Privacy policy

Last Updated on 25.04.2023  

AGE IN REVERSE PTE. LTD. (the “Company”, “we,” “us,” “our”) take our responsibilities under Singapore’s Personal Data Protection Act 2012, any regulations thereunder, and any guidelines that may be issued from time to time by the Personal Data Protection Commission (collectively referred to as the “PDPA”) very seriously.

The purpose of this document (“Policy”) is to assist you in understanding how we collect, use, disclose and/or process the personal data you have provided to us, as well as to assist you in making an informed decision before providing us with any of your personal data.

Please read this Policy carefully to understand how we may collect, use and disclose your personal data on our Application or otherwise in the course of our normal business operations.  

This Policy is intended to be read with the Terms of Use. This Policy uses terms defined in the Terms of Use.  

  1. Consent

By accessing the Application and/or providing personal data to us, you acknowledge that you have read this Policy and that you consent to the collection, use and disclosure of your personal data by the Company in accordance with this Policy as amended or updated from time to time. If you do not consent to the terms of this Policy (or variation thereof), please do not access the Application or provide your personal data to the Company.

We reserve the right, at our sole discretion, to change any parts of this Policy at any time for any reason.  

You should periodically visit this page to review the current Policy terms so that you are aware of any changes to which you are bound. If we make any changes to this Policy, we will either post the changes to this Policy on the Application and update the “Last Updated” date at the top of this Policy or notify you of such variation by email at the email address you used to register as a User. Changes will take effect no less than seven (7) days after such notice was provided on any of the above-mentioned methods. Your continued use of the Application after any such variation constitutes your acceptance of the latest terms of the Policy.

If you provide personal data on behalf of someone else, you warrant that you have obtained the written authorisation from that person to provide such personal data on his/her behalf and you agree to indemnify and hold harmless the Company from any claim that such authority did not exist. If your account is registered by someone else on your behalf and by using the Application through your account, you are deemed to have agreed to the terms of this Policy.

  1. Unsolicited Information and Exclusions

This Policy shall not apply to any unsolicited information you provide to the Company.  

We do not knowingly collect or solicit personal data from those below the age of 18 (or the applicable legal age in your location) (a “minor”), or knowingly allow such persons to register an account. If you are a minor, please do not use the Application, or attempt to register an account or send any personal data about yourself to us. If we discover that a minor has submitted personal data to us, we will delete such information as soon as we become aware of the source of the submission (unless we are required to retain information, and if so, we will retain only that information that we are required to retain).  

Access to and use of the Application and/or our services may be limited in scope to certain geographical territories. If our services are not available in the country in which you reside, please do not use the Application, or attempt to register an account or send any personal data about yourself to us.

  1. What is personal data?

“Personal data” means data about a person who can be identified (i) from that data, or (ii) from that data and other information to which the Company has or is likely to have access.

  1. How do we collect your personal data, and what personal data do we collect?

We collect and use the following types of personal data of our Users:

  1. Personal data you provide us when you use the Services. Generally, this category refers to any information, data or content you actively and voluntarily create or provide through our Services such as:

  1. Contact information such as your name, email and physical addresses, or telephone number that you provide through the Services when you fill our online form or register for an account with us or when you update your account details.

  1. Information you provide during a transaction you perform through the Services, or other transaction-based content that you generate related to such transaction.

  1. Any personal data in any Self-Provided Information.

  1. Any personal data in any User Generated Content which you share on the Application, whether to other Users or to us.

  1. Health Information and any other information you provide us in the scope of your use of the Services, including by linking your fitness trackers and information provided by you in respect of your diet, exercise routine, emotional and mental state, perceived sense of viability, as well as ongoing feedback that you provide us regarding your satisfaction from the diet and exercise.

  1. The contents of your interaction with our customer support or sales departments, which may include text/video/audio recording and transcripts of such communications including information you enter in our “Contact Us” online form or any similar input.

  1. Financial information (such as credit card or bank account numbers) that you provide us in the scope of transactions you make through the Services, which is processed by our third-party services providers to which we have no access.

