Privacy Policy

Who we are

Tonik Asia Group Sdn Bhd (TAGS) is one of Asia’s largest integrated physical therapy healthcare groups, encompassing TAGS clinics across Malaysia. 

The purpose of this document (“Data Privacy Policy”) is to inform you of how Tonik Asia Group Sdn Bhd, including but not limited to its subsidiaries, related corporations or any of its affiliates (collectively, the “Tonik Asia Group”, “us”, “we” or “our”) manages Personal Data (as defined below) which is subject to the Malaysia Personal Data Protection Act 2010 (Act 709) (“the Act”).

Please take a moment to read this Data Privacy 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 the Tonik Asia Group, as well as its representatives and/or agents collecting, using, disclosing and sharing amongst themselves your Personal Data, and disclosing such Personal Data to our authorised service providers and relevant third parties in the manner set forth in this Data Privacy Policy. 

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

Tonik Asia Group may from time to time update this Data Privacy Policy to ensure that this Data Privacy 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 this Data Privacy Policy as updated from time to time on our website. 

Please check back regularly for updated information on the handling of your Personal Data. 

This Data Privacy Policy was first published on 1st January 2021.

1. Personal Data

1. In this Data Privacy 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.

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, personal health information 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:

1. when you submit any form, including but not limited to customer inquiry forms or other forms relating to any of our services;
2. when you enter into any agreement or provide other documentation or information in respect of your interactions with us, or when you use our services;
3. when you interact with our staff, including customer service officers, for example, via telephone calls (which may be recorded), letters, fax, face-to-face meetings, text messages, social media platforms and emails;
4. when you interact with us via our websites or use services on our websites;
5. when you request that we contact you or request that you be included in an email or other mailing list;
6. when you respond to our promotions, initiatives or to any request for additional Personal Data;
7. when you submit an employment application or when you provide documents or information including your resume and/or CVs in connection with any appointment as an officer, director, representative or any other position;
8. when your images are captured by us via CCTV cameras while you are within our premises, or via photographs or videos taken by us or our representatives when you attend our events;
9. when you are contacted by, and respond to, our marketing representatives and customer service officers;
10. when we seek information about you and receive your Personal Data in connection with your relationship with us, including for our products and services or job applications, for example, from business partners, public agencies, your ex-employer, referral intermediaries and the relevant authorities; and/or
11. 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 paragraph 6 below for information on cookies and other technologies which we have implemented on our website. We do not, at our website, automatically collect Personal Data unless you provide such information to us.

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, or delays in providing you with products and services you have requested, or processing your applications.

2.5 We will never knowingly collect or solicit Personal Information from individuals under the age of eighteen (18) without first obtaining verifiable parental consent. If you are under the age of 18 you should not provide information to us. If we become aware that a person under 18 has provided Personal Information to us without verifiable parental consent (as may be the case where the information is provided via our website), we will remove such Personal Information from our files.

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

3.1 Generally, Tonik Asia Group collects, uses and discloses your Personal Data for the following purposes: 

1. responding to, processing and handling your queries, feedback, complaints and requests;
2. verifying your identity;
3. managing and planning the administrative and business operations of Tonik Asia Group and complying with internal policies and procedures;
4. facilitating business asset transactions (which may extend to any mergers, acquisitions or asset sales);
5. requesting feedback or participation in surveys, as well as conducting market research and/or analysis for statistical, profiling or other purposes for us to design our services, understand customer behaviour, preferences and market trends, and to review, develop and improve the quality of our products and services;
6. matching any Personal Data held which relates to you for any of the purposes listed herein;
7. preventing, detecting and investigating crime and analysing and managing commercial risks;
8. managing the safety and security of our premises and services (including but not limited to carrying out CCTV surveillance and conducting security clearances);
9. monitoring or recording phone calls and customer-facing interactions for quality assurance, employee training and performance evaluation and identity verification purposes;
10. in connection with any claims, actions or proceedings (including but not limited to drafting and reviewing documents, transaction documentation, obtaining legal advice, and facilitating dispute resolution), and/or protecting and enforcing our contractual and legal rights and obligations;
11. conducting any form of investigations including but not related to those relating to disputes, billing, fraud, offences, prosecutions etc;
12. 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 Tonik Asia Group (including but not limited to responding to regulatory complaints, disclosing to regulatory bodies and conducting audit checks, due diligence and investigations); and/or
13. purposes which are reasonably related to the aforesaid.
14. marketing promotions of our facilities, services, doctors, packages, promotion, etc

3.2 In addition, Tonik Asia Group collects, uses and discloses your Personal Data for the following purposes depending on the nature of our relationship:

