Privacy

PURPOSE

The purpose of these Privacy Terms is to describe how Heyy Pte Ltd. (“Heyy” ,“Company”, “us,” “we,” or “our”) uses, collects, and shares information about you through our website, platform and application (“Platform”) owned and controlled by us. Your use of our Platform is also governed by the Terms and Condition. Terms used but not defined in this Privacy Terms can be found in our Terms of Use. Heyy controls the limited data it receives through its website or through third parties about you, for the purposes mentioned in detail herein. By accessing the Platform, you consent to the usage and sharing of data as mentioned herein, that you understand the terms of this Privacy Terms, and agree to the Terms and Conditions. If you need any clarity on the terms of the Privacy Terms please send us an email at privacy@heyy.life.

ABOUT HEYY

HEYY PTE LTD. is a company having its registered office at 117 Sunset Way, Clementi Park #02-03, Singapore 597150. HEYY is an anonymous peer to peer social platform that helps people undergoing mental stress by connecting them with their peers, to get support. We also have a network of Heyy Helpers, professionals and Care Providers, whose services can be booked. These are paid sessions.

As part of our service, HEYY provides you with online and mobile access to our secure digital platform.

At HEYY, protecting your privacy and ensuring that you control the way your information is used is our priority. We hold ourselves to high standards, including by complying with the applicable privacy laws of the jurisdiction of service and this policy.

WHAT YOU AGREE TO BY USING OUR Platform

We consider that the legal bases for using your personal information as set out in this Privacy Terms are as follows:

• our use of your personal information is necessary to perform our obligations under any contract with you (for example, to comply with the Terms of Use of our Platform which you accept by browsing our Platform, or using and accessing the Services and/or to comply with our contract to provide Services to you); or

• our use of your personal information is necessary for complying with our legal obligations; or

• our use of your personal information is necessary for our legitimate interests or the legitimate interests of others. Our legitimate interests are to:

• run, grow and develop our business;

• operate our Platform and provide our Services;

• select appropriately skilled and qualified suppliers;

• build relationships with partners;

• carry out research and statistical analysis;

• carry out marketing and business development; and

• for internal administrative and auditing purposes.

• consent, to send you certain communications or where required to rely upon consent by local law.

Which legal basis applies to a specific activity will depend on the type of personal information used and the context in which it is being used.

If we rely on our (or another party’s) legitimate interests for using your personal information, we will undertake a balancing test to ensure that our (or the other party’s) legitimate interests are not outweighed by your interests or fundamental rights and freedoms which require protection of the personal information.

We may process your personal information in some cases for marketing purposes on the basis of your consent (which you may withdraw at any time as described below).

If we rely on your consent for us to use your personal information in a particular way, but you later change your mind, you may email us at forgetme@heyy.life. If you withdraw your consent, this may impact the ability for us to provide some of our Services to you. We will suspend your account, and/or Services provided to You.

INFORMATION WE COLLECT

This Privacy Terms covers information we collect from you through our Platform. In order to access certain features and benefits on our Platform, you may need to submit, or we may collect, “Personal Data” (i.e., information that can be used to identify you and which may also be referred to as “personally identifiable information” or “personal information” or “sensitive personal information”). Personal Data can include information such as your name, nickname, gender, email address, IP address, and device identifier, among other things. You are responsible for ensuring the accuracy of the Personal Data you submit to us. Inaccurate information may affect your ability to use the Platform, the information you receive when using the Platform, and our ability to contact you, or for the Heyy Helpers and Care Providers. For example, your email address should be kept current because that is one of the primary manners in which we communicate with you. Personal Data also includes your personal health information, including information about mental health conditions you provide to us, the Heyy Helpers or the Care Providers or we receive through a third party provider.

INFORMATION RELATED TO USE OF WEBSITE/PLATFORM

When you visit our Platform, we may track, collect, and aggregate information indicating, among other things, which pages of our Platform were visited, the order in which they were visited, when they were visited, and which hyperlinks were clicked. We also collect information from the URLs from which you linked to our Platform. Collecting such information may involve logging the IP address, and browser software used by each user of the Platform. We may be able to determine from an IP address a user’s Internet Service Provider and the geographic location of their point of connectivity. We may also use cookies when you visit our Platform.

We and the Heyy Helpers and Care Providers may further receive such personal health information, including sensitive personal information such as health information, including but not limited to mental health information. We shall use such personal health information only for the purposes of providing the services to You. You consent to your personal health information shared by you, to be further shared with the Heyy Helpers and Care Providers, and for them to control and process such information solely for the purposes of providing the services, and helping you. We ensure that whoever uses our Platform are bound contractually to confidentiality obligations to maintain the confidentiality of personal information in our Platform, and also to comply with all applicable data privacy laws, or laws relating to data privacy.

INFORMATION COLLECTED FOR BUSINESS IMPROVEMENT

We may de-identify your general personal information (but not your health information without your consent, as we’ve described above), and use it in aggregate form to conduct analysis on how our platform is being used in order to improve our services and provide benefits back to our users.

When we refer to ‘de-identified’ information, we mean information that has undergone a process of removing all personal identifiers that can reasonably identify you. When we use this information for the purposes of business improvement, it is always in de-identified form.

We may also collect de-identified information via cookies on our website, such as your browser type, operating systems and other websites visited, but these do not contain any of your personal information and will not be used to link back to you individually.

