Participant Information Sheet

Privacy Policy

Terms & Conditions

INTELLECT COMPANY PTE. LTD. PRIVACY POLICY

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 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.
Employer – 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.
Third Party Providers – 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.

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 Mailchimp to send Newsletters only to customers who have consented
specifically to receive the newsletter.
● We use Twilio 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.

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. Your continued use of our platform after recent updates to the Privacy
Policy will constitute your acknowledgment of the modifications and your consent to abide and
be bound by the modified Privacy Policy.

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

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.

Age of Approval
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.

Collection and Use of Personal Data
Information We Collect
“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. 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.

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, employeeID (if
applicable), department, title, job code (if applicable).

• 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 users 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 on all assigned or impending tasks on our platform;
• Process your Payment.

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 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 identify you.

Processing of Personal Data
The Bases on Which We Process Information about You are as follows –
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, 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.

For example, we may process your data on this basis for the purposes of:
● record-keeping for the proper and necessary administration of our organization.
● 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 personalize 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.

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 only
for as long as required by us to provide you with the services you have requested; to comply with
other law; to support a claim or defence in court.

Security
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.

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:
a. To satisfy any laws or regulations including Local, State, or Federal laws;
b. To respond to requests, such discovery, criminal, civil, or administrative process,
subpoenas, court orders, or writs from law enforcement or other governmental or legal
bodies;
c. To bring legal action against a user who has violated the law or violated the terms of use
of this platform;
d. As may be necessary for the operation of this platform;
e. To generally cooperate with any lawful investigation about our users;
f. 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.
g. To Third Party Providers on whose behalf the information was collected for the purpose
of providing services to you.
h. 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.
i. In the event of a merger, acquisition, asset sale, reorganization 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.
j. Enterprise Service: To inform the necessary Legal Authorities or Emergency Contacts
about situations of imminent danger such as threat to life or reckless actions of the user
that can affect other users, emergency crisis, 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 contact@intellect.co.

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 contact@intellect.co.

Opt Out
You always have the opportunity to opt-out of our communications with you or change your
preferences by contacting us at contact@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.

Your Right and Applicable Laws
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:
– 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 contact@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 bases 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
the third party.
– Correction: You have the right to require us to correct any personal information held
about you that is inaccurate and have incomplete data completed. Where 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:
o You believe the personal information is not accurate for the period it takes for
us to verify whether the data is accurate;
o We wish to erase the personal information, but you want us to simply restrict
the use of that data;
o 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
o 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 detail 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 contact@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: You may request that we erase the personal information we hold about you
in the following circumstances:
o where you believe it is no longer necessary for us to hold the personal
information;
o we are processing it based on your consent, and you wish to withdraw your
consent;
o we are processing your data based on our legitimate interest and you object to
such processing;
o 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
contact@intellect.co.

Contact Us
By using our platform, you hereby consent to our Privacy Policy and agree to its Terms and
Conditions. For more information about our Privacy Policy, if you have questions, or if you
would like to make a complaint, please contact us by email at contact@intellect.co.

Terms and Conditions for the NTU Resilience Programme

Duration

1. The NTU Resilience Programme (“NRP”) will be conducted from 23 May 2022 to 31 August 2022 (both dates inclusive). 

Participation Eligibility

2. The NRP is for students and staff of Nanyang Technological University (NTU) only.
   • Intellect has absolute discretion to refuse and/or revoke participation of additional Participants once 450 eligible Participants have been successfully registered.
3. Participants will be eligible to take part in the NRP and be entitled to receive the appropriate services defined in the “Scope of NRP”, if and only if the following are completed prior to the start date of the NRP:
   • read, understand, and agree to the Participants’ Information Sheet, Privacy Policy and Consent Form; 
   • agree to participate in the NRP;
   • allow Intellect to use data collected during the course of the study for research purposes; 
   • allow NTU to receive aggregated and anonymised data;
   • successfully create an account on the Intellect app.
4. Intellect has the absolute discretion to determine the eligibility of Participants. Such determination shall be final and conclusive and Intellect is not obliged to give any reason for its determination.
5. Intellect has absolute discretion to disqualify any Participants from the NRP who do not meet the criteria set out in these Terms and Conditions. Such determination is final and conclusive, and Intellect is not obliged to give any reason for its determination.

Scope of NRP

6. Privileges of participating in the NRP are as follows:
   • premium access to the full library of Learning Paths, Rescue Sessions, and Journals within the Intellect mobile application;
   • up to two (2) coaching credits allowing booking of up to two (2) coaching sessions in the Intellect mobile application
   • provision of one (1) single-use promotional code per Participant for Garmin products to be used on the Convergent platform, accessible through this link: NTU Resilience Programme
   • For terms and conditions of the discount vouchers, please refer to the link above. Note that, Intellect is not responsible for misuse or validity of the discount vouchers.
   • entry into the Reward Programme, where the two (2) Participants with the highest number of completed Questionnaires will be eligible to receive the Garmin product- 2x Venu SQ music.
   • If more than one (1) Participants are tied for the Rewards, the Participant with the earliest date of creation of Intellect account creation will receive the Reward.

7. Participants are required to complete questionnaires about their physical and mental wellbeing (“Questionnaires”) on a daily and weekly basis for a period of three (3) months from the date of participation as well as during registration and after the study
   • Each daily and weekly Questionnaire will appear in the form of a pop-up when the Intellect mobile application is opened. 
   • Questionnaires to be completed during registration and after the study will be completed through the Qualtrics platform, with links provided via email when Participants register for the NRP and after the NRP has concluded.
8. Intellect has the absolute discretion to determine and change the Scope and rewards of NRP without consent of Participants. Such determination and changes shall be final and conclusive and Intellect is not obliged to give any reason for determination or changes.