Privacy Policy

1. General Info

Protecting your privacy is important to us. We hope the following statement will help you understand how our app deals with the personal identifiable information ('PII') you may occasionally provide to us via Internet (the Google Play Platform).

This Privacy Policy (the "Policy") serves to explain what information Health Applines Limited and its affiliates and subsidiaries (collectively, "we", "us", or "our") collect, and how we use and protect your information when you use any mobile applications that we develop and are available for download in the Google Play Store.

This Policy applies exclusively to information collected within the app, as well as to email, text, and other electronic communications sent by you through or in connection with the app.

Please read this policy carefully to understand our policies and practices regarding your information and how we handle it. If you do not agree with our policies and practices, please refrain from downloading, registering or using this app. By downloading, registering or using the app, you agree to abide by this privacy policy.

Reviewing this Privacy Policy will help you become familiar with your privacy rights and choices. If you have any questions or concerns, please feel free to contact us at support@healthapplines.com.

2. Data Collection and Usage

2.1  What Information Do We Collect?

2.1.1 Device information

We collect your device and network connection information in order to provide you better experience when you use our app.

This information depends on the context of your interactions with us, the choices you make, including your privacy settings, and the products and features you use, and may include:

* SDK/API/JS code version, IP address, platform, timestamp, application identifier, application version, application distribution channel, independent deice identifier, the terminal manufacturer, the terminal device operating system version, the location of the language, the time zone and the network state (Wi-Fi and so on), the CPU, and the battery use, Screen resolution, Memory usage, Storage usage, sim operator, sim card country, Application release status in google play, Ad loading strategy, Ad platform and advertising placement id. Phone height and width,sim operator name,os version.

We store the information collected through the Android ID tied to the device you are using. In this way, we can retain your advertising behavior while you are using the app. We will treat this information as personal information

2.1.2 Data about your use of the Services

* Number of clicks, landing pages, pages viewed and order of those pages, the amount of time spent on particular pages, the date and time of your request, number of the app opened and some viewed page.

* Permissions status.

* First open time timestamp.

* Your device Internet Protocol(“IP”) address.

* Firebase device ID.

* Device name.

* Operating system version.

* System language.

* Other log data.

The above information is only used to improve the product experience and will not be sold to any third parties.

2.1.3 The data you provide to us

We collect your information that you voluntarily provide to us when you use the app, express an interest in obtaining information about us or our apps, when you participate in activities on the app, or send us feedback.The information that we collect depends on the context of your interactions with us and the app. User information we collect may include: email address & user name.

2.1.4 Monetization and Analytical Information from Other Sources

Third-party SDKs intergrated in our app may access your information, including:

* Google Advertising ID

* Demographic data (e.g. determination of your IP address)

* Data to fight against fraud (e.g. click fraud in advertising)

* Data associated with your device (e.g. device type, technological information, country)

* Data to do advertising, marketing and analysis

* Advertisers may store or read cookies

The information collected by third-party SDKs is governed by the providers of these SDKs and we have no control over such third parties. The third-parties include monetization partners, such as Google Admob, Facebook Audience Network, Applovin, Mintegral etc., and also analytical tools partners, such as Firebase, Google Analytics, Facebook Analytics and AppsFlyer. The links to the above mentioned platforms’ privacy policy are attached in the section "Third-party Privacy Policy".

2.2 How Do We Use the Information?

2.2.1 To improve and optimize the Services

To provide better Services to you, we have a legitimate interest to collect and process necessary data to:

* Update and develop the Services

* Develop and improve your experience

* Manage the relationship with you

* Customize your service experience

* Respond to your comments and questions and provide support to you

* Provide offers in the Services as well as in other websites and services

* Send related information (e.g. updates, security alerts, support messages) to you

2.2.2 To provide the Services

To provider the Services, we process data necessary to:

* Allow you to use the Apps and the Services

* Operate the Services

* Provide and deliver products and services that you request

2.2.3 To carry out activities related to advertisements and marketing

To send you personalized advertising and marketing materials, we may use the information collected from you such as ad identifiers, age, country, region, gender, language, games played by you, information related to the interaction of you with the Services and with other users, and so forth.

We may also use various third party advertising and marketing partners to assist us on our behalf and may share information collected from you with such third parties for this purpose.

Hence, we have a legitimate interest to process necessary data to:

* Track the content you access in connection with the Services and your online behavior

* Deliver, target and improve our advertising and marketing materials

* Pass the information collected from you to third party advertising and marketing partners

By accepting this Privacy Policy and downloading or continuing to use the Services, you consent to us and our advertising and marketing partners collecting and using information about you to personalize advertising and marketing materials and to improve your experience unless you opt out of receiving this service.

