Syai provides you with the Syai family of products, include mobile applications which include the “Syai Tag” App and the “Syai Lnk” App. For more information see +About Us and +EU Representatives below.
We are committed to protecting your personal information. This Privacy Notice explains how we handle and what we do to keep your personal information secure when using the Syai family of products. We understand that there is a lot of information included in this Privacy Notice. We want to provide you with a short and easily accessible summary of how we collect, protect, retain, store and disclose your personal information. For more information, see +Background on the Syai Data Management System and +Security of Personal Information below.
THIS SUMMARY IS NOT COMPREHENSIVE. YOU WILL NEED TO READ THE RELEVANT SECTIONS OF THE PRIVACY NOTICE BELOW TO FULLY UNDERSTAND HOW WE PROCESS YOUR PERSONAL INFORMATION.
We use personal information when you create your own Syai Tag account. We process data from sensors and/or readers, such as how often you scan or use your sensor, reader, glucose values, insulin and targets as well as data from connected third party devices. we will collect personal information if you request customer support and share system troubleshooting/diagnostics data. We also use cookies on our websites. For more information, see +Personal Information Collection via the Syai Data Management System and +Country Specific Provisions below. The +Country Specific Provisions supplement and/or amend specific provisions, where required by law, that appear to conflict with the overall contents of this Privacy Notice.
We use personal information to: (1) provide you with the Syai family of products and services; (2) comply with legal obligations, including those related to medical device safety, quality and improvement, complaints and adverse incident reports; (3) send you marketing communications where you have opted in or there is a legitimate basis to send communications; and (4) conduct research once the personal information has been de-identified, pseudonymized, aggregated and/or anonymized, so that it does not identify you by name. We conduct research to understand how our products and services are used, their effectiveness and for real-world evidence studies. For more information, see +Use of Personal Information, +Medical Devices and other Legal Requirements, +Research, +Use of Cookies and Similar Technologies on Syai Tag, +Retention of Personal Information and +How Syai Sends Marketing and Other Material below.
We strictly limit access to your personal information to duly authorized personnel and strictly limit who we share your personal information with. We will never sell the information to third parties for our commercial benefit. We do share personal information with third party suppliers to provide you with the Syai family of products, such as our third-party cloud service providers who are required to keep your personal information confidential and secure. Wherever we provide your personal information to third-party suppliers, they are required to comply with the conditions set forth in this document and keep your personal information confidential and secure and to use your personal information to the minimum extent necessary. We also share personal information with some of our affiliates in the Syai, in particular to de-identify, pseudonymize, aggregate and/or anonymize personal information for research, or to perform troubleshooting/ diagnostics and broader analysis to detect systemic issues. For more information, see +Security of Personal Information, +Disclosure of Personal Information and +How You May Share Information with your Health Care Provider or Others below.
Where your location grants you certain rights in relation to your personal information, we will respond to your requests to exercise those rights. For more information, see +How Individual Users Can Access and Correct Personal Information and Your Rights below.
We store personal information on servers located in the country closest to your country of residence. For more information, see +Data Storage and +Cross-Border Transfers of Personal Information below.
Please contact us in the first instance if you have any questions, comments or complaints. You can do this by emailing us at info@syai.com. For more information, see +Contact Us below.
When we update this Privacy Notice with material changes, we may alert you through email or by another means. For more information, see +Changes to this Privacy Notice below.
- SYAI PRIVACY NOTICE FOR USE OF SYAI DATA MANAGEMENT SYSTEM
Effective Date: January 2024
Syai ("Syai" or "us", "our", "we") recognizes the importance of data protection and privacy and is committed to protecting personal information, including health-related information. This Privacy Notice describes how your personal information, including health-related information, is collected and used by Syai and how it is uploaded, transmitted and stored by you in the Syai Tag App. References in this Privacy Notice to "affiliate companies" or "third parties" are those of Syai’s affiliate companies and third parties listed in the section titled +Disclosure of Personal Information .
Please read this Privacy Notice carefully before creating a Syai Tag account as it applies to your use of the Syai Tag App and to the processing, transfer and storage of your personal information, including health-related information in the cloud by Syai and certain affiliated companies as described below. More specifically, this Privacy Notice describes the privacy and data protection practices of Syai and applies only to the personal information processed by us in the Syai Tag App through:
- the Syai Tag App;
- the Syai Lnk App, which may be used by invitation only; and
- use of the Syai customer care line.
