Privacy Statement


Privacy Statement Introduction

Roffe International Holdings Pte Ltd (ROFFE) is advancing the world of health by improving medical discovery, diagnostics and the delivery of care. In doing so, we collect, process and use information. We collect and use information from customers, healthcare professionals, patients, business partners and other external parties with whom we interact. ROFFE takes data privacy seriously and we believe that carrying out our business activities in compliance with applicable privacy and data protection laws is fundamental to our business success. This external privacy statement (“Privacy Statement”) describes our practices in connection with information that we or our service providers collect through our websites and applications as part of ROFFE Services although additional terms may apply when you access some specific services in some areas of this website or when you click on links that navigate away from this website. By using the ROFFE Services that are in scope for this Privacy Statement, you are agreeing to the terms of ROFFE’s most recent version of this Privacy Statement.

Supplemental Privacy Notice to Singapore Residents.

What follows is a table of contents listing the areas covered by our Privacy Statement. We recommend you read our entire Privacy Statement carefully but you may select on individual sections of the Privacy Statement below as well.


Welcome to (the "Site"). This Site is operated by Roffe International Holdings Pte Ltd("ROFFE" or "we" or "us") and has been created to provide our customers the information, products and other initiatives developed and/or offered by ROFFE and its subsidiaries and affiliates (collectively, the " ROFFE Services"). You are important to ROFFE and, as described in this Privacy Statement, we will take appropriate measures to protect your privacy as you use this Site. This Privacy Statement sets forth ROFFE 's approach with respect to information that is collected from users of this Site. Your use of ROFFE Services that link to this Privacy Statement are subject to this Privacy Statement and the Terms of Use of the Site.

Note About Children

We do not knowingly collect or use any Personal Data directly from children under 18. We do not knowingly allow children to order our products, to communicate with us, or to use any of our online services. If you are a parent and become aware that your child has provided us with information, please contact us using one of the methods specified below, and we will work with you to address this issue.

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"Aggregated Data" includes customer demographics, interests and behavior based on Personal Data and other information provided to us, which is compiled and analyzed on an aggregate and anonymous basis.

"Personal Data" includes all information that enables an individual to be identified, including, by way of example, the individual's name and e-mail address.

"Public Information" includes information posted to any public areas of the Site, such as bulletin boards, chat rooms and comment areas as well as the definition of "Public and Unsolicited Information" contained in our Terms of Use.

"Unsolicited Information" includes any ideas for new products or modifications to existing products and other unsolicited communications. Personal Data included in Unsolicited Information will be handled in the manner set forth in this Privacy Statement; however please refer to our discussion of "Public and Unsolicited Information" contained in our Terms of Use.

"User Data" includes all information passively collected from users of the Site that does not identify a particular individual, including, by way of example, statistical information on Site usage. The terms "you" "your" and "yours" when used in this Privacy Statement means any user of this Site.

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What Information Do We Collect?

Information That You Give Us: We collect Personal Data such as your name, title, date of birth, company name, work contact information, e-mail or mailing address from you when you voluntarily
 choose to register for or use certain ROFFE  Services at this Site. We use the Personal Data that we collect in an effort to provide you with a superior customer experience on the Site and to 
improve and market  ROFFE Services.

We may combine your information with data gathered from other sources. For instance, if incorrect postal codes are received, we may use third party software to correct them. We also may collect e-mail or other addresses from prospect lists of other companies, for example, in connection with a joint marketing effort. When we do so, (1) we expect those third party companies to have obtained all e-mail and other addresses in accordance with applicable law; and (2) we provide a means for recipients of ROFFE communications to opt-out of further communications from us. In addition, we may ask you for Personal Data if you enter an educational program, contest or promotion sponsored by ROFFE. When you contact ROFFE we may keep a record of that correspondence and may occasionally ask you to complete surveys for sales and research purposes.

Information That You Give Us When You Sign Up for a ROFFE Mobile Application for Personal Use: In addition to the Personal Data collection described above, we collect other Personal Data when you sign up for and use a ROFFE mobile application. This Personal Data typically includes your personal username and password, individual health-related information, medications taken, and information from other applications or devices that you consent to link to the ROFFE application. In the case of ROFFE mobile applications, we also provide additional and more specific information to users at the point each user signs up for use of a mobile application.

Information That You Give Us in the Context of Participating in a ROFFE patient-support or other patient-specific Program: If you sign up for a ROFFE patient support or other patient-specific program, in addition to the Personal Data collection described above, we collect other Personal Data, including username and password, health-related information, medication taken, reactions to medication, financial insurance information and other related information used to determine your eligibility for the program, as well as any other information you may choose to provide.

