Data Protection Policy

The purpose of this document (“Data Protection Policy”) is to inform you of how Silverline Mobile Pte Ltd. manages Personal Data which is subject to the Singapore Personal Data Protection Act (No. 26 of 2012) (“the Act”). Please take a moment to read this Data Protection Policy so that you know and understand the purposes for which we collect, use and disclose your Personal Data.

By interacting with us, submitting information to us, or signing up for any Products and Services offered by us, you agree and consent to Silverline Mobile Pte Ltd. (including its related corporations and business units) (collectively, the “Companies”), as well as their respective representatives and/or agents (collectively referred to herein as “Silverline”, “us”, “we” or “our”) collecting, using, disclosing and sharing amongst themselves your Personal Data, and disclosing such Personal Data to the Companies’ authorised service providers and relevant third parties in the manner set forth in this Data Protection Policy.

This Data Protection Policy supplements but does not supersede nor replace any other consents you may have previously provided to Silverline in respect of your Personal Data, and your consents herein are additional to any rights which to any of the Companies may have at law to collect, use or disclose your Personal Data.

Silverline may from time to time update this Data Protection Policy to ensure that this Data Protection Policy is consistent with our future developments, industry trends and/or any changes in legal or regulatory requirements. Subject to your rights at law, you agree to be bound by the prevailing terms of the Data Protection Policy as updated from time to time on our website Please check back regularly for updated information on the handling of your Personal Data.

1. Personal Data

1.1 In this Data Protection Policy, “Personal Data” refers to any data, whether true or not, about an individual 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, including data in our records as may be updated from time to time.

1.2 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, network data and any other information relating to any individuals which you have provided us in any forms you may have submitted to us, or via other forms of interaction with you.

2. Collection of Personal Data

2.1 Generally, we collect Personal Data in the following ways:

(a) when you submit an application form or other forms relating to any of our Products and Services (defined below);

(b) when you interact with our customer service officers, for example, via telephone calls, letters, face-to-face meetings and emails;

(c) when you use some of our services, for example, websites and apps including establishing any online accounts with us;

(d) when you request that we contact you, be included in an email or other mailing list;

(e) when you respond to our promotions, initiatives or to any request for additional Personal Data;

(f) when you are contacted by, and respond to, our marketing representatives and customer service officers;

(g) when we receive references from business partners and third parties, for example, where you have been referred by them;

(h) when we seek information from third parties about you in connection with the Products and Services you have applied for; and

(i) when you submit your Personal Data to us for any other reasons.

2.2 When you browse our website, you generally do so anonymously but please see the section below on cookies. We do not at our website automatically collect Personal Data unless you provide such information or login with your account credentials.

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

2.4 You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with the Products and Services you have requested.

3. Purposes for the Collection, Use and Disclosure of Your Personal Data

3.1 Generally, Silverline collects, uses and discloses your Personal Data for the following purposes:

(a) responding to your queries and requests;

(b) managing the administrative and business operations of Silverline and complying with internal policies and procedures;

(c) facilitating business asset transactions (which may extend to any mergers, acquisitions or asset sales) involving any of the Companies;

(d) matching any Personal Data held which relates to you for any of the purposes listed herein;

(e) resolving complaints and handling requests and enquiries;

(f) preventing, detecting and investigating crime and analyzing and managing commercial risks;

(g) providing media announcements and responses;

(h) monitoring or recording phone calls and customer-facing interactions for quality assurance, employee training and performance evaluation and identity verification purposes;

(i) organising promotional events;

(j) legal purposes (including but not limited to obtaining legal advice and dispute resolution);

(k) conducting investigations relating to disputes, billing or fraud;

(l) meeting or complying with any applicable rules, laws, regulations, codes of practice or guidelines issued by any legal or regulatory bodies which are binding on Silverline (including but not limited to responding to regulatory complaints, disclosing to regulatory bodies and conducting audit checks, due diligence and investigations); and

(m) purposes which are reasonably related to the aforesaid.

