INTELLECT COMPANY PTE. LTD. PRIVACY POLICY

Last Updated: 20th December 2024

Table of Content

Introduction
Recital
Third Parties We Use
Modification/ or Changes
Obtaining Consent
Collection and Use of Personal Data
Enterprise Service
De-identified Information
Processing of Personal Data
Storage and Location of Personal Data
Security
Disclosure of Personal Data
Accuracy of Personal Data
Opt-Out
Your Rights and Applicable Laws
Health Insurance Portability and Accountability Act (HIPAA) of 1996 Compliance (USA)
General Data Protection Regulations (GDPR) Compliance (EU)
Contact Us

1. Introduction

At Intellect, one of our main priorities is the privacy of our visitors and users. This Privacy Policy describes how your personal information is collected, used, and shared when you visit and use our website, mobile, web and desktop applications, wearable technologies, dashboards, extension, and services (collectively “Our Platform”). By using our platform in any manner, including but not limited to visiting, browsing, creating an account, or logging into the platform, you agree to observe and be bound by this policy and the additional terms and conditions referred to on this platform or available by hyperlink. This policy complies with the following global legal regulations and their updated version:

Australia’s Privacy Act 1988;
Bangladesh’s Data Protection Act 2022;
China’s Personal Information Protection Law 2021;
Clause 24 of the Constitution of the Republic of Fiji 2013;
General Data Protection Regulations (GDPR),
Health Insurance Portability and Accountability Act (HIPAA);
Hong Kong’s Personal Data (Privacy) Ordinance 1996;
India’s Digital Personal Data Protection Act;
Indonesia’s Personal Data Protection Act 2022;
Japan’s Protection of Personal Information Act 2003;
Malaysian Personal Data Protection Act 2010;
Maldives data protection rules and laws;
Mexico’s Protection of Personal Data 2010;
Myanmar’s Electronic Transactions Law 2003;
New Zealand’s Privacy Act 2020;
Papua New Guinea’s Cybercrime Code Act of 2016;
Philippines’s Personal Data Protection Act 2012;
Singapore’s Personal Data Protection Act 2012 (PDPA);
South Korea’s Personal Information Protection Act 2012;
Sri Lanka’s Personal Data Protection Act 2022;
Taiwan’s Personal Data Protection Act 1995;
Thailand’s Personal Data Protection Act 2022;
The Privacy Act of 1974 of the USA;
Vietnam’s Personal Data Protection Act 2023;
El Salvador’s Personal Data Protection Act;
Honduras Law for the Protection of Confidential Personal Data;
Costa Rica Personal Data No. 8968 of 2011;
Argentina’s Personal Data Protection Act No. 25.326 of 2000;
The Brazilian General Data Protection Law (LGPD);
Panama’s Law No. 81 on Personal Data Protection 2019;
Chile’s Law No. 19,628/1999 – Personal Data Protection Law;
Nicaragua’s Law on Personal Data Protection No. 787;
Dominican Republic’s Law No. 172-13 on Protection of Data;
Belize Data Protection Act, 2021;
Peru’s Law No. 29733 on the Protection of Personal Data;
Uruguay’s Law No. 18.331 on the Protection of Personal Data;
Cuba’s Data Protection Regulations;
Guyana’s The Data Protection Act No.18 of 2023;
California Consumer Privacy Act of 2018 (CCPA) and
other related privacy legislations.

2. Recital:

The Employer or main contracting Party refers to our Client (which may be a Company/Corporation/Organization) who enters into a binding contract to create accounts on our platform and enrol its employees on a selected program.

Third-party providers refer to providers, agents, and affiliates of both parties to whom we may disclose personal information relating to our users. This shall include but is not limited to payment providers, insurance companies, cloud communication platforms, and in the case of an emergency, hospitals, designated health practitioners (for example, a medical doctor), referred personnel who are specialists in their fields (for example, psychiatry), the Court of Law and governing authorities. Please be advised that Intellect shall not bear responsibility for any liabilities arising from actions including, but not limited to, financial losses, negligence, misconduct, fraud, personal injury, or death caused by any third-party providers as well as those specifically referenced herein. Third-party providers are required to adhere to the established terms and conditions of this Policy.

Intellect to the best of our abilities shall ensure that all of Intellect’s employees and/or agents and service providers accessing your personal information are aware of the purposes it will be used for and shall not process personal information in a manner that is inconsistent with relevant data protection laws and regulations.

3. Third Parties We Use

The following are third parties that we use to store and process data:

We use Google Analytics to track usage patterns on our Platform in order to improve our services.
We use Moengage to send emails and notifications on our Platform to Platform users regarding their care.
We use Moengage to send Newsletters only to customers who have consented specifically to receive the newsletter.
We use Twilio, Zoom and Daily.co for any calls and chats, such as coaching sessions, that are done through our App.
We use Onesignal to create notifications on our Platform.
We use Amazon Web Services to store and process data obtained through our Platform.
We might engage Third Party Insurance Providers to provide our services to you.
Enterprise Service: If you are an employee, we might use Third Party Insurance providers to engage your Employer to provide our services to you

4. Modification/ or Changes

We may revise and update this privacy policy from time to time in order to reflect changes to our practices or for other operational, legal or regulatory reasons. Such updates shall be communicated to you for example via an email update. Your continued use of our platform after recent updates to the Privacy Policy will constitute your acknowledgement of the modifications and your consent to abide by and be bound by the modified Privacy Policy.

5. Obtaining Consent

By submitting your Personal Information, you consent to use that information as set out in this policy. This shall include and not be limited to disclosure to third-party providers referred to in this policy.

6. Collection and Use of Personal Data

Information We Collect
“Personal Information” or “Personal Data” is non-public information that is personally identifiable to you and obtained for us to provide you with the prescribed services within our platform. This may include, but is not limited to your full name; gender; age; country; email address; city. Through our Platform, services and other surveys and questionnaires provided to you, we collect Personal Information that you voluntarily provide to us, our behavioural health coaches, holistic coaches and clinicians on our platform, including information about your health and personal goals. We also automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device; Usage Data; Universally unique identifier (UUID); Crash information; device information; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); geography/region; number of users; number of sessions; session duration; In-app purchases; Application opens; Application updates; first launches; operating systems. We may also collect personal information classified as Personal Health Information (PHI) under certain privacy laws. Within this Privacy Policy, personally identifiable information and PHI shall be referred to as Personal Information.

7. Enterprise Service

Despite the collection of Personal Information mentioned above, we may collect additional information when your Employer signs you up on our platform or when you use our platform. We may ask either you or your Employer to provide us with certain personal information that can be used to contact or identify you. This information may include your suffix, sex, employee ID (if applicable), department, title, and job code (if applicable) which shall form part of, and collectively referred to as Personal Information or Personal Data.

How We Use the Information About You
We gather this information from you and your Employer to allow us to:

Process your registration;
Process your subscription;
Provide access to the services we offer on our platform including webinars, behavioural health coaching sessions, and user support;
Browse our website through your browser’s cookies;
Deliver through emails our special offers on services we think may be of interest to you;
Contact you to ask for your feedback and comment on our services;
Notify you of all assigned or impending tasks on our platform;
Process your Payment.

8. De-identified Information

Also, we may de-identify users’ information and statistics to form de-identified information for the purposes of monitoring usage of our Platform and website in order to help us to develop our website and our services, provide insight to the Employers on user’s performance and stress level on workloads, assess mental and risk impact of users, and evaluate insurance coverage. We may also provide such de-identified information to third parties including academic journals and external publications for research and analysis purposes. This may be different from our use to monitor and improve our services. These statistics will not include information that can be used to identify you.

9. Processing of Personal Data

At Intellect, we ensure that we process Personal Information collected from you only for the purposes necessary for providing services based on relevant binding agreements and contracts with the Employer. In addition, the basis on which we process information about you may also include the following –
Information we process with your consent: Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our platform, you provide your consent to us to process information that may be Personal Information. Wherever possible, we aim to obtain your explicit consent to process this information, for example, by asking you to agree to our use of cookies. We continue to process your information on this basis until you withdraw your consent, or it can be reasonably assumed that your consent no longer exists.

Information we process for the purposes of legitimate interests: We may process information on the basis there is a legitimate interest, either to you or to us, in doing so. When we process your information on this basis, we do so after having given careful consideration to whether the same objective could be achieved through other means; whether processing (or not processing) might cause you harm; whether you would expect us to process your data; and whether you would consider it reasonable to do so.

For example, we may process your data on this basis for the purposes of:

record-keeping for the proper and necessary administration of our organisation.
responding to unsolicited communication from you to which we believe you would expect a response.
protecting and asserting the legal rights of any party.
insuring against or obtaining professional advice that is required to manage risk.
protecting your interests where we believe we have a duty to do so.

Information we process because we have a legal obligation: Sometimes, we must process your information in order to comply with a statutory obligation. For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order. This may include your Personal Information.

Cookies: Our Platform uses “Cookies” to identify the areas of the Platform that you have visited. A cookie is a small piece of data stored on your computer or mobile device by your web browser. We use cookies to personalise the Content that you see on our Platform. Most web browsers can be set to disable the use of Cookies. However, if you disable Cookies, you may not be able to access functionality on our Platform correctly or at all. We never extract Personal Information in Cookies.

Log Files: Log files track actions occurring on our Platform, including but not limited to our App and Website, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.

Please note that our Platform offers “Do Not Track” features to manage the Personal Information we track and process.

10. Storage and Location of Personal Data

We store your personal data on our data processing server. Our Data Processor is Amazon Web Services (AWS). Kindly go through their Privacy Policy to learn and understand how your information is stored. Please note that our servers are located within Singapore.
Except as otherwise mentioned in this privacy policy, we keep your Personal Information:

I. If the User is actively using the Service, for the lifetime of the User plus six years;

II. If the User is inactive, for six years from the date the User becomes inactive;

III. For up to 15 years, in cases which are (i) deemed as “high risk”, (ii) may require internal investigations, or where (iii) legal action has been or might be taken against us; to comply with other law; to support a claim or defence in court; and

IV. If the applicable law where the User is located has a requirement to retain the Personal Information for a period longer or shorter than the above specified period, we will retain the Personal Information as per the applicable law.

11. Security

We assure you that your information is subject to access control and Intellect employees can only access such information on a need-to-know basis.

To ensure the security of your information, we use the following methods: Zero-knowledge encryption and transmission, SSL Protocol, SET Protocol, Automatic backup, Digital Certificate, Username/Password, authorizations to access management, and Firewalls. Please note that the internet is not secure and no system involving the internet and the transmission of electronic data is 100% secure. Nevertheless, we take all reasonable efforts to safeguard and protect your information.
We encrypt all video and audio communications on our Platform. This means that your video and audio conversations done through our Platform are secure and end-to-end encrypted.
Also, note that our use of zero-knowledge encryption for the security of your information may have an adverse effect on you in the event that you lose your primary device. If you change your device or migrate to a new device, some of your Personal Information on our Platform does not transfer to the new device. You may need to re-enter your information again to continue using our Platform.
In the event of a breach which affects your Personal Information, you will be notified within 72 hours of discovery of such breach and the measures we took to rectify the breach. Note that you may request at any time to access and delete your information with us.

