LivWell Holding Pte. Ltd. (“we”) are committed to protecting and respecting yourprivacy. This policy (together with our terms of use https://www.livwell.asia/terms-of-use.html and any other documents referred to onit) sets out the basis on which any personal data we collect from you, or thatyou provide to us, will be processed by us. Please read the following carefullyto understand our views and practices regarding your personal data and how wewill treat it. By visiting http://livwell.asia/ OR logging in and using LivWell App, youare accepting and consenting to the practices described in this policy.

INFORMATION WE COLLECT FROM YOU

We will collect information in the following ways: Information you give us. Thisis information about you that you give us by filling in forms on our site www.livwell.asia or LivWell App (“our site”) or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our site, subscribe to our service, submit your data, participate in discussion boards or other social media functions on our site, and when you report a problem with our site. The information you give us may include your name, address, e-mail address and phone number, personal information such as height, weight, gender and other health related information, hobbies and interests, personal description and photograph and any other information that may be required for generating health data and general use of the LivWell App. Information we get from your use of our services. We automatically collect information about the services that you use and how you use them, as following information: 

·      Technical information, including the Internet Protocol (IP) address used to connect yourmobile device or computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;

·      Information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling,clicks, and mouse-overs), methods used to browse away from the page, and anyphone number used to call our customer service number; and 

·      From time to time, we may collect or ask you to provide personal information including (without limitation) the following: your name, mobile phone number,email address, password, IP address, unique device identifiers and other identification credentials, biographical details, location, photographs and/orpayment information. Information we receive from other sources. This isinformation we receive about you if you use any of the other websites weoperate or the other services we provide. In this case we will have informedyou when we collected that data if we intend to share such data internally and combine it with data collected on this site. We are working closely with third parties (including, for example, business partners, employers, sub-contractors in technical, advertising networks, analytics providers, search information providers). We will notify you when we receive information about you from them and the purposes for which we intend to use that information.

USES MADE OF THE INFORMATION

‍We use information held about you in the followingways: Information you give to us. We will use this information: 

·      verify your physical movement and location and issue LivWell Coins on the basis ofthis verified data either through your connected devices or wearables; 

·      to carry out our obligations to provide you with your health statistics, productsand services that you request from us in particular, provide health and fitnessrecommendations, including but not limited to, training classes, lessons, foodand drinks and other health and lifestyle services provided by ourpartners; 

·      to provide you, or permit selected third parties to provide you, with informationabout goods or services we feel may interest you. If you are an existingcustomer, we will only contact you by electronic means (e-mail or through oursite) with information about goods and services. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please tick the relevant box situated on the form on which we collect your data; 

·      to notify you about changes to our service; and 

·      to ensure that content from our site is presented in the most effective manner for you and for your computer.

Information we collect about you. We will use this information: 

•       to generate LivWell Coins which can be used to redeem products, services and other benefits via our site; 

•       to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes; 

•       to improve our site to ensure that content is presented in the most effective manner for you and for your computer;

•       to allow you to participate in interactive features of our service, when you choose to do so; 

•       as part of our efforts to keep our site safe and secure; 

•       to measure or understand the effectiveness of advertising we serve to you andothers, and to deliver relevant advertising to you; 

•       to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them; 

•       to operate the LivWell Reward Platform; 

•       to investigate disputes in case of any abnormal data or fraud or dispute inregards to LivWell Coins; and/or 

•       to the developer requests permission to read and write heath data from the HealthApp on your personal phone. 

Information we receive from other sources. We will combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above(depending on the types of information we receive).

DISCLOSUREOF YOUR INFORMATION 

We are committed to protecting your privacy and understand the importance ofkeeping your personal information private. We would make every effort to protect and regulate the use of such personal information and/or data. You agree that your personal information and/or data may be disclosed to thefollowing third parties in the normal course of our business: 

·  Any member of our group, which means our subsidiaries, our ultimate holding companyand its subsidiaries. 

·  Selectedthird parties including: 

o   businesspartners and employers for the performance of any contract we enter into withthem or you; 

o   advertisers; 

o   analytics and search engine providers that assist us in the improvement and optimisationof our site; and 

o   Governmentbodies or authorities, under any law or order of the court. 

Datacollected from Health App on your personal phone including height, weight,gender, heart rate, steps, or calories on your personal phone shall not beshared with the third parties unless you consent so. If you do not want us touse your personal information for advertisement purpose, you may request us tocease our provision by following instruction specified in advertisement itemsent to you or on our product/services.

WHERE WE STORE YOUR PERSONAL DATA 

Toprovide you with the Services, we may store, process and transmit informationin Vietnam and locations around the world - including those outside yourcountry. Information may also be stored locally on the devices you use toaccess the Services. This includes staff engaged in, among other things, thefulfilment of your order, the processing of your payment details and theprovision of support services. By submitting your personal data, you agree tothis transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy. 

Ifyou are located in the European Union or other regions with laws governing data collection and use that may differ from Vietnamese law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction. 

All information you provide to us is stored on our secure servers. Any paymenttransactions will be encrypted using SSL technology. Where we have given you(or where you have chosen) a password which enables you to access certain partsof our site including mobile application, you are responsible for keeping thispassword confidential. We ask you not to share a password with anyone. 

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guaranteethe security of your data transmitted to our site; any transmission is at yourown risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access. 

Your personal data will be kept only for as long as is necessary. We take reasonable industry standard care in keeping all our data secure and in preventing anyunauthorised access or unlawful use of it.

COOKIES 

We will only read cookies from your cookies file placed there through your webbrowser's interaction with the LivWell Website.

YOUR RIGHTS 

You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You have the right to delete your account and any personal information wehold on you. You can exercise your right to delete your LivWell account and thepersonal information attached to it yourself, by triggering an accountdeletion. You can also exercise the right at any time by contacting us at Admin@Livwell.asia.

LINKS TO OTHER WEBSITES

Our site may, from time to time, contain links to and from the websites of ourpartner networks, advertisers and affiliates. If you follow a link to any ofthese websites, please note that these websites have their own privacy policiesand that we do not accept any responsibility or liability for these policies.Please check these policies before you submit any personal data to thesewebsites.

CHANGESTO OUR PRIVACY POLICY 

Anychanges we make to our privacy policy in the future will be posted on this pageand, where appropriate, notified to you by e-mail. Please check back frequentlyto see any updates or changes to our privacy policy.

CONTACT 

Questions, comments and requests regarding this privacy policy are welcomed and should beaddressed to Admin@Livwell.asia.