It also applies to the processing of your personal information by our affiliated companies and by our processors if required to resolve a customer service issue related to the Syai Tag App. You can find more information about how we process your personal information for customer support purposes in the privacy policies relevant to your country of residence which can be accessed at https://www.syai.com
This Privacy Notice does not apply to personal information processed or collected by other Syai affiliates or subsidiaries or via other methods, such as other Syai websites, other Syai customer call centers. Other privacy policies may apply to the personal information processed or collected through these methods.
By creating a Syai Tag account and using Syai Tag App or Syai Lnk App, you:
affirm that you are of legal age to acknowledge this Privacy Notice;
that you are agreeing either on your own behalf or on behalf of another individual for whom you have actual authority to legally acknowledge this Privacy Notice; and
accept this Privacy Notice.
YOU ARE PROVIDING EXPLICIT CONSENT TO THE PROCESSING OF YOUR PERSONAL INFORMATION, INCLUDING HEALTH-RELATED INFORMATION BY CLICKING "ACCEPT".
YOU MAY ALSO BE PRESENTED WITH AN OPTION TO PROVIDE EXPLICIT CONSENT TO ALLOW YOUR PERSONAL INFORMATION TO BE USED FOR RESEARCH, AS SET OUT IN THE SECTION TITLED +RESEARCH. BY CLICKING TO AGREE OR OPT IN TO RESEARCH, YOU ARE PROVIDING YOUR EXPLICIT CONSENT.
YOUR CONSENT IS GRANTED AT YOUR FREE WILL AND YOU ACKNOWLEDGE THAT YOU ARE NOT UNDER ANY LEGAL OBLIGATION TO PROVIDE PERSONAL INFORMATION TO SYAI.
+About Us
Syai Health Pte. Ltd. of 112 Robinson Singapore, 068902 is the developer of the Syai family of products that include the Syai Health website (“Syai Health”), mobile applications which include the “Syai Tag App” and the Syai Lnk app (“Syai Lnk”) as well asSyai branded sensors and readers. When the Syai family of products are used together, they may be referred to as the“Syai Data Management System”.
We have appointed representatives in the EU. References in this Privacy Notice to "affiliate companies" or "third parties" are those of Syai’s affiliate companies and third parties listed in the section titled +Disclosure of Personal Information.
Syai is a controller of personal information, including health-related information, uploaded, transmitted to or stored by you in the Syai Data Management System. Professional users are also a controller of your personal information for the purpose of providing you with medical care. The word ‘controller’ is used here based on its definition in the data protection laws of the EEA and, where applicable, has the equivalent meaning of similar terms in other countries’ data protection and privacy laws in which you reside.
+Personal Information Collection
This Privacy Notice applies only to the personal information, including health-related information, processed by us in the Syai Tag App when:
you submit information when creating an account in the Syai Tag App or Syai Lnk App;
you upload and store information in your Syai Tag account from your sensor, reader or mobile device;
we receive such information from is stored within a Syai Tag account;
you contact the Syai customer care line seeking support in respect of the Syai Tag App or Syai Lnk (more information about how we process personal information for customer support purposes can be found in the privacy policies relevant to your country of residence, which can be accessed at https://www.syai.com); and
you share diagnostic information, including health-related information, with us for the purposes of troubleshooting/diagnostics and to perform broader analysis to detect systemic issues.
When you sign up for a Syai Tag account, your account profile information is kept in a separate database that does not include your health-related information, and Syai uses technical and administrative measures to ensure data separation. Please note that your name and glucose data will be combined when you use the share functionality to share a report of your glucose data with your health care provider or any other third party, or where you are in a country that requires opt-in or consent for you to share your Syai Tag App, and you elect to connect your account to your health care provider’s electronic medical records system, as set out in the section titled +Background on the Syai Data Management System and +Disclosure of Personal Information.
Where you opt in to receiving marketing communications from us, we will combine your Syai Tag account profile (name, age range, mobile, email address, language and country) with other information you may have provided to us for marketing purposes, such as your address, and if you are a Syai Tag App User the time of your first sensor scan and frequency of sensor use, as set out in the sections titled +Use of Personal Information and +How Syai Sends Marketing and Other Material.
