We value your trust and confidence and shall exercise reasonable efforts to protect your right to privacy. Please read the following carefully to understand our views and practices regarding personal data and how it will be treated.

Hati Health reserves the right to amend, revise and/or update this Privacy Policy from time to time without prior notice, but shall promptly publish any revisions on our website for your immediate guidance.

I. INTRODUCTION

1. Hati Health has created the following Data Privacy Policy (“Privacy Policy” or “Policy”) to let you know what personal information we collect when you visit and use our site, “Messaging Apps” (including Facebook Messenger, Whatsapp, Viber and others we may support from time to time) and/or use the Hati Health Services (“Services”), which is aptly described in the Terms & Conditions (www.hati.health), why we collect it and how it is used and stored. This Policy takes into consideration the rights and obligations as outlined under the Data Privacy Act 2012 (Republic Act 10173), its Implementing Regulations, and the applicable laws of the Republic of the Philippines.

   
   

2. We recognize the importance of the Personal Information you have entrusted to us and as such, we are committed to ensuring that your privacy is safeguarded, and we are transparent as to how we manage, protect, and process your personal information. This Privacy Policy is designed to guide you in understanding how we collect, use, disclose and/or process the personal information that you have entrusted to us.

   
   

3. Personal Information simply means any information or data that can be used to distinguish, identify or contact you. This may include personal information or sensitive personal information. Under the Data Privacy Act of 2012, Personal Information refers to any information whether recorded in a material form or not, from which the identity of an individual is apparent or can be reasonably and directly ascertained by the entity holding the information, or when put together with other information would directly and certainly identify an individual.” Sensitive Personal Information, on the other hand, refers to sensitive personal information" refers to personal information: (1) about an individual’s race, ethnic origin, marital status, age, color, and religious, philosophical or political affiliations; (2) about an individual’s health, education, genetic or sexual life of a person, or to any proceeding for any offense committed or alleged to have been committed by such individual, the disposal of such proceedings, or the sentence of any court in such proceedings; (3) issued by government agencies peculiar to an individual which includes, but is not limited to, social security numbers, previous or current health records, licenses or its denials, suspension or revocation, and tax returns; or (4) specifically established by an executive order or an act of Congress to be kept classified.”

   
   

4. This Policy explains the data collection and data use practices of Hati Health website and Messaging Apps. The terms “you,” “your,” and “yours” refer to the customer/purchaser utilizing our site. The terms “Hati Health,” “we,” “us,” and “our” refer to Hati Health Pte Ltd. By using the Hati Health Services website, Messaging Apps or other official supported channels, you consent to the data practices prescribed in this Privacy Policy. In the event that you do not consent to the processing of your personal information as laid out in this Policy, please do not use our services or access our website or mobile application.

   
   

5. We may update this Privacy Policy from time to time to comply with applicable laws. It is recommended that you visit this page frequently to check for changes. This Privacy Policy is available on our website or mobile application for easy reference.

   
   

II. WHY WE COLLECT PERSONAL INFORMATION AND HOW WE USE IT

1. Our primary purpose in collecting personal information is to provide you with a secure, efficient, and customized experience. We may collect, use, process and examine your personal information when reasonable, relevant and necessary to:

   
   

   • Provide Hati Health services and customer support timely and efficiently at your request;

   • To customize product and service offerings and making recommendations to you, including third-party products and offerings;

   • To create your account on our platform and let you log in to your account and use the platform;

   • To personalize your experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our websites, Messaging Apps, third-party sites, and via email or text message (with your consent, where required by law);

   • To provide, support, personalize, and develop our platform and wellness assistant and teleconsultation services;

   • To comply with applicable laws, including, but not limited to laws related to protecting client and public health and safety;

   • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;

   • To market the platform and wellness services to you;

   • To measure and improve the quality, the effectiveness and the delivery of our services;

   • To supervise, administer and monitor the service;

   • To enable and facilitate the wellness assistant and wellness consultation services;

   • To provide more customized responses for you with our wellness assistant service or with a health and wellness professional as part of our service;

   • For billing-related purposes;

   • To contact you or provide you with information, alerts and suggestions that are related to the service;

   • To manage your account, provide you with customer support, and ensure you are receiving quality service;

   • Prevent potentially prohibited or illegal activities;

   • Customize, measure, and improve Hati Health services and the content and layout of our website and applications;

   • Deliver direct marketing, service update notices, and promotional offers based on your communication preferences;

   • Compare information for accuracy and verify it with third-parties; and

   • Monitor the quality and security of the network and train our staff

   
   

2. When we can, we aggregate and anonymize this information such that you are never identified as an individual. For the avoidance of doubt, with this practice we try to present information in segments or categories and remove any personally identifiable information from the data.

