Last Updated: 21st February 2022
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 on this platform or available by hyperlink. This policy complies with Singapore’s Personal Data Protection Act 2012 (PDPA), General Data Protection Regulations (GDPR), Health Insurance Portability and Accountability Act (HIPAA), and other related privacy legislations.
This 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 to a selected program.
This refers to providers, agents, and affiliates of both parties but who we may disclose personal information relating to our users. This includes payment providers, insurance companies, cloud communication platforms, and in the case of an emergency, hospitals or designated health practitioners (example, a medical doctor). Please note that we shall not be liable for the actions or liability of these third-party providers. Ensure to abide by their terms and conditions.
The following are third parties that we use to store and process data:
If you have any questions about this policy or the practices described herein, you may contact us at firstname.lastname@example.org.
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.
To use our Platform, you agree to be 18 years of age or the age of majority in some jurisdictions. Although we collect and process personal information of our users, we do not knowingly collect or process information of minors. Therefore, our platform is not directed at minors. The use of this platform is void where prohibited by applicable law and we assume no responsibility or liability for any misrepresentation of age.
“Personal Information” 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 and clinicians on our platform, including information about your health and personal goals.
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, employeeID (if applicable), department, title, job code (if applicable).
We gather this information from you and your Employer to allow us to:
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 users 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
The Bases on Which We Process Information about You are as follows –
We may process information on the basis there is a legitimate interest, either to you or to us, of doing so. Where we process your information on this basis, we do 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.
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.
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.
or defence in court.
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 a reasonable timeframe of such breach and measures we took to rectify the breach. Note that you may request at any time to access and delete your information with us.
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:
If you have any questions, comments, or concerns regarding your rights, please contact us through email to email@example.com.
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 firstname.lastname@example.org.
You always have the opportunity to opt-out of our communications with you
or change your preferences by contacting us at email@example.com.
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.
You have the following rights to the processing of your personal information under relevant privacy laws including but not limited to Singapore PDPA, EU GDPR, and US HIPAA:
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.