Last update: 01.01.2022

iPlena Pte. Ltd. (“iPlena”, “we”, “us”, or “our”), we are committed to protecting your (“you”, “your”, or “yourself”) privacy and security. As such, we want you to be familiar with how we collect, use, and disclose information in our effect to provide you with the best possible experience on our application iPlena (the “App”).

This Privacy Policy applies to App and related services, sales, marketing, events and other interactions you may have with iPlena. This Privacy Policy does not apply to any third party applications or software that integrate with the App (“Third Party Services”), or any other third party products, services or businesses.

If you do not agree with the terms, do not access or use the App or any other aspect of iPlena’s services.

The App don’t not ask for nor do it collect any of your personal health information.
iPlena may collect and receive information and data (“Information”) in a variety of ways:

• General Information. iPlena collects, generates and/or receives information:

a) Account Information. To create or update an account in our App, you supply iPlena with phone number, nickname, password and/or similar account details (e.g. sex and year of birth), as well as with billing details such as credit card information, banking information and/or a billing address.

b) Usage Information.

- Log data. As with most websites and technology services delivered over the Internet, our App collect Information when you access or use our App and record it in log files. This log data may include the Internet Protocol (IP) address, browser type and settings, the date and time the App were used, information about browser configuration and plugins, language preferences and cookie data.

- Device information. iPlena collects information about devices accessing the App, including type of device, what operating system is used, device settings, application IDs, unique device identifiers and crash data. Whether we collect some or all of this General Information often depends on the type of device used and its settings.

- Location information. We may receive information from you and other third-parties that could help us approximate your location. We may, for example, collect an address submitted by you, or an IP address received from your browser or device leading to determination of approximate location.

• User Data. Users submit messages, photo, files or other content when using App.

• Cookie Information. iPlena uses cookies and similar technologies in our App that help us collect Information. You can change the settings to block cookies or to alert you when cookies are being sent to your device. Please note that disabling cookies may prevent you from using certain parts of the App. The cookies used on our App are essential to enable you to browse around our App and use its features. They enhance the App performance and allow our remembering the choices you make when browsing. The information these cookies collect will not personally identify you, and they cannot track your browsing activity on non-IPlena Apps or websites.

• Third Party Services. User can choose to permit or restrict Third Party Services. Typically, Third Party Services are software that integrate with our App. Once enabled, the provider of a Third Party Service may share certain information with iPlena. When a Third Party Service is enabled, iPlena is authorized to connect and access Information made available to iPlena in accordance with our agreement with the Third Party Provider. We do not, however, receive or store passwords for any of these Third Party Services when connecting them to the App.

No one is under a statutory or contractual obligation to provide any Information. However, some parts of Information are collected automatically and, if some Information, such as buyer’s account setup details, is not provided, we may be unable to provide access and services to the App.

iPlena uses Information in furtherance of our legitimate interests in operating our App or other business. We uses Information:

• To communicate with you by responding to your requests, comments and questions. If you contact us, we may use your Information to respond.

• To provide, update, improve, maintain and protect our App and other our services.

• As required by applicable law, legal process or regulation.

• To send emails and other communications. We may send you service, technical and other administrative emails, messages and other types of communications. We may also contact you to inform you about changes in our App or other services, and important service-related notices, such as security and fraud notices. These communications are considered part of the essential function of our business and you may not opt out of them if you continue using our App. In addition, we may send emails about new product features, promotional communications or other news about iPlena. These are marketing messages so you can control whether you receive them.

• To investigate and help prevent security issues and abuse.

• For billing, account management and other administrative matters. iPlena may need to contact you for invoicing, account management and similar reasons and we use account data to administer accounts and keep track of billing and payments.

If Information is aggregated or de-identified so it is no longer reasonably associated with an identified or identifiable natural person, iPlena may use it for any business purpose. To the extent Information is associated with an identified or identifiable natural person and is protected as personal data under applicable data protection law, it is referred to in this Privacy Policy as “Personal Data.”

iPlena respects your privacy and is committed to protecting it as set forth in this Privacy Policy. Except as otherwise provided in this Privacy Policy or any Terms of use, iPlena will keep your Personal Information private and will not disclose it to third parties without your prior consent, unless we believe in good faith that such disclosure is reasonably necessary or appropriate:

(a) to comply with a court order or other legal process;

(b) in order to establish, exercise, protect, or enforce the rights of iPlena or others (including, without limitation, for purposes of fraud prevention);

(c) to enforce iPlena’s Terms of Use;

or (d) to protect against imminent harm to the property or safety of iPlena, our customers, or the public.