Information That We Get from the Following Other Sources:

·       Publicly available sources

·       Customers, including healthcare providers and insurance providers

·       Third party organizations that we work with to provide services to customers and consumers

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Other information:

Device and Other Information: When you interact with ROFFE through this Site, we receive and store certain "User Data." That User Data, which is collected passively using various technologies, is not used to specifically identify you. ROFFE may store that User Data itself or it may be stored in databases owned and maintained by ROFFE's affiliates, agents or service providers.

This Site will use User Data together with data provided by other parties and pool it with other information to track, for example, the total number of visitors to our Site, the number of visitors to each page of our Site, the keywords visitors used to find our Site and the domain names of our visitors' Internet service providers. We also may disclose User Data in order to describe our services to current and prospective business partners, and to other third parties for other lawful purposes. It is important to note that no Personal Data is available or used in this process.

Aggregated Data: In an ongoing effort to better understand and serve our users, ROFFE often conducts research on Aggregated Data. ROFFE may share this Aggregated Data with government agencies, its affiliates, agents and business partners. This aggregated information does not identify you personally. ROFFE also may disclose Aggregated Data in order to describe our services to current and prospective business partners, and to other third parties for other lawful purposes.

Cookies: In operating this Site, we may use a technology called "cookies." A cookie is a piece of information that the computer that hosts our Site gives to your computer (actually to your browser) when you access our Site. Our cookies help provide additional functionality to the Site and allow us to analyze Site usage more accurately. For instance, our Site may set a cookie on your browser that eliminates any need for you to remember and then enter a password more than once during a visit to the Site. In all cases in which we use cookies, we will not collect Personal Data through the use of such technology. On most web browsers, you will find a "help" section on the toolbar. Please refer to that help section for information on how to receive notification when you are receiving a new cookie and how you may turn cookies off. We recommend that you leave cookies turned on because they allow you to take advantage of some of the Site's features. You are also welcome to select your specific cookie preferences by visiting ROFFE’s Cookies Settings preference center by clicking the Cookies Settings in the footer of every page of the Site and selecting the type of cookies to which you give your consent.

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Transfer of Your Data Abroad

By voluntarily providing us with your Personal Data, you are consenting to our use of it in accordance with this Privacy Statement. Due to the nature of the Internet if you are visiting this Site from a country other than the United States, your communications will inevitably result in the transfer of information across international boundaries. By visiting this Site you consent to these transfers. If you provide Personal Data to this Site, you acknowledge and agree that such Personal Data may be transferred from your current location to the offices and servers of ROFFE and the affiliates, agents and service providers referred to herein located in the United States and in other countries.

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What are Your Choices?

You can use this Site without providing your Personal Data, although doing so may limit your ability to obtain certain information or to use other valuable ROFFE Services, including, for example, informational newsletters and responses to specific inquiries you may have. Where no Personal Data is legally required or is necessary for a particular service (for example, to contact you in response to your request), the use of a pseudonym is accepted.

We keep your Personal Data only for as long as reasonably necessary for the purposes for which it was collected or to comply with any applicable legal reporting or document retention requirements. We will take reasonable steps to update, correct or, upon your request, delete your Personal Data in our possession that you have previously submitted via this Site. In order to request an update, with respect to your Personal Data, please contact us as provided below. If at any time you wish not to receive further communications, you may also follow the unsubscribe procedure included in our communication.

Access & Deletion

Depending on where you reside, applicable law may entitle you to additional consumer rights, including the right (with certain limitations and exceptions) to:

·       Know the categories and/or specific pieces of personal information collected about you, including whether your personal information is sold or disclosed, and with whom your personal information was shared

·       Access a copy of the personal information we retain about you

·       Request deletion of your personal information

To guard against fraudulent requests for access and deletion, ROFFE will require information that it determines is sufficient to allow it to confirm the identity of the person making the request before granting access or making corrections. ROFFE will endeavor to provide the information in question within a reasonable time and may charge an appropriate cost (e.g. photocopying, mail charges) to the individual making the request, where permissible under applicable law. ROFFE reserves the right not to change any Personal Data but will append alternative text the individual concerned believes is appropriate.

In addition, in certain circumstances, ROFFE may decline to provide access to Personal Data, including where ROFFE determines that the information requested:

·       (a) May disclose:

o   a. The Personal Data of another individual or of a deceased individual; or

o   b. Trade secrets or other business confidential information;

·       (b) Is subject to attorney-client or litigation privilege or a professional privilege or obligation;

·       (c) Is not readily retrievable and the burden or cost of providing would be disproportionate to the nature or value of the information;

·       (d) Does not exist, is not held, or cannot be found by ROFFE;

·       (e) Could reasonably result in serious harm to the treatment or recovery of the individual concerned, serious emotional harm to the individual or another individual, or serious bodily harm to another individual; or

·       (f) May harm or interfere with law enforcement activities or other investigative or regulatory functions of a body authorized by statute to perform such functions.

