Privacy Policy

Last updated: July 23, 2021 

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You. 

We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy. 

 

Interpretation and Definitions 

Interpretation 

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural. 

Definitions 

For the purposes of this Privacy Policy: 

Account means a unique account created for You on the Application. 

Affiliate means an entity that is related to, or controlled by, directly or indirectly, or is under common control of the Company or the Company’s Shareholders.  

Application means the reach52 software program and platform that is being used to collect your data.  

Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to reach52 Pte Ltd (UEN 201625706K), with address at 531A Upper Cross Street #04-95, Hong Lim Complex, Singapore 051531 

Device means any device that can access the Service such as a computer, a cellphone or a digital tablet. 

Personal Data is any information that relates to an identified or identifiable individual. 

Service refers to the service that is available to You on the Application. 

Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used. 

Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself. 

You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable. 

 

Collecting and Using Your Personal Data 

Types of Data Collected 

Personal Data 

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to Your: 

Email address 

First name and last name 

Phone number 

Address, State, Province, ZIP/Postal code, City 

Usage Data 

Health Data 

We may collect from You or You may voluntarily provide us with certain health-related information which may include, but is not limited to Your: 

Health status 

Medication history (such as any medication you are currently taking or any chronic conditions You suffer from) 

Health screening results (which may be collected from Our Service or that You voluntarily share with us)  

We will generally seek Your consent before collecting your health data, unless We are otherwise authorized or required by law to do so.  

Usage Data 

Usage Data is collected automatically when using the Service. 

Usage Data may include information such as Your Device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data. 

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data. 

We may also collect information that Your browser sends whenever You use Our Application or when You access the Service by or through a mobile device. 

Information Collected while Using the Application 

While using Our Application, in order to provide features of Our Application, We may collect: 

  • Pictures and other information from your Device’s camera and photo library 

We use this information to provide features of Our Service, to improve and customize Our Service. The information may be uploaded to the Company’s servers and/or a Service Provider’s server or it may be simply stored on Your device. 

Use of Your Personal Data 

The Company may use Personal Data for the following purposes: 

To provide and maintain our Service, including to monitor the usage of Our Service. 

To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user. 

For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service. 

To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation. 

To provide You with news, special offers and general information about other goods, services and events which We offer that are similar to those that You have already purchased or enquired about unless You have opted not to receive such information. 

To manage Your requests: To attend and manage Your requests to Us. 

For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred. 

For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of Our promotional campaigns and to evaluate and improve our Service, products, services, marketing and Your experience. 

We may share Your personal information in the following situations: 

  • With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, to contact You. 
  • For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company. 
  • With Affiliates: We may share Your information with Our affiliates, in which case We will require those affiliates to honor this Privacy Policy. Affiliates include related entities and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us. 
  • With business partners: We may share Your information with Our business partners to offer You relevant products, services or promotions, and/or to perform data analysis and research. 
  • With Your consent: We may disclose Your personal information for any other purpose with Your consent. 

Retention of Your Personal Data 

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy and in accordance with applicable laws. We will retain and use Your Personal Data to the extent necessary to comply with Our legal obligations (for example, if We are required to retain Your data to comply with applicable laws), resolve disputes, and enforce Our legal agreements and policies. 

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods. 

Transfer of Your Personal Data 

Your information, including Personal Data, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction. 

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer. 

The Company will take steps that are reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy, and that any transfer of Your Personal Data will be subject to controls in place including for the security of Your data. 

 

Disclosure of Your Personal Data 

Business Transactions 

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be disclosed to persons involved in such transaction. We will provide notice of such disclosure where required by law. 

Law enforcement 

Under certain circumstances, the Company may be compelled to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency). 

Other legal requirements 

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to: 

  • Comply with a legal obligation 
  • Protect and defend the rights or property of the Company 
  • Prevent or investigate possible wrongdoing in connection with the Service 
  • Protect the personal safety of Users of the Service or the public 
  • Protect the Company against legal liability 

Security of Your Personal Data 

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security. 

 

Children’s Privacy 

Protecting the privacy of children is Our primary concern, hence We will only collect and maintain personally identifiable information from anyone under the age of 13 with prior consent from the parent or legal guardian. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data without Your consent, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers. 

 

Changes to this Privacy Policy 

We may update Our Privacy Policy from time to time.  

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page. 

 

Contact Us 

If you have any questions about this Privacy Policy, You can contact our Data Protection Officer by email at: dataprivacy@reach52.com. 

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