We encourage you to review the privacy policies of our third party advertising and marketing partners so that you can understand how these third parties collect, use and share your information. We are not responsible for the privacy policies of any third party whether accessed through the Services or otherwise.

We may disclose your information to comply with legal requirements, such as responding to a court order or government request. If our application is acquired or merged with another company, your information will be transferred with your consent as part of the transaction.

2.3 What Information Do We Share?

As mentioned above, your personal information may be shared with our third-party partners. We may disclose your personal information to our business partners, including advertisers, publishers, and data tracking companies. These business partners may use your personal information to show you advertisements, measure your ad/site interaction, and better understand the site and app traffic usage or user behavior in order to improve their services. Such partners' use of the information that we disclose to them will be governed by their privacy policies.

2.4 What Are the Important Permissions We Request?

To enable certain functionalities, the app requires the following on your device:

* CAMERA PERMISSION - Camera functionality is necessary when measure heart rate.

3. Data Security and Storage

3.1 To secure the services

Ensuring the security in the course of performing the Services is a top priority for us. We take appropriate security and technical measures to protect your information from unauthorized access, loss and misuse. To achieve this purpose, we also request our suppliers who process personal information on our behalf to take appropriate security measures.

In order to keep the Service safe, to fight fraud and to ensure acceptable use otherwise, we have a legitimate interest to process necessary data to:

* Analyze and monitor use of the Services

* Prevent cheating, crime or fraud

* Take action against fraudulent or misbehaving users

3.2 To secure your data

The privacy of your data is paramount to us. We adhere to universal accepted protocols to safeguard the data provided to us, both during transmission and following its receipt. However, no methodology of electronic transmission or storage can be 100% secure. Consequently, you acknowledge and accept that we cannot ensure the protection of your personal information transmitted to our applications or customer service capabilities and any such transmission is conducted at your own peril. We will utilize rigorous procedures and security measures to deter unauthorized access to it.

We DO NOT require you to create an account on our App, and therefore, We DO NOT collect any personal data from you when you download and/or use our app. Regarding the automatic information we collect, we only collect it for operating purposes, and we do not retain it. All the data only stored on your Device, your data will be permanently erased by deleting system data or uninstalling Our App.

4. Your Rights

We provide you with the rights described below when you use our Services. Please contact us at support@healthapplines.com if you would like to exercise your rights under applicable law. When we receive an individual rights request from you, please make sure you are ready to verify your identity. Please be advised that there are limitations to your individual rights. We may limit your individual rights in the following ways:

* Where denial of access is required or authorized by law;

* When granting access would have a negative impact on other's privacy;

* To protect our rights and properties; and Where the request is frivolous or burdensome.

4.1 Right to withdraw consent

If we rely on consent to process your personal information, you have the right to withdraw your consent at any time. A withdrawal of consent will not affect the lawfulness of our processing or the processing of any third parties based on consent before your withdrawal.

4.2 Right of access and rectification

If you request a copy of your personal information that we hold, we will provide you with a copy without undue delay and free of charge, except where we are permitted by law to charge a fee. We may limit your access if such access would adversely affect the rights and freedoms of other individuals. You may also request to correct or update any of your personal information held by us, unless you can already do so directly via the Services.

4.3 Right to erasure(the “Right to be Forgotten”)

You may request us to erase any of your personal information held by us that: is no longer necessary in relation to the purposes for which it was collected or otherwise processed; was collected in relation to processing that you previously consented to, but later withdrew such consent; or was collected in relation to processing activities to which you object, and there are no overriding legitimate grounds for our processing.

4.4 Right to restriction

You have the right to restrict our processing your personal information where one of the following applies:

* You contest the accuracy of your personal information that we processed. We will restrict the processing of your personal information, which may result in an interruption of some or all of the Services, during the period necessary for us to verify the accuracy of your personal information;

* The processing is unlawful and you oppose the erasure of your personal information and request the restriction of its use instead;

* We no longer need your personal information for the purposes of the processing, but it is required by you to establish, exercise or defense of legal claims; or

* You have objected to processing, pending the verification whether the legitimate grounds of our processing override your rights.

We will only process your restricted personal information shall with your consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest. We will inform you if or when the restriction is lifted.

4.5 Right to object to processing

You may object to our processing at any time and as permitted by applicable law if we process your personal information on the legal basis of consent, contract or legitimate interests. We can continue to process your personal information if it is necessary for the defense of legal claims, or for any other exceptions permitted by applicable law.

4.6 Right to data portability

If we process your personal information based on a contract with you or based on your consent, or the processing is carried out by automated means, you may request to receive your personal information in a structured, commonly used and machine-readable format, and to have us transfer your personal information directly to another "controller", where technically feasible, unless exercise of this right adversely affects the rights and freedoms of others.