Please note that although after receiving a request to update, correct or delete information, we will make reasonable efforts to effect such a change promptly, it is not always possible to complete the process before another communication is distributed. We apologize for any inconvenience this may cause. Even if you have requested removal of your Personal Data from our lists, ROFFE reserves the right to retain it in our files in some limited circumstances such as when such Personal Data may be necessary to honor your request to opt out of further communications, resolve disputes, troubleshoot problems, comply with applicable law or as provided in our Terms of Use. If ROFFE is required to retain any portion of the Personal Data for such purposes, ROFFE will use reasonable efforts to limit that retention of Personal Data to what is necessary to accomplish the particular purpose. Further, you acknowledge that due to technical constraints and the fact that we back-up our systems, Personal Data may continue to reside in our systems even after deletion. Therefore, you should not expect that your Personal Data will be completely removed from our systems in response to your request.

ROFFE will not respond to repetitious or vexatious requests for access. In determining whether a request is repetitious or vexatious, we will consider such factors such as the frequency with which information is updated, the purpose for which the information is used, and the nature of the information.

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How Do We Use Your Personal Data and Other Information?

ROFFE uses the Personal Data you provide for our business purposes in a manner that is consistent with this Privacy Statement.

·       If you provide Personal Data for a certain reason, that Personal Data will be available to us for use in connection with the reason for which it was provided or for a consistent purpose, including, if applicable, processing an order placed by you or informing you that the product is no longer available. For instance, if you contact us by e-mail, we may use the Personal Data you provide to respond to you; or if you contact us about a job listing, the information you provide to us may be used to consider you for the position. We may also combine Personal Data that you have provided to us with information obtained by us from other parties.

·       ROFFE and its affiliates also may use your Personal Data, User Data and other information collected through the Site to help us improve the content and functionality of the Site, to better understand our customers and markets, to improve our products and services and to effect and facilitate sales.

·       ROFFE and its affiliates may use this information to contact you, electronically, through telemarketing or otherwise, in the future to tell you about, and to offer for sale, products or services we believe will be of interest to you. If we do so, each communication we send you will contain instructions permitting you to "opt out" of receiving future communications.

·       In some instances, we contract with outside parties to collect and maintain our information collection servers and to perform technology and related services. We seek to provide any such third parties with only the information they need to perform their specific function and we require them to protect your Personal Data in accordance with this Privacy Statement.

If at any time you wish not to receive any future communications or to have your name deleted from our mailing lists, you may follow the "unsubscribe" procedure included with our communication. In addition, you may e-mail us at frankie@theroffe.comSee How to Contact ROFFE below.

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Do Not Track browser settings: does not use pervasive online web tracking for behavioral advertisements. Enabling of the Do Not Track setting in your browser will have no effect on the types of data ROFFE collects and uses as follows:

·       Personally non-identifiable information is used only for commonly accepted practices such as visit and click-through rates collected to improve site design and navigation

·       Personally identifiable information is only gathered when data is explicitly entered into a ROFFE on-line form and you have explicitly accepted the applicable ROFFE privacy statement or policy. At any time, you can also opt-out of receiving any future communications.

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Do We Share the Information that We Receive?

ROFFE considers your information to be a vital part of our relationship with you. ROFFE will share information including Personal Data with its subsidiaries and affiliates that have also agreed to be bound by this Privacy Statement. In addition, ROFFE, like many businesses, sometimes hires other companies to perform certain business-related functions. Examples include mailing information, maintaining databases and processing payments. When we retain another non-affiliated company to perform a function of this nature, we seek to provide them with only the information that they need to perform their specific functions, and we require them to protect your Personal Data in accordance with this Privacy Statement and ROFFE's other contractual or legal restrictions.

In addition, if you input Personal Data on a co-branded registration page, relating, for example, to a contest co-sponsored by both ROFFE and a partner company, then your Personal Data will be available both to ROFFE and to such partner company. While ROFFE will only use such Personal Data in accordance with this Privacy Statement, such partner company's use of your Personal Data will be subject to the privacy policy of that company and ROFFE cannot be responsible for their use of your information. We encourage you to review the privacy policy of such partner company before providing information on any such co-sponsored page or promotion.