   
   

3. For the avoidance of any doubt, as we may be using third party channels, their respective Privacy Notices would be applicable. For example, if you are accessing our Wellness Assistant via Facebook Messenger, the applicable T&Cs and Privacy Policy would apply.

   
   

4. You may also allow us to connect to third-party services, such as Apple HealthKit and Google Fit, to enable us to import Personal Information about your health and activities into the Services. This imported data may include sports activities, weight, calories burned, heart rate, number of steps/distance traveled, and other data about your health. We will process this data in order to provide you with the functionality described below.  When you choose to have this data imported you are subject to the respective third-party privacy policies and practices.

III. HOW WE COLLECT INFORMATION ABOUT YOU

1. When you visit the Hati Health website or use Hati Health Services or Hati Health Wellness Assistant, we collect information sent to us by your computer, mobile phone, or other access device. This information may include your IP address, device information including, but not limited to, unique identifier, name and type, operating system, location, mobile network information and standard web log information such as your browser type, traffic to and from our site, and the pages you accessed on our website.

   
   

2. Before being able to use Hati Health services, we may require you to provide additional information so we can create an account, such as your date of birth. We also collect your contact details like billing address, telephone number, mobile phone number, email address.

   
   

3. When you use Hati Health services, we collect information about your health and wellness (including sexual activities), physical and mental well-being, and related activities, including personal life, through our Wellness Assistant,  and your other activities on our website and we may collect information about your computer or other access device for fraud prevention purposes. As applicable, we may also collect your professional or employment-related information, such as employer details and contact information, job title, office location, and company details.

   
   

4. You may choose to provide us with access to certain personal information stored by third parties such as messaging apps and sites (such as Facebook and Viber). Such information is collected, and stored by those third parties. We will have access to certain information. The information we have access to varies by site and is controlled by your privacy settings on that site and your authorization. By associating an account managed by a third-party with your Hati Health account and authorizing Hati Health to have access to this information, you agree that Hati Health may collect, store and use this information in accordance with this Privacy Policy.

   
   

5. We may obtain your information through third-party sources, such as from eligibility files and claims data that we receive from your employer or your health plan, and from family members and personal representatives who are registered with or interact with Hati Health. If you are interacting with our Site as a potential business customer of Hati Health, such as our “Contact Us” page or “Demo Request” page, we may supplement your personal data with information we receive from marketing partners and social media companies. We may combine this information with the information we collect about you to help us tailor our communications and improve our Services.

   
   

6. In order to help protect you from fraud and misuse of your personal information, we may collect information about your use and interaction with our website or Hati Health services. For example, we may evaluate your computer, mobile phone or other access device to identify any malicious software or activity that may affect the availability of Hati Health services.

   
   

7. Finally, we may collect additional information from or about you in other ways such as interactions with our customer support team.

   
   

IV. HOW WE USE COOKIES

1. When you access our website or content or use our application or Hati Health services, we or companies we work with may place small data files called cookies or pixel tags on your computer or other device. We use these technologies to:

   a. Recognize you as a Hati Health customer;

   b. Customize Hati Health services, content, and advertising;

   c. Measure promotional effectiveness; and

   d. Collect information about your computer or other access device to mitigate risk, help prevent fraud, and promote trust and safety.

   e. We use both session and persistent cookies when you access our website or content. Session cookies expire and no longer have any effect when you log out of your account or close your browser. Persistent cookies remain on your browser until you erase them or they expire.

1. We also use Local Shared Objects, commonly referred to as “Flash cookies,” to help ensure that your account security is not compromised, to spot irregularities in behavior to help prevent fraud, and to support our sites and services.