4.7 Notification to third-parties

If we share your personal information with third parties, we will notify them of any requests for rectification, erasure or restriction of your personal information, unless this proves impossible or involves disproportionate effort. Upon your request, we will identify such third parties.

4.8 Automated individual decision-making, including profiling

You have the right not to be subject to a decision based solely on automated processing of your personal information, including profiling, which produces legal or similarly significant effects on you, unless an exception applies under applicable law.

4.9 Right to lodge a complaint

If you believe we have infringed or violated your privacy rights, please contact us at support@healthapplines.com so that we can work to resolve your concerns. You also have a right to lodge a complaint with a competent supervisory authority situated in a Member State of your habitual residence, place of work, or place of alleged infringement.

5. Third-party Partners’ Privacy Policy

Here we list the links to the third-party partners' privacy policy. Please note that these policies are governed by the third parties and we have no control over them. Check the following links to get details about how user data is collected, used and shared.

* Google Admob & Firebase & Google Analytics

https://policies.google.com/privacy?hl=en

* Facebook Audience Network & Facebook Analytics

https://www.facebook.com/about/privacy

* AppsFlyer:

https://www.appsflyer.com/legal/privacy-policy/

* AppLovin:

https://www.applovin.com/privacy/

* Mintegral:

https://www.mintegral.com/en/privacy/

* Pangle:

https://www.pangleglobal.com/zh/privacy/enduser-en

6. California Residents’ Privacy Rights

We prepare this separate Privacy Notice for California Consumers to comply with the California Consumer Privacy Act of 2018 ("CCPA") and other California privacy laws.This notice is designed to supplement the information described in our and applies solely to users who reside in the State of California ("consumers" or "you").

IF YOU ARE NOT A CALIFORNIA RESIDENT, THIS POLICY DOES NOT APPLY TO YOU. PLEASE REFER TO OUR MAIN PRIVACY NOTICE HERE INSTEAD.

6.1 Your Right to Request for Information

As required by CCPA, you( or your authorized agent) have the right to request us to disclose information to you about how we collect, use and share your personal information over the past 12 months.These information include: the categories of personal information we collected; the categories of sources for personal information we collected; our business purpose for collecting that personal information; the categories of third parties with whom we share that personal information.

6.2 Your Right to Delete Information

Under the CCPA, You( or your authorized agent) have the right to opt out of having your information sold or shared.You (or your agent)have the right to request that we delete your specific personal information that we collected from you and retained, except in the following cases Such cases include:

* We need your information to detect security incidents, protect against malicious, or illegal activity;

* We need your information to identify and repair application errors that impair existing intended functionality; We need your information to exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

* We need your information to conduct internal uses that are reasonably aligned with your expectations based on your relationship with us;and other cases provided by CCPA and other California laws.

6.3 How You Exercise Your Rights

To exercise your rights described above, please submit a verifiable consumer request to us by support@healthapplines.com.

Only you or your authorized agent may make a verifiable consumer request related to your personal information. You may only make a verifiable consumer request for request for information twice within a 12-month period. A verifiable consumer request must:Provide sufficient information that allows us to reasonably verify you identity and make us confirm we collected personal information about you.Describe your request with sufficient details that allows us to understand and respond to it.

We cannot respond to your request accurately if we cannot verify your identity.

6.4 How We Respond Your Request

We endeavor to respond to a verifiable consumer request within 45 days of receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period by email ,telephone or other electronic means.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

6.5 Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Such discrimination include: denying you our services; charging you different prices or rates for our services; providing you a different level or quality of our services; suggesting that you may receive a different price or rate for services or a different level or quality of services.

6.6 Data collection instructions for minors

These Services do not address anyone under the age of 13. We do not knowingly collect personally identifiable information from children under 13. In the case we discover that a child under 13 has provided us with personal information, we immediately delete this from our servers. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us so that we will be able to do necessary actions. For users aged 13~16, they have the right to opt in, and if you are the parent or guardian of users who are aged 13~16, you can also contact us.

7. Children’s Privacy & Age Restriction

These Services cater to individuals aged 14 years and above. We do not knowingly collect personally identifiable information from children under 13. In the case we discover that a child under 13 has provided us with personal information, we immediately delete this from our servers. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us so that we will be able to do necessary actions.

8. Updates to the Privacy Policy

Any information that is collected is subject to the Policy in effect at the time such information is collected. We may, however, modify the Policy from time to time. If such change has been made, we will provide you additional forms of notice of modifications or updates as appropriate under the circumstances. Your continued use of our app or services following the change of the Policy will mean you accept those changes.

9. Contact details

We welcome your comments or questions regarding this Privacy Policy. Please email us at support@healthapplines.com