Privacy Policy

Last updated: 13 May 2024

1. About the wellmee Marketplace

   wellmee (operated by Aladdin Labs PTE. LTD. (Singapore)) (referred to as the “wellmee”, "Marketplace", "we", "us", or "our") is a digital designed for the discovery and booking of health and wellness services, facilitating communications between clients and practitioners, and providing other related functionalities. The Marketplace operates by creating a marketplace for therapies facilitating direct interaction and a direct contract for the provision of them between practitioners and clients.

   The Marketplace features:

   • Profile creation and management for both clients and practitioners;
   • Appointment scheduling system that includes management of bookings, cancellations, and reminders;
   • Secure messaging system for practitioners to communicate with clients regarding appointments and health management;
   • Digital forms and payment processing for services rendered via the Marketplace.
2. Who is affected by this privacy policy?

   This privacy policy concerns all individuals who create an account on the Marketplace (clients and practitioners), i.e., users of the Marketplace (referred to as "you").

   This privacy policy (the "Privacy Policy") is provided to help you understand why and how we collect and use the personal information you provide to us.

   When you provide us with personal data, it is processed in accordance with applicable data protection and privacy legislation, including the EU General Data Protection Regulation ("EU GDPR"). Depending on your place of residence or on the country whom which you access the Marketplace, additional rules may apply in accordance with the local law on data protection.

3. What personal data do we collect?

   • Contact details: Names, addresses, phone numbers, and email addresses;
   • Health information: Appointment history, treatment records (transcription and video), and other health-related details provided by you;
   • Financial information: Transaction details related to the services accessed through our Marketplace;
   • Identification data: Necessary details required for verifying your identity, such as government issued identification, for account management and so as to allow us to comply with relevant laws.
4. How do we collect this data?

   We collect, directly from you, the data you provide at the time of creation of your account on the Marketplace, and any time you book and enjoy the service, or use the Marketplace in any other manner.

5. What purposes do we collect this data for?

   We collect data above for the following purposes:

   • Operating and maintaining the functionalities of the Marketplace: [specify what data (categories) you use for this purpose];
   • Facilitating communication between clients and practitioners: [specify what data (categories) you use for this purpose];
   • Managing user accounts: [specify what data (categories) you use for this purpose];
   • Processing user transactions: [specify what data (categories) you use for this purpose].

   We may also use the collected data to improve our services and develop new features. Before any such use, we will make the data anonymous, i.e., we will convert the personal data into information that the data protection legislation no longer applies to.

6. On what legal basis do we collect this data?

   The legal basis for the processing of your personal data is either: (i) your consent given by ticking the appropriate box and filling in the relevant fields in the registration form, on the Marketplace, after receiving this Privacy Policy; or (ii) where permitted under applicable law, our legitimate interest.

   The legal basis for the processing of your sensitive personal data, such as health data, is your explicit consent given by ticking the appropriate clauses in the registration form on the Marketplace, after receiving this Privacy Policy.You may withdraw this consent at any time, however this may result in your not being able to use the Marketplace.

   In addition, we may process your personal data to fulfill legal obligations to which we are subject.

7. How long will we keep your personal data?

   We retain your data while you have an active account on the Marketplace and for six (6) months after your close your account.

   At the end of the above period, the data will be deleted or anonymised.

8. Do we share your personal data with other companies?

   Yes, we cooperate with partners who process some of the above data.

   Personal data provided by you or referring to you may be disclosed or may come to the attention of external parties who collaborate with us as data processors such as but not limited to: companies, firms and/or freelancers for consulting and/or management activities in technical, corporate, marketing or IT fields.

   Your personal data may be disclosed to other companies who collaborate with us as business partners if you have consented to such disclosure or if it is permitted by applicable law.

9. Do we transfer personal data outside the border of your country?

   Yes, your personal data may be shared with a company that is based outside your country. The Marketplace is hosted in the European Union.

   We ensure an adequate level of protection for personal data by taking appropriate measures, such as transferring it to a country that provides an adequate level of protection for personal data, or entering into specific contracts.

10. What are your rights in relation to your personal data?

    The legal rights you have over the data we hold about you may depend on where you are based physically.However, as we host our Marketplace in the EU, unless required by your local law, we will provide all users with the rights given to data subjects under the EU GDPR.

    We inform you that you have rights in relation to the personal data we process, including the following:

    • Right to be informed: you have the right to receive clear, transparent and easily understandable information about how we use your personal data and your rights in this regard. This is why we provide you with this Privacy Policy.
    • Right of Access: you have the right to obtain confirmation about the processing of your personal data, details of such processing, access to your personal data, and a copy of your personal data.
    • Right to Correction: you have the right to have your personal data rectified if it is inaccurate or incomplete.
    • Right to Erasure: you have the right to request the deletion or removal of your personal data if there is no valid reason to continue using it. Note that this is not an absolute right and exceptions apply.
    • Right to restrict processing: you have the right to block or prevent further use of your personal data. If processing is restricted, we may continue to store your personal data, but its use will be limited.
    • Right to object to processing: where processing is based on our legitimate interest, you have the right to object to such processing, unless we have a compelling legitimate reason to continue processing your personal data.
    • Objection to direct marketing: you have the right to object at any time to the processing of your personal data for direct marketing purposes.
    • Right not to be subjected to automated decision-making: you have the right not to be subjected to a decision based solely on automated processing (including profiling) that produces legal effects for you or significantly affects you. This is not the case.

    You can exercise the above rights in relation to your personal data by contacting us on dop@wellmee.com.

    Please note that you can exercise your rights only in relation to the personal data we hold in this specific context.

    You may also file a complaint about the way we process your personal data or the way we have handled your request to exercise your rights with the national data protection authority, namely the Data Protection Authority.

11. Modification of this Privacy Policy

    We reserve the right to change this Privacy Policy periodically without notice. Any changes will be effective upon publication of the new Privacy Policy on the Marketplace. Your continued use of the Marketplace constitutes acceptance of any change.

12. Choice of Law

    This Privacy Policy and its interpretation are governed by Singaporean Law.