PRIVACY POLICY

1.1  Welcome to www.healthbeta.co , cloud.healthbeta.co and/or the BETA mobile application operated by Health BETA Pte. Ltd. and/or its affiliates (“BETA”). BETA takes the privacy of its Users seriously and is committed to respecting the privacy rights and concerns of all Users of the Platform and/or the Services.

1.2  This Privacy Policy is designed to assist the User in understanding how BETA collects, uses, discloses and/or processes (a) the Personal Data and information the User has provided to BETA; and/or (b) the Personal Data and information that BETA possesses in relation to the User.

1.3  BETA may update this Privacy Policy from time to time. Any changes made to the Privacy Policy in the future will be reflected on the Platform. Where permissible under Data Protection Laws, the User’s continued use of the Services or access to the Platform following the modifications, updates or amendments to this Privacy Policy (whether or not the User has reviewed such document) shall constitute the User’s acknowledgment and acceptance of the changes BETA has made to this Privacy Policy. The User agrees that it is the User’s responsibility to review and check the Privacy Policy frequently to see if any updates or changes have been made to this Privacy Policy.

1.4  This Privacy Policy applies in conjunction with other notices, contractual clauses, consent clauses that apply in relation to the collection, storage, use, disclosure and/or processing of the User’s Personal Data by BETA and is not intended to override those notices or clauses unless BETA expressly states otherwise.

1.5  In this Privacy Policy, unless the context otherwise requires, the following general definitions shall apply:

(a)  “Data Protection Laws” means applicable laws and regulations relating to the use and/or processing of personally identifiable information and data and privacy.

(b)  “Information”means, collectively, all web pages on the Platform, including the information, images, links, sounds, graphics, video, health data, medical data, software, applications, and other materials displayed or made available on the Platform and the functionalities or services provided on the Platform.

(c)  “Personal Data” means:

(i)  data, whether true or not, about an individual who can be identified:

 (1)  from that data; or

 (2)  from that data and other information to which BETA has or are likely to have access; and

(ii)   any data that is analogous to the foregoing, as defined in Data Protection Laws.

(d)  “Platform” means (a) both the cloud, web and mobile versions of the website operated and/or owned by BETA which is presently located at the following URL: cloud.healthbeta.co  and www.healthbeta.co ; and (b) the mobile applications made available from time to time by BETA, including the iOS and Android versions.

(e)  “Purposes” means the purposes for which BETA collects the User’s Personal Data as set out in this Privacy Policy.

(f)  “Services” means the website features, application features for mobile, functions and services provided from time to time through the Platform.

(g)  “Physician” or “Technician” means qualified medical professionals licensed to conduct medical practices.

(h)  “Users” means the users of the Platform and/or the Services, each a “User”.

(a) The Personal Data and information that BETA collects include but is not limited to the following:

(i) name;

(ii) email address;

(iii) mobile or telephone number;

(iv) date of birth;

(v) government issued identification or other like information National identification number;

(vi) ethnicity (race);

(vii) gender;

(viii) billing and/or delivery address;

(ix) information sent by or associated with the device(s) used to access the Platform and/or the Services;

(x) information about the User’s network, including the User’s contact list when the User share permissions on the User’s device, and the people and accounts the User interacts with;

(xi) medical and health data and records;

(xii) photographs or audio or video recordings;

(xiii) marketing and communications data, such as the User’s preferences in receiving marketing from BETA and third parties, the User’s communication preferences and history of communications with BETA, BETA’s service providers, and other third parties;

(xiv) usage and transaction data, including details about the User’s searches, orders, the advertising and content the User interacts with on the Platform, and other products and services related to the User;

(xv) location data;

(xvi) any other information about the User when the User signs up to use the Services or Platform, and when the User uses the Services or Platform, as well as information related to how the User uses the Services or Platform; and

(xvii) aggregate data on content the User engages with.

(b) The User agrees not to submit any information to BETA which is inaccurate or misleading, and the User agrees to inform BETA of any inaccuracies or changes to such information. BETA reserves the right at it sole discretion to require further documentation to verify any information provided by the User.

(c) If the User does not want BETA to collect the aforementioned information or Personal Data, the User may opt out at any time by notifying BETA’s Data Protection Officer at support@healthbeta.co. Further information on opting out can be found in this Privacy Policy.

