Privacy Policy

Last modified: December 2024

This Privacy Policy explains how Nao Health collects, uses, shares, and protects personal information, and the privacy rights and choices we offer, in connection with our websites, online services, and products and services (collectively, our “Services”). In this Privacy Policy, “Nao Health” means Nao Health Pte Ltd (Company No. 202435212D).

Personal Information We Collect

Information you provide to us. Personal information you may provide to us includes, but not limited to:

Contact details, such as your first and last name, organization name, email and mailing addresses, and phone number.
Account data, such as the username and password that you may use to establish an online account with us.
Communications that we exchange with you, including when you contact us with questions, feedback, or otherwise.
Order and purchase history, including your interactions with our checkout page.
Payment details, such as your payment card number, bank account number and shipping address. We rely on payment providers, such as HitPay Payment Solutions Pte Ltd, to process payments and we do not have access to payment card numbers stored with these providers.
Subscriber survey data, including the information you provide when you fill out surveys, and recordings of video or voice chats with our team.
Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.

Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with our websites, online services and our communications, such as:

Device data, such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., WiFi, LTE, 3G), and general location information such as city, state or geographic area.
Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to our websites, navigation paths between pages or screens, information about your activity on a page or screen, access times, duration of access, and whether you have opened our marketing emails or clicked links within them.

We collect this information using cookies and other similar technologies. For more information, please visit our Cookie Policy.

How We Use Personal Information

We use personal information for the following purposes:

Service delivery. We use personal information to perform our contractual obligation under our terms of use, including to:

Provide, operate and improve our Services and our business;
Process your payments and complete transactions with you; and
Communicate with you about our Services, including by sending announcements, updates, security alerts, and support and administrative messages.

For our legitimate interests. To improve, monitor and protect our Services. We use personal information to improve and keep our services safe for our users, which includes:

Understanding your needs and interests, and personalizing your experience with the Services and our communications;
Engaging in surveys and focus groups, and recording our video and audio chats with consumers
Troubleshooting, testing and research to keep the services secure; and
Investigating and protecting against fraudulent, harmful, unauthorized or illegal activity.

For research and development. We may process personal information for research and development under our legitimate business interests, aimed at analyzing and enhancing our Services and business activities. During these processes, we might convert personal information into aggregated, de-identified, or anonymous forms. This involves removing any details that could personally identify you, ensuring that the data is not traceable back to you as an individual.

For direct marketing. We may send you direct marketing communications as allowed by law (e.g., if we have a commercial relationship with you) and according to your marketing preferences to keep you informed about our products, activities, promotions, and other initiatives. For instance, we will send you our newsletter based on your subscription settings. You can choose to opt out of our marketing communications as outlined in the Opt-out of marketing section. Where applicable law requires, we will send you direct marketing communications only with your consent.

For interest-based advertising. We may partner with third-party advertising companies to display our advertisements on their online platforms. Additionally, we might share user information with these companies to help target advertisements for our services to you or to users with similar profiles on other online platforms. These interest-based advertising efforts aim to provide you with updates that are relevant to your interests, including information about our products, promotions, and other initiatives. Where required by applicable law, we will engage in this form of advertising only with your consent. To learn more about how to limit interest-based advertising, please refer to our Cookie Policy.

To comply with our legal obligations. We may use personal information to comply with our legal obligations, including to:

Ensure our compliance with applicable laws (including consumer laws with respect to purchases you make), lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
Audit our internal processes for compliance with legal requirements;
Enforce the terms of service that govern our Services;
Prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft; and
Protect our, your or others’ rights, privacy, safety, or property (including by making and defending legal claims).

How We Disclose Personal Information

We may disclose personal information to:

Affiliates. Within Nao Health for purposes consistent with this Privacy Policy

Service providers. Companies and individuals that provide services on our behalf or help us operate our Services or our business (such as hosting, information technology, customer support, email delivery, survey platform providers and website analytics services).

Payment processors. When you make a purchase at Nao Health, your payment card information is collected and processed directly by our payment processors. We do not record or maintain payment card or bank account details. These payment processors may use your payment data in accordance with their privacy policies.

Third parties. Third parties, such as advertising companies, data providers and data co-ops, for interest-based advertising and other marketing purposes, including those third parties’ own purposes. To learn how to opt-out, please see the “Privacy Rights and Choices” section below.

Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.

Business transferees. Acquirers and other relevant parties involved in business transactions—or in negotiations for such transactions—that pertain to a corporate divestiture, merger, consolidation, acquisition, reorganization, sale, or other disposition of all or part of the business or assets, or equity interests in Nao Health (including in situations involving bankruptcy or similar proceedings).

Please be aware that if you voluntarily disclose your personal information for viewing by third parties or the public through our Services, that information can be seen, collected, and used by others. We are not responsible for the use of such information by third parties.