There are also a limited number of circumstances in which we may share your Personal Data and other information in our possession with certain additional third parties without further notice to you, as set forth below:

Legal Requirements:

ROFFE may disclose your Personal Data, User Data and other information if required to do so by law or in the good faith belief that such action is necessary to (a) comply with a legal obligation, (b) protect and defend the rights or property of ROFFE or its affiliates, (c) act in urgent circumstances to protect the personal safety of users of the Site or the public, or (d) protect against legal liability. Please note that compliance with a legal obligation is not limited to compliance with court orders or other legal processes specifically related to this Privacy Statement. Instead, we may also collect, use, and disclose Personal Data consistent with FDA and other governmental agency guidance, directions, regulations, and laws where applicable.

Business Transfers, Combinations and Related Activities:

As we develop our business, we might sell, buy, restructure or reorganize businesses or assets. In the event of any sale, merger, reorganization, restructuring, dissolution or similar event involving our business or assets, Personal Data may be part of the transferred assets.

ROFFE is the parent company of a large international group of companies. In light of this fact, we may, from time to time transfer your Personal Data to one of our databases in another country as provided above under the heading Transfer of Your Data Abroad.

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Public and Unsolicited Information

The protections set out in this Privacy Statement do not apply to Public Information you provide to ROFFE through this Site or through any other means. If you include Personal Data in Public Information, we will use that Personal Data only as provided here, but we caution you that, because such information (including your Personal Data) was made available in a forum accessible by the public, the use and disclosure of information by others accessing the Site is not monitored or controlled in any way by ROFFE - nor are their activities governed by this Privacy Statement.

In addition, if you submit unsolicited Personal Data we will use it as provided here, however, your unsolicited submission is not covered by this Privacy Statement. Please refer to our discussion of "Public and Unsolicited Information" contained in our Site Terms of Use.

Please note that, as set forth above, this Privacy Statement does not apply to the providing or use of certain Personal Data other than through the Site nor to the providing or use of Personal Data of past or present employees of, or consultants engaged by, Roffe International Holdings Pte Ltd and/or its subsidiaries, for employment or benefits administration purposes, both of which are governed by ROFFE policies designed for those respective purposes.

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Links to Other Websites

This Privacy Statement applies only to this Site. This Site may frame or contain references or links to other ROFFE web sites as well as other web sites not operated or controlled by ROFFE (the "Third Party Sites") none of which sites are governed by the policies and procedures we describe here. The links from this Site do not imply ROFFE's review or endorsement of the Third Party Sites. We suggest that you contact those sites directly for information on their privacy, security, data collection and distribution policies.

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ROFFE takes reasonable steps to protect any Personal Data you provide to us and to protect such information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Unless otherwise stated on the relevant page of the Site, ROFFE uses general security standards but has not taken additional action to secure data provided to its sites, and such transmissions are subject to normal Internet security risks. As noted, no Internet or e-mail transmission is ever fully secure or error free. In particular, e-mail sent to or from this Site may not be secure, and you should therefore take special care in deciding what information you send to us. Please keep this in mind when disclosing any Personal Data to ROFFE or to any other party via the Internet. Moreover, when you use passwords, ID numbers, or other special access features on this Site, it is your responsibility to safeguard them, in this respect please refer to the Terms of Use of Site Use.

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Supplemental Privacy Notice to Singapore Residents

If you reside in Singapore and we receive or collect CA Personal Information about you in a manner that is not an exception that is excluded by applicable law, we are required to provide additional information to you about how we use and disclose your information, and you may have additional rights with regard to how we use your information. We have included this Singapore-specific information below.

Singapore Consumer Privacy Act of 2018 (CCPA)

Singapore Personal Information. Consistent with the "What Information Do We Collect?" section above, we collect certain categories and specific pieces of information about Singapore consumers or households that are considered "Personal Information" in Singapore ("CA Personal Information"). For example and specific to CA Personal Information, ROFFE may have collected the following categories of information about you:

·       Personal information under the Singapore Customer Records statute – such as: signature, physical characteristics or description, telephone number, medical information, health insurance information

·       Protected classifications under Singapore or federal law – such as: sex, age, physical or mental disability

·       Commercial information – such as: products or services obtained or considered, or other purchasing or consuming histories

·       Internet or other similar network activity – such as: information regarding a consumer’s interaction with a website or application

CA Personal Information does NOT include information that is:

·       Publicly available from government records

·       De-identified or aggregated consumer information

·       Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) or the Singapore Confidentiality of Medical Information Act (CMIA) or clinical trial data

·       collected in the context of ROFFE's business-to-business interactions

·       other personal or financial information that is covered under certain sector-specific privacy laws.