3.2 In addition, Silverline collects, uses and discloses your Personal Data for the following purposes:

(a) If you are a customer or an employee of an organisation which is a customer of Silverline (including but not limited to Mobile, Web and/or Cloud Computing products and services (“Products and Services”)):

(i) opening or continuation of accounts and establishing or providing you with the Products and Services you subscribe to (including but not limited to service activation, service operations, service delivery and order processing);

(ii) facilitating the continuation or termination of your subscription to our Products and Services (including but not limited to administering subscription arrangements, account maintenance, account closure, processing renewal of contracts and customer relationship management);

(iii) facilitating the daily operation of the Products and Services (including but not limited to billing, customer service, customer verification, technical support, network maintenance and troubleshooting);

(iv) managing and executing our service-level agreements with you;

(v) processing of payment instructions, direct debit facilities and/or credit facilities requested by you;

(vi) enforcement of repayment obligations (including but not limited to debt collection, filing of claims and retrieval of payments from losses made by service partners);

(vii) administering and processing any insurance claims and payments arising under the respective policies;

(viii) credit and internal risk management (including but not limited to performing credit checks and disclosures to law enforcement agencies);

(ix) generating internal reports (including but not limited to annual, operational and management reports);

(x) processing referral payments and commission fees to our external partners;

(xi) administering fee adjustments, refunds and waivers;

(xii) analysing your use of our Products and Services so as to help us improve, review, develop and efficiently manage the Products and Services offered to you; and

(xiii) purposes which are reasonably related to the aforesaid.

3.3 Furthermore, where permitted under the Act:

(a) Silverline may also collect, use and disclose your Personal Data for the following “Silverline Additional Purposes”:

(i) analytics and tracking, including facilitating the sale of analytical data

(ii) conducting market research and surveys to enable us to understand and determine customer location, preferences and demographics to develop special offers and marketing programmes in relation to Silverline’s Products and Services, and to improve our service delivery and your customer experience at our touchpoints;

(iii) providing additional Products and Services and benefits to you, including promotions, loyalty and reward programmes from Silverline;

(iv) matching Personal Data with other data collected for other purposes and from other sources (including third parties) in connection with the provision, marketing or offering of Products and Services by Silverline;

(v) leads generation and management for marketing Silverline’s Products and Services;

(vi) administering contests, competitions and marketing campaigns, and personalising your experience at Silverline’s touchpoints;

(vii) communicating to you advertisements involving details of our Products and Services, special offers and rewards, either to our customers generally, or which we have identified may be of interest to you (including but not limited to upselling, cross selling and telemarketing);

(viii) organising promotional events and corporate social responsibility projects; and

(ix) purposes which are reasonably related to the aforesaid.

In addition, where permitted under the Act and subject to the provisions of any applicable law, your Personal Data may be disclosed, for Silverline Additional Purposes, to the vendors or other third party service providers in connection with promotions and services offered by Silverline.

(b) Silverline may also collect, use and disclose your Personal Data for the following “Preferred Partners Additional Purposes” :

(i) conducting market research and surveys to enable us to understand and determine customer location, preferences and demographics to develop special offers and marketing programmes with our preferred partners;

(ii) matching Personal Data with other data collected for other purposes and from other sources (including third parties) in connection with the provision, marketing or offering of products and services (including promotions, loyalty and reward programmes) by our preferred partners;

(iii) leads generation and management for marketing the products and services offered by our preferred partners;

(iv) administering contests, competitions and marketing campaigns in connection with the products and services offered by our preferred partners;

(v) sending you informational, recruitment and other notification messages communicated by our preferred partners;

(vi) communicating to you advertisements involving details of the products, services, special offers and rewards offered by our preferred partners, either to our customers generally, or which we or our preferred partners have identified may be of interest to you (including but not limited to upselling, cross selling and telemarketing); and

(vii) purposes which are reasonably related to the aforesaid.