   
   

2. We encode our cookies so that only we can interpret the information stored in them. You are free to decline our cookies if your browser or browser add-on permits, but doing so may interfere with your use of our website. The help section of most browsers or browser add ons provides instructions on blocking, deleting or disabling cookies.

   
   

3. You may encounter Hati Health cookies or pixel tags on websites that we do not control. For example, if you view a web page created by a third-party or use an application developed by a third-party, there may be a cookie or pixel tag placed by the web page or application. Likewise, these third-parties may place cookies or pixel tags that are not subject to our control and the Hati Health Privacy Policy does not cover their use.

   
   

V. HOW WE PROTECT AND STORE PERSONAL INFORMATION

1. Throughout this policy, we use the term “personal information” to describe information that can be associated with a specific person and can be used to identify that person. We do not consider personal information to include information that has been anonymized so that it does not identify a specific user.

   
   

2. We store and process your personal information on our computers in Asia-Pacific and elsewhere in the world where Hati Health facilities or our service providers are located, and we protect it by maintaining physical, electronic and procedural safeguards. We use computer safeguards such as firewalls and data encryption. We enforce physical access controls to our buildings and files. And we authorize access to personal information only for those employees who require it to fulfill their job responsibilities.

   
   

VI. RIGHTS OF HATI HEALTH CUSTOMERS

1. Filipino citizens and residents that are customers of Hati Health irrespective of current jurisdiction have been guaranteed certain privacy and information security rights under the Data Privacy Act of 2012. We value and respect the rights afforded to you. As such, Hati Health strictly adheres to data privacy rights expressly stated under the Data Privacy Act of 2012, where applicable.2. Subject to internal processes, and requirements, conditions, and exemptions under relevant law and Data Privacy Laws, you are entitled to the following rights:a. To access your personal data;b. To dispute any inaccuracy or error in your personal data and require Hati Health to correct or update the same;c. To obtain a copy of your personal data in an electronic or structured format for your further use;d. To suspend, withdraw, or order the blocking, removal, or destruction of your personal information from Hati Health’s system, provided such action involves is not critical nor required by applicable laws and regulation to maintain the products and services that you availed with us;e. To file a complaint with the National Privacy Commission.3. You may access the National Privacy Commission website at www.privacy.gov.ph, for a complete reference of your rights under the Data Privacy Act of 2012.

   
   

VII. HOW WE SHARE PERSONAL INFORMATION TO FULFILL HATI HEALTH SERVICES

1. To provide you our Services we may securely share some of your personal information with the person or company that will be providing you the service. This includes your contact information; date of birth; a summary of your interaction with the Hati Health Wellness Assistant. We manage these data sharing activities by the guidelines of our information security policy as well as this policy. In addition, this and other information may also be shared with third-parties when you use these third-parties (eg. Third Party Messaging channels and Apps) to access Hati Health Services. For such services, the respective Terms of Use and Privacy Policies of these Third Party Messaging Apps and channels would apply.

   
   

2. If you are buying goods or services and pay facilitated by Hati Health, we may also provide the service provider with your details to help complete your transaction or fulfillment of the service request. The service provider is not allowed to use this information to market their services to you unless you have agreed to it.

   
   

3. We work with third-parties, to enable them to offer their services to you through Hati Health. In this case a third-party may share information about you with us, such as your email address or mobile phone number to inform you that a service request has been booked or a payment is sent to you.

   
   

4. In relation to the sharing of and release of your personal information, you hereby acknowledge and agree that your personal information may be collected, used, disclosed and/or processed or otherwise dealt with outside of the Philippines where Hati Health, its subsidiaries, and affiliates, and third-parties may operate their business, in providing Hati Health services.

   
   

VIII. HOW WE SHARE PERSONAL INFORMATION WITH OTHER PARTIES

1. We may share your personal information with:

   1. Service providers under contract who help with parts of our business operations. Our contracts dictate that these service providers only use your information in connection with the services they perform for us and not for their own benefit, .including organizations that provide services related to: maintaining, operating, hosting, and improving the Services; payment processing; customer service; sending emails; fulfilling orders; technical support; data analytics; and marketing and advertising. It is our policy to limit our service providers’ use of your Personal Data to that which is necessary to perform their services for us.