Privacy Rights and Choices

Account choices. If you have an Nao Health account, you can review and update certain account information by logging into your account. Registered users may also contact us to request deletion of their account and certain personal information.

Opt out of marketing communications. You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the emails you receive from us. You may continue to receive service-related and other non-marketing emails.

Personal information requests. We also offer you choices that affect how we handle the personal information that we control. Depending on your location and the nature of your interactions with our Services, you may request the following in relation to personal information

Information about how we have collected and used personal information. We have made this information available to you without having to request it by including it in this Privacy Policy.
Access to a copy of the personal information that we have collected about you.
Opt out of the sale of personal information and the processing and sharing of personal information for targeted advertising. We engage in targeted advertising activities and may share personal information with third parties to provide you with offers and promotions, which may qualify as a data “sale” under certain applicable laws.
Correction of personal information that is inaccurate or out of date.
Deletion of personal information that we no longer need to provide the services or for other lawful purposes.
Additional rights, such as to object to the processing of your personal information for our legitimate business interests or any marketing related purposes, to request that we restrict our use of personal information, and where applicable, you may withdraw your consent to our processing of your personal information.

Limits on your choices. In some instances, your choices may be limited, such as where fulfilling your request would impair the rights of others, our ability to provide a service you have requested, or our ability to comply with our legal obligations and enforce our legal rights.

How to submit personal information requests

To request access, deletion, opt out of the sale of your personal information or for other personal information requests, please write to us at hello@naohealth.co.

We may ask for specific information from you to help us confirm your identity. You are entitled to exercise the rights described above free from discrimination.

Depending on your jurisdiction, you may designate an “authorized representative” to submit requests on your behalf. We will require authorized representatives to verify their identity and demonstrate their authority to act on your behalf, in accordance with Singapore's Personal Data Protection Act (PDPA) and other applicable laws.

If you are not satisfied with how we address your request, you may submit a complaint at hello@naohealth.co.

Other Sites and Services

Our Services may contain links to websites and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites or online services operated by third parties, and we are not responsible for their actions

Security

We employ a number of technical, organizational and physical safeguards designed to protect the personal information we collect. However, no security measures are failsafe and we cannot guarantee the security of personal information.

Data Privacy Framework

Nao Health complies with Singapore's Personal Data Protection Act (PDPA) and ensures that the collection, use, and retention of personal information align with the obligations under the PDPA. Nao Health is committed to protecting personal data and adheres to the principles of accountability, consent, and purpose limitation as set forth in the PDPA. If there is any conflict between the terms in this Privacy Policy and the PDPA, the PDPA shall govern. For more information about our data protection practices, please refer to the Personal Data Protection Commission's website at https://www.pdpc.gov.sg.

Nao Health may transfer personal information to third parties as described in this Privacy Policy. Nao Health ensures that contracts with third-party service providers include provisions that restrict their access, use, and disclosure of personal information in compliance with our obligations under Singapore's Personal Data Protection Act (PDPA). Nao Health remains accountable if these third parties fail to meet their obligations under the PDPA and if we are responsible for the event giving rise to the damage.

In compliance with Singapore's Personal Data Protection Act (PDPA), Nao Health commits to addressing complaints about our collection or use of personal information. Individuals with inquiries or complaints regarding our Privacy Policy should first contact Nao Health at hello@naohealth.co.

If you do not receive a timely acknowledgment of your complaint from us, or if we have not resolved your complaint, you may escalate the matter to the Personal Data Protection Commission (PDPC) in Singapore. For more information on filing a complaint, please visit https://www.pdpc.gov.sg.

Nao Health may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. Nao Health remains committed to complying with the PDPA and applicable laws governing the protection of personal data in Singapore.

Children

Our Services are not intended for use by children under 18 years of age. If we learn that we have collected personal information through our Services from a child under 18 without the consent of the child’s parent or guardian as required by law, we will delete it.

Retention of Personal Information

We retain personal information only for as long as is necessary to fulfil the purposes for which it was collected and processed, in accordance with our retention policies, and in accordance with applicable laws and regulatory obligations or until you withdraw your consent (where applicable).

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of personal information, the purposes for which we use personal information and whether we can achieve those purposes through other means, and the applicable legal and regulatory requirements.

Changes to This Privacy Policy

We reserve the right to modify this Privacy Policy at any time. Should there be material changes to this Privacy Policy, we will notify you by updating the date of the policy and posting it on our websites and online services. Additionally, if required by law, we will provide notification of changes through another method we deem likely to reach you, such as by email or another form of communication through our Services. Any modifications to this Privacy Policy will take effect upon our posting of the updated version (or as otherwise specified at the time of posting). By continuing to use our Services after the effective date of any changes, you are agreeing to the revised Privacy Policy.

How to Contact Us

Nao Health Pte Ltd is the entity responsible for the processing of personal information and is the data controller in respect of such processing. You can reach us by email at hello@naohealth.co.