HOW WE USE YOUR PERSONAL INFORMATION

We use your general personal information and your health information to enable you to access and use the HEYY platform and for us to deliver and improve our products and services. Breaking this down, we use your general personal information and your health information to:

a) Capture your nickname, age, gender, email and phone number and sign you up to the HEYY platform

b) Design, provide and manage our products and services

c) Manage our relationship with you, and improve our service to you and your experience with us (such as generating de-identified user trends in Terms of Use of the platform to identify improvements on our services)

d) Offer a forum for regular recovery meetings and encourage engagement

e) Contact you when we need to tell you something important about the HEYY platform or your information.

f) Capture information based on your messages and confirmation with Heyy Helpers, Care Providers and other users of your

g) Collect information from forum discussions. You should refrain from sharing any personally sensitive information like health information, and financial information in a forum. Heyy is not responsible and liable if any other user of the Platform uses or exploits such information posted on the forum.

h) Information collected from surveys, where you may have participated in

i) We may receive Personal Data when you access or log-in to a third party site. This may include the text and/or images of your Personal Data available from the third party site.

j) Heyy provides you facility to pay for the services using a credit card or other methods through a third party payment processing service provider. Please note that Heyy does not collect and process your financial information.

We may use aggregated, de-identified information for marketing purposes. This shall not include any personal health information.

We will comply with laws applicable to the jurisdiction of services, and assist government or law enforcement agencies where we are required and authorised to do so.

For Services that require identity verification, we may use the Personal Data that we collect for verifying your identity, and for authenticating that submissions made on the Platform were made by you.

We may use various service providers, vendors, contractors or other third parties (collectively, “Contractors”) to assist us in providing our Services to you. Our Contractors may have limited access to your Personal Data in the course of providing their products or services to us, so that we in turn can provide our Services to you. These Contractors may include vendors, helpers caregivers, experts and suppliers that provide us with technology, and services, related to the operation and maintenance of the Platform. Access to your Personal Data by these Contractors is limited to the information reasonably necessary for the Contractor to perform its limited function for us and you.

We may disclose and/or transfer your Personal Data to an acquirer, assignee or other successor entity in connection with a sale, merger, or reorganisation of all or substantially all of the equity, business, or assets of Heyy to which your Personal Data relates.

There could be external links made available in the Platform. If you click on such links, and visit such websites, we are not responsible or liable for any data sharing with such websites, applications or platforms.

RETENTION OF INFORMATION

We keep your Personal Data for no longer than necessary for the purposes for which the Personal Data is collected and processed. The length of time we retain Personal Data depends also on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise, or defend our legal rights.

WHERE DO WE STORE INFORMATION

We store all of your information on the AWS cloud servers. AWSis the Cloud computing service platform byAmazon Web Services for mobile apps. The data acquired through the app for users is stored at the AWS S3 service. Heyy, explicitly indicates the AWS database to store data at the asia-south1 region (Mumbai, India). We don’t store user information overseas, but some logical functions required for the application (such as Firebase Functions, and AWS services, accessible through the Firebase platform).AWS Service Termsterms & conditions can be found here.

YOUR RIGHTS

Your health information and your general personal information is not ours. We don’t seek to own it. You have rights in and to it, and we take that seriously. Here are the things you can ask us to do in relation to your information at any time while you use the HEYY platform.

Withdrawal of Consent: You may withdraw your consent for further processing. Note that if you withdraw your consent, we may not be able to provide services to you, or grant you access to the Platform.

Access: You can request a copy of your information, and to ask for it in a format that can be easily reused or transferred to another person that you direct.

Correct: You can ask us to correct or update your information.

Complain: You can express your concerns or complaints to us about your privacy or the way we are handling your information. We take your concerns seriously and will seek to fix any problem as soon as possible.

Delete: You have the right to delete information

Port: You have the right to port information. This may require additional cost.

Where we are not able to fulfil your request to access, correct or delete your health information or your general personal information for a legal or other reason, we will let you know why.

If you’re not happy with the way we handle your query or handle your information (including our response to your request to access, correct or delete your health information or your general personal information), you have a right to lodge a complaint with the data privacy authority.

To exercise any of your rights in relation to your information, you can contact us at privacy@heyy.life.

CONFIDENTIALITY AND SECURITY

We will use industry standard physical, technical, and administrative security measures to keep your Personal Data confidential and secure, and will not share it with third parties, except as otherwise provided in this Privacy Terms, or unless such disclosure is necessary in special cases, such as a physical threat to you or others, as permitted by applicable law. The Internet is not an absolutely secure environment. There are new threats everyday.Hence, we cannot guarantee the security of your Personal Data.There could also be some risk that an unauthorised third party may find a way to circumvent our security systems and / or intercept transmission of your information over the Internet. It is your responsibility to protect and secure your login information. Email communication or communication using other third party tools may not be secure, and may be a part of the services.

CHANGE IN POLICY

We may change the terms of this Privacy Terms in order to comply with the laws, or to fulfil our business obligations within the bounds of and keeping in mind your rights to privacy, and within the guardrails or applicable laws.

GOVERNING LAW

The Privacy Terms shall be governed by and interpreted under the laws of Singapore, without regard to its conflict of laws principles. Courts in Singapore will have jurisdiction on any disputes arising out of these Privacy Terms. The Parties agree to first escalate and resolve any issues through mediations and discussions. If the dispute is not resolved within 30 days, then the Parties shall submit themselves to arbitration, under a sole arbitrator agreed by both the Parties, or if the parties are not able to reach a conclusion on an arbitrator, then the arbitrator shall be chosen as per the rules of SIAC. The arbitration shall be governed by the rules of SIAC, and the language of arbitration shall be English. The adjudication by the arbitrator shall be final and binding on the Parties.