This Privacy Notice covers the collection of the following information:
For users of the Syai Tag App:
Your account profile that you complete when you sign up to or create a new account, which may include the name, mobile phone number (where it is applicable), date of birth, country, and email address for adult users for their own use or for use by another adult (where you have authority to do so). In addition to the categories of information listed here, other categories of personal information may be collected from you in relation to certain programs. If and when that collection of information is necessary, we will explain how that information is collected, used, and shared.
Health-related information from your sensor, reader or connected device such as how often you scan or use your sensor, your use of readers, glucose targets, glucose values, insulin, logged food, and other logged notes, sensor generation, and sensor started and ended information (where it is applicable);
Diagnostic data, when you contact us and share your troubleshooting/diagnostics data (see +Diagnostics Data Use for more information);
Bluetooth connection and disconnection data (where it is applicable); and
Information about whether glucose information has been viewed by a user (where it is applicable).
Information about your mobile device, including information about your operating system and other troubleshooting and analytical data that might include sensor serial numbers and free text notes.
For Android users only: information in order to facilitate the initial connection between the Syai Tag App and your sensor via Bluetooth (where Bluetooth is applicable) (see +Disclosure of Personal Information by Us for more information).
+Use of Personal Information
When you sign up for a Syai Tag account, account profile data (including name, mobile phone number (where it is applicable), country, date of birth, email address) are kept separate from the information you upload from your sensor or reader. Syai uses technical and administrative measures to ensure data separation and will never combine these data, unless otherwise stated below.
Syai uses your personal information, including health-related information, data derived from your sensor or reader, and technical information about your mobile device if you use the Syai Tag App or Syai Lnk App in the following ways:
For users of the Syai Tag App and Syai Lnk App:
to provide you with a Syai Tag account to give you access to and present your information, including health-related information, in an easy to use and effective manner, to allow you to store, back-up and retrieve your historic glucose values and to ensure continuous access to information about how you manage your diabetes;
to secure your account access when we use two-factor authentication during your Syai Tag account registration process or when you log into your account;
if you are a parent or guardian, to enable you to create a Syai Tag account for use by your child, and to allow you to manage their use of the Syai Tag account;
where you have opted in, we will prepare and send you marketing information, which may be tailored based on the data uploaded (including whether you have Type I or Type II diabetes) or connected to your Syai Tag account (including scans, alarms, login and events), including from your local Syai company. We do this so that you receive information that is relevant to you. You will be provided with an opportunity to opt-in to these communications when you first provide us with your personal information and when you log into your account. After you initially opt-in, you will also be provided an opportunity to opt-out through each marketing communication you receive from us;
to contact you in order to learn more about your use of Syai Tag App and to offer education and assistance with using our products;
to help us fix any technical issues, when you contact us and share your troubleshooting/diagnostics data, including health-related information (please also see +Diagnostics Data Use for more information) and to perform broader analysis to detect systemic issues;
to help us analyze the performance of the Syai Tag App (regardless of whether or not you are signed into your Syai Tag account on the Syai Tag App). Syai uses Google’s Firebase Analytics to collect performance monitoring data for the Syai Tag App in an aggregated and de-identified format. The performance monitoring data may include app version, country, OS level, device, radio and carrier information. It will not include your sensor serial number nor any other personal information including health-related information; and
where you have opted in, we will combine Syai Tag App usage data with data including scans, alarms, log-in and event data, purchase information from our Syai Tag webshops, statistical information about the number of calls you make to our customer services and statistical information about educational and marketing-related communications that we send you, and use this combined information to:
give you personalized services by providing you with information that is relevant to you. For example, if you are using a reader, we may send you information that is relevant to the use of a reader or to send you timely messages to enable you to use the Syai Tag App effectively;
better understand you and improve our interactions with you. For example, we may connect your call or text for support to your recent purchase on our webshop, which would enable us to help you during your call;
understand your preferences, to improve our interactions with you and to provide you with relevant content, products and promotions that are of interest to you. For example, if you are a new user of our products or have downloaded a new version of the Syai Tag App, we can send you educational materials that are relevant to you as a new user; and
to gain insights into and learn about the preferences and behaviors of our customers, after aggregating, anonymizing or de-identifying your personal information.
