PRIVACY POLICY

1. BACKGROUND

1.1 How this Policy applies:

This Policy applies to individuals who access or use the Products ("User", "you", or "your").

1.2 Review and Updates:

We periodically update our Policy and encourage you to regularly review this Policy for any changes.

2. PERSONAL DATA THAT WE COLLECT

We collect, use, store, disclose, transfer, retain, and otherwise process different types of personal data about you, as may be applicable, depending on your use of the Products.

The personal data we collect includes, but is not limited to:

1. Identity Data: This includes data such as your first and last name, email address, age, date of birth, gender and contact details.
2. Profile Data: This includes data such as your username and password, where applicable.
3. Lifestyle Data: This includes responses to assessments and questionnaires, information relating to your mood, motivation, emotional wellbeing, resilience and lifestyle habits.
4. Technical and Usage Data: This includes data such as your activity on the Products, internet protocol address, operating systems, booking history, date and time stamps and other similar data.
5. Marketing and Communications Data: This includes information posted in service requests, offers, feedback, comments, responses to user surveys and polls, your preferences in receiving marketing communications from us and third parties, and your communication preferences.

Individuals under 18 (Eighteen) years of age are not permitted to enrol in the Mave's wellness programme or access and use the Products. We do not knowingly collect personal data from individuals under 18 (Eighteen) years of age.

We also collect, use, and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data under law as it is not directly or indirectly linked to your identity. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data, which will be used in accordance with this Policy.

We are required to collect certain personal data to provide you with the Products. If you fail to provide us that data as and when requested by us, we will not be able to perform our obligations under the arrangement we have with you or wish to enter into with you. In this case, we may have to cancel or limit your access to our Products (or part thereof).

3. HOW WE COLLECT YOUR PERSONAL DATA

We use different methods to collect personal data from and about you, including through:

1. Direct Interactions: We collect data directly from you if and when you provide it to us through the Products.
2. Automated technologies or interactions: Each time you access and use the Products, we will automatically collect certain technical and usage data. We collect such personal data by using cookies, web beacons, pixel tags, server logs, and other similar technologies. We may also receive data about you if you visit other websites or applications that employ our cookies.
3. Information we receive from third parties and publicly available sources: We may receive personal data about you from various third parties such as community networks, advertising and marketing partners, search information providers, and other publicly available sources.

4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. We and our partners may use your personal data for the following purposes:

1. to carry out our obligations arising from the relationship with you, and/or to provide you with relevant information in relation to our Products, products or services;
2. to market, promote or advertise our products or services to you;
3. to manage our relationship with you, which will include notifying you about changes to this Policy;
4. to administer and protect our business and the Products (including troubleshooting, data analysis, testing, system maintenance, support, reporting, and hosting of data);
5. to use data analytics to enhance security and make improvements to our products, or services;
6. to enforce our legal terms and policies;
7. to comply with applicable legal requirements, such as government regulations and industry standards, contracts, and law enforcement requests;
8. to respond to court orders, establish or exercise our legal rights, or defend ourselves against legal claims;
9. to address your grievances, feedback, or inquiries;
10. to detect, respond and recover from cybersecurity incidents;
11. to monitor trends so we can improve our products and services, including through surveys or reviews; and
12. to detect and protect us against error, fraud, money laundering and other criminal activities.

5. DISCLOSURE OF INFORMATION

You agree and acknowledge that any and all information pertaining to you, whether or not you directly provide it to us, may be collected, compiled, and disclosed by us in order to render the Products to you or improve the Products, pursuant to our arrangement with you or your consent. This may include but not be limited to disclosures to third party service providers, third party partners, marketing and advertising partners, storage providers, data analytics providers, consultants, lawyers, and auditors. We may also share this information with our affiliates and subsidiaries in connection with the above-mentioned purposes.

You agree and acknowledge that we may share your personal data without your consent, when required by law or by any court or a government or regulatory authority.

6. THIRD-PARTY SERVICES OR LINKS

Our Products may, from time to time, contain third-party services or links to third-party services. Please note that the third-party services that may be accessible through the Products have their own privacy policies. Please review the privacy policies of such third parties to understand their data collection and usage practices. We do not accept any responsibility or liability for the policies or for any personal data that may be collected through the third-party services.

We use third-party user experience improvement services and applications to better understand your behaviour on the Products.

Your relationship with these third parties and their services and tools is independent of your relationship with us. These third parties may allow you to permit or restrict the information that is collected. It may be in your interest to individually restrict or enable such data collections.

7. COOKIES

Cookies are small files that a site or its service provider transfers to your device's hard drive through your web browser (if you permit it to) that enable the websites or service providers' systems to recognise your browser and capture and remember certain information.

We use cookies to help us distinguish you from other users of the Products, understand and save your preferences for future visits and compile aggregate data about platform traffic and platform interaction so that we can offer you a seamless user experience. We may contact third-party service providers to assist us in better understanding our platform visitors. These service providers are not permitted to use the information collected on our behalf except to help us conduct and improve our business.

Additionally, you may encounter cookies or other similar devices that are placed by third parties. We do not control the use of cookies by third parties.

8. YOUR RIGHTS IN RELATION TO YOUR PERSONAL DATA

Under certain circumstances and subject to applicable laws, you may have certain rights in respect of your personal data, including the rights provided below:

1. Accessing and Updating Your Personal Data: When you use our Products, we make best efforts to provide you with the ability to access and correct inaccurate or deficient data, subject to any legal requirements.
2. Opting-out of Marketing and Promotional Communications: When we send you marketing and promotional content through email, we make best efforts to provide you with the ability to opt-out of such communications by using the opt-out instructions provided in such emails.
3. Right to Withdraw Consent: Where you have provided us your consent to process your personal data or information, you have the option to withdraw such consent at any time by writing to us at care@mavehealth.com.

9. TRANSFER OF PERSONAL DATA

We comply with applicable laws in respect of storage and transfer of personal data. As a part of your use of our Products, the information and personal data you provide to us may be transferred to and stored in countries other than the country you are based in. This may happen if any of our servers are from time to time located in a country other than the one you are based in, or one of our service providers is located in a country other than the one you are based in.

In the event we go through a business transition, including but not limited to a merger, acquisition by another organisation, or sale of all or a portion of our assets, your personal data might be among the assets transferred.

By submitting your information and personal data to us, you agree to the transfer, storage, and processing of such information and personal data in the manner described above.

10. DATA RETENTION

You agree and acknowledge that your personal data will continue to be stored and retained by us for as long as necessary to fulfil our stated purpose(s) and for a reasonable period after the termination of your account to comply with our legal rights and obligations.

In some circumstances, we may de-identify information and create anonymous and aggregate datasets to improve the quality of the Products and for other business purposes, in which case we may use this information indefinitely without further notice to you.

11. DATA SECURITY

We implement reasonable security procedures to protect your personal data from unauthorised access and disclosure, including managerial, technical, operational, and physical security control measures that are commensurate with the information assets being protected.

Where you have chosen a login ID or password that enables you to access our Products ("Credentials"), or certain parts thereof, you are responsible for keeping these Credentials secure and confidential. We will not be responsible for any unauthorised use of your information, or for any lost, stolen, or compromised Credentials, or for any activity on your account due to such unauthorised disclosure of the Credentials. In the event your account or Credentials have been compromised in any manner whatsoever, you should promptly notify us to enable us to initiate a change of Credentials or otherwise secure your account.

12. GRIEVANCE OFFICER

If you have any questions about this Policy, how we process or handle your personal data, or otherwise, you may reach out to us with your queries, grievances, feedback, and comments by contacting our grievance officer whose details are provided below: