OUR SERVICES ARE ONLY CONTEMPLATED FOR NON-EMERGENT, NON-URGENT CONDITIONS OR CONCERNS. WE ARE NOT A CRISIS-PROVIDER.  IF YOU ARE EXPERIENCING AN EMERGENCY OR CRISIS, CALL 995 OR YOUR LOCAL EMERGENCY SERVICES IMMEDIATELY (SUCH AS SOS 24-HOUR HOTLINE AT 1767 OR IMH HOTLINE AT 6389-2222).

PLEASE READ THIS PRIVACY POLICY CAREFULLY BEFORE USING OUR SERVICES, WEBSITE OR MOBILE APPLICATION (“Mobile App”).

THE WELLNESS CONCIERGE PTE. LTD. (“Company”, “we”, “us” or “our”) respects your privacy. This privacy policy (“Privacy Policy”), which is incorporated into our Terms by reference, describes how Data (as defined below) provided by you through the Platform and Services is collected, used, disclosed or otherwise processed by us in accordance with the Personal Data Protection Act 2012 of Singapore (“PDPA”).

It is important that you read this Privacy Policy and our Terms so that you are fully aware of your rights and our responsibilities in relation to your data. Except where the context requires otherwise, terms used in this Privacy Policy shall have the same meanings as those defined in our Terms.

This Privacy Policy applies to all data in our possession or under our control, including data in the possession of third parties which we have engaged to collect, use, disclose or process data for the purposes set out in the Privacy Policy. 
This Privacy Policy applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your data by us.

1. Acceptance of Privacy Policy

1.1 By using or accessing the Platform and/or Services, you acknowledge that you have read and understood this Privacy Policy, agree to be bound by this Privacy Policy and conclude a legally binding contract with us, and give your consent for the collection, use and disclosure of data for the Purposes (as defined below). If you do not agree to this Privacy Policy, please do not use or access the Platform and/or Services.
1.2 We reserve the right, at our sole discretion, to modify or update this Privacy Policy at any time without notice and all changes will become immediately effective upon posting on the Platform . Your continued use or access of the Platform and/or Services  after such changes have been made constitutes your acknowledgement and acceptance of, and consent to, such changes and the amended Privacy Policy. It is your sole responsibility to check this Privacy Policy regularly for changes. You may determine if any such revision has taken place by referring to the date on which this Privacy Policy was last updated. If you do not agree to the amended Privacy Policy, please do not continue to use or access the Platform and/or Services .
1.3 The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is withdrawn by you in accordance with this section. You may withdraw consent and request us to stop using or disclosing your personal data for any or all of the purposes listed below by submitting your request via email to our Data Protection Officer, or any of our representative and/or employee, at the contact details provided in Clause 10 below.
1.4 Upon receipt of your request via email to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on the provision of our Platform and/or Services to you) to process your request and to notify you of the consequences of us acceding to your request, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within ten (10) business days of receiving it.
1.5 Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be able to continue providing our Platform and/or Services to you and we shall, in such circumstances, notify you before completing the processing of your request.
1.6 Should you decide to cancel your withdrawal of consent, please inform our Data Protection Officer via email at the contact details provided in Clause 10 below.
1.7 Please note that withdrawing consent does not affect (a) the lawfulness of any collection, use, disclosure or processing of your personal data prior to your withdrawal; (b) our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws; or (c) the lawfulness of any collection, use, disclosure or processing of any Data that is not personal data at any time.

2. Collection of Data

2.1 Depending on the nature of your interaction with us, we may collect the following data (“Data”)  provided by you through the Platform and/or Services, which may constitute personal data, including:

(a) Technical data, which includes the URL from which you came to our Platform and/or Services, your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our Platform and/or Services;
(b) Identity data, which includes your first and last name, username or similar identifiers;
(c) Verification data, which includes your mobile phone number and/or email address;
(d) Profile data, which includes without limitation your username and password, full name, address, property type, gender, date of birth, email address, occupation, relevant parties’ information, emergency contact information, mobile number, credit card details, feedback and survey / rating / review responses, work experiences, work preferences, specific skills, relevant accreditation, interests, and results from
personality tests, and any other items of information that you provide to us for the purposes of using or participating in our Platform and/or Services; 
(e) Appointment data, which includes information relating to your Session appointment and any other information in relation to the Session that you choose to provide;
(f) Usage data, which includes information about how you use our Platform and Services;
(g) Marketing and communications data, which include your preferences in
receiving marketing materials from us and third parties, and your communication preferences; and
(h) Communications data, which include your communications, audio and video files and the
information provided therein to Registered Users through our messaging system on our      Platform.

2.2 You shall take note that your data may be stored and used pursuant to the PDPA.
2.3 We will only retain your personal data for as long as necessary to fulfil the purposes for which it was collected, or as required or permitted by applicable laws including satisfying any legal, accounting, or reporting requirements.
2.4 We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.
2.5 We use cookies on our Platform. Cookies are small files containing a text-only string of information that our Platform transfers to your device’s hard disk or hard drive. We may use both persistent cookies as well as session cookies. Session cookies are deleted after you close your Platform . These cookies may be used to store information for enabling certain functions pertaining to our Services, such as completing forms, facilitating website navigation, video playback, authentication, recognising your device when you return to our Platform, and allowing us to compile aggregated statistics that help us improve the structure and performance of our Platform. You may accept or decline cookies by modifying the settings of your browser. Please be aware that without cookies, our Platform  may have limited functionality or may not work at all.      

Registration as a Registered User
2.6 If you wish to register with us as a Registered User, you agree to provide us with, inter alia, the following data about you, which may constitute personal data, in our registration form for an account on the Platform , and/or with any of our Services:
(a) Full name;
(b) Date / Year of birth;
(c) Gender; 
(d) Address and property type;
(e) Occupation; 
(f) Mobile number; 
(g) Credit card details; 
(h) Relevant accreditations, qualifications and skills/work experience/work preferences/personal profile write-ups/rates (for Listener / Listener +);
(i) Emergency Contact (Name, Relations, Mobile Number);
(j) Email address; and
(k) Your password.

2.7 You will be required to consent to this Policy in the registration form.
2.8 We will not collect any personally identifiable information about you, unless you provide it.
2.9 Payment information. Your credit card information or payment information, will be processed by Stripe (payment platforms) which will treat and safeguard your data with total security and with the exclusive purpose of processing the purchase of the services. Stripe reserves the right to contract any payment platform available in the market, which treats your data for the exclusive purpose of processing the purchase of the services. Please consult Stripe’s Privacy Policy here: https://stripe.com/privacy-center/legal
2.10 GOOGLE Analytics. We use Google Analytics provided by Google, Inc., USA (“Google”). These tool and technologies collect and analyze certain types of information, including IP addresses, device and software identifiers, referring and exit URLs, feature use metrics and statistics, usage and purchase history, media access control address (MAC Address), mobile unique device identifiers, and other similar information via the use of cookies. The information generated by Google Analytics (including your IP address) may be transmitted to and stored by Google on servers in the United States. We use the GOOGLE Analytics collection of data to enhance the website and platform and improve our service.

Please consult Google’s privacy policy here: https://policies.google.com/privacy

Third Party Websites

2.11 Our Platform may include links to third party websites, plug-ins and applications (“Third Party Websites”). Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control Third Party Websites and are not responsible for the information they collect or for their privacy or data protection policies, and will not be responsible or liable to you for the same. Your use or access of such third party links is at your own risk and it shall be your sole responsibility to read the privacy policy of such third parties before providing your personal data to them.

Consent
2.12 By downloading the application, registering, using the services and providing us with personal information to communicate with you, you agree that we collect and use your information in accordance with this Privacy Policy. You can withdraw your consent by contacting us through the contact information or the contact page on our Platform.

3. Use of data

3.1 We only collect, store or use information for any or all of the following purposes in connection with the Platform     and/or Services (“Purposes”), which shall not extend beyond what is reasonable for us to provide you with our Platform and/or Services including, but not limited to:
(a) To process your registration for the Platform and/or Services;
(b) To register you as a Registered User;
(c) To process payment transactions made by you through the Platform;
(d) To provide details of a Session including but not limited, to your name, address, mobile phone number and/or email address;
(e) To contact you in order to respond to your enquiries or requests or to send you information, notices or updates relating to the Platform and/or Services;
(f) To promote, market or advertise the Platform and/or Services including making marketing calls or sending marketing messages to your email address or Singapore telephone number provided by you through the Platform     and/or Services;
(g) To provide customer service and support;
(h) To customise and personalise your experience on the Platform;
(i) To help us provide, maintain, develop, test, improve and enhance the Platform and/or Services;
(j) To administer and protect our business and Platform and/or Services (including troubleshooting, data analysis, testing, system maintenance and support, reporting and hosting of data);
(k) To detect or investigate any prohibited, illegal, unauthorised or fraudulent activities;
(l) To monitor and analyse user activities and demographic data including trends and usage of the Platform and/or Services;
(m) To measure consumer interest in the Platform and/or Services;
(n) To generate and/or track anonymous analytics data, which would not constitute personal data within the meaning of the PDPA although it may be derived from your personal data;
(o) To back up our systems and allow for disaster recovery;
(p) To comply with any applicable laws, regulations, codes of practice, guidelines, rules, court order or other legal compulsion, or to assist in law enforcement and investigations conducted by any governmental or regulatory authority;
(q) To protect the rights, property or personal safety of our staff or the public;
(r) For any other purposes for which you have provided the information;
(s) For any other purposes related to or in connection with above; and 
(t) To transmit to any unaffiliated third parties including our Third-Party Service Providers and agents, or relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes. 