In addition, where permitted under the Act and subject to the provisions of any applicable law, your Personal Data may be disclosed, for Preferred Partners’ Additional Purposes, to the vendors or other third party service providers in connection with promotions and services offered by Silverline’s preferred partners. However, please be assured that we do not disclose your Personal Data to our preferred partners for the purposes of the above.

3.4 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, Silverline may contact you using such Singapore telephone number(s) (including via voice calls, text, fax or other means) with information about our Products and Services or those products and services offered by our preferred partners (including discounts and special offers).

3.5 In relation to particular Products and 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.

3.6 You have a choice to withdraw your consent for receiving marketing or promotional materials/communication. You may contact us using the contact details found below.

3.7 Please be aware that once we receive confirmation that you wish to withdraw your consent for marketing or promotional materials/communication, it may take up to 30 working days for your withdrawal to be reflected in our systems. Therefore, you may still receive marketing or promotional materials/communication during this period of time. Please note that even if you withdraw your consent for the receipt of marketing or promotional materials, we may still contact you for other purposes in relation to the Products and Services that you hold or have subscribed to with Silverline.

4. Disclosure of Personal Data

4.1 Silverline will take reasonable steps to protect your Personal Data against unauthorised disclosure. Subject to the provisions of any applicable law, your Personal Data may be disclosed, for the purposes listed above (where applicable), to the following:

(a) Silverline’s related corporations and employees to provide content, Products and Services to you, address your questions and requests in relation to your customer accounts, subscription and billing arrangements with us as well as our Products and Services, to activate, deactivate, install, maintain and operate our systems and/or services;

(b) companies providing services relating to insurance and consultancy to Silverline;

(c) agents, contractors or third party service providers who provide operational services to Silverline, such as courier services, telecommunications, information technology, payment, printing, billing, payroll, processing, technical services, training, market research, call centre, security or other services to Silverline;

(d) vendors or third party service providers in connection with marketing promotions and services offered by Silverline or its preferred partners;

(e) commercial shops and retailers in relation to providing rewards and benefits;

(f) other telecommunications, content or other service providers to facilitate their provision of content or services, or for interconnection, inter-operability, system operation and maintenance and billing between service providers;

(g) any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale) involving any of the Companies;

(h) collection and repossession agencies in relation to the enforcement of repayment obligations for debts;

(i) external banks, credit card companies and their respective service providers;

(j) our professional advisers such as auditors and lawyers;

(k) relevant government regulators, statutory boards or authorities or law enforcement agencies to comply with any laws, rules, guidelines and regulations or schemes imposed by any governmental authority; and

(l) any other party to whom you authorise us to disclose your Personal Data to.

5. Use of Cookies

5.1 A cookie is a small piece of information that is placed on your computer when you visit certain websites.

5.2 Silverline uses cookies on its websites for the following purposes:

(a) enabling certain features and functions on our websites, eg. remembering your user-id, favourite channel selections, browsing and other service preferences;

(b) building up a profile of how you and other users use the website;

(c) improving the efficiency of our website;

(d) administering services to you and to advertisers; and

(e) establishing usage statistics

5.3 Most internet browsers provide you the option of turning off the processing of cookies (please see the “help” section of your browser), but this may result in the loss of functionality, restrict your use of the website and/or delay or affect the way in which it operates.

5.4 Advertisements on the Silverline website may be provided by third party advertisers and their agencies. These may generate cookies to track how many people have seen a particular advertisement (or use the services of third parties to do this), and to track how many people have seen it more than once. Silverline does not control these third parties and their cookie policies and if you have questions about their cookie policies, please contact Silverline and we will try our best to assist by providing you information about these third party advertising agencies.

5.5 Silverline is not responsible for the Personal Data policies (including Personal Data protection and cookies), content or security of any third party websites linked to the Silverline website.

