HOPES Privacy Policy

This Privacy Policy sets out the basis which the MOH Office for Healthcare Transformation ("We", "Us", or "Our") may collect, use, disclose or otherwise process personal data of Our users in accordance with the Personal Data Protection Act 2012 including any re-enactment, supplement and amendments thereto from time to time ("PDPA"). This Policy applies to User Contributed Information, user-provided data, 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. All access of any part of the HOPES including its mobile application ("App") and services is governed by the Terms of Use including the Privacy Policy. If you do not accept any of these terms, please discontinue the use or access of HOPES immediately. By continuing to use or access HOPES and/or provide us with User Contributed Information, you acknowledge that you have read and understood these terms and agree to be bound by these terms.

    PERSONAL DATA

  1. As used in this Policy:

    "User" means an individual who (a) has contacted Us through any means to find out more about any goods or services We provide, or (b) may, or has, entered into a contract with Us for the supply of any goods or services by Us; and

    "Personal data" means data, whether true or not, about a user 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.

    "User-provided data" means data about a user that is created in the course of or as a result of your use of HOPES.

  2. Depending on the nature of your interaction with Us, some examples of personal data which We may collect from you include your name and identification information such as your NRIC number, contact information such as your address, email address or telephone number, nationality, gender, date of birth, marital status, photographs and other audio-visual information, employment information and medical records.
  3. Other terms used in this Policy shall have the meanings given to them in the PDPA (where the context so permits).

    4. COLLECTION, USE AND DISCLOSURE OF YOUR PERSONAL DATA

  4. HOPES does not proactively collect any data that directly identifies you ("Personally Identifiable Information"). Upon registration on the HOPES platform, you will be given an anonymised serial number, and only your Health Provider will have knowledge of your serial number. We will not be able to identify you from this serial number.

    5. COLLECTION, USE AND DISCLOSURE OF YOUR DATA

  5. The HOPES platform requires access to multiple sensors and functions within your mobile devices and/or wearable devices to function. This data and/or any part or subset thereof is then collected and transmitted to the HOPES servers which process this data. Collectively, the transmitted data, data received and/or User-provided data is classified as the "User Contributed Information". The User Contributed Information and/or the data from you or which you may submit to Us includes the data listed in Appendix A. The list of information you may submit to Us and/or which the HOPES platform requires access, may change from time to time. The use of this information shall be in accordance with these terms, Our Privacy Policy and/or for any purposes that you have been notified of and/or consented to. You acknowledge that all transmitted information may be viewed, edited, or deleted by another authorised user. We may collect, use, disclose and retain User Contributed Information including your User-provided data and your personal data for any or all of the following purposes:
    1. performing obligations in the course of or in connection with Our provision of the HOPES service;
    2. verifying your identity;
    3. responding to, handling, and processing queries, requests, applications, complaints, feedback , and facilitating communications;
    4. managing your relationship with Us;
    5. 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;
    6. any other purposes for which you have provided the information;
    7. 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;
    8. in an aggregated or de-identified form for the purposes of improving Our systems, or for research, statistical and planning purposes;
    9. we may share your User Contributed Information including your User-provided data and your personal data and other related data with other government agencies and public healthcare institutions, to enable us to provide you with better healthcare. We may also share such data with the Ministry of Health, the relevant regulatory authority for healthcare professionals, other ministries, statutory bodies and public agencies for the purpose of complying with their respective requirements, policies, and directives;
    10. security and risk management; and
    11. any other incidental purposes related to or in connection with the above.
  6. We may disclose User Contributed Information including your User-provided data:
    1. where such disclosure is required for performing obligations in the course of or in connection with Our provision of the HOPES service; or
    2. to third party service providers, agents, and other organisations including to Our Affiliates which We have engaged to perform any of the functions listed in clause 5 above for Us.

  7. You acknowledge that in relation to the User Contributed Information and/or your data: (i) you have the necessary rights, licenses, consents, and permissions to submit, use and authorise Us and/or Our Affiliates to use the User Contributed Information and/or any part or subset thereof; and (ii) you shall comply with the PDPA and/or any other applicable law relating to data privacy or confidentiality, and will not cause Us and/or Our Affiliates to be in breach of such laws. The purposes listed in the above clauses may continue to apply even in situations where your relationship with Us (for example, pursuant to a contract) 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 any contract with you).

    If you are accessing or using HOPES and/or the services including in relation to the User Contributed Information on behalf of a minor or any other individual, you represent and warrant that you have the permission and authority to act on their behalf and to agree to these terms. In such cases, the terms "you" and "your" shall refer to the user, the minor, the individual and their parent, guardian and/or representative. You shall be fully responsible for compliance with these terms.

    If you are a minor or an individual which requires permission from your parent, guardian and/or representative for the use of HOPES and the services including in relation to the User Contributed Information and to agree to these terms, you represent and warrant that you have obtained the consent and permission of your parent, guardian and/or representative for the use of HOPES and the services including in relation to the User Contributed Information and to agree to these terms. By using HOPES and the services and/or providing the User Contributed Information, you confirm that you have received such consent, and you and your parent, guardian or representative will be responsible for compliance with these terms. In such cases, for the avoidance of doubt, the terms "you" and "your" shall refer to the user, the minor, the individual and their parent, guardian and/or representative.

