We at CureFit Healthcare Singapore Pte. Ltd. (UEN: 201906748N), a company incorporated under the laws of Singapore, and its subsidiaries, affiliates and related corporations (“CureFit”, “Company”, “we”, “us”, or “our”), own and operate the ‘CureFit’ mobile application, related website and domain name, and any other linked pages (the “Platform”) which provides curated content, products and services relating to physical and mental wellness, and cooking and nutrition. This Privacy & Data Protection Policy (the “Privacy Policy”) explains how we collect, use, disclose or process your personal data through your interactions with our services, websites, platforms, devices, applications, programmes, servers, software including the following properties which are owned and operated by us:
What does this privacy policy cover?
This privacy policy covers our treatment of personally identifiable information ('personal information') that we gather when you are accessing or using our Platform and Services. This policy does not apply to the practices of companies that we do not own or control, or to individuals that we do not employ or manage.
We do not knowingly collect or solicit personal information from anyone under the age of 18 or knowingly allow such persons to register for the Services. If you are under 18, please do not attempt to register for the Services or send any information about yourself to us, including your name, address, telephone number, email address or provide your biometric information. No one under age 18 may provide any personal information to us or through the Services. In the event that we learn that we have collected personal information from a child under age 18 without verification of parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 18, please contact us at by writing to our Data Protection Officer (contact details below).
What information does CureFit collect?
We gather various types of personal information from our users, as explained more fully below. We may use this personal information to personalize and improve our services, to allow our users to set up a user account and profile, to contact users, to fulfill your requests for certain products and services, to analyze how users utilize the Platform and Services, and as otherwise set forth in this Privacy Policy. We may also share certain types of personal information with third parties. We collect the following types of information:
Information you provide to us:
We receive and store any information you knowingly provide to us. For example, we collect personal information such as your name, username, email address, gender, birth date, weight, height, location, nutrition data, workouts, physical activity, photographs, biometric information, and sleep habits and we may collect other sleep, activity, or health-related information as our services and products are further developed. You can choose not to provide us with certain information, but then you may not be able to register with us or to take advantage of some of our features or Services. We may anonymize your personal information so that you cannot be individually identified, and provide that information to our partners. For example, you may tell us that you are female and sleep an average of 6 hours per night; we may combine this information with content received from our other users, and disclose to our partners that on the whole, our male users sleep more hours per night than our female ones, but we will not tell those partners who you are individually.
Information collected automatically:
Whenever you interact with our Platform, we automatically receive and record information on our server logs from your browser including your IP address, 'cookie' information, and the page you requested. 'Cookies' are identifiers we transfer to your computer or mobile device that allow us to recognize your browser or mobile device and tell us how and when pages in our Platform are visited and by how many people. You may be able to change the preferences on your browser or mobile device to prevent or limit your computer or device's acceptance of cookies, but this may prevent you from taking advantage of our Platform's best features.
When we collect usage information (such as the numbers and frequency of visitors to the Platform), we only use this data in aggregate form, and not in a manner that would identify you personally. For example, this aggregate data tells us how often users use parts of the Platform, so that we can make the Platform appealing to as many users as possible. We may also provide this aggregate information to our partners; our partners may use such information to understand how often people use our Platform, so that they, too, can provide you with an optimal online experience. We never disclose aggregate information to a partner in a manner that would identify you personally.
If you are using our Services, you understand and acknowledge that, any information, data or readings from the Services, or collected from Your use thereof, will be automatically uploaded to your account with us. To the extent these automatically collected readings can be used to personally identify you, these readings are personal information for the purposes of this privacy policy.