For users of the Syai Lnk App: to provide you with a Syai Tag account to be able to view glucose readings of your family member or friend.
For Android users only: to facilitate the initial connection between the Syai Tag App and your sensor via Bluetooth (see +Disclosure of Personal Information for more information).
+Medical Devices and other Legal Requirements
Syai may use personal information, including health-related information, where legally required and, where possible, we will de-identify, pseudonymize, aggregate and/or anonymize information to comply with various legal requirements. For example, as a medical device manufacturer, Syai has certain legal obligations to help ensure the ongoing safety of our medical devices. This may require Syai to share personal information with regulatory authorities responsible for the quality and safety of medical devices (e.g. where your health care provider reports an adverse incident to us relating to an Syai device). The information Syai may be required to share is not used to identify you individually by your name or email address, except where there is a legal obligation to include this information, such as when a health care provider makes a complaint or reports an adverse incident. Our parent company, Syai Laboratories, assists us as a processor to ensure such information does not identify a patient by de-identifying, pseudonymizing, aggregating and/or anonymizing personal information.
The legal requirements for which Syai may use this information include:
ensuring the ongoing safety of a device and any future development;
monitoring and improving the quality, security and effectiveness of medical devices and systems;
validating upgrades, and keeping the Syai Data Management System safe and secure;
performing broader analysis to detect systemic issues for public interest in the area of public health;
identifying options to improve the usability, performance and safety of the Syai Data Management System;
testing and evaluating the Syai Data Management System to improve product features and functionality; and
where required by law, responding to requests from any competent law enforcement body, regulatory or government agency, court or other third party where we believe the disclosure is necessary or appropriate to comply with a regulatory requirement, judicial proceeding, court order, government request or legal process served on us, or to protect the safety, rights, or property of our customers, the public, Syai or others, and to exercise, establish or defend Syai’s legal rights or where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of this Privacy Notice, or as evidence in litigation in which we are involved.
We use the terms ‘de-identify’ and ‘pseudonymize’ interchangeably. The US Health Insurance Portability and Accountability Act and its implementing regulations (HIPAA) describe de-identified information as information where ‘there is no reasonable basis to believe that the information can be used to identify an individual’. The EU General Data Protection Regulation (2016/679) (GDPR) defines ‘pseudonymization’ as ‘the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information’. Anonymized data is information that does not relate to a person and from which a person cannot be identified, and this kind of data is not subject to data protection and privacy laws.
For more information about GDPR, please see the +European Economic Area and UK section below.
+Research
Syai conducts research for limited purposes using your personal information after it has been de-identified, pseudonymized, aggregated and/or anonymized. Such data includes limited demographic data, namely, year of birth and country of residence, and device related data (such as the frequency and days of sensor scans or usage, frequency of use of readers, glucose target ranges, average glucose values, insulin, mealtime patterns, logged exercise and other logged notes, and information generated by a sensor, namely, sensor started and ended information, Bluetooth connection and disconnection (where it is applicable), information about whether glucose information has been viewed by you). This information may also include data received from your third party connected devices or apps as well as your responses to research surveys. Our parent company SyaiLaboratories assists us, as a processor, to de-identify, pseudonymize, aggregate and/or anonymize your personal information. Where data has been anonymized, it is no longer subject to privacy and data protection laws.
A data set processed for research purposes will not include your name, address, phone number or email address. This de-identified, pseudonymized, anonymized or aggregated data set is securely held by Syai and will not be used to identify you individually by your name or email address. If you delete your account , the data that has already been or is in the process of being anonymized, de-identified, pseudonymized and/or aggregated for research purposes as described in this section will not be deleted. The research purposes for which Syai may use this data set include:
to create, access, retain, use and share information with affiliated companies and third-party researchers, health care entities or professionals or public health authorities for the purposes of advancing scientific research through statistical and other analysis;
to evaluate how the Syai Tag App is provided and used and its effectiveness, including its performance or impact on users (including base user demographics, such as geography) based on real-world evidence and observational studies;
to research, develop and test health care systems and management; and
to research, develop and test medical devices, including new and existing features and functionality for product development, and advancing scientific research through statistical and other analysis and surveys.