12. Disclosure of Personal Data

Although our policy is to maintain the privacy of your information as described herein, we may disclose your information if we believe that it is reasonable to do so in certain cases, in our sole and exclusive discretion. Such cases may include, but are not limited to:

To satisfy any laws or regulations including Local, State, or Federal laws;
To respond to requests, such as discovery, criminal, civil, or administrative process, subpoenas, court orders, or writs from law enforcement or other governmental or legal bodies;
To bring legal action against a user who has violated the law or violated the terms of use of this platform;
To escalate a case (i) from one Intellect provider to another provider; or (ii) to the Client or an external service provider (including, among others, a relevant doctor, or authority when needed) in accordance with our Escalation protocol (https://intellect.co/care-model-and-escalation-protocol). The Escalation Protocol provides clear guidelines and a framework for assessing risk and escalating cases when necessary.
As may be necessary for the operation of this platform;
To generally cooperate with any lawful investigation about our users;
If we suspect any fraudulent activity on this platform or if we have noticed any activity which may violate our terms or other applicable rules.
To Third Party Providers on whose behalf the information was collected for the purpose of providing services to you.
To third parties, we engage to provide services on our behalf such as processing transactions and operating services on our Platform. We have taken all necessary action to enter into agreements that require these third parties to protect such information and use the Personal Information they receive only to perform services for us.
In the event of a merger, acquisition, asset sale, reorganisation or similar transaction, we may transfer any and all Personal Information we collect to the relevant third party involved in the transaction, with your consent if and as required under applicable privacy laws.
Enterprise Service: To inform the necessary Legal Authorities or Emergency Contacts about situations of imminent danger such as threats to life or reckless actions of the user that can affect other users, emergency crises, suicidal tendencies, and other related actions by a user;

If you have any questions, comments, or concerns regarding your rights, please contact us
through email to support@intellect.co.

13. Accuracy of Personal Data

We generally rely on personal data provided by you, your authorised representative or your employer. In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at support@intellect.co.

14. Opt-Out

You always have the opportunity to opt out of our communications with you or change your preferences by contacting us at support@intellect.co.

Enterprise Service: If you have signed up through your Employer as an employee account, please reach out to your Employer to cancel your account. You may still receive communications from us even after you cancel your account unless you also opt out of our communications, as described above.

15. Your Rights and Applicable Laws

You have the following rights to the processing of your Personal Information under applicable privacy laws including but not limited to Singapore PDPA, EU GDPR, USA HIPAA, and USA CCPA:

Access: You have the right to know whether we process Personal Information about you, and if we do, to access data we hold about you and certain information about how we use it and who we share it with. To obtain information and access to your Personal Information held by us, please contact us at support@intellect.co.
Portability: You have the right to receive a subset of the Personal Information you provide us if we process it on the legal basis of our contract with you or with your consent in a structured, commonly used, and machine-readable format and a right to request that we transfer such Personal Information to another party. If you wish for us to transfer the Personal Information to another party, please ensure you detail that party and note that we can only do so where it is technically feasible. We are not responsible for the security of Personal Information or its processing once received by a third party.
Correction: You have the right to require us to correct any Personal Information held about you that is inaccurate and has incomplete data completed. When you request a correction, please explain in detail why you believe the Personal Information we hold about you to be inaccurate or incomplete so that we can assess whether a correction is required. Please note that while we assess whether the Personal Information we hold about you is inaccurate or incomplete, you may exercise your right to restrict our processing of the applicable data as described below.
Restriction of processing to storage only: You have a right to require us to stop processing the Personal Information we hold about you other than for storage purposes in the following circumstances:
- You believe the Personal Information is not accurate for the period it takes for us to verify whether the data is accurate;
- We wish to erase the Personal Information, but you want us to simply restrict the use of that data;
- We no longer need the Personal Information for the processing, but you require us to retain the data for the establishment, exercise, or defence of legal claims; or
- You have objected to us processing Personal Information we hold about you based on our legitimate interest and you wish us to stop processing the Personal Information while we determine whether there is an overriding interest in us retaining such Personal Information.
Objection: You have the right to object to our processing of data about you and we will consider your request. Please provide us with details as to your reasoning so that we can assess whether there is a compelling overriding interest in us continuing to process such data or we need to process it concerning legal claims. You also have the right, at any time, to object to our processing of data about you to send you marketing, including where we build profiles for such purposes and we will stop processing the data for that purpose.
Choice/Opt-Out of Marketing Communications: You always have the opportunity to opt-out of our marketing communications with you or change your preferences by emailing us at support@intellect.co or by using the unsubscribe link (if any) found at the bottom of a marketing email to opt-out of receiving future emails. Some communications from us are considered transactional or service communications (for example, important account notifications and billing information), and your account(s) on our platform are provided to you upon the condition that you receive these communications from us. You must cancel your account(s) on our platform, as applicable, if you do not wish to receive any transactional or service communications. To cancel your account(s), please follow the instructions found in the terms of service for the applicable Service. You may still receive marketing communications from us even after you cancel your account unless you also opt-out of our marketing communications, as described above.
Erasure: Personal Information we hold about you will be deleted within thirty (30) days, if you leave the employment of your Employer, or if your Employer wishes to end the services we provide. You may request that we erase the Personal Information we hold about you in the following circumstances:
- where you believe it is no longer necessary for us to hold the Personal Information;
- we are processing it based on your consent, and you wish to withdraw your consent;
- we are processing your data based on our legitimate interest and you object to such processing;
- you no longer wish us to use your data to send you marketing; or
- you believe we are unlawfully processing your data.
- Upon request for erasure of your data, it will take us approximately thirty (30) days to delete your data. We may send an update to you acknowledging the deletion. Please note that if we delete your data, it is permanent and we will not be able to retrieve such data. You may be required to create a new account if you still want to access and use our Platform.
Withdrawal of Consent: Where you have provided your consent to us processing your data, you can withdraw your consent at any time by emailing us at support@intellect.co.

By using our platform, you hereby consent to our Privacy Policy and agree to its Terms and Conditions.

16. Health Insurance Portability and Accountability Act (HIPAA) of 1996 Compliance (USA)

Our Legal Duty as Healthcare Professionals in compliance with the United States of America (USA) HIPAA are as follows;

Maintain the privacy of your mental health information, to the extent required by state and federal law;
Give you this Notice explaining our legal duties and privacy practices with respect to mental health information about you;
Notify affected individuals following a breach of unsecured mental health information under federal law; and
Follow the terms of the version of this Privacy Policy that is currently in effect.

Uses and Disclosures for Health Information

The following categories describe the different reasons that we typically use and disclose mental health information. These categories are intended to be general descriptions only and not a list of every instance in which we may use or disclose your mental health information. Please understand that for these categories, the law generally does not require us to get your authorization in order for us to use or disclose your mental health information.

Consultation: With your approval or upon your request, we may disclose your mental health information to an external psychiatrist for specialised services. For example, should your care require referral to or consultation by another psychiatrist of a speciality outside of the Services we provide, we may provide that psychiatrist with your mental health information in order to aid the psychiatrist in his or her services for you.

Payment: We may use and disclose mental health information about you so that we may bill and collect from you, an insurance company, or a third party for the health care services we provide. For example, we may send a claim for payment to your insurance company, and that claim may have a code on it that describes the services that have been rendered to you. If, however, you pay for an item or service in full, out of pocket and request that we do not disclose to your health plan the mental health information solely relating to that item or service, as described more fully in this Notice, we will follow that restriction on disclosure unless otherwise required by law.

Health Care Operations: We may use and disclose mental health information about you for our health care operations. These uses and disclosures are necessary to operate and manage our practice and to promote quality care. For example, we may need to use or disclose your mental health information in order to assess the quality of care you receive or to conduct certain cost management, business management, administrative, or quality improvement activities or to provide information to our insurance carriers.

Quality Assurance: We may need to use or disclose your mental health information for our internal processes to assess and facilitate the provision of quality care to our patients.