(a) BETA may collect the User’s Personal Data and information:

(i) when the User registers and/or uses the Services or Platform, or open an account with BETA;

(ii) when the User submits any form, including, but not limited to, application forms or other forms relating to the Services, whether online or by way of a physical form;

(iii) when the User enters into any agreement or provide other documentation or information in respect of the User’s interactions with BETA, or when the User uses the Services;

(iv) when the User interacts with BETA, such as via telephone calls (which may be recorded), letters, fax, face-to-face meetings, social media platforms and emails, including when the User interacts with BETA’s customer service agents;

(v) when the User grants permissions on the User’s device to share information with the Platform;

(vi) when the User carry out transactions through the Services;

(vii) when the User list products and/or services for sale on the Platform and conduct transactions with other Users in respect of the sale and purchase of those products and/or services;

(viii) when the User activates or uses any payment related functions available on the Platform or provided by BETA’s third-party service

(ix) when the User uses the internal messaging and/or chat function on the Platform; providers;

(x) when the User provides BETA with feedback or complaints;

(xi) when the User subscribes to BETA’s publications or marketing collaterals;

(xii) when the User registers for a competition, promotion or survey;

(xiii) when the User participates in any activity or campaign on the Platform;

(xiv) when any other User posts any comments on the contents the User has uploaded on the Platform, or when the User posts any comments on other Users’ content uploaded on the Platform;

(xv) when a third-party lodge a complaint against the User or the content the User has posted on the Platform; and

(xvi) when the User submits the User’s Personal Data to us for any reason. The above does not purport to be exhaustive and sets out some common instances of when Personal Data and information about the User may be collected.

(b) BETA may collect Personal Data and information about the User from the User directly, BETA’s affiliates, third parties, and from other sources, including without limitation business partners (such as test laboratories, logistics or payment service providers), credit bureaus or scoring agencies, marketing service providers or partners, referral or loyalty programs, other users of the Services or publicly available or governmental sources of data.

(c) During the course of the User’s use of the Platform and BETA’s provision of the Services, the User agrees that the User has provided consent (whether to BETA or the third party) to the transfer of the User’s Personal Data from third parties and BETA’s affiliates for the Purposes.

(d) BETA will only be able to collect certain categories of Personal Data if the User voluntarily provides the Personal Data to BETA or as otherwise provided for under this Privacy Policy. If the User chooses not to provide such Personal Data to BETA or subsequently withdraws the User’s consent to use of the User’s Personal Data, BETA may not be able to provide the User with certain features or functionality for the Services or the Platform.

(e) In some situations, the User may provide Personal Data of other individuals to BETA (such as the User’s family members or friends or persons in the User’s contact list). If the User provides BETA with such Personal Data, the User represents and warrants that the User has obtained their consent for their Personal Data to be processed in accordance with this Privacy Policy.

(a) As with most websites and mobile applications, the User’s device sends information which may include data about the User that gets logged by a web server when the User browses the Platform. This typically includes without limitation the User’s device’s Internet Protocol (“IP”) address, computer/mobile device operating system and browser type, type of mobile device, the characteristics of the mobile device, the unique device identifier (“UDID”) or mobile equipment identifier (“MEID”) for the User’s mobile device, the address of a referring web site (if any), the pages the User visit on the Platform and the times of visit, and sometimes a “cookie” (which can be disabled using the User’s browser preferences) record the User’s last access to the Platform. If the User is logged in, this information is associated with the User’s personal account. The information is also included in anonymous statistics to allow BETA to understand how Users use the Platform.

(b) The User’s mobile applications may collect precise information about the location of the User’s mobile device using technologies such as GPS, Wi-Fi, etc. BETA collects, uses, discloses and/or processes this information for one or more Purposes including, without limitation, location-based services that the User requests or to deliver relevant content to the User based on the User’s location or to allow the User to share the User’s location to other Users as part of the Services. For most mobile devices, the User would be able to withdraw the User’s permission for BETA to acquire this information on the User’s location through the User’s device settings.

(c) As and when the User views pages on the User’s website or mobile application, when the User watches content and advertising and access other software on the Platform or through the Services, such information may be sent to BETA (including, without limitation, IP Address, operating system, information on the content, advertisement viewed and/or software installed by the Services and the Platform from time to time).

(a) BETA or BETA’s authorized service providers and advertising partners may from time-to-time use “cookies” or other features to allow BETA or third parties to collect or share information in connection with the User’s use of the Services or Platform. These features help BETA improve the Platform and the Services it offers, help BETA offer new services and features, and/or enable BETA and BETA’s advertising partners serve more relevant content to the User, including through remarketing. “Cookies” are identifiers that are stored on the User’s computer or mobile device that record data about computer or device, how and when the Services or Platform are used or visited, by how many people and other activity within the Platform. BETA may link cookie information to Personal Data. Cookies also link to information regarding the items the User has selected for purchase and web pages the User has viewed. This information is used to keep track of the User’s shopping cart, to deliver content specific to the User’s interests, to enable BETA’s third-party advertising partners to serve advertisements on sites across the internet, and to conduct data analysis and to monitor usage of the Services.