  1. Shipping, delivery, postage, billing and other information used to transact and deliver through the Services, as well as, where applicable, information required to clear customs.

  1. Personal data shared with us by third parties which process your genetic data. As described in Terms of Use, we procure third party providers to provide you genetic test kits, and for your biological samples to be processed and analysed by third party providers. Your biological sample is mailed to the third-party provider lab directly and once processed, we receive the analysis of the biological sample from the third-party provider. We will upload the analysis onto your User account. As mentioned in the Terms of Use, the third-party providers have their own terms of use and privacy policies which we cannot control. Please review the terms of use and privacy policy of the third-party providers before sending your biological samples to them.  

  1. Personal data we collect automatically when you use our Services. The Company collects data that is sent automatically by your mobile or tablet device. This may include your IP address, the address of the web page you were visiting when you accessed our Site, date and time of your visit, information about the device you are using and other information. Please check the settings of your device if you want to know what data is automatically sent or if you wish to change your settings. Please also refer to the section on “Use of Cookies” below.

  1. Personal data collected from third parties. When using the Services, you may choose to connect your account with certain other third-party accounts you hold with such third-party applications and platforms (such as Apple Health Kit, Google Fit, Android Health Connect, Fitbit, Oura, Garmin etc.) and thereby to provide us with access to information available on such accounts. To the extent that information is linked or connected to your identity, we will treat that information as your personal data.

  1. Social Media. We may provide you a direct linkage to allow you to share information with social platforms or use social platforms to create your User account or to connect your User account with the respective social platforms. Those social platforms may give us automatic access to certain personal data retained by them about you (e.g., content viewed by you, content liked by you, your public profile other profiles you are associated with, and information about the advertisements you have been shown or have clicked on, etc.). You control the personal data you allow us to have access to through the privacy settings on the applicable social platforms and the permissions you give us when you grant us access to the personal data retained by the respective social platforms about you.  

  1. How do we use your personal data?

Generally, we collect personal data in order to provide our Services to you, and to personalize and improve our Services and your experience with us.  

We may use your personal data for the following purposes:

(a) to provide you with the Services;

(b) to contact you for feedback about our Services;

(c) to conduct research about our customer base;

(d) to inform you of promotions, offers, surveys, events, products and services, which may be of interest to you;

(e) to process your payments including credit cheques and collection;

(f) to notify you of technical updates or changes in Policy;

(g) to update and back-up our records;

(h) to reduce credit risk, detect and protect us against error, fraud and other criminal activity;

(i) to comply with law, the requests of law enforcement and regulatory officials, or orders of court;

(j) to enforce our legal rights and remedies; or

(k) for such other purposes notified to you on or before collection or use of the data.

​

  1. Legal basis of the collection, use and disclosure of your data

We collect, use and disclose your personal data, which is adequate, relevant and limited to what is necessary in relation to the purposes described in this Privacy Policy, based at least on one of the following legal grounds:

  1. In the performance of our contractual obligations: We collect and process your Personal Information in order to provide you with the Services.

  1. With your consent: We obtain your consent for the collection, use and disclosure of your personal data including specifically any Genetic Information for the purposes set forth in this Policy and you have the right to withdraw your consent at any time.  

  1. Legitimate interest: We use process your personal data for our legitimate interests while applying appropriate safeguards that protect your privacy. This means that we process your information for things like detecting, preventing, or otherwise addressing fraud, abuse, security, usability, functionality or technical issues with our Services, protecting against harm to the rights, property or safety of our properties, or our Users, or the public as required or permitted by law; enforcing legal claims, including investigation of potential violations of this Policy; defending legal claim made by you or on your behalf against us, in order to comply and/or fulfil our obligation under applicable laws, regulation, guidelines, industry standards and contractual requirements, legal process, subpoena or governmental request, as well as our Terms of Use.

  1. Who do we disclose your personal data to?

We do not trade or sell your personal data.  

The Company may disclose your personal data (other than User Generated Content) only to:

  1. to any affiliate, subsidiary or partner of the Company;  

  