6. Contacting Us – Withdrawal of Consent, Access and Correction of your Personal Data

6.1 If you:

(a) have any questions or feedback relating to your Personal Data or our Data Protection Policy;

(b) would like to withdraw your consent to any use of your Personal Data as set out in this Data Protection Policy; or

(c) would like to obtain access and make corrections to your Personal Data records, please contact Silverline as follows:

Write in: Data Protection Officer

Silverline Mobile Pte Ltd
67 Ubi Avenue 1
#05-01 StarHub Green
Singapore 408942

6.2 Please note that if your Personal Data has been provided to us by a third party (e.g. a referrer), you should contact that organisation or individual to make such queries, complaints, and access and correction requests to Silverline on your behalf.

6.3 If you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, Silverline may not be in a position to continue to provide its Products and Services to you, administer any contractual relationship in place, which in turn may also result in the termination of any agreements with Silverline, and your being in breach of your contractual obligations or undertakings. Silverline’s legal rights and remedies in such event are expressly reserved.

7. Governing Law

7.1 This Data Protection Policy and your use of this website shall be governed in all respects by the laws of Singapore.

Last Updated: 10 October 2015

Privacy Policy

Effective Date: 28 June 2013

This Privacy Policy sets forth how and when Silverline Mobile ( (“Silverline”, “we,” “us,” or “our”) collects, uses, shares, and protects information in relation to our mobile services, websites, and any software provided on or in connection with Silverline services (collectively referred to as the “Services”). Our Privacy Policy applies to all visitors, users, and others who access the Services (“Users”). By using Silverline you expressly consent to all terms and conditions of this Privacy Policy and all personal information you provide to Silverline is subject to this Policy and Silverline’s Terms of Service.

Silverline is bringing the smartphone revolution to seniors including providing any easy and safe way to share. Our goal is to provide a platform for seniors who want to share their health and wellnesss information to create collective knowledge about disease, health, and treatments. We know our success in achieving this goal depends on a shared belief in our Openness Philosophy. Being open about one’s health is not for everyone, and we strive, with full transparency, to outline the benefits and risks of being part of this sharing site, including those related to privacy.

This Privacy Policy outlines the type of information Silverline collects from individuals who have registered to join Silverline (“Users”) and how it is shared with other third parties, including, but not limited to, pharmaceutical companies, medical device companies, non-profits, and research institutions (“Partners”).

We reserve the right to modify this policy at any time, and without prior notice, by posting an amended Privacy Policy and terms on this website. We encourage Users to review this policy periodically for any updates.



Shared Data

Some of the information that Users provide about themselves may be shared with the Silverline community, Partners, and others (“Shared Data”). Examples of Shared Data that Users may submit using the Services, including through their health profile (“My Profile”), may include:

  • Biographical information, e.g. photograph, biography, gender, age, location (city, state and country), general notes;
  • Condition/disease information, e.g. diagnosis date, first symptom, family history;
  • Treatment information, e.g. treatment start dates, stop dates, dosages, side effects, treatment evaluations;
  • Symptom information, e.g. severity, duration;
  • Primary and secondary outcome scores over time, e.g. ALSFRS-R, MSRS, PDRS, FVC, PFRS, Mood Map, Quality of Life, weight, InstantMe;
  • Laboratory results, e.g. CD-4 count, viral load, creatinine;
  • Genetic information, e.g. information on individual genes and/or entire genetic scans;
  • Individual and aggregated survey responses;
  • Information shared via free text fields, e.g. the forum, treatment evaluations, surveys, annotations, journals, feeds, adverse event reports; and
  • Connections to other people using our platform, e.g. invited care team member, mentors, feeds, subscriptions.

In the course of using the Services, Users may share information that could be used to reasonably identify them (“Personal Information”), including name, photograph, and email address. When a User chooses to share Personal Information via a free text field (e.g. forum, treatment evaluations, annotations, journals, feeds and adverse event reports) and photos or images, the information shall be treated as Shared Data.


Restricted Data

Some of the information that Users enter into certain fields when registering to use or using the Services will not be shared (“Restricted Data”). The type of Restricted Data that Users may submit at the Site may include:

  • Name, as collected as part of registration or in a User’s Account Information;
  • Email address, as collected and verified as part of registration or in a User’s Account Information;
  • Password, as collected as part of registration or in a User’s Account Information;
  • Mailing address, as collected via email, forms, or private message as part of Users programs such as t-shirt giveaways.
  • Date of birth, as collected in My Profile; and
  • Private messages.