Syai conducts product usage research based on de-identified, pseudonymized, aggregated and/or anonymized data for limited purposes, in particular to help us understand the performance of the Syai Tag App and Syai Lnk App, to help us understand issues which may need fixing with the apps and to help us understand how many times the apps have been downloaded from App Stores.
We use the terms ‘de-identified’ and ‘pseudonymized’ interchangeably. The EU General Data Protection Regulation (2016/679) (GDPR) defines ‘pseudonymization’ as ‘the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information’.
For more information about GDPR, please see the +European Economic Area, UK and Switzerland section below. Where you live in a country that requires Syai to obtain consent before we are able to use a de-identified, pseudonymized, or aggregated data set, you will be asked to provide consent by clicking the opt-in button.
+Diagnostics Data Use
When you share your troubleshooting/diagnostic data, the following information will be transmitted to us and collected by us (whether or not you are signed into Syai Tag account on the Syai Tag App):
information about your device, reader and/or sensor (serial and/or model number of your device, reader or sensor) when you report a fault; data about configuration information, error codes, battery related information, software and hardware versions, phone model, operating system and other technical diagnostic information;
health-related information including glucose values as this information may be required to diagnose the fault;
information you may have entered into your reader or device including insulin, food, medication, reminders and free text information, as these may be required to diagnose the fault.
When you contact us to report a fault, we collect your name, address, phone number, country and email address. Your use of customer support is governed by the privacy policies relevant to your country of residence which can be accessed at https://www.syai.com. If you live outside of the United States of America, we do not combine your contact information with the product diagnostic/troubleshooting information you provide. We will keep these categories of data separately.
+Data Storage
+Retention of Personal Information
Syai will retain personal information associated with your Syai Tag account for the following periods:
Creation/use of a Syai Tag account: for a period of 6 months following your last use of your account, and, where you contact us for customer support, for a period of at least 2 years but no longer than 10 years from the last date the device was made available for sale to the public by Syai, or longer if required by law;
Once we have resolved or closed your customer support ticket, we retain your contact information and details of the fault for the longer of 2 years after you reported the fault or 10 years after the product is no longer manufactured.
Marketing: once you opt-in, we will provide you with marketing-related information unless and until you opt-out or for a period that complies with legal requirements;
Medical Devices and Other Legal Requirements: as legally required for a maximum period of ten (10) years from the last date the device was made available for sale to the public by Syai or other legally required retention period; and
Research: for a maximum period of then (10) years from the date the last device was made available for sale by Syai in your country or territory once the information has been de-identified, pseudonymized, aggregated or anonymized.
Unless otherwise stated above, Syai will continue to store your personal information while you have an active Syai Tag account. Your Syai Tag account will be considered to be inactive once there has been no activity on it for six (6) months. Once your Syai Tag account is considered inactive or where you delete your account, all personal information will be permanently and irrevocably deleted unless (1) Syai is required or permitted to retain the personal information or (2) with respect to such information that has already been or is in the process of being anonymized, de-identified, pseudonymized and/or aggregated for the purposes set out in the section titled +Research. We will notify you in advance by sending an email to the email address associated with your Syai Tag account so that you have an opportunity to ensure your account stays current and available for your use. The section titled +Deleting your Syai Tag Account explains how you can delete your account and what happens to your personal information once your account has been deleted.
+Disclosure of Personal Information
We share personal information including health-related information with the following, and in each case only the minimum amount of personal information is shared for the purposes for which the third party is engaged:
Health care providers: If your health care provider has created a Syai Tag account, your health care provider has the ability to use the Syai Tag App to create patient profiles and to connect your reader to their Syai Tag account to view and print out a patient report and to remotely view patient reports and share those reports with other professionals in their practice. Syai discloses such information pursuant to its contract with your health care provider and processes such data as a ‘processor’.
Where requested by your health care provider, Syai may also share your personal information with your health care provider’s electronic medical records system (but only in countries where this is permitted or where you have opted-in or otherwise consented to such sharing). Where Syai shares your personal information and health-related information, it does so under a data sharing agreement with your health care provider.
