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U-APP PRIVACY POLICY

 (As of 26 January 2023)

1.           Collection of personal information

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‍For purposes of this Privacy Policy, “personal information” means any information that relates to an identified or identifiable individual. The personal information we collect through the U-APP Platform will be apparent by the context of the page and/or the circumstances in which the personal information is being collected. This may include collection and processing of personal information including, but not limited to, the following categories of information.

 

1.1        Information you provide to us

 

U-APP may collect the following categories of personal information about you that you choose to provide to us when you use the U-APP Platform or otherwise interact with or receive our Products and Services:

 

Contact information and identifiers.  When you use our Platform, we may ask you to provide certain contact information including your first and last name and email address. We may also collect your social media identification number if you choose to access the Platform via a social media platform.

 

Account Information. If you decide to set up an account with us, we may ask you to provide certain additional contact information including, for example, your first and last name, e-mail address (personal and/or work), telephone number, mailing address, employer or company name, job title, student identification number, emergency contact information, as well as password and other authentication-related information. For individuals who participate in a special subscriptions and features, including group plans, we may collect additional personal information, for example, home address and names and emails of household members for example, the names and emails of household members.

 

Surveys, health, and medical information.  We may present you with surveys or other information forms on our Platform order to provide you with information about our Products and Services that we think may be of interest to you or for research purposes. These surveys may give you the opportunity to describe certain things about you, such as your current mental, emotional, and physical status, wellness goals, current life events, and other health-related information.

 

Profile and demographic information.  Through your account on our Platform, you may have to opportunity to provide additional information about yourself, such as your age, race and ethnicity, sexual orientation, preferred pronouns, gender or gender identity, sex at birth, marital status, and details about your health and medical history.

 

Payment information.  If you sign up for a paid product or service from us, you may be required to provide your payment card or bank account information.  Please note that U-APP does not directly process payment card information, but does rely on third party payment processors to do so on our behalf. Please note that third party terms may apply to these payment services. Personal information collected for these purposes includes card number, type, expiration date, and billing address, and certain anonymized, limited and/or truncated versions of this information may be provided to U-APP.

 

Communication information.  When you send or respond to emails, messages, or other communications from U-APP, we may collect your email address, name, and any other personal information you choose to include in the body content of your communications. In addition, when you interact with certain features of our Platform, we may collect the content of those communications.

 

1.2        Information from others

In certain circumstances, we may collect personal information from others. This may include the following:

- If you receive access to U-APP through your employer, health plan, or other U-APP Partner, we collect your name and email address and demographic information that such Partner submits to us to facilitate your enrollment in our programs.

- We may collect the name, email address, content engagement, and preferences of individuals that our users identify through our sharing and referral features. We use this data for the sole purpose of sharing content and referring individuals to join the Products.

- We may collect personal information from parents or guardians who wish to enroll their adolescent dependents. We will use this data to enroll the teen. 

- If you choose to have your account verified to confirm your eligibility for a select subscription offering, we may allow a third party platform to access the specific personal information you provide in order to perform the verification. Any failure to provide sufficient information or any response U-APP considers abnormal may result in U-APP refusing (or being unable) to verify your eligibility.

‍If you would like us to delete personal information that may have been provided to us by others as described above, you can do so by opting out as described in the invitation or other communication that we may have sent to you, or by contacting us at help@u-app.com.sg.

 

1.3        Information we automatically collect

Our Platform, including the Websites, may collect information from you automatically as your use our Platform, including individual Websites and Apps. This information may include:

- Browser and device data, such as IP address, device identifier, device type, operating system and Internet browser type, screen resolution, operating system name and version, device manufacturer and model, language, plug-ins, add-ons, and the language version of the Websites and Apps you are visiting; and

- Usage data, such as geolocation data, browsing history, time spent on the Platform, pages visited, links clicked, language preferences, performance of features, patterns of use, and the pages that led or referred you to our Platform including individual Websites and Apps.  For example, we use Google Analytics on our Websites to help us analyze your use of our Websites and diagnose technical issues.

- Cookies and web-beacons. We may use cookies and other tracking technologies such as pixels, web beacons, embedded scripts, and tags (“Cookies”). We also collect information about your online activities on websites and connected devices over time and across third-party websites, devices, apps, and other online features and services.

Please review our Cookies and tracking technologies section below, as well as our Cookie Policy for more information about our use of these technologies.

 

1.4        Aggregated, anonymous, and de-identified data

We may create aggregated, anonymous, or de-identified data from personal information by removing data components that make the data personally identifiable to you, or potentially personally identifiable to you, or through obfuscation or other means. Once information is aggregated, anonymized, or de-identified such information is no longer personal information, and use of the data is not subject to this Privacy Policy.