1. If you are a prospective, current or former patient or customer of Tonik Asia Group:
   1. providing customer service and support (including but not limited to customer relationship management, processing your admissions, processing and settlement of bills, facilitating, arranging and providing reminders of your appointments, medical examinations, screenings or checkups, applying for visas on your behalf, contacting you regarding medical reports and results, providing follow-up calls, providing you with administrative support, and administering insurance coverage and processing insurance claims);
   2. administering and processing your requests including creating and maintaining profiles of our customers in our system database for administrative purposes (including tracking your attendance at various Parkway Pantai Group facilities);
   3. personalising your experience at Tonik Asia Group’s touchpoints and conducting market research, understanding and analysing customer behaviour, location, preferences and demographics in order to improve our service offerings;
   4. administering medical care (including keeping patient case and procedure records, providing medication, ordering medical tests, reports and biological samples, and facilitating internet-based tele-consultations and correspondence with doctors);
   5. liaising with third party specialist doctors, clinics, hospitals and/or medical institutions in relation to your medical care (including by providing them with access to your medical records);
   6. if you use our mobile applications, including WhatsApp and SMS or online registration, including email and payments systems, displaying your medical data, sending you health-related notifications, and facilitating the provision of our services to you;
   7. administering debt recovery and debt management; and/or
   8. purposes which are reasonably related to the aforesaid.
2. If you are a nominated caregiver or next-of-kin of a patient or customer of Tonik Asia Group:
   1. informing you of the patient’s medical status and whereabouts; and/or
   2. purposes which are reasonably related to the aforesaid.
3. If you are an employee, officer or owner of an external service provider or vendor outsourced or prospected by Tonik Asia Group:
   1. assessing your organisation’s suitability as an external service provider or vendor for Tonik Asia Group;
   2. managing project tenders and quotations, processing orders or managing the supply of goods and services;
   3. creating and maintaining profiles of our service providers and vendors in our system database;
   4. processing and payment of vendor invoices and bills;
   5. facilities management (including but not limited to issuing visitor access passes and facilitating security clearance); and/or
   6. purposes which are reasonably related to the aforesaid.
4. If you submit an application to us as a candidate for employment, internships or scholarships:
   1. conducting interviews;
   2. processing your application (including but not limited to pre-recruitment checks involving your qualifications and facilitating interviews);
   3. obtaining references and for background screening;
   4. assessing your suitability for the position applied for;
   5. enrolling successful candidates as our employees and facilitating human resource planning and management (including but not limited to preparing letters of employment, name cards and building access passes); and/or
   6. purposes which are reasonably related to the aforesaid.
5. If you are an existing employee of Tonik Asia Group:
   1. providing remuneration, reviewing salaries and bonuses, conducting salary benchmarking reviews, staff appraisals and evaluation, as well as recognising individuals for their services and conferring awards;
   2. staff orientation and entry processing;
   3. administrative and support processes relating to your employment, including its management and termination, as well as staff benefits, including travel, manpower, business continuity and logistics management or support, processing expense claims, medical insurance applications, medical screenings and immunisations, leave administration, long-term incentive plans, training, learning and talent development, and planning and organising corporate events;
   4. providing you with tools and/or facilities to enable or facilitate the performance of your duties;
   5. facilitating professional accreditation and complying with compliance audits;
   6. compiling and publishing internal directories and emergency contact lists for business continuity;
   7. managing corporate social responsibility projects;
   8. conducting analytics and research for human resource planning and management, and for us to review, develop, optimise and improve work-related practices, environment and productivity;
   9. ensuring that the administrative and business operations of Tonik Asia Group function in a secure, efficient and effective manner (including but not limited to examining or monitoring any computer software and/or hardware installed within Tonik Asia Group, your work emails and personal digital and storage devices);
   10. compliance with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities (including but not limited to disclosures to regulatory bodies, conducting audit checks or surveillance and investigation);
   11. administering cessation processes; and/or
   12. any other purposes relating to any of the above.
6. If you are a specialist doctor at Tonik Asia Group:
   1. facilitating professional accreditation and complying with compliance audits;
   2. facilitating disbursements of fees collected on your behalf;
   3. managing and providing you with tools, services and/or facilities to enable or facilitate the performance of your duties;
   4. planning and organising events for specialists;
   5. creating and maintaining profiles of our accredited doctors in our system database;
   6. facilities management (including but not limited to issuing visitor access passes and facilitating security clearance); and/or
   7. any other purposes relating to any of the above.

3.3 Furthermore, where permitted under the Act, Tonik Asia Group may also collect, use and disclose your Personal Data for the following “Additional Purposes”:

1. taking or filming photographs and videos for corporate publicity or marketing purposes, and featuring your photographs and/or testimonials in our articles and publicity materials;
2. providing or marketing services and benefits to you, including promotions, service upgrades, loyalty, reward and/or membership programmes;
3. organising roadshows, tours, campaigns (including health talks, health check or vaccination campaigns) and promotional or events and administering contests and competitions;
4. matching Personal Data with other data collected for other purposes and from other sources (including third parties) in connection with the provision or offering of services;
5. sending you details of services, clinic updates, health-related information and rewards, either to our customers generally, or which we have identified may be of interest to you;
6. conducting market research, aggregating and analysing customer profiles and data to determine health-related patterns and trends, understanding and analysing customer behaviour, location, preferences and demographics for us to offer you other products and services as well as special offers and marketing programmes which may be relevant to your preferences and profile; and/or
7. purposes which are reasonably related to the aforesaid.

3.4 If you have provided us with your telephone number(s) and have indicated that you consent to receiving marketing or promotional information via your telephone number(s), then from time to time, Tonik Asia Group may contact you using such telephone number(s) (including via voice calls, text, social media application, fax or other means) with information about our products and services.

3.5 In relation to particular 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 21 calendar 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.

3.8 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 services that you have requested or purchased from Tonik Asia Group.

4. Disclosure of personal data

4.1 Tonik Asia Group 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 entities or parties, whether they are located overseas or in Malaysia:

1. 1. 1. amongst the Tonik Asia Group members and affiliates (including their staff and medical practitioners);
      2. third party doctors, clinics, hospitals and/or medical institutions;
      3. companies providing services relating to insurance to Tonik Asia Group;
      4. agents, contractors, sub-contractors or third party service providers who provide operational services to Tonik Asia Group, such as courier services, telecommunications, information technology, payment, printing, billing, debt recovery, processing, technical services, transportation, training, market research, call centre, security, or other services to Tonik Asia Group;
      5. vendors or third party service providers and our marketing and business partners in connection with marketing promotions, products and services;
      6. our corporate clients;
      7. 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);
      8. external banks, credit card companies, other financial institutions and their respective service providers;
      9. our professional advisers such as consultants, auditors and lawyers;
      10. relevant government ministries, 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 (including the Ministry of Health); and/or
      11. any other party to whom you authorise us to disclose your Personal Data to.