3.2 The Purposes listed above may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under any contract with you).
3.3 We will secure your consent to share your data with any other organisations explicitly in each instance except when we are compelled to make a disclosure by due legal process applicable in your jurisdiction in which case we shall use best endeavours to notify you that the disclosure is being made and what aspects of your data are being disclosed.
3.4 We may also collect, use and share aggregated data such as statistical or demographic data for any purpose. For example, we may use such aggregated data for data analytics purposes to improve our Website, Services, marketing, customer and User relationships and experiences. Such aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. In the event such aggregated data is combined with or connected to your personal data such that it can directly or indirectly identify you, we will treat such combined data as personal data, which will be used in accordance with this Policy.
3.5 Your personal data will be kept for the time necessary to provide the services or as long as the user does not delete the application from his phone or withdraw his consent. Your personal data will be promptly deleted from our database after you terminate your account.

4. Disclosure of data

4.1 We may disclose data to parties including, but not limited to, in the following circumstances:
(a) To our Third-Party Service Providers including our advisers and consultants, our agents, our advertisers, our vendors, our subcontractors and out payment gateway, credit or debit card companies, banks and other entities processing payment transactions made by you through the Platform and/or Services;
(b) To Third-Party Service Providers, agents and other organisations we have engaged to perform any of the functions
listed in Clause 3.1 above for us; 
(c) To third parties that require relevant data in connection with a corporate merger, consolidation, the sale of substantially all assets or other fundamental corporate change of us; 
(d) To other Registered Users contacted and/or engaged by yourself through a Session booking;
(e) Government or regulatory authorities; and/or
(f) To any other party where such disclosure is required for performing our obligations in the course of or in connection with the provision of our Platform and/or Services, to the extent required in the normal course and scope of our business in the provision of the Platform and/or Services.

4.2 We do not control and to the fullest extent permissible by applicable laws, shall not be responsible or liable in any way for the collection, use or disclosure of data by the parties to whom we disclose such data. If we engage a Contractor from time to time to provide services relating to the processing of personal data obtained from the Platform and through your Services, we will take the necessary steps to ensure that such Contractor agrees to comply with the obligations under Personal Data Protection Act 2012 (the “PDPA”) as required.
4.3 We may, from time to time, collect, use or disclose data as a data intermediary on behalf on an event organiser. In such event, our only obligation is to ensure that, as a data intermediary, we comply with the obligations under the      PDPA which are applicable to a data intermediary     
4.4 By using our Platform and/or Services, you expressly acknowledge and consent to the disclosure of your personal data to the parties listed in Clause 4.1.

5. Security
We work to protect the security of your information during transmission by using Secure Sockets Layer (SSL) software, which encrypts information you input. 
5.1 We maintain safeguards and put in place security measures which we deem to be reasonably appropriate to ensure the security and privacy of data collected by us.
5.2 We also limit the disclosure of personal data both internally and to our agents, contractors, Third-Party Service Providers and other third parties to a need-to-know basis. We require all third parties to respect the security of your personal data and to treat it in accordance with the law and in accordance with their own privacy policies.
5.3 Notwithstanding the foregoing, while we strive to protect your data, we cannot guarantee the security or privacy of such data or that such data will not be subject to any loss, theft or unauthorised access, collections, use disclosure, alteration or disposal, and subject to any applicable law, we hereby disclaim any responsibility or liability directly or indirectly arising out of or in connection with the same.
5.4 It shall be your sole responsibility for safeguarding and maintaining the confidentiality of your data and checking your privacy settings regularly to ensure the security and privacy of your data. You should be aware that no method of transmission over the Internet or method of electronic storage is completely secure. 
5.5 No method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while IHEARU strives to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

6. Transfer of personal data overseas

Data collected by us will be stored on our servers, which may be located in Singapore or overseas. If we need to transfer data outside Singapore, we will put in place measures to provide a standard of protection in such territory outside Singapore that is comparable to the protection under the PDPA. By using our Platform, registering as a Registered User, or using our Services, you consent to the transfer of your personal data to countries outside of Singapore, including without limitation, for the purposes set out in Clause 3.1. 

7. Retention of your personal data

7.1 We will only retain your personal data for as long as necessary to fulfil the purposes for which it was collected, or as required or permitted by applicable laws. including satisfying any legal, accounting, or reporting requirements.