 

 

2.           Use of personal information

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We may use your personal information in the following ways:

- To provide our Products and Services, including the delivery of content and facilitation of interactive features;

- To communicate with you regarding the U-APP Platform, Products and Services;

- To notify you about updates or changes to the U-APP Platform, Products and Services;

- To provide customer service, answer your questions or requests for information, or handle your complaints;

- To facilitate payment transactions, manage your orders, and account for applicable sales taxes;

- To inform businesses, government entities, hospitals, universities and other organizations and groups that wish to make our Products and Services available to their members, employees and their families, patients, customers, residents or others (collectively, our “Partners”) about your registration and, in limited cases, use of the Products and Services;

- To effectuate our performance on any agreements that we may have with you;

- To maintain and improve the quality of the U-APP Health Platform, Products and Services, including to perform research and development, understanding our user trends, and understand the effectiveness of our marketing and advertising;

- To provide you with information about new Products and Services, promotions, and other opportunities that we believe may be of interest to you, whether offered by us or third-party partners, and to personalize, measure, and improve such offers;

- To serve our advertisements to you through third-party platforms, such as Facebook or Google, on other sites and apps or across your devices, to the extent that you have provided consent and/or consistent with notice and any opt-out rights for such uses under applicable law;

- To protect ourselves, you and others; preventing fraud and other unlawful or unauthorized activity; and creating and maintaining a trusted, secure, and reliable online environment; and

- To comply with our legal obligations; respond to subpoenas, court orders or legal process; and to establish or exercise our legal rights or defense against legal claims.

Please note that we may also use your personal information to cross-reference or convert various types of accounts that you may be associated with on our Platform.

 

 

3.           Sharing of personal information

We may share your personal information with any member of our group, which includes U-APP Pte. Ltd. and our subsidiaries and affiliates, for any of the purposes described in this Privacy Policy.

 

We may also disclose your personal information with the following categories of third parties:

- Our service providers. In some circumstances, based on your specific requests, we may need to disclose your personal information to a third party so that they can provide a service on our behalf, such as to help deliver Products or Services that you have requested. These service providers may include services such as analytics, payment processing, advertising and marketing, website hosting, customer and technical support, and other services.

 

Our service providers have access to your personal information only to perform these tasks on our behalf and are obligated to maintain the confidentiality and security of your personal information, and to not disclose or use the information for any other purpose, consistent with this Privacy Policy and applicable law.

- Third party advertising platforms. We may share your personal information with third party platform providers who assist us in serving advertising regarding the U-APP Platform, Products and Services to others who may be interested.  We also partner with third parties who use Cookies to serve interest-based advertising and content on their respective third-party platforms that may be based on your preferences, location and/or interests.

- Our Partners. In limited cases, we may provide certain personal information to our Partners, which may include your employer, in order to provide the U-APP Platform, Products and Services as a benefit of your employment.

- Third party business partners. In limited cases, we may provide certain personal information to third party businesses with which we have a joint promotional relationship or other trusted partnership. This type of sharing will most often be consistent with your notice, consent, direction, and/or reasonable expectations in light of the circumstances in which you provided the personal information.

- Compliance and harm prevention. If we are under a duty to disclose or share your personal information in order to comply with any legal obligation, such as to comply with a subpoena, bankruptcy proceeding, similar legal process, or in order to enforce or apply our agreements with you; or to protect the rights, property, or safety of U-APP, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction. We may also disclose personal information where we believe that doing so would be in accordance with or required by any applicable law, regulation or legal process

- Affiliate and business transfer. If U-APP, including any of its subsidiaries, brands or affiliates, is involved in a merger, acquisition, asset sale, or other corporate combination, your personal information may be transferred to the acquiring or surviving entity. If such transfer results in a material change to the use of your personal information, we will provide notice before your personal information is transferred and/or becomes subject to a different privacy policy.

 

 

4.           Your Rights and Choices

You may have rights and choices regarding our use and disclosure of your personal information. Unless instructed otherwise, you can exercise these rights and choices using the information in the Contact us section at the end of this Privacy Policy.

- Privacy rights, choices, and preferences. If you have an account on our Platform, please visit your account for any privacy rights, choices, or preference options that may be offered. In your U-APP user profile, you are able to make additions or edits to any of your personal, payment, or membership information, and you may request to delete your account. You may also submit a request to help@u-app.com.sg.

- Opting out of receiving electronic communications from us. You will not receive promotional electronic communications from us if you have opted out of receiving such communications. If you wish to opt out, you may opt out via the unsubscribe link included in such emails or by contacting us at help@u-app.com.sg. We will comply with your request as soon as reasonably practicable. Please note that if you opt out of receiving promotional emails from us, we may still send you important administrative messages that are required in order to provide you with our Products and Services or for other reasons disclosed in this Privacy Policy. 

