Syai-Privacy Policy-20241005

TABLE OF CONTENTS

1. About Us

2. How We Collect Your Data

3. Our Use of Your Data

4. Adherence to Legal and Regulatory Standards

5. Data Retention Policy

6. Disclosure of Your Data

7. Data Security

8. Transfer of Your Information

9. Marketing and Advertising Practices

10. Your Rights and Choices

11. Account Deletion

12. Policy Updates

13. Contact Us

At Syai, we’re committed to protecting your personal data. Syai Health provides you with our collection of products and services, including applications such as the "Syai Tag" App, the "Syai Link" App, the "Syai Doctor" App, the "Syai Essential" App and the "Syai Partner" platforms with other mirroring versions and services where applicable following the business development and adjustments. The Privacy Policy outlines how we collect, use, and safeguard your personal information when you use our products and services. Please read carefully before use. If you have any questions or concerns that require our statements or clarifications, please see the details in the "Contact Us" section. By proceeding to use the above-mentioned applications, services and so forth, you agree to and consent to this Privacy Policy.

Effective Date: 05 Oct, 2024.

About Us

Syai Health ("Syai Health") Pte. Ltd. of 112 Robinson Rd, Singapore, 068902 is the developer of the Syai ("Syai Health") collection of products that include but not limited to the Syai official website, mobile applications which contain the "Syai Tag App", Syai Link App ("Syai Link"), Syai Doctor App ("Syai Doctor") as well as Syai Health branded Monitors. When the Syai Health collection of products is used in conjunction with specific usage scenarios, they may be referred to as the "Syai Health Ecosystem". For example, an HCP will utilize Syai Doctor Web or mobile application to set up connections with Syai Tag users and access their healthcare data upon permission.

How We Collect Your Data

Key Points to Remember:

• Your Information, Your Control: We believe you should have control over your personal information.

• Security First: We implement robust security measures to protect your data.

• Transparency: We’re open about our data practices.

The personal data includes but is not limited to your health-related data, processed by us for example usage scenarios as below:

1. Registration of the Syai account to access our applications and services in the collection (requires your personal details such as name, height, weight, year diagnosed for diabetes mellitus, gender and treatment options, etc.).

2. Data generated and stored under your Syai account from the usage of our products in the collection (your Monitor readings, application-generated analytics and standardized glucose reports).

3. Your Syai account information updates and data storage (Logs made with the Logbook feature, etc.).

4. Your customer service records with us, our distributors and other verified channels (Customer Service Feedback Form with your personal details, delivery address, relevant diagnostic data and Monitor details as SN numbers.).

5. Your participation in our marketing promos and other activities within our software systems and official website (Email subscriptions).

6. You consent to share usage information such as error codes for us to look into cases and provide further assistance with your Monitor, application, and so forth (feedback form with device details and your personal details).

7. When you contact us and share your troubleshooting/diagnostics data to fix technical issues with us.

For users of the Syai Health Ecosystem (devices, applications, and services all together):

1. To access the full features of specific applications & services, you may be prompted to provide or submit private information such as your personal details. The information may or may not be required for the service to operate but will aid in analytics for your glucose management routine in-app.

2. Device services will be utilized by the applications and services from us, such as Bluetooth, NFC, location services, notification, and storage permissions, they are mandatory for essential features.

Our Use of Your Data

Syai uses your personal information, including health-related information, data derived from your Monitor or other Syai devices, and technical information about your mobile device if you use the Syai Tag App, Syai Link App, or other component in the Syai Health Ecosystem, including but not limited to the following ways:

• To provide you with real-time monitoring data and analytics in-app and via other components in the Syai Health Ecosystem.

• To ensure secure access to your account registered and private information submitted, etc.

• To provide you with relevant information, such as customer services, product info and Monitor details, etc.

• To make sure the application functions as designated, such as location services required by the Syai Tag application to pair your Monitor during individual device applications.

• For users of the Syai Link App and Syai Doctor App: to provide you with a Syai account to be able to view the glucose readings of your family member or friend, or access a patient's report/other glucose data with a Syai Doctor account registered.

Adherence to Legal and Regulatory Standards

We may process your personal information, including health-related data, as required by law. To protect your privacy, we will take steps to de-identify, anonymize, or aggregate the data whenever possible following the EU General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR) regulations where applicable.

We will implement technical and administrative measures to ensure data separation and will never combine them unless for the identical scenarios as described below:

We may be required by law to disclose your personal information, including health-related information. In such cases, we'll take steps to minimize the amount of information shared and to de-identify or anonymize it whenever possible.

We may be required to disclose your personal information to comply with legal obligations, such as responding to lawful requests from law enforcement or regulatory authorities. We may also disclose information to protect the safety of our users or others, to investigate potential fraud or illegal activities, or to exercise our legal rights.

Syai Health will process your private information following the GDPR articles where applicable. The word 'pseudonymization' is defined in the EU General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR), effective May 25, 2018, 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.’ Anonymization mentioned in this document refers to information or data that cannot be used to identify any relevant person or individual and is not related to any data protection or privacy legal requirements or subject to changes following their updates.

Data Retention Policy

We may use personal information, including health-related information, if required by legal obligations. Where applicable, the relevant information will be de-identified, pseudonymized, aggregated, and/or anonymized to ensure legal compliance.

We will retain your personal information for the minimum period necessary to fulfil the purposes outlined in this policy, unless you request deletion or as required by law.

We determine the appropriate retention period based on factors such as the nature of private information, the purpose for which it was collected, and any legal obligations we may have.

Disclosure of Your Data

Depending on your selection of country, you may have limited ability to connect to other users of the Syai Health Ecosystem who choose a different country of residence. Where you use the share functionality in the Syai Health Ecosystem, we will seek your consent before sharing your personal information with your healthcare provider or with other third parties. It also applies to sharing of 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.

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:

Regarding the usage of the Syai Health Ecosystem, Android devices will require location service access to find the nearby Monitor. You may temporarily turn off the service once the Monitor is connected/activated in-app. Syai does not collect or sell any location data associated with this permission. By enabling location services, you're helping to ensure a seamless user experience with your Syai Health device; it's only used for monitoring data transfers with the app and device connection.

Local distributors or partners with Syai: We will seek your consent before sharing your personal information with local distributors regarding scenarios such as customer service. This will only occur where you consent to share. When we collaborate with local distributors/partners in your country/region to assist in problem-solving and addressing issues from your feedback, we will share the minimum amount of your personal information necessary with them.

Third-party usage of Syai Health Ecosystem: We may will seek your consent before sharing your personal information with third parties if you explicitly consent to it, such as when you use the sharing features within the Syai Health Ecosystem. For example, when you use the "Home/Doctor Care" feature in the Syai Tag App, your personal information, including health-related data such as your real-time glucose readings, trend graphs, generated glucose reports, and potential glucose alerts will be shared with third-party service providers such as certified HCPs. The sharing behaviours initiated by you to the third-party providers/software applications will not be governed by this Document, but follow the designated endpoint's privacy policy announcement when applicable.

Your third-party connected device, where applicable, may exchange data with the Syai Health Ecosystem (with your consent). When you connect a device of compatible third-party partners to the Syai Health Ecosystem (for example, if you shared your glucose data in the Syai Tag App with Apple Health), the device will also share related information to aid in services provided within the Syai Health Ecosystem. The consented choices that you have made for the Syai Health Ecosystem will be applied to the data sent to and received from the connected device. The sharing and use of your data by the third-party partner will be governed by the third-party partner's privacy policy when applicable.

We will not sell your personal information to third parties for commercial gain. We will seek your consent before sharing your information with trusted third-party service providers who assist us in delivering our products and services. We will only share your information with third parties with your explicit consent or as required by law.

In the event of a merger, acquisition, or sale of our business, we will notify you about transferring your personal information to the relevant party.

We may be required to disclose your personal information to comply with legal obligations, such as responding to lawful requests from law enforcement or regulatory authorities. We may also disclose information to protect the safety of our users or others, to investigate potential fraud or illegal activities, or to exercise our legal rights.

Please note that your personal information may be subject to foreign laws and accessible by foreign authorities.

Data Security

By using Syai products, you trust us with your personal information. We’re committed to honouring that trust.

1. We implemented robust security measures to protect your personal information stored, including:

Access Controls: Limiting access to authorized personnel on a need-to-know basis.

Encryption: Using encryption technologies to safeguard sensitive information.

Physical Security: Protecting our facilities and equipment.

Please be aware that no Internet transmission is entirely secure. We encourage you to exercise caution when transmitting sensitive information over Wi-Fi networks.

While we take significant steps to protect your information, we cannot guarantee absolute security. We are not liable for breaches caused by factors beyond our reasonable control, such as cyberattacks or unauthorized access.

2. When Syai Discontinues Services

If Syai discontinues its products or services, we will:

○ Cease Data Collection: Immediately stop collecting new personal information.

○ Notify You: Inform you about the service discontinuation.

○ Data Deletion or Anonymization: Delete or anonymize your personal information, subject to legal requirements.

3. Please be aware that the Syai Tag App may be unavailable during periods of routine maintenance.

4. You (the user) are responsible for safeguarding your Syai account and devices. To enhance security, we recommend:

Strong Passwords: Create a strong, unique password for your Syai account.

Device Security: Implement strong security measures on your devices, such as using passwords or biometric authentication.

Privacy: Keep your account information and password confidential.

If you suspect unauthorized access to your account, please contact us immediately.

Please note that Syai Health is not liable for any unauthorized activity resulting from your failure to protect your account information and devices.

Transfer of Your Information

We will not share your personal information with third parties, except in the following circumstances:

With Your Consent: We may share your information with other parties if you explicitly consent to it.

