Privacy Policy

1. Scope

This Policy applies to SmartWell accounts and authentication; profiles and onboarding; wellness goals and targets; meal and nutrition tracking; meal photographs; water, sleep, steps and exercise tracking; AI-assisted analysis and recommendations; subscriptions and entitlements; support and administrative functions; and related application, security and operational activities.

2. Personal data we may process

Depending on your use, we may process email address, telephone number, authentication identifiers, account and session information, supported identity-provider information, age, height, weight, preferences, lifestyle and wellness information, goals and targets, meals and nutritional values, dates and times, favourites, meal photographs, water, sleep, steps and exercise records, AI inputs and outputs, subscription and billing status, IP address, browser and device information, logs, security events, diagnostics, support communications, and legal acceptance records. Passwords are handled by our authentication provider and are not intended to be stored by SmartWell in readable form. Payment-card data may be handled directly by a payment provider; the actual provider and flow should be confirmed.

3. How we collect personal data

We may collect personal data directly from you when you create an account or use SmartWell; from a supported identity provider such as Google; automatically through application, authentication, security and operational systems; and from service providers acting on our behalf where necessary to operate and secure SmartWell.

4. How we use personal data

We may use personal data to create and maintain accounts; provide profiles, onboarding and wellness features; store and display records; calculate targets; analyse meals or photographs at your request; generate AI-assisted recommendations; maintain progress; operate subscriptions; respond to support; maintain and improve reliability; protect accounts and investigate incidents; maintain required legal records; comply with law; and carry out other notified, permitted or required purposes.

5. Wellness information and medical limitations

SmartWell is designed for general wellness tracking and informational guidance. Information may relate to health and wellness, but SmartWell is not a medical record system and does not replace medical advice, diagnosis or treatment. Do not use it as an emergency service or the sole basis for a medical decision.

6. AI-assisted processing

SmartWell may use third-party AI services for meal analysis and personalised recommendations. Information reasonably necessary for a requested feature may be transmitted to the provider, including meal descriptions or photographs, nutritional information, wellness targets, recent tracking information and other relevant information. AI output may be inaccurate, incomplete or unsuitable and is not regulated professional advice.

7. Service providers and disclosures

We may make personal data available where reasonably necessary to providers of hosting, databases, authentication, private file storage, identity-provider authentication, AI processing, payment or subscription processing, monitoring, security, and professional, legal or technical support. SmartWell uses or is intended to use Supabase, Vercel, Google authentication and OpenAI; this should be verified against production before publication. We may disclose information where required or permitted by law. We do not sell personal data to advertisers.

8. Administrative access

Authorised SmartWell or IM Communications personnel may have limited administrative access to account or application information where reasonably required for support, security, abuse prevention, service administration or legal compliance. The extent of access should be confirmed against production permissions before publication.

9. Overseas processing and transfers

Technology and service providers may process or store personal data outside Singapore. Where required, we take reasonable steps to ensure comparable protection to that required under applicable Singapore data-protection law.

10. Security

We use reasonable administrative, technical and organisational measures intended to protect personal data, which may include authentication, user-level controls, row-level permissions, private file storage, encryption in transit, access restrictions, software updates, security logging and secure development practices. No electronic system is completely secure.

11. Retention

We retain personal data as reasonably necessary to provide SmartWell; maintain accounts and requested records; meet subscription, accounting, operational, security and legal-acceptance requirements; resolve disputes; enforce agreements; and comply with law. When no longer necessary, we cease retaining it or remove its association with an identifiable individual where appropriate and required. Specific retention periods and deletion procedures should be reviewed before launch.

12. Access and correction

You may request access to or correction of personal data, subject to applicable law and exceptions. Certain information may be corrected directly in SmartWell. Where law permits a reasonable access fee, we will inform you before processing.

13. Withdrawal of consent

Where processing relies on consent and law allows withdrawal, you may contact our Data Protection Officer. We may then be unable to provide some features or the service. Withdrawal does not affect prior lawful processing or processing otherwise permitted or required. Terms acceptance and acknowledgement of this Policy are separate from optional consent.

14. Accuracy

SmartWell generally relies on you to provide accurate information. Please update information when it changes; inaccurate or incomplete data may affect calculations and AI-assisted recommendations.

15. Children and eligibility

SmartWell is intended for adults and is not designed for children. If the production eligibility rule is age 18 or older, this section should expressly state that threshold. The final age threshold should be confirmed before publication.

16. Changes to this Privacy Policy

We may update this Policy. The current version and effective date will be available through SmartWell. A material change may require authenticated users to review and acknowledge a new required version; a routine, formatting or other non-material update may not. Terms and Privacy versions may change independently.

17. Data Protection Officer and privacy requests

Questions or requests may be directed to IM Communications, Data Protection Officer, at dpo@imcomms.com.

dpo@imcomms.com

18. Relationship with the Terms of Use

This Privacy Policy should be read together with the SmartWell Terms of Use and any additional privacy notice presented for a specific feature or processing activity.

Read the SmartWell Terms of Use.