 

 

5.           Data security

The security of your personal information is important to us. We follow generally accepted standards, practices, and procedures to protect the personal information submitted to us, both during transmission and once it is received. We maintain appropriate technical, administrative and physical safeguards to help protect the security of your personal information against unauthorized access, destruction, loss, alteration, disclosure or misuse. 

If you have an account with us and you suspect unauthorized use of your account or its credentials, you should notify us immediately using the information in the Contact Us section at the end of this Privacy Policy.

 

 

6.           Cookies and tracking technologies

 

When you visit the U-APP Platform, we may collect information from you automatically through Cookies. We also rely on service providers and other partners to provide many features of our Platform using data about your use of the Platform, which may include personal information. Please review the Cookie Policy for more information regarding our collection of Cookies, the purposes for which we use them, and how to exercise your preferences regarding them including the ability to opt-out through our Platform or via your browser.

 

The U-APP Platform uses Google Analytics code to gather statistical data. Google Analytics sets cookies to help us accurately estimate the number of visitors to the Platform and the volumes of usage of the Products and Services. This is done to ensure that the Platform and its associated Products and Services are available when you want them and are fast. For more data on how Google Analytics processes this data, visit www.google.com/analytics.

We will acquire consent from you in order to use such trackers or provide you with the opportunity to opt-out of such trackers, to the extent required by applicable law. For more information on the types of cookies used by U-APP and your ability to restrict the behavior of cookies or disable them in your browser’s settings, please refer to the Cookie Policy.

 

We do not support Do Not Track functionality. Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

 

Other tracking on our Platform.  Our Platform, including our Websites, may utilize tracking technologies to collect and record your activities and movements across our Websites throughout your browsing session, including to track button clicks, mouse movements, scrolling, resizing, touches, keystrokes, data entered, device information and orientation, browser visual elements, and screen size (“Session Data”), for purposes of our own internal analytics and improving our products, services, and user experience. Such tracking may include recorded sessions, which we may play back for these purposes.

 

Our Platform also utilizes live chat and/or chat bot technology, which visitors to communicate directly with our automated customer service system and/or customer service representatives via a chat window about our Products and Services. Text entered into this form prior to submission may be collected, retained, and used by U-APP for our business purposes, including by our customer service and other personnel and service providers.

 

We may share Session Data and chat bot correspondence data with our third-party analytics or service providers, which may change from time-to-time, for these purposes, who will use the data solely on the behalf of, and for the benefit of, U-APP.

 

 

7.           Children’s privacy

Our Platform is intended for individuals at least 18 years of age, or the age of majority in your province, territory or country. Individuals ages 13 of 18, or the applicable age of majority, may utilize the U-APP Platform only with the consent and involvement of a parent or legal guardian. This provision is not applicable to registrations made under select subscriptions or special offerings, including business to business sales and enterprise partnerships, where specified in applicable contracts.

 

If you are a parent or guardian and you are aware that a child under age 13 has provided us with personal information without parental consent, please contact us at help@u-app.com.sg. If we become aware that we have collected personal information from children under age 13 without parental consent, we will take steps to remove that information from our servers.

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8.           International data transfers

The U-APP Platform is operated in Singapore.

 

The subsidiaries, service providers or other third parties described in this Privacy Policy and to whom U-APP may disclose your personal information may be domiciled abroad, and, in particular, outside Singapore. In such case, U-APP will require them to take, in accordance with applicable legislation, contractual, organizational and technical measures designed to ensure an adequate level of protection of your personal information.

 

General disputes arising from your use of the U-APP Platform, as well as our Products and Services, can be found in our Terms & Conditions. However, if you have any questions or concerns regarding our information collection, use, and sharing practices as described in this Privacy Policy, you may reach us using the Contact us section at the end of this Privacy Policy and we will investigate the matter and resolve any issues, if we can.

 

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9.           Links to other websites

Our Platform, including its Websites and Apps, may contain links to other websites that are not operated by U-APP. We are not responsible for the content or privacy policy policies of websites we do not own or control, and our Privacy Policy does not apply to third-party websites. We strongly suggest you review the privacy policies for third-party websites to understand how your personal information is used and stored by those websites.

 

 

10.        Changes to this Privacy Policy

We may change this Privacy Policy from time to time to reflect new services or changes in our data practices or relevant laws. The “effective date” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes are effective when we post the revised Privacy Policy on the U-APP Platform, including the Websites. We may take reasonable measures to notify you via email and/or a prominent notice on our Platform prior to certain changes becoming effective, and will update the effective date at the top of this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes.

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