Utilization Review: We may need to use or disclose your mental health information to perform a review of the services we provide in order to evaluate whether the appropriate level of services is received, depending on your condition and service outcomes.

Credentialing and Peer Review: We may need to use or disclose your mental health information for us to review the credentials, qualifications, and actions of our healthcare providers.

Consultation options: We may use and disclose your mental health information to tell you about or recommend possible consultation options or alternatives that we believe may be of interest to you.

Appointment Reminders and Health-Related Benefits and Services: We may use and disclose mental health information, in order to contact you (including, for example, contacting you by phone and leaving a message on an answering machine or text you) to provide appointment reminders and other information. We may use and disclose mental health information to tell you about health-related benefits or services that we believe may be of interest to you.

Business Associates: There are some services (such as billing or legal services) that may be provided to or on behalf of our Practice through contracts with business associates. When these services are contracted, we may disclose your mental health information to our business associates so that they can perform the job we have asked them to do. To protect your mental health information, however, we require the business associate to appropriately safeguard your information.

Individuals Involved in Your Care or Payment for Your Care. We may disclose mental health information about you to a friend or family member who is involved in your healthcare, as well as to someone who helps pay for your care, but we will do so only as allowed by state or federal law (with an opportunity for you to agree or object when required under the law), or in accordance with your prior authorization.

As Required by Law: We will disclose mental health information about you when required to do so by federal, state, or local law or regulations.

To Avert an Imminent Threat of Injury to Health or Safety: We may use and disclose mental health information about you when necessary to prevent or decrease a serious and imminent threat of injury to your physical, mental or emotional health or safety or the physical safety of another person. Such disclosure would only be to medical, law enforcement personnel or within Intellect and its main contracting Party.

Research: We may use or disclose your mental health information for research purposes in certain situations. In accordance with applicable laws, provided that the end user’s identity is not disclosed either directly or indirectly, we may disclose your mental health information to qualified personnel for research purposes without your written consent. De-identified health information, as described in the HIPAA Privacy Rule, is not Protected health information (PHI), and thus is not protected by the Privacy Rule. PHI may be used and disclosed for research with an individual’s written permission in the form of an Authorization. PHI may be used and disclosed for research without Authorization in limited circumstances: Under a waiver of the Authorization requirement, as a limited data set with a data use agreement, preparatory to research, and for research on decedents’ information.

Electronic Disclosures of Mental Health Information: Under applicable law, we are required to provide notice to you if your mental health information is subject to electronic disclosure. This Notice serves as general notice that we may disclose your mental health information electronically for payment, or health care operations or as otherwise authorized or required by state or federal law.

Other Uses of Mental Health Information

Authorizations: There are times we may need or want to use or disclose your mental health information for reasons other than those listed above, but to do so we will need your prior authorization. Other than expressly provided herein, any other uses or disclosures of your mental health information will require your specific written authorization.

Right to Revoke Authorization: If you provide us with written authorization to use or disclose your mental health information for such other purposes, you may revoke that authorization in writing at any time. If you revoke your authorization, we will no longer use or disclose your mental health information for the reasons covered by your written authorization. You understand that we are unable to take back any uses or disclosures we have already made in reliance upon your authorization and that we are required to retain our records of the care that we provided to you.

17. General Data Protection Regulations (GDPR) Compliance (EU)

On May 25, 2018, the European Union (the “EU”) implemented a new data privacy and protection regulation, called the General Data Protection Regulation and the United Kingdom (the “UK”) post-Brexit implemented the UK General Data Protection Regulations (collectively referred to as the “GDPR”). This regulation aims to standardize data protection laws across the EU and the UK and lay down standards to be observed worldwide while processing personal data originating in the EU and the UK. The GDPR also has a strong emphasis on affording individuals stronger, more consistent rights to access and control their personal information.

At Intellect Company Pte. Ltd. (“we”, “us”, “our”, “Intellect”), we take compliance with data privacy and security regulations very seriously. For the GDPR, we are working diligently to ensure that we are compliant with the rules laid out by the law. In the following sections, we have outlined our approach to complying with the GDPR.