We recognise the importance of safeguarding your personal data and take our responsibility to properly manage, protect and process your personal data seriously in compliance with the Personal Data Protection Act 2012 (No. 26 of 2012) of Singapore (the “PDPA”). We are a controller of the personal data collected from you through the Platform and/or during the process of the registration as a User of the Services. This Privacy Policy applies to all our interactions with you as well as other Services that have a reference or link to this Privacy Policy. Unless otherwise defined herein, capitalised terms used in this Privacy Policy shall have the same meanings as those defined in the Terms of Use
Please read this Privacy Policy carefully and should you have any queries about how we may manage, protect or process your personal data, please do not hesitate to contact our Data Protection Officer at [email protected]. By continuing to use our Services, you are deemed to have consented to the terms of this Privacy Policy. Please note that certain features of the Platform, Website and Apps require the provision of your personal data, and where you do not provide such requested information, we may not be able to provide you with the Services. Please notify us and stop using our Services immediately if you do not consent to this Privacy Policy. Further, if you do not consent to us using your personal data as described above, please do not provide us with your personal data and terminate your CureFit account immediately. Please also write to us at [email protected] / [email protected] with subject heading: “Personal Data – Withdrawal of consent” and we will terminate your access to the CureFit Platform and remove your personal data from our database as soon as possible, unless the same is required to be retained under applicable law. You will not be able to access CureFit’s content, products and services if you do not consent to the above.
Personal data collected by us
We own and operate the Platform that provides curated content, products and services relating to physical and mental fitness, wellness, and cooking and nutrition.
Collection – Whose personal data is collected?
In this Privacy Policy, “personal data” means personally identifiable information that you provide to us, or we collect about or from you, through your use of the Services. By using our Services, whether as a: (i) visitor of the Website; (ii) User of the Services; or (iii) regulated third parties (duly authorised by the Users), we may collect your personal data.
Collection – What personal data is collected?
In using the Services, you may be asked to provide us with personal data such as your name, passport or ID number, email address, residential or business address, contact phone number, age, date of birth, gender or any information you choose to provide when filling in a contact form or otherwise on our Platform, IP address or any other technical information that tells us how you use the Website, and we may collect your personal data either directly from you, your authorised representatives, and/or through our third-party service providers (e.g. partners or third-party applications) to personalise your experiences and improve our Services. In addition, during the onboarding process and for the purposes of our Know-Your-Customer (“KYC”) background checks, we may require information about your race, ethnicity and background, as well as other details that may be contained in the KYC documents you had provided to us, such as the copy of your passport, identification card or driver’s license.
By accessing or using our Services or otherwise providing us with your personal data, we shall be entitled to assume that you understand and agree to the terms of this Privacy Policy and consent to the collection, use and disclosure of your personal data by us. If you do not consent to any of these terms, please do not access or use any of our Services or provide us with any of your personal data.
Purposes for collection, use, disclosure & processing of personal data
We use your personal data to provide you with relevant Services and to operate our
business. We may also use the data collected to communicate with you, for instance, to inform you about new
features of the Services, security updates, or to inform you about your account. Your personal data may also
be used to show you more relevant information, content, advertisements, whether through the Services or
third-party applications and in combination with information from other sources.
Some examples of how we use your personal data include:
We process your personal data for these purposes listed above on the following legal basis:
You can indicate your objection to our processing, based on our legitimate interests, at any time by writing to our Data Protection Officer. Please also refer to paragraph 5.9 below, for more details.
The way your personal data is used will depend on the circumstances at hand, and it will be used in compliance with applicable laws and regulations.
We may process and use your personal information to facilitate a change of control or sale of the Company or to facilitate a restructuring or other corporate rearrangement.
Sharing your personal data with third parties; International Transfers
It may also be necessary in certain circumstances for us to share your personal data with third parties such as our subsidiaries, affiliates, related corporations, service providers, vendors, regulatory authorities or other third parties. Such third parties processing your personal data either on our behalf or otherwise may be located in a different country from the point of collection of your personal data (e.g. transfer to servers located outside of the country you are accessing the Services from), or may have multiple physical locations and backups (e.g. cloud based services). We have carefully selected these third-party service providers and have taken steps to ensure that when we share your personal data with them, it is adequately protected. All of our service providers are bound by contracts to process personal data provided to them only for the purpose of providing the specific service to us and to maintain appropriate security measures to protect your personal data.
Where your personal data must be shared with third parties in circumstances that are not reasonably
contemplated within the normal course of our dealings with you, we would usually first seek your consent
unless the disclosure:
Where we disclose your personal data to third parties, we will employ our best efforts to require such third parties to protect your personal data and meet our data security standards, including ensuring they are bound by legally enforceable obligations to comply with all applicable personal data protection requirements while such personal data remains in its possession or under its control.
By using our Services, you agree that the transfer of your personal data to various countries is reasonably necessary for us to provide you with these Services.