   2. Companies that we plan to merge with or be acquired by. (Should such a combination occur, we will require that the new combined entity follow this privacy policy with respect to your personal information. You will receive prior notice of any change in applicable policy.)

   3. Practitioners. We may disclose your Personal Data to wellness professionals and facilities offering their services via the Services (the “Practitioners”), with your consent, so that they may provide virtual consultations and telehealth to you as part of the Service. In addition, when you communicate with us or submit information through the Services, we may share that information with Practitioners to enable them to communicate with you and provide the Services.

   4. Your Employer or Health Plan. If your access to the Services is offered in connection with a program offered or supported by your employer or health plan. In certain circumstances, when permissible under applicable laws, your employer or group health plan may ask that we share certain Personal Data with a third party designated provider to use for their own purposes, such as cost analysis and understanding care outcomes.

   5. Law enforcement, government officials, or other third-parties when:- We are compelled to do so by a subpoena, court order or similar legal procedure; or- We believe in good faith that the disclosure of personal information is necessary to prevent physical harm or financial loss;- We report suspected illegal activity or to investigate violations of our Terms & Conditions.- Other third-parties with your consent or direction to do so.

      
      

2. Hati Health will not sell or rent any of your personal information to third-parties for their marketing purposes and only share your personal information with third-parties as described in this policy.

   
   

3. If there is an actionable breach of your personal information, we will notify you within 72 hours.

   
   

4. If you establish a Hati Health account indirectly on a third-party website or via a third-party application, any information that you enter on that website or application (and not directly on a Hati Health website) will be shared with the owner of the third-party website or application and your information may be subject to their privacy policies.

   
   

IX. HOW WE PROTECT YOUR INFORMATION

1. The integrity, confidentiality and security of your information are particularly important to us. That’s why we strictly enforce our privacy policy within the company and we have implemented technological, organizational and physical security measures that are designed to protect your information from unauthorized access, use, alteration and disclosure. We also put in effect safeguards such as:

   1. We keep and protect your information using a secured server behind a firewall, encryption and security controls;

   2. We restrict access to your information only to qualified and authorized personnel who hold your information with strict confidentiality;

   3. We undergo regular audit and rigorous testing of our infrastructure’s security protocols to ensure your data is always protected; and

   4. We let you update your information securely to keep our records accurate.

   5. We will retain your Personal Information throughout the subscription of our products and services. We will only retain your Personal Information for as long as we need it to fulfill our purposes, including any relating to legal, accounting, or reporting requirements.

   6. When retention is no longer required, your Personal Information will be destroyed in irretrievable and unusable form in accordance with our secure information destruction and disposal policy and with respect to applicable laws.

X. HOW YOU CAN ACCESS OR CHANGE YOUR PERSONAL INFORMATION

1. You have certain rights in relation to your Personal Information under the Data Privacy Act of 2012, which includes the right to object to processing, the right to access your data, the right to amend or rectify inaccurate data, and the right to erasure or blocking of data.

   
   

2. If you wish to have access to your personal information in our records; or you think that such personal information we have of you is incomplete, not up-to-date, or otherwise inaccurate; or prefer to opt-out of this privacy policy you may get in touch with our Data Privacy Officer through the contact details provided below.

   
   

3. You may always review and edit your personal information by contacting our DPO. If you close your account, your personal identifiable information will not be used by us for any further purposes, nor sold or shared with third-parties, except as necessary to prevent fraud, assist law enforcement, as required by law, or in accordance with this Privacy Policy.

   
   

XI. HOW YOU CAN CONTACT US ABOUT PRIVACY CONCERNS/QUESTIONS

1. If you have questions, concerns, complaints regarding this Privacy Policy or the handling of your personal information, you may contact our Data Protection Officer directly through the following address and contact information:

   
   

Company Name:

Hati Health Pte. Ltd.

Address and Contact Information

30 Cecil Street #19-08 Prudential Tower, Singapore

[email protected]

Please include your name, contact information, and the nature of your concern/request so that we can appropriately respond to your communication.

1. For other Hati Health concerns, you may reach us on our support page through any of the official channels.