Intellect’s GDPR compliance policies are available below:

Intellect GDPR Privacy Policy Notice

Intellect Data Retention Policy

Intellect Organizational Data Protection Compliance Policy

Representative

We value your privacy and your rights as a data subject and have therefore appointed Prighter Group with its local partners as our privacy representative and your point of contact for the following regions:

European Union (EU)
United Kingdom (UK)

Prighter gives you an easy way to exercise your privacy-related rights (e.g. requests to access or erase personal data). If you want to contact us via our representative, Prighter or make use of your data subject rights, please visit the following website:https://app.prighter.com/portal/16799264912

Intellect and GDPR Compliance

Intellect is the owner and is responsible for the day-to-day operation of the website Intellect | Redefining Mental Health for Global Workforces (“Website”) and of applications available at Intellect | Create A Better You (“Application”) and our product offered as a software as a service (SaaS) platform, which facilitates end-to-end mental health care coaching and services (“Services”). The Website showcases the Services of the Company.

We at Intellect process the personal information of our customers in the capacity of a Data Controller (for any personal information submitted on the Website) and in the capacity of a Data Processor (for any personal information provided by our customers when they use our Services).

Risk Assessment

We have performed a company-wide information discovery exercise to identify and assess what personal information we hold, where it comes from, how and why it is processed, and to whom it is disclosed.

Data Subject Consent

As a Data Controller, Intellect has updated its Privacy and Cookie Policies and Disclaimer for the usage of Cookies in as per the requirements of the GDPR on its website https://intellect.co/ and it requires all the visitors, and users of its website to provide consent for the use of personal information. Intellect also allows such users to exercise their rights in relation to their personal information such as modification, rectification, and deletion of their data.

As a Data Controller, we execute contracts required under the GDPR with our data processors to ensure that the data processors process the personal information as per the GDPR. Additionally, we implement technical and organizational security measures to ensure compliance.

As a Data Processor, we comply with the required safeguards pertaining to the safety of personal information received from our clients.

Data Subject Rights & Transfer of Data Outside the EU and the UK

We at Intellect, have in place a GDPR-compliant data processing addendum (as required by Article 28 of the GDPR) including the EU Standard Contractual Clauses (“SCCs”) and the UK International Data Transfer Addendum (“ITDA”) to ensure an appropriate legal basis for data transfers outside the EU and UK respectively.

Data Retention & Erasure

We have formulated an organisational data protection compliance policy. This Policy includes a data retention schedule which ensures that we comply with the principles under the GDPR, including ‘data minimization’ and ‘storage limitation’ and that personal information is stored, archived, and destroyed in accordance with the GDPR.

Record Keeping as per the GDPR

According to Article 30 of the GDPR, each processor and controller’s representative needs to maintain a record of all activities pertaining to the processing of personal information in such an organization. Intellect maintains such records as required under Article 30(1) and Article 30(2) of the GDPR.

Data Breach and Mitigation Process

The GDPR has stipulated measures and notifications that must be made upon discovery of a data security breach. We at Intellect have implemented internal measures to minimize the risk of any data security breach happening. However, in the unlikely event of any such breach happening, Intellect intends to honour its responsibilities as laid down under the GDPR, which includes notifying in a timely manner, its customers, and the supervisory authorities.

Intellect’s Promise on GDPR

At Intellect, maintaining the security, integrity, safety and confidentiality of personal data in our possession is of the highest priority. Intellect has already taken adequate measures to ensure that we fulfil our promise of being fully compliant with the GDPR.

18. Contact Us

If you have any questions about this policy or the practices described herein, you may contact us at support@intellect.co.

Disclaimer: Intellect specializes in offering professional consultation services. It is important to note that these services do not include any form of diagnosis or treatment. Intellect provides guidance and support rather than medical evaluations or interventions.

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