We may also elect to anonymise your personal data before sharing it with third parties. The legal basis for such anonymisation is set out at paragraph 2.3. The terms of this Privacy Policy do not apply to such anonymised data.
We neither rent nor sell your personal information in personally identifiable form to anyone. We share your personal information in personally identifiable form with third parties only as described below.
Affiliated businesses and third-party websites we do not control: In certain situations, businesses or third-party websites we're affiliated with may sell items or provide services to you through the Platform (either alone or jointly with us). You can recognize when an affiliated business is associated with such a transaction or service, and we will share your personal information with that affiliated business only to the extent that it is related to such transaction or service.
Agents: We employ other companies and people to perform tasks on our behalf and need to share your information with them to provide the Services to you. Unless we tell you differently, our agents do not have any right to use the personal information we share with them beyond what is necessary to assist us.
User submissions: Any content or personal information that you voluntarily disclose online in a manner other users can view (on discussion boards, in messages and chat areas, etc.) becomes publicly available, and can be collected and used by others.
Business transfers: We may choose to buy or sell assets. In these types of transactions, customer information is typically one of the business assets that is transferred. Also, if we (or substantially all of our assets) are acquired, or if we go out of business or enter bankruptcy, personal information would be one of the assets transferred to or acquired by a third party.
Protection of CureFit and others: We may release personal information when we believe in good faith that release is necessary to comply with laws; enforce or apply our conditions of use and other agreements; or protect the rights, property, or safety of Curefit, our employees, our users, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.
With your consent: Except as set forth above, you will be notified when your personal information may be shared with third parties, and you will be able to prevent the sharing of this information.
Third party links
Our Website may contain links to other websites that are not operated by us. If you click on a third-party link, you will be directed to that third party's website. These third-party websites have separate and independent privacy policies. We strongly advise you to review the privacy policy of every website you visit.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party websites or services.
How is my iOS HealthKit, Health app and Google Fit data handled? When you share your iOS Health app data or Google Fit with our Products, that data is covered by this Privacy Policy.
We handle all iOS Health app and HealthKit data in accordance with Apple's development guidelines. To view Apple's HealthKit developer guidelines, go to https://developer.apple.com/app-store/review/guidelines/#health-and-health-research.
We handle Google Fit data in accordance with Google Fit Terms of Service. To view Google Fit Terms of Service go to https://developers.google.com/fit/terms.
We acknowledge that HealthKit, Health app, iPhone, and Apple are registered trademarks of Apple Inc. and Google Fit and Google are registered trademarks of Google Inc., respectively.
Rights in relation to your personal data
Rights under the PDPA Under the PDPA, you may submit a written request to us to ascertain whether the information we hold about you is accurate and current, and you may also access and correct your personal data.
Right to access and / or to correction of personal data: You may request access to or correct the personal data held by us by submitting a written request at any time to our Data Protection Officer . We may require further information from you to verify your identity as well as the nature of your request, to deal with your request. Handling and processing fees may be payable before we can proceed with your request. Once we have sufficient information to deal with your request, we will seek to provide you with the relevant personal data or information within thirty (30) days of your request, unless otherwise stated. There are certain circumstances in which we will decline to comply with your request under paragraph, which include (to the extent allowable under applicable law) situations where: (i) a government agency in Singapore or regulator with jurisdiction over us directs us not to comply with a customer’s request; (ii) the information may, in our discretion, affect the safety of any person or persons; and (iii) the data may be relevant to a regulator or official investigators as part of an investigation into criminal conduct or breach of applicable laws.
Withdrawal of consent to use your personal data: Should you wish to withdraw your consent to our use of your personal data, please stop using the Services immediately and notify us in writing by writing to our Data Protection Officer to inform us that you wish for us to stop collecting, using or sharing your personal data and we will process your request within a reasonable time from such a request. You may also elect to withdraw your consent to the use of your personal data for a specific purpose, so please ensure that your notification contains sufficient and specific information to enable us to comply with your request. However, your withdrawal of consent could result in certain legal consequences arising from such withdrawal. In this regard, depending on the extent of your withdrawal of consent for us to process your personal data, it may mean that we will not be able to continue with your existing relationship with us and we will no longer be able to provide you with access to our Services.
What personal information can I access?
