of their personal data under specific circumstances, such as when the accuracy of data is contested.

Right to Object
Individuals have the right to object to the processing of personal data for specific purposes, including direct marketing.

Right to Complain
Data subjects have the right to lodge a complaint with the relevant supervisory authority if they believe that their privacy rights have been violated.

Third-Party Links

Breakthrough Mental Health Services' platforms may contain links to third-party websites, products, or services. These links are provided for convenience, and their inclusion does not imply endorsement or responsibility for the content, privacy policies, or practices of the linked sites. We encourage individuals to review the privacy policies of third-party sites before providing personal information, as we do not have control over their data handling practices.

Children's Privacy

Protection of Children's Data
Breakthrough Mental Health Services recognizes the importance of protecting the privacy of children. We do not knowingly collect, use, or disclose personal information from children without verifiable parental consent or as permitted by law.

Procedures for Parental Consent
If we become aware that we have collected personal information from a child without proper consent, we will take steps to obtain parental consent or promptly delete the information. Parents or guardians may contact us to review, modify, or delete any personal information we may have collected from their children.

Data Retention

Retention Periods
Breakthrough Mental Health Services retains personal data only for as long as necessary to fulfill the purposes for which it was collected or as required by applicable laws and regulations. Retention periods are defined in line with legal obligations, business needs, and industry standards.

Data Destruction
Upon the conclusion of the retention period, personal data is securely deleted or anonymized. We follow strict procedures for data destruction, ensuring that the information is rendered irretrievable and that the process is compliant with legal and ethical guidelines.

Records of Retention and Destruction
Breakthrough Mental Health Services maintains detailed records of data retention and destruction, documenting the lifecycle of personal information within our systems. This contributes to transparency, accountability, and compliance with privacy governance.

Changes to this Policy

Periodic Review and Updates
Breakthrough Mental Health Services regularly reviews and updates this Privacy Policy to ensure it aligns with current legal requirements, industry standards, and organizational practices. Changes may be made to reflect new technologies, products, or services, as well as modifications to existing laws and regulations. We encourage users to review this Privacy Policy periodically to stay informed about how we collect, use, and protect personal information.

Breakthrough Mental Health Services is committed to protecting your personal data and strives to provide a safe, secure user experience. If you have any questions (including your rights of access and correction), comments or suggestions regarding this Privacy Policy or your Personal Data, we would be glad to hear from you. Please contact breakthrough.mhs@gmail.com.

Where the Personal Data is in connection with data subject under 18 years old, you represent [(by clicking “Submit”)] that: (i) you are either a parent, guardian or person who has parental responsibility for the data subject concerned for the purpose of the Personal Data Protection Act 2010; and (ii) have the requisite authority to provide consent for and agree to this Privacy Policy on behalf of that data subject. You shall indemnify Breakthrough Mental Health Services and its officers, directors, employees, contractors, sub-contractors and representatives for any loss, damage, fine, penalties, charges and other fees and expenses incurred in connection with a breach of any of these representations.