Privacy Policy

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LivWell Holding Pte. Ltd. (“LivWell”, “we”, “us” or “our”) is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, disclose, store and protect your personal data when you visit www.livwell.asia, use the LivWell App or interact with our services (together, the “Services”). It also explains your rights and how you may exercise them. 

Please read this Privacy Policy together with our Terms of Use at https://www.livwell.asia/terms-of-use.html. By using the Services, you acknowledge that you have read this Privacy Policy. Where applicable law requires consent, we will request your specific and informed consent before processing. You may withdraw consent at any time, although withdrawal does not affect processing carried out lawfully before withdrawal and may affect features that depend on the relevant data.

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1. Personal data we collect

• Account and contact information, including your name, email address, phone number, password, address, profile information and other identifiers. 
• Health and fitness information, including height, weight, gender, heart rate, steps, calories, physical activity, wellness information, health statistics, consultation information and other information that you choose to provide or connect. Health and location information may be sensitive personal data under applicable law. 
• Device and technical information, including your IP address, device identifiers, advertising identifiers, operating system, app version, browser type, time zone, login information, crash information and security logs. 
• Usage and interaction information, including pages viewed, searches, clickstream, feature usage, session information, scrolling, clicks, download errors and communications with our support team.
• Location and movement information from your device, connected devices or wearables where you enable the relevant feature. 
• Payment and transaction information necessary to process purchases, rewards or other transactions. Payment providers may process payment details directly. 
• Information received from connected devices, business partners, employers, service providers, analytics providers, advertising or search providers and other services you use.

2. How we use personal data

• To provide, operate, maintain and improve the Services, including health statistics, fitness recommendations, rewards, classes, products and partner services. 
• To verify physical movement and location, calculate and issue LivWell Coins, operate the LivWell Reward Platform, and investigate fraud, abnormal data or disputes. 
• To enable the LivWell App to connect to the Health App on your device, including Google Health Connect on Android and Apple HealthKit on iOS, to read and, where enabled, write the specific health data needed for the feature you select. 
• To provide teleconsultation, customer support, in-app messaging and other services that you request.
• To administer, secure and troubleshoot the Services; conduct testing, research, statistical analysis and surveys; and detect, prevent or investigate fraud, abuse and security incidents. 
• To communicate with you about your account, service changes, transactions and support requests. 
• With your consent where required, to send marketing communications or allow selected partners to send marketing communications. You may opt out at any time.
• To comply with legal obligations, enforce our terms, protect rights and safety, and respond to lawful requests.

3. Health Connect and Apple HealthKit

We request only the health-data types required for a specific, user-facing feature. Access to Health Connect or Apple HealthKit is not required for unrelated parts of the Services. 

Health data obtained through Google Health Connect or Apple HealthKit is used only for the purposes described in this Privacy Policy and the relevant in-app permission prompt. We do not sell this data, use it for advertising or interest-based advertising, or transfer it to data brokers. 

We do not use Health Connect or Apple HealthKit data to determine insurance eligibility, insurance premiums, coverage decisions, employment eligibility, creditworthiness or other similarly significant decisions. 

You can pause synchronization or manage permissions in the LivWell App settings. On Android 14 and later, go to Settings → Health Connect → App permissions → LivWell. On earlier Android versions, go to the Health Connect app → Data and access → LivWell → App permissions. On iOS, manage access through Settings → Health → Data Access & Devices → LivWell, where available. 

If you revoke access, we will stop new reads and writes. Data previously collected may remain where necessary to provide a service you requested, meet legal obligations, resolve disputes, prevent fraud or maintain security, subject to your deletion rights and applicable retention requirements.

4. Legal basis and consent

We process personal data as permitted by applicable law, including to provide a requested service or perform a contract, comply with legal obligations, protect vital interests, pursue legitimate operational interests where permitted, and based on your consent. 

For sensitive personal data, including health data, we will provide the required notice and obtain the consent or rely on another lawful exception required by applicable law. Consent requests will identify the data, purpose, recipients or categories of recipients, and relevant rights. Silence or inactivity is not consent. 

You may refuse optional processing without losing access to unrelated Services. Withdrawing consent may disable a feature that requires the relevant data.