Through your account settings, you may access, and, in some cases, edit or delete the following information
you have provided to us:
The information you can view and update may change as the Platform changes. Please note that any information that is automatically uploaded to the Platform or collected otherwise from You by us, cannot be later changed or updated. If you have any questions about viewing or updating information we have on file about you, please contact us by writing to our Data Protection Officer at [email protected].
Retention, Administration & Management of personal data
We will take reasonable efforts to ensure that your personal data is accurate and complete, based on the information that you have provided us with, and we may require further documents or evidence to enable us to verify any information provided. We may also conduct independent verification of any personal information that you have provided us with. Please ensure that all information provided to us is up to date and keep us informed of any relevant changes. You can always opt not to disclose information to use, but keep in mind some information may be needed to register with us or to take advantage of some of Platform features or Services. We will retain Your personal information for a reasonable period or as long as the law requires. If you would like us to delete/modify Information that you have provided via the Platform or otherwise to us, please contact us at [email protected] and we will respond in a reasonable time. Please note that some or all of the information provided by You to us may be required in order for the Platform to function properly. You may be able to add, update, or delete information as explained in section above. When you update information, however, we may maintain a copy of the unrevised information in our records. Please note that some information may remain in our private records as part of our Platform archive after your deletion of such information from your account. We may use any aggregated data derived from or incorporating your personal. We value your privacy and have security arrangements to ensure that your personal data is adequately protected and secured. We will also put in place measures such that your personal data in our possession or under our control is destroyed and/or anonymised as soon as it is reasonable to assume that: (i) the purpose for which that personal data was collected is no longer being served by the retention of such personal data; and (ii) retention is no longer necessary for any other legal or business purposes. Otherwise, personal data collected by us is generally only retained for as long as it is reasonably necessary for the purpose for which the data provided and we may destroy or delete any information or personal data provided by you thereafter, unless required by law, regulation or other business or audit requirements. Where your personal data is to be transferred out of Singapore or such other jurisdiction in which it is collected, we shall take reasonable steps to ascertain that the recipient of the personal data is bound by legally enforceable obligations to protect your personal data in accordance with this Privacy Policy and the PDPA.
Email and other communications
We may contact you, by email or other means; for example, we may send you promotional offers on behalf of other businesses, or communicate with you about your use of the Platform or the Services. Also, we may receive a confirmation when you open an email from us. This confirmation helps us make emails more interesting and improve our service. If you do not want to receive email or other mail from us, please indicate your preference by writing to us at [email protected].
Will curefit share any of the personal information it receives?
We neither rent nor sell your personal information in personally identifiable form to anyone. We share your personal information in personally identifiable form with third parties only as described below. In terms of the Services, the Company shall share the information collected from You with only such third parties in relation to whom you provide express consent. Affiliated businesses and third-party websites we do not control: In certain situations, businesses or third-party websites we're affiliated with may sell items or provide services to you through the Platform (either alone or jointly with us). You can recognize when an affiliated business is associated with such a transaction or service, and we will share your personal information with that affiliated business only to the extent that it is related to such transaction or service. Agents: We employ other companies and people to perform tasks on our behalf and need to share your information with them to provide the Services to you. Unless we tell you differently, our agents do not have any right to use the personal information we share with them beyond what is necessary to assist us. User submissions: Any content or personal information that you voluntarily disclose online in a manner other users can view (on discussion boards, in messages and chat areas, etc.) becomes publicly available, and can be collected and used by others. Business transfers: We may choose to buy or sell assets. In these types of transactions, customer information is typically one of the business assets that is transferred. Also, if we (or substantially all of our assets) are acquired, or if we go out of business or enter bankruptcy, personal information would be one of the assets transferred to or acquired by a third party. Protection of CureFit and others: We may release personal information when we believe in good faith that release is necessary to comply with laws; enforce or apply our conditions of use and other agreements; or protect the rights, property, or safety of Curefit, our employees, our users, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction. With your consent: Except as set forth above, you will be notified when your personal information may be shared with third parties, and you will be able to prevent the sharing of this information.