Syai Laboratories: We share your personal information with our parent company to assist us as a processor with the de-identification, pseudonymization, aggregation and/or anonymization process and assist us with IT operations to support the diagnostic data platform.
Third-party suppliers: We share personal information with third-party suppliers solely to provide, maintain, host, and support the Syai Data Management System. Syai uses Amazon Web Services (AWS), Microsoft Azure and other cloud providers (see below) to host Syai Data Management System accounts in the cloud. (Please see the section titled +Data Storage for further information) Where we provide your personal information to third-party suppliers to assist us with the provision of your Syai Data Management System account, they are required to keep your personal information confidential and secure and to use your personal information to the minimum extent necessary. Where possible, Syai uses third party service providers to report system errors so that we can support and improve the Syai Data Management System and in such instances, the information sent to such third parties will not involve the use of your personal information.
Syai uses third-party service providers to provide you with the Syai Data Management System. For example, we use third-party service providers to report when either the Syai Tag App or Syai Lnk App crashes or experiences certain scanning errors so that we can support and improve the apps, and when these crashes or scanning errors occur, the app will send certain information about the incident to such third parties. The information sent to such third parties will not involve the use of your personal information. Syai uses Lomaco et AGPS to ensure invoicing of telemedicine acts in France to the social security system. Some versions of the Syai family of products may be accessed via mobile devices that may contain pre-loaded third-party operating and device management software. More information about the device manufacturers’ privacy practices may be found in the device manufacturers’ privacy policy or website(s).
For some Syai Tag Apps, Android devices require location services permissions to be granted in order to discover and connect to the Syai Tag sensor using Bluetooth technologies. The data from such location services is not collected by the Syai Tag App or transferred from the device; as such, it cannot be used by Syai. Once the sensor is connected, location services permissions can be turned off with no impact on the Syai Tag App; however, they must be turned on again to connect to a new sensor. For more information on Google’s privacy practices, please see Android’s support website.
Syai also uses third party suppliers to send surveys and collect your responses for research purposes and will, if required by law, obtain your consent to do so.
Local affiliated Syai companies: We may share your personal information with local affiliated Syai companies with whom we are jointly marketing a product or service or jointly conducting a program or activity. This will only occur where you consent to sharing, for example, where you opt-in to receive marketing communications from Syai (or its affiliates) or where we have a legitimate basis for sharing personal information as described in this Privacy Notice. Where we require assistance from Syai companies in your country to address diagnostics/troubleshooting and the fault you have reported, we will share the minimum of your personal information necessary to them.
Third Party Partners of Syai: We also may share your personal information with third parties where you have expressly asked us to do so and/or consented to share your personal information, including where you use the share functionality in the Syai Tag App. When you use that share functionality your personal information, including health-related information from your third party connected device, sensor or reader, such as your glucose targets, glucose values, insulin, logged food and other logged notes may be shared. Where you decide to share your personal information, including health-related information, the use of your personal information, including health-related information by the third party partner of Syai is not governed by this Privacy Notice, and will be governed by the third party partner’s privacy policy.
Your third party connected device, where applicable, may share data with the Syai Tag App. When you connect the device of an Syai third party partner to the Syai Tag App, and your third party connected device shares data with the Syai Tag App, the consent choices that you have made for the Syai Tag App will apply to the data you share from the connected device to Syai. The sharing and use of your data by the third party partner will be governed by the third party partner’s privacy policy.
You can elect to stop sharing data to/from your Syai Tag account at any time by turning off the sharing function.
Other third parties: We may share de-identified, pseudonymized, aggregated, and/or anonymized information with affiliated Syai companies and with other third parties for the purposes relating to +Research as set out above. This is information which Syai securely holds and will not be used to identify you individually by your name or email address.
We will not sell or license your personal information to third parties except in connection with the sale, merger, or transfer of a product line or division, so that the buyer can continue to provide you with information and services. We will not sell your personal information for commercial purposes to third parties and we may only share your personal information with third parties where you have provided consent or where permitted by applicable law.