When a Member enters Personal Information, including name and email address, as part of registering to use Silverline, that Personal Information is treated as Restricted Data.



A cookie is a small data file that often includes an anonymous, unique token, which is sent to your browser from a website’s computers and may be stored on your computer’s hard drive. Two types of cookies are required to use the Services:

  • Session Cookies are temporary cookies that remain only until you log out of the website or exit your web browser. Session Cookies do not store any Personal Information, only a unique visitor ID number that may be used to ensure Users are properly authenticated and can view site information.
  • Persistent Cookies remain in the cookie file of your browser for much longer, even after you leave the Site. Persistent Cookies also do not store any Personal Information. Persistent Cookies store preferences that should persist from visit to visit, like “Remember Me,” and a unique token to enable us to understand how Users use the Services (“Site Usage”).



Users should expect that every piece of information they submit (even if it is not currently displayed), except for Restricted Data, may be shared with the community, other seniors, and Partners. Users are encouraged to share health information but should consider that the more information that is entered, the more likely it is that a User could be located or identified.

There are instances where both Shared Data and Restricted Data, including Personal Information, may be used and disclosed including, but not limited to, the following:

  • Silverline uses Shared Data, Restricted Data, and Services Usage internally, as needed, for research, for maintenance and operation of the Services, and to create the best possible tools and functionality for seniors.
  • Silverline may use a User’s data in the case of an emergency or other circumstance that we determine requires a member of the management team to directly contact the User.
  • Silverline may share or disclose a User’s data where required by law or to comply with legal process.
  • In the event Silverline goes through a business transition, such as a merger, acquisition by another organization, or sale of all or a portion of its assets, the Shared Data and Restricted Data, including Personal Information, might be among the assets transferred. Users will be notified via this Services of any such change in ownership or control of Personal Information.


How Shared Data is Used

Shared Data is viewable via My Profile and through aggregated reports that are made available to other Silverline Users. In some instances, this Shared Data is also viewable to those not registered to join Silverline (“Non-members”). We report publicly Shared Data in aggregate, such as the number of seniors on a particular treatment or the number of seniors experiencing a particular symptom (see publicTreatment and Symptom Reports). If a User chooses to designate My Profile as “Public” (see Privacy Settings below), their Shared Data can also be viewed by Non-members and linked with aggregated reports.

In addition to serving the individual needs of our Users, Silverline and its Partners are interested in better understanding the senior experience and improving treatment options and health outcomes for everyone. For example, we may look at questions such as, “Do certain treatments work better for some types of people versus others?” Silverline provides Shared Data, in individual and aggregate format, to Partners and other third parties for use in scientific research and market research. When selling this information, Silverline removes User’s Restricted Data to reduce the likelihood of re-identification prior to sharing information with Partners.

Silverline also provides a voluntary opt-in service to allow Partners to directly communicate with Users through our system.

Silverline may also periodically ask Users to complete short surveys about their experiences (including questions about products and services). Survey responses are analyzed, combined with Users’ Shared Data and shared with and/or sold to Partners. Member participation in these surveys is not required, and refusal to do so will not impact a User’s experience on the Services.

Silverline may also report individual adverse event and drug safety information to the FDA, CDC, and/or other regulatory bodies (U.S. and international) as well as directly to pharmaceutical and biotechnology companies. Silverline does not provide Restricted Data to such regulatory bodies, although we reserve the right to contact Users for follow-up at the request of agencies or Partners. The information Silverline reports includes, but is not limited to, all of the information about the Users and/or free text or images on the forums or evaluations, which may include Shared Data. In addition, certain areas within our Services are provided with the support of Partners. These Partners may have adverse event reporting requirements that relate to regulated products that are used by Users of our community, and Silverline assists such Partners with reporting adverse events to regulatory agencies.