7.2 We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.

8. Access and correction of your personal data

8.1 Subject to the exceptions referred to in Section 21 of the PDPA, you have the right to request access to a copy of your personal data which we hold about you or information about the ways in which we use or disclose your personal data.
8.2 You also have the right to request for the correction or update of any personal data of yours which we hold. We generally rely on personal data provided by you. We want to ensure that your personal data is current, complete and accurate. Please update us if there are changes to your personal data.
8.3 If you wish to make (a) an access request, or (b) a correction request, you may submit your request in writing of via email to our Data Protection Officer at the contact details provided below. 
8.4 We will respond to your request as soon as reasonably possible or practicable. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of receiving your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).
8.5 We may need to request specific information from you to help us confirm your identity. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also need to verify the accuracy of any new data you provide us.
8.6 You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if: 
(a) Your request unreasonably interferes with our operations due to its repetitious or systematic nature; 
(b) The burden or expense of providing access would be unreasonable to us or disproportionate to your interests; 
(c) The information  does not exist, cannot be found, or is trivial; or 
(d) Your request is otherwise frivolous or vexatious. Alternatively, we may refuse your request in these circumstances.

9. Visiting the Platform from outside Singapore

9.1 The Platform is operated and hosted in Singapore. If you are visiting the Platform from outside Singapore, please be aware that your data may be transferred to, stored and processed in Singapore where our servers are located. By using and accessing the Platform, you hereby consent to the transfer of your data to Singapore and its collection, use and disclosure as set out in this Privacy Policy. You further agree that all payment transactions made by you through the Platform shall  be deemed to have occurred in Singapore.
9.2 You also acknowledge that your use or access of the Platform may be subject to local laws applicable in such territory outside Singapore from where you are visiting the Platform. It shall be your sole responsibility to ensure that you use and access the Platform only in compliance with such applicable local laws.

10. Contact details

You may contact our Data Protection Officer, or any of our representatives and/or employees, if you have any enquiries or feedback on this Policy, our personal data protection policies and procedures, or if you wish to make any request, at info@ihearu.app.

Definitions

“Company”, “we”, “us” or “our” means THE WELLNESS CONCIERGE PTE. LTD.  (a company incorporated under the laws of the Republic of Singapore and holding registered company number: 202406860N, with registered office at 60 PAYA LEBAR ROAD, #07-54, SINGAPORE (409051), including where the context so allows, its shareholders, employees and affiliates; 

“Mobile App” means the I HEAR U mobile application; 

“Caller” means the individual seeking mental wellness support through listening or therapy, and “Callers” shall be construed accordingly;      

“Contractor” means any third-party service provider we engage to provide services relating to the processing of personal data such as and not limited to advisers, consultants, agents, advertisers, marketers, vendors, subcontractors, out payment gateway, credit or debit card companies, banks and other entities processing payment transactions made by you through our Platform and Services;

“PDPA” means the Personal Data Protection Act 2012 of Singapore; 

“Personal data” means data, whether true or not, about an individual who can be identified: 

(a) from that data; or 

(b) from that data and other information to which we have or are likely to have access, which is provided to us or any other User in relation to or in connection with any Service including information provided during registration, the reviews and rating of Listener / Listener + and any other communication processes arising as a result of your use of the Platform     and/or Services; 

“Platform” means the IHEARU Website and any web or Mobile App owned and/or operated by The Wellness Concierge Pte. Ltd.;          

“Privacy Policy” means our privacy policy, as amended by us from time to time, found at [https://www.IHEARU.COM/]; 

“Purposes” has the meaning given to the word in Clause 3.1; 

“Registered User” and “User” mean, collectively, any Caller/Callers, Care Caller/Care Callers and/or Listener / Listener + that has registered with the Company, and “Registered Users” and “Users” shall be construed accordingly;

“Services” means the services, information and resources provided by the Company to Registered Users through our Mobile App and/or Website; 

“Session” means work carried by any Listener / Listener + , for any Caller, through the Platform as requested by a Caller and accepted by a Listener/Listener +, and “Sessions” shall be construed accordingly;

“Listener”, “Listener +”, “Counsellor” or “Psychologist” means a mental wellness provider for a Caller     

“Terms” means the Terms of Service of THE WELLNESS CONCIERGE PTE. LTD.  for its Mobile App, as amended by us from time to time, found at [https://www.IHEARU.APP/]; 

“Third Party Service Provider” means external service providers who have entered into service agreements with us to assist us in: 

(a) Operating our Platform; 

(b) Providing our Services to you; or 

(c) Conducting our business generally;  

“Third Party Websites” means websites which are not owned or controlled by the Company; and  

“User” or “You” means any user of or an individual who accesses the Platform and/or Services.