(b) The User may refuse the use of cookies by selecting the appropriate settings on the User’s browser or device. However, refusing the use of such cookies may affect the full functionality of the Platform or the Services.

(a) to facilitate the User’s use of the Services or access to the Platform;

(i) to allow Physician and Technician to review User’s medical records online;

(ii) to allow Physician and Technician to generate medical reports using the Platform;

(iii) to allow Physician and Technician to make referral during the required circumstances;

(b) to administer the online account that the User may have set up with BETA;

(c) to conduct analytics, research, business and development:

(i) to better understand user experience with the Services and the Platform;

(ii) to improve the layout or content of the pages of the Platform and customise them for users;

(iii) to identify visitors on the Platform;

(iv) to conduct surveys, including carrying out research on the Users’ demographics and behaviour to improve BETA current technology (e.g. physical activities, diet intake, sleeping habits, etc) via machine learning or other means;

(v) to derive further attributes relating to the User based on Personal Data provided by the User (whether to BETA or third parties), in order to provide the User with more targeted and/or relevant information;

(vi) to conduct data analysis, testing and research, monitoring and analysing usage and activity trends; and

(vii) to further develop the Platform and the Services.

(d) for legal and operational purposes, including:

(i) to ascertain the User’s identity in connection with fraud detection purposes;

(ii) to compare information, and verify with third parties in order to ensure that the information is accurate;

(iii) to process any complaints, feedback, enforcement action and take-down requests in relation to any content the User has uploaded to the Platform;

(iv) to produce statistics and research for internal and statutory reporting and/or record-keeping requirements;

(v) to store, host, back up the User’s Personal Data for operational, legal or business purposes;

(vi) to prevent or investigate any actual or suspected violations of the Terms of Service, Privacy Policy or any of our policies, fraud, unlawful activity, omission or misconduct, whether relating to the User’s use of the Services or any other matter arising from the User’s relationship with BETA;

(vii) to perform due diligence checks;

(viii) to comply with legal and regulatory requirements (including, where applicable, the display of the User’s name, contact details and company details), including any law enforcement requests, requests by any governmental or regulatory authority having jurisdiction over BETA, in connection with any legal proceedings, or as otherwise deemed necessary by BETA; and

(ix) to protect the life, health or personal safety of BETA’s employees, the Users and/or the public.

(e) to respond to legal processes or to comply with or as required by any applicable law, governmental or regulatory requirements of any relevant jurisdiction or where BETA has a good faith belief that such disclosure is necessary, including, without limitation, meeting the requirements to make disclosure under the requirements of any law binding on BETA (including, where applicable, the display of the User’s name, contact details and company details);

(f) to respond to any threatened or actual claims asserted against BETA or other claim that any Information violates the rights of third parties;

(g) to store, host, back up (whether for disaster recovery or otherwise) of the User’s Personal Data, whether within or outside of the User’s jurisdiction; or

(h) any other purpose to which the User’s consent has been obtained, in compliance with BETA obligations under Data Protection Laws, including to notify the User at the time of obtaining the User’s consent, (collectively, the “Purposes”).

(a) BETA’s subsidiaries, affiliates and related corporations;

(b) the User has transacted with or interacted with on the Platform or in connection with the User’s use of the Services for the above-stated Purposes;

(c) other Users for one or more of the above-stated Purposes;

(d) contractors, agents, service providers and other third parties BETA uses to support BETA’s business. These include but are not limited to those parties which provide administrative or other services to BETA such as mailing houses, logistics service providers, financial services providers, advertising and marketing partners, telecommunication companies, information technology companies, and data centres;

(e) governmental or regulatory authorities having jurisdiction over BETA or as otherwise permitted under Clause 3.2;

(f) a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of BETA’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which Personal Data held by BETA in relation to the Users is among the assets transferred; or to a counterparty in a business asset transaction that BETA or any of its affiliates or related corporations is involved in; and

(g) third parties to whom disclosure by us is for one or more of the Purposes and such third parties would in turn be collecting and processing the User’s Personal Data for one or more of the Purposes.

In the event of any questions or concerns in relation to the privacy practices of BETA, please contact BETA’s Data Protection Officer at support@healthbeta.co.