·       In addition, Singapore personnel are notified separately about the use and disclosure of their CA Personal Information.

Sources. We may collect certain categories of CA Personal Information from you and other third parties as described in the "What Information Do We Collect?" section above.

Purposes. Consistent with the "How Do We Use Your Personal Data and Other Information?" section above, we may share and/or disclose your CA Personal Information for business or commercial purposes, as follows:

·       Sharing your CA Personal Information for business purposes: As described in the "Do We Share the Information that We Receive?" section above, in the past twelve months, we may have used or disclosed (shared) the following categories of your CA Personal Information with service providers, affiliates, third party partners, public or government authorities and future business partners for one or more of our operational or business purposes:

o   To provide products and services to consumers

o   To respond to consumer requests

o   To improve and personalize the consumer experience on our Site

o   For analytical purposes to improve or further develop products or services

o   To monitor the safe and effective use of our products (or services)

o   For any activity described to a consumer that engages with ROFFE digitally and provides personal information or as otherwise permitted under the CCPA

o   To conduct troubleshooting, audits, or other quality control activities related to the Site or other micro-sites, products, or services

o   To detect and protect against security incidents and potential deceptive, malicious, or fraudulent activity

o   To maintain and repair any ROFFE Services

o   As described above, examples of business purposes include business-related functions, internal operations, prevention of fraud and other harm, and legal or regulatory compliance.

·       Sharing your CA Personal Information as a “sale” under Singapore law: We do not sell the personal information of Singapore consumers. If ROFFE determines that any activity that ROFFE is engaged in may constitute a "sale" under Singapore law, ROFFE will modify this notice and add a Do Not Sell button to the Site. Note that none of the following types of disclosures constitute a “sale” under the CCPA:

o   requests or direction from consumers to disclose their personal information

o   instances where a consumer tells ROFFE to interact with a third party that does not sell personal information of Singapore consumers

o   situations where ROFFE shares personal information pursuant to a written contract with a service provider that is necessary to perform a business purpose where that third party is limited to only using the personal information to perform under that contract

o   cases where a consumer’s personal information is transferred as part of a transaction (merger or acquisition) under which the third party assumes full or partial control of one of our businesses.

Singapore Consumer Rights. Subject to certain exceptions, as a Singapore resident, you may have the following rights to your CA Personal Information: (i) Access. Request access to your CA Personal Information that we collect, use, disclose, or sell (if applicable); (ii) Deletion. Request deletion of your CA Personal Information, although ROFFE may deny the request for a number of reasons authorized under Singapore or other applicable law; and (iii) CA Personal Information Sold or Disclosed for Business Purposes. Request information about the CA Personal Information we have "sold" (as defined under CCPA) or disclosed for business purposes within the preceding 12 months. As noted above, ROFFE does not sell consumers’ personal information. To the extent permitted by applicable law, we may be required to retain some of your CA Personal Information and certain CA Personal Information is strictly necessary in order for us to fulfil the purposes described in this Privacy Statement.

Exercising Singapore consumer rights. If you are a Singapore resident and wish to exercise any of these rights, you may submit a verifiable request to us as follows : (a) contact us via e-mail: as described in the “How to Contact ROFFE” section below with the specific nature of your request, referencing “Your Singapore Privacy Rights”; or (b) call the following toll-free number: (65) 66766869. We are not responsible for requests that are not labelled or sent properly, or do not have complete information. We will verify your identity prior to providing any information in response to a consumer rights request. Please note that you are limited by law in the number of requests you may submit per year. Only you, or a person registered with the Singapore Secretary of State that you authorize to act on your behalf (Authorized Agent), may attempt to make a consumer request for you. We cannot respond to a request if we are unable to verify your identity or confirm your Authorized Agent. Follow these steps if you wish to submit a request to exercise your rights under Singapore law:

1.     Give us enough information to reasonably verify you are a Singapore resident and entitled to rights under Singapore law;

2.     Describe your request with enough detail to allow us to understand and respond to your request; and

3.     Tell us how you prefer to receive a written response – by USPS mail or e-mail. Note that if you do not specify your preference, ROFFE will respond to a verified request by e-mail.

We will not discriminate against you by offering you different pricing or products, or by providing you with a different level or quality of products, based solely upon you exercising your rights to your CA Personal Information. Finally, making a verifiable consumer request does not require you to create an account with ROFFE.

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How to Contact ROFFE

Please also feel free to contact us if you have any questions about ROFFE's Privacy Statement or the information practices of this Site.

You may contact us as follows:

Roffe International Holdings Pte Ltd

Toll Free Phone Number: (65) 66766869


This Privacy Statement was last updated on June 23, 2020.