Your account is protected by a password for your privacy and security. You need to prevent unauthorized access to your account and personal information by selecting and protecting your password appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your account. We endeavor to protect the privacy of your account and other personal information we hold in our records, but we cannot guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time. The Platform may contain links to other sites. We are not responsible for the privacy policies and/or practices on other sites. When following a link to another site you should read that site's privacy policy. However, as effective as encryption technology is, no security system is impenetrable. We cannot guarantee the security of our database, nor can we guarantee that information you supply will not be intercepted while being transmitted to us over the Internet. Any transmission of information by you to our Platform or otherwise is at your own risk.
Complaints / Queries
If you do not consent to any of the terms of this Privacy Policy, our use of your personal data or have any complaint or grievance regarding about how we handle your personal data, we welcome you to contact us with further details at:
Contact details of Data Protection Officer
E-mail address: [email protected] Office address: Curefit HQ Office #17/17C BDA 3rd Sector, HSR Layout, Bengaluru, Karnataka, 560102 Attn: Data Protection Officer
Please ensure that your correspondence provides us with sufficient information and detail for us to address your concerns.
Updates on data protection policy
As part of our efforts to ensure that we properly manage, protect and process your personal data, we will be reviewing our policies, procedures and processes and may update, at our absolute discretion, the terms of this Privacy Policy from time to time. Any revised Privacy Policy will be posted on our Website. You are encouraged to visit the above Website from time to time to ensure that you are well informed of our latest policies in relation to personal data protection. We may amend this privacy policy from time to time. Use of information we collect now is subject to the privacy policy in effect at the time such information is used. If we make changes in the way we use personal information, we will notify you by posting an announcement on our Platform or sending you an email. You are bound by any changes to the privacy policy when you use the Platform after such changes have been first posted. If you do not wish to receive email or other correspondence from us, please email us at: [email protected]. Please note that if you do not want to receive legal notices from us, such as updates to this Privacy Policy, those legal notices will still govern your use of the Platform, and you are responsible for reviewing such legal notices for changes.
Cookie Policy
We may collect information from you (or others on your behalf) de-identified information to help us in our business and provide you with the relevant Services. Such anonymised and de-identified information does not constitute personal information and may be transferred, disclosed, assigned, leased, licensed, sold and otherwise shared with and by our partners, service providers, advertisers and/or other third parties for purposes permitted under law. Cookies (small text files placed on your device that record information about your preferences and enable log-ins, provide interest-based advertising, analyse how our Services are performing) are an example of such anonymised data which we collect. While compiling information about your browsing habits, cookies can also enhance your user experience. There may also be third party cookies on our Websites. For more information on cookies, please refer to allaboutcookies.org/manage-cookies/. You can control cookies through your web browser settings. This allows you to determine which cookies to allow and which to refuse. If you disallow the use of cookies on our Website, please note that you may not be able to access the full range of functions that our Platform offers. Our advertising partners may also transmit cookies to your browser or device, when you click on advertisements that appear on the Services. Further, if you click on a link to a third-party website or service, a third party may also transmit cookies to you. For the avoidance of doubt, this Privacy Policy does not cover the use of cookies by any third parties, and we are not responsible for their privacy policies and practices. Please be aware that cookies placed by third parties may continue to track your activities online even after you have left our Services, and those third parties may not honour ‘Do Not Track’ requests that you have set using your browser or device. If you do not consent to our use of cookies, you should adjust your browser settings accordingly or not use any of the Services. Your interest profile can be removed by deleting your browser’s cookies. The cookie information stored on the User's hard drive is: (i) User segment hits or information on a specific product, service, brand or model in which the User has shown interest during its visit to a certain website and (ii) time and date stamp of the latest update of the User profile. If the cookie is deleted by the User, all profile data is removed. For the sake of clarity, no segments relating to information which CureFit considers sensitive have been or will be created, such as segments relating to political opinions, religious beliefs, physical or mental health conditions or sexual life. Further, CureFit is very sensitive to the issue of children's privacy and marketing directed to children. No segments are intended to be established for the profiling of children.
Note: By using the Services, you are representing that you agree to the terms and conditions contained in this Privacy Policy and our Terms of Use, and this agreement supersedes any other agreement that we might have with you concerning the use of your personal data. If you do not agree to any of these terms and conditions, you must stop using/accessing the Services. This Privacy Policy is governed by the laws of Singapore.
Last Updated on 09 May 2020.
Copyright © 2020, All rights reserved.