Silverline, like most Internet communities, is a public forum, and Users acknowledge and accept that any information shared through free text or images might be connected to Users’ Shared Data (which may be shared with, sold to, or displayed for others). For example, if a User puts his or her name (or other Personal Information) into a free text field like the biography, forum, journals or annotations, the User should know this information may be included in what is shared with, displayed for, or sold to Partners.


How Restricted Data is Used

Restricted Data is not automatically shared with, sold to, or displayed for other Users or Partners. Specific instances where Restricted Data may be used include, but are not limited to, the following:

  • If a User provides a date of birth, the User’s current age will be viewable via My Profile;
  • If a User registers with, or is switched to, an official doctor and research account, the User’s full name and affiliation will be viewable via My Profile;
  • If a User chooses the Public privacy setting (see below), Silverline and others may use public profiles in reports, conference presentations, media mentions, etc.;
  • If a User agrees to participate in a media interview (as arranged by User), Silverline will share the contact information the User provides (i.e. name, email, telephone) with the reporter for the purpose of conducting an interview;
  • If a User OPTS IN to a public registry (e.g. the Silverline ALS Public Registry), Silverline will display the User’s name and some Shared Data and/or Restricted Data as part of this registry (which is viewable by anyone on the Internet);
  • If a User explicitly opts in to have their Restricted Data shared with a Partner, Silverline will share the information as instructed by the User (e.g. co-registration with a non-profit);
  • If a User makes a request, Silverline may use Restricted Data, including sharing the User’s Restricted Data with software/service vendors, for the purpose of fulfilling the request. Examples include requesting to receive the company newsletter via email, requesting an email response from the Silverline support team, and requesting a t-shirt be mailed to the User’s residence.



There are two privacy levels a User may choose for participation at Silverline:

  • Visible: Only Silverline Users can see My Profile and user name, and can contact you through Silverline;
  • Public: Non-members and Users can see My Profile and user name, but only Silverline Users can contact you through Silverline.

Users may change their privacy level at any time. Public profiles may be indexed or stored by Internet search engines (e.g. Google) or other independent sites, which means a User’s Shared Data, including any Personal Information shared, may come up in the search results by anyone on the Internet, even after switching privacy levels.

Because the value of Silverline is in sharing one’s experiences to help others, we hope that Users feel comfortable enough to make their profiles as public as possible.



Silverline cannot guarantee the identity of any other Users with whom a User may interact in the course of using the Services or who may have access to a User’s Shared Data. Additionally, we cannot guarantee the authenticity of any data that User may provide about themselves.

Finally, User should know that Silverline takes commercially reasonable technical precautions to help keep Users data secure.



While our goal is to help seniors improve health outcomes, there are no certain benefits to using our services. However, keeping track of personal well-being, treatments, and symptoms has been shown to be helpful in improving overall health.

There are also no known risks to using our services, but there is a possibility that users may feel uncomfortable sharing information online. It is possible that a user could be identified using information shared on Silverline (and/or in conjunction with other data sources). A User could be discriminated against or experience repercussions as a result of the information shared. For example, it is possible that employers, insurance companies, or others may discriminate based on health information.

Users should understand that anyone can register at Silverline and view the Shared Data in the system. If you are reading this Privacy Policy because you have access to the Personal Information of a service participant, we urge you to recognize and fulfill your responsibility to protect the privacy of that person.

In using the Service, Users are free to skip any non-required questions or data fields that make them feel uncomfortable. Users are also free to stop using this service at any time. If a User chooses to deactivate his/her account, Silverline will not display or sell the data in that account as of the date of deactivation. However, the User’s data will remain in the system for auditing purposes, and research conducted prior to the deactivation of a User’s account will still include the User’s data.



Silverline complies with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. Silverline has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Silverline’s certification, please visit



If you have questions or comments about our Privacy Policy, please let us know, or contact us at:

Silverline Mobile Pte Ltd
237 South Bridge Rd
Singapore 058786