    1. For the purposes of the Terms of Use and the Privacy Policy, "Our Affiliates" shall mean an organisation, institution or entity that:
      • Is related to MOHT by reason of MOHT directly or indirectly controlling the organisation, institution or entity;
      • Is related to MOHT by reason of the organisation, institution or entity directly or indirectly controlling MOHT;
      • Is related to MOHT by reason of both MOHT and the organisation, institution or entity being, directly or indirectly, controlled by or under the common control of a third party;
      • Is obliged to provide support or other services to or otherwise collaborate with that organisation, institution or entity (including the Ministry of Health or any other Ministry of the Government of Singapore, or any statutory board) for any reason; or
      • By reason of that organisation, institution or entity being a related corporation of MOHT (as defined by the Companies Act 1967).
    2. In the context of corporate entities, a person "controls" the entity if it owns and controls:
      • More than FIFTY percent (50%) of shares or other securities entitled to vote for election of directors (or other managing authority) of the entity; or
      • More than FIFTY percent (50%) of the equity interest in the entity; or
      • Is otherwise able to direct or cause the direction of the management and policies of such person or entity whether by contract or otherwise;

    8. APPENDIX

    List of Data Collected

    Data Collected

    Explanation

    HOPES Application

    Device Information

    We collect information about your phone model, Device ID, FCM token and phone operating system during registration.

    Motion Data - Pedometer, Accelerometer and Gyroscope (for Android users only)

    Phone movement is used to determine your steps and patterns of physical activity.

    Ambient Light (for Android users only)

    Ambient light sensors allow Us to understand the lighting conditions in your environment

    GPS Data (Obfuscated)

    GPS Data is obfuscated by adding a random displacement to your location.

    We will NOT be able to find out your exact location at any immediate point in time.

    Finger Taps (for Android users only)

    Taps within each app category are recorded along with the screen orientation.

    We will NOT be able to identify or collect the exact location on the screen of each tap.

    App Usage (for Android users only)

    App Usage such as usage frequency and time spent on each app category (e.g. social, games, productivity, etc)

    Power State

    For Android users - We collect data on when the phone is turned on.

    For iOS users - We collect data on battery percentage and whether the phone is being charged.

    Sleep

    For Android users - We access your device's Physical Activity sensors via Google Play Services to provide sleep tracking features including sleep intervals and sleep confidence scores.

    HOPES Application Usage

    We collect data you input into the application and how you use the HOPES application and features. This excludes the journal content which is only accessible by the app user.

    Fitbit

    Sleep

    Your sleep data is derived by Fitbit which determines your time spent asleep, your time in sleep stages, and your sleep efficiency.

    Steps

    Fitbit collects your number of steps taken

    Heart Rate

    Fitbit collects your heart rate at predefined intervals

    Heart Rate Variability

    Fitbit collects your data on your heart rate variability (HRV) which measure the variability of time between beats.

    WITHDRAWING YOUR CONSENT

  8. 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 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 your Care Team.
  9. 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.
  10. 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.

    11. PROTECTION OF DATA

  11. 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 such as up-to-date antivirus protection, encryption and the use of privacy filters to secure all storage and transmission of personal data by Us, and disclosing personal data both internally and to Our authorised third party service providers and agents only on a need-to-know basis.
  12. 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 information and are constantly reviewing and enhancing Our information security measures. We shall not liable for any claims, losses, damages and expenses arising from the damage, loss or corruption to your data. We do not accept any liability for the authenticity, confidentiality, integrity, and security of any communications and other transactions made through HOPES.
  13. While HOPES takes extensive measures to obfuscate and anonymise transmitted User Contributed Information including your User-provided data, given the nature of said data, We cannot guarantee that you can be identified due to the uniqueness of User Contributed Information including your User-provided data.

    14. RETENTION OF DATA

  14. We may retain your 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.
  15. If you registered with an email address and you decide to deactivate your account, we will stop providing you access to and use of HOPES and/or the services and will delete or anonymise your personal data where reasonably possible, unless we are required or permitted by applicable laws to retain certain information for legal, regulatory, security, or business purposes.
  16. We generally 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.

    17. TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE

  17. We generally do not transfer your personal data to countries outside of Singapore. However, if We do so, We will obtain your consent for the transfer to be made and 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.

    18. DATA PROTECTION OFFICER

  18. 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:

    19. Data Protection Officer
    Email Address: MOHT.DPO@moht.com.sg
    1 North Buona Vista Link #09-02
    Singapore 139691

    EFFECT OF POLICY AND CHANGES TO POLICY

  19. This Policy applies in conjunction with any other policies, notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by Us. For the avoidance of doubt, this Policy is not intended to supersede or replace any consent previously provided to us.
  20. We may revise this 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 Policy was last updated. Your continued use of Our services constitutes your acknowledgement and acceptance of such changes.

Effective date : 06 March 2026
Last updated : 06 March 2026