We reserve the right to disclose your personal information to respond to requests from any competent law enforcement body, regulatory or government agency, court or other third party where we believe the disclosure is necessary or appropriate to comply with a regulatory requirement, judicial proceeding, court order, government request or legal process served on us, or to protect the safety, rights, or property of our customers, the public, Syai or others, and to exercise, establish or defend Syai’s legal rights or where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of this Privacy Notice, or as evidence in litigation in which we are involved. Your personal information may be subject to foreign laws and may be accessible by foreign governments, courts, law enforcement, and regulatory agencies.
+How You May Share Information with your Health Care Provider or Others
The Syai Tag App allows users to share information with health care providers and professional users of Syai Tag. You may also share your personal and health-related information with a person you invite to use the Syai Lnk app. Depending on your selection of country, you may have limited ability to connect to other users of the Syai Tag App who choose a different country of residence. Where you use the share functionality in the Syai Tag App, we may share your personal information with your health care provider or with other third parties. We may also share your personal information with third parties where you have expressly asked us to do so and/or provided consent to share your data with our partners and third parties.
You may elect to share information with health care providers by using the share functionality in the Syai Tag App.
Where you use the share functionality in the Syai Tag App, you can send reports with your personal information and glucose data to your health care provider.
Syai may also share your personal information with your health care provider where you have consented to or opted into connecting your Syai Tag account to your health care provider’s electronic medical records system if you are located in a country that requires such consent or opt-in.
+Security of Personal Information
We have implemented administrative, technical and physical safeguards to protect your personal information, including health-related information, from unauthorized or unlawful access, accidental loss, destruction, damage, misuse, disclosure and alteration, including the use of cryptographic technologies. Syai restricts access to personal information by its employees on a need to know basis. Personal information including health-related information may only be accessed by duly authorized personnel, respecting the principles of proportionality and necessity, and all personal information is treated with confidentiality. Please keep in mind that no internet or Wi-Fi transmission is 100% secure, so please exercise caution when uploading personal information, especially health-related information, to your Syai Tag account. Despite the above agreement, we will not bear the corresponding legal responsibility for the leakage, public disclosure, loss or theft of personal information caused by computer/mobile phone terminal problems, hacker attacks, computer/mobile phone terminal virus intrusion, resulting in damage to your legitimate rights and interests.
Syai Tag sensors transmit personal glucose information to Syai Tag apps and devices using NFC (Near Field Communication) and Bluetooth technologies. NFC and Bluetooth are both secure means of transferring information between devices. NFC has the added level of protection by requiring very close physical proximity. Encrypted Bluetooth connections for Syai Tag sensors are established during an NFC communication between a Syai Tag sensor and a Syai Tag App or reader.
Please be aware that the Syai Tag App may be unavailable during periods of routine maintenance.
You are responsible for protecting against unauthorized access to your Syai Tag account and devices. We recommend securing access to Syai Tag App by logging-out, choosing a robust password for your Syai Tag account that nobody else knows or can easily guess, implementing security settings on your mobile device or computer such as a password to access it, keeping your device locked when not in use and keeping your account information and password private. Syai is not responsible for any lost, stolen or compromised passwords or for any activity on your Syai Tag account from unauthorized users where caused by you. If you think your account has been compromised, please contact us as soon as.
+Cross-Border Transfers of Personal Information
When you share your personal and health-related information with a person you invite to use the Syai Lnk app, we use Firebase Cloud Messaging to send notifications from your Syai Data Management System account to the individuals connected to you via Syai Lnk.More information about how we process personal information for customer support purposes is available in the privacy policies relevant to your country of residence which can be accessed at https://www.syai.com.
In addition, we also transfer de-identified, pseudonymized, aggregated and/or anonymized data to the United States, which does not identify you by name, for the purpose of conducting research as described in the section titled +Research above, and we transfer your personal information (in de-identified, pseudonymized, aggregated and/or anonymized form where possible), for the purpose of complying with our legal obligations as described in the section titled +Medical Devices and other Legal Requirements above. However, we put appropriate contractual, technical and organizational safeguards and supplemental measures in place to protect your personal information and we may implement additional safeguards to continue to protect your personal information as required.
+How Syai Sends Marketing and Other Material
Syai (or its affiliates) may send you advertising and marketing-related information or request that you participate in surveys about diabetes care or other products and services, provide you with news and newsletters, or notify you about special offers and promotions at any time if (where required by law) you opted-in to receive such communications or if we have a legitimate basis for sending you this material.
You may receive marketing information which is tailored to your specific needs based on the information uploaded or connected to your Syai Tag App, such as account profile (name, age range, email address and country) with other information you may have provided to us for marketing purposes, such as if you’re a Syai Tag App User the time of your first sensor scan and frequency of sensor use, so that we can send you information relevant to you.
You will be provided with an opportunity to opt-in to these communications (where required by law) when you first provide us with your personal information and when you log into your Syai Tag account. After you opt-in, you will also be provided an opportunity to opt-out through each marketing communication you receive from us. These materials may be sent by us or by an affiliate of Syai. You may opt out from receiving marketing-related communications by either clicking on the unsubscribe link in each marketing-related communication or by contacting us. We will process opt-out requests without undue delay.
Neither Syai nor its affiliates or licensors will knowingly send advertising or marketing-related information to children.
Syai will not sell your personal information to third parties for direct marketing purposes.
Where you opt out of receiving marketing-related information about diabetes care, we may send you non-marketing related information, where required by law, such as information related to necessary system and service updates or issues relating to user or product safety.
+How Individual Users can Access and Correct Personal Information and Your Rights
You may correct your profile information (your name, mobile phone number (where it is applicable), country, date of birth (except children), email address and password) through the Syai Tag account settings, or through the settings within your Syai Tag App or Syai Lnk App. We are not able to correct or amend any sensor readings that you have uploaded into your Syai Tag account or any data uploaded from a Syai Tag reader, but we will assist you with deleting your Syai Tag account and creating a new one so that you can reload the correct information.
Depending on your place of residence, you may have the right to: (a) access the personal information we hold about you; (b) request we correct any inaccurate personal information we hold about you; (c) delete any personal information we hold about you; (d) restrict or cease the processing of personal information we hold about you; (e) object to the processing of personal information we hold about you; and/or (f) receive any personal information you have provided to us on the basis of your consent in a structured and commonly used machine-readable format or have such personal information transmitted to another company by using the export function in your Syai Tag account, where accessible. Please note that Syai is not required by law to adopt or maintain systems that are technically compatible with other companies. It may not be possible for Syai to directly transmit your personal information to another company.
Children may also have the right to access the personal information held about them through the Syai Tag App. Where we receive a request for access for a child’s personal information from the child’s parent/guardian, we may respond directly to the child’s parent/guardian. We will always seek to verify the identity of person seeking access to a child’s information, whether it is from the child him/herself or from a parent or guardian.
To request the exercise of these rights, please contact us using any of the methods set out in the section titled+Contact Us.
Syai Health Technology Pte., Ltd.
Address: #03-01 112 Robinson SINGAPORE 068902
Email enquiries: info@syai.com
+Deleting your Syai Tag account
If you would like to delete your Syai Tag account, you may do so by logging into your Syai Tag account and using the delete account functionality. Please be aware that if you delete your account, all data in the Syai Tag account will be deleted but we will retain information that has already been or is in the process of being anonymized, aggregated, pseudonymized and/or de-identified for the purposes set out in the section titled +Research. We may also need to retain certain personal information when required by law. See +Retention of Personal Information for more information.
Once your Syai Tag System account has been deleted, you will no longer have access to the Syai Tag App and deletion of your account is irreversible. You are not therefore able to reactivate your Syai Tag account or retrieve any personal information, including health-related information, so you may want to download and save any required information before requesting that we delete your account from the Syai Tag App.
If you have chosen to share your Syai Tag account information with your health care provider or with other connections and you delete your account, those persons will no longer be able to view your glucose readings.
Please be aware that if your health care provider has set up their own account in the Syai Tag App and created a patient profile specific to you, your deletion of your Syai Tag account may have no effect on the account or patient profile created by your health care provider.
Syai reserves the right to delete inactive Syai Tag accounts after six (6) months. We will notify you in advance by sending an email to the email address associated with your Syai Tag account so that you have an opportunity to ensure your account stays current and available for your use.
In all communications to us, please include a detailed explanation of your request or query. We will do our best to respond to all reasonable requests in a timely manner. We reserve the right to charge a reasonable fee to process an access request, as permitted under the Personal Data Protection Act 2012.