5. Disclosure of personal data

We may disclose personal data to members of our corporate group, professional advisers, payment providers, business partners providing a service you request, government authorities where legally required, and service providers acting on our instructions. 

We do not sell personal data. We require service providers processing personal data on our behalf to protect it and use it only for authorised purposes.

Our current service providers include: CleverTap for push notifications and engagement analytics - no health data; PostHog for product analytics - no health data; Firebase for push notifications and crash reporting - no health data; Intercom for in-app support messaging - no health data; Branch for deep linking - no health data; DiaB for teleconsultation - limited health data in the consultation context; and MongoDB Atlas, hosted through GCP Singapore, for data storage and hosting - health data as required for stored data. 

Data collected from the Health App on your device, including height, weight, gender, heart rate, steps or calories, and data connected through Google Health Connect or Apple HealthKit, will not be shared with third parties unless your consent or disclosure is otherwise required or permitted by applicable law.

6. International transfers and storage

We may store, process and transmit personal data in Vietnam and other countries, including Singapore and countries where our service providers operate. These countries may have different data-protection laws. We use contractual, technical and organisational safeguards appropriate to the data and the transfer and will provide additional information where required by applicable law. 

Where required by Vietnamese law, LivWell maintains personal-data processing impact-assessment records and cross-border transfer assessment records. These operational records are separate from this public Privacy Policy. 

We retain personal data only for as long as necessary for the purpose for which it was collected, to provide the Services, meet legal and accounting requirements, resolve disputes, enforce agreements and maintain security. When data is no longer required, we delete, anonymise or securely destroy it where appropriate.

7. Security

We use reasonable technical and organisational safeguards, including access controls, authentication, encryption in transit, secure hosting practices, logging, backups, vendor controls and staff confidentiality obligations. No transmission or storage system is completely secure, so we cannot guarantee absolute security. 

If we discover a personal-data incident, we will investigate, contain and remediate it and make notifications required by applicable law.

8. Your rights and choices

Depending on applicable law, you may request access, correction, deletion, restriction of processing, data portability, withdrawal of consent, or objection to marketing and other processing. 

Under Vietnamese personal-data protection law, data subjects may have rights including the right to be informed, consent or refuse, access, correct, withdraw consent, delete, restrict processing, provide personal data, object, complain, seek compensation and protect their own rights. 

You may manage certain account information in the App or contact us. We may verify your identity as reasonably necessary and will respond within the period required by applicable law. Where we cannot fulfil a request, we will explain why, subject to legal exceptions. 

To stop marketing communications, use the unsubscribe mechanism in the message or contact us. To delete your account, use the in-app account-deletion function or contact us. Account deletion may not immediately remove data that we must retain by law or for security, fraud prevention, disputes or legitimate operational records.

9. Children 

The Services are not directed to children where use is prohibited by applicable law. We do not knowingly collect children’s personal data without the required consent of a parent or guardian. If you believe that a child has provided personal data improperly, contact us so that we can investigate and delete it where required. 

10. Cookies and similar technologies 

We use cookies and similar technologies on our website to operate the site, remember preferences, understand usage and, where permitted, measure marketing. You can control cookies through your browser settings. Some features may not work correctly if optional cookies are disabled. 

11. Automated decisions and profiling 

We may analyse usage, movement, fitness or reward data to provide recommendations, detect fraud and improve the Services. We do not use Health Connect or Apple HealthKit data for insurance eligibility, insurance premiums, coverage decisions, employment eligibility or similarly significant decisions. Where applicable law gives you rights regarding automated decision-making or profiling, you may contact us. 

12. Links to other websites 

The Services may contain links to third-party websites, products or services. Their privacy practices are governed by their own policies, and LivWell is not responsible for them. Please review those policies before submitting personal data. 

13. Changes to this Privacy Policy 

We may update this Privacy Policy from time to time. We will post the updated version on this page and, where appropriate, notify you through the Services or by email. The “Last updated” date identifies the effective version. 

14. Contact 

Questions, requests and complaints regarding this Privacy Policy or the processing of your personal data are welcomed. Please contact: 

LivWell Holding Pte. Ltd. 

General privacy contact: Admin@Livwell.asia 

Data-protection-specific inquiries: vikas@livwell.asia