Business Transfers: In the event of a merger, acquisition, or bankruptcy, your information may be transferred to the acquiring company. We will require the acquiring company to adhere to the principles outlined in this Privacy Policy or obtain your consent.

Marketing and Advertising Practices

Cookies:

Regarding our official website and web portals, we use cookies and similar technologies to enhance your browsing experience. Cookies are small text files stored on your device to track your preferences and browsing behavior. You can manage cookie settings and preferences in the device or browser settings. Our cookies share data about your use of our website with analytics, social media platforms, and other advertising partners in strict accordance with our Privacy Policy and Terms of Use. By continuing to access our web pages and corresponding services, you consent to the sharing of your personal data.

Marketing activities:

We may send you marketing communications, such as newsletters, special offers, and survey invitations based on your subscription with us, if you've opted in to receive them or if we have a legal basis to do so. These communications may relate to diabetes care, the latest Syai products, or local services from our Syai partners.

We may use information from your Syai Tag App, such as your usage patterns and account details (name, email address, country, delivery address), to tailor our marketing communications to your interests. This helps us provide you with relevant information about diabetes care and other products or services.

You can unsubscribe from these communications at any time by clicking the "unsubscribe" link in the email or by contacting us directly.

Syai Health will not knowingly send marketing materials to minors or sell your personal information to third parties for their marketing purposes or relevant surveys.

Even if you unsubscribed from our marketing telecommunications, we may still send you important non-marketing information (where required by law), such as essential announcements regarding product updates.

Your Rights and Choices

You may update your profile information (such as your name, mobile phone number, gender, weight, height, and other profile details where applicable, country, date of birth (except children), email address and password) through the Syai account settings, or the settings within your Syai Tag App, Syai Link App or Syai Doctor App. We are not able to correct or amend any Monitor readings that are stored under your Syai account.

Your Rights

Depending on applicable laws from the EU General Data Protection Regulation or other regional legal basis, you may have the following rights regarding your personal details:

Access: The right to access and view your personal details.

Correction: The right to request correction of inaccurate or incomplete information.

Erasure: The right to request deletion of your personal details.

Restriction: The right to restrict the processing of your personal details.

Objection: The right to object to the processing of your personal details.

Data Portability: The right to receive your personal details in a portable format or request its transfer to another company.

Please note that these rights may be subject to certain limitations and exceptions under applicable law for different countries/regions. Additionally, Syai may not be able to directly transfer your data to another company due to technical limitations.

If we receive requests from parents and guardians for their child's personal information access within the Syai Health Ecosystem. We will verify the identity of the requester before providing access to the child's information, even if the user's age doesn't meet the criteria for the use of Syai Health products.

Account Deletion

Your Syai account can access general applications and services such as the Syai Link, Syai Tag, and Syai Essential Apps.

For professional applications and services such as the Syai Doctor and Syai Doctor Web, you will need to register for a Syai Doctor account.

Syai Health will assist our Syai Partners to set up their Syai Partner account for the Syai Partner platform.

The deletion means to terminate the access permanently on corresponding applications or services and the mirroring software versions or services on other platforms with us.

If you would like to delete your account, you may do so by logging into the corresponding application or services first and using the delete account functionality in-app or web portals. Please be aware that if you delete your account, all data in the Syai account will be erased, but we may retain information that has already been or is in the process of anonymization, aggregation, pseudonymization, and/or de-identified for the purposes mentioned in the "Data Retention Policy" section above. We may also be required to retain certain information by law.

Once you delete your Syai account, you will lose access to all associated applications and platforms. This action is irreversible, meaning you cannot reactivate your account or recover any personal information afterwards, including but not limited to healthcare info, analytics, generated reports, patient details, etc. Before deleting your account, please ensure you have downloaded and saved any necessary information.

If you've set up connections with your HCPs or other caregivers through the Syai Link or Syai Doctor App, deleting your account will revoke their access to your glucose data, or you will not be able to stay updated with the Syai Tag users from invitations in-app. For HCPs, deleting your account may impact your ability to access patient information and historical data with specific patients. As for Syai Partners, you might not be able to manage the resources with hospitals and doctors involved.

Syai Health reserves the right to delete inactive accounts after certain months in certain cases. We will notify you in advance by sending an email to the email address/phone number used for account registration so that you have the opportunity to check your account status.

Policy Updates

This Privacy Policy document is regularly updated to reflect the latest changes to our privacy policy. Email notifications will be sent about changes made.

Syai Health reserves the right to update and amend the document without prior notice for changes that will not materially impact the way we handle your details and relevant data.

If you do not agree to the updates regarding the Privacy Policy, you should execute the account deletion procedure in-app or through the corresponding web portals.

Contact Us

If you have questions, comments or complaints about our privacy handles, you may contact us via the details below:

Company Name: Syai Health Technology Pte., Ltd.

Address: #03-01 112 Robinson Rd, SINGAPORE 068902

Email inquiries: info@syai.com