Notwithstanding anything in this Privacy Policy to the contrary, we may share Traffic Data and Demographic Data with advertisers and other third parties and may share your Contact Data and Financial Data with third parties for the purpose of executing financial transactions between you and iPlena that have been authorized by you. Any Traffic Data and Demographic Data we share with advertisers and other third parties is not linked to any Personal Information and cannot identify any individual person.

Furthermore, notwithstanding anything in this Privacy Policy to the contrary:
(a) we may share your Personal Information (including, without limitation, your Phone number and Financial Data) with our employees or third parties who have a need to know your Personal Information (including, without limitation, your Phone number and Financial Data) in connection with providing you with the products and services purchased, licensed, or used by you from us, provided that such employees or third parties have agreed to comply with the restrictions on use and disclosure contained in this Privacy Policy with respect to such Personal Information; and

(b) in the event that iPlena sells or is contemplating selling all or a portion of its business or assets in any manner whatsoever, iPlena reserves the right to disclose and/or transfer your Personal Information (including, without limitation, your Contact Data and Financial Data) to the purchaser or prospective purchaser in connection with such acquisition, provided that such purchaser or prospective purchaser has agreed to comply with the restrictions on use and disclosure contained in this Privacy Policy with respect to such Personal Information.

We generally retain your personal data as long as you keep your account open or as needed to provide you services. This includes data you or others provided to us and data generated or inferred from your use of our App.

In some cases, we choose to retain certain information (e.g., insights about services use) in a depersonalized or aggregated form.

You can make a specific request and be assured that personal data is not being misused for anything other than the legitimate purpose for which it was originally provided. We assure that all our users have the following rights:

Right to information and access. You can ask us for information about what personal data is being processed and the rationale for such processing. We ensure your right to get access to your personal data that is being processed.

Right to rectification. You can ask us for modifications to your personal data in case you believe that your personal data is not up to date or accurate.

Right to withdraw consent. You can withdraw a previously given consent for the processing of your personal data for a purpose.

Right to be forgotten. You can ask for the deletion of their data. This applies to situations where you would like to stop using our App.

Right for data portability. You can ask to transfer of your personal data. The personal data will be provided or transferred in a machine-readable electronic format.

Right in relation to automated decision making and profiling. You have the right to not be subject to entirely automatic profiling algorithms. If any such algorithms are used, you have the right to know details of their operation.

All the requests regarding the data subject rights should be sent in a written form by the user or his/her legal representative by email to health@iplena.ai.

We take all necessary measures to protect your information from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, as well as from other illegal actions of third parties. We secure your Information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. All Information is protected using appropriate physical, technical and organizational measures.

We applied the security measures recommended by GDPR.

However, given the nature of communications and information processing technology, iPlena cannot guarantee that Information, during transmission through the Internet or while stored on our systems or otherwise in our care, will be absolutely safe from intrusion by others. Transmission of personal information to and from our App is at your own risk. You should only access the App within a secure environment.

iPlena does not knowingly collect any information from persons who aren’t of the legal age of majority in their country, state, province jurisdiction of residence. If a parent or guardian becomes aware that his or her child has provided us with Personal Information, he or she should contact us electronically using the contact us by email to health@iplena.ai. If we become aware that a child has provided us with Personal Information, we will delete or dispose of such Personal Information in a manner that employs reasonable and current technical and organizational security methods to prevent any unauthorized access to such Personal Information.

iPlena reserves the right, at any time and without notice, to change, modify, add to, or delete portions of this Privacy Policy, simply by posting such change to this Privacy Policy on the App. Any such change will be effective immediately upon posting on the App. It is your responsibility to regularly check the App to determine if there have been changes to this Privacy Policy and to review such changes. If we make any changes to this Privacy Policy, we will indicate at the top of this Privacy Policy the date this Privacy Policy was last revised. Your continued use of the App or your purchase, license, or continued use of any products or services offered by iPlena after any such changes constitutes your acceptance of the new Privacy Policy. If you do not agree to and accept, without limitation or qualification, all of the terms and conditions of this Privacy Policy or any future Privacy Policy without modification, do not use or access (or continue to use or access) the App or purchase, license, or use (or continue to purchase, license, or use) any products or services offered by iPlena.

In order to resolve a complaint regarding the App or to receive further information regarding use / collection of your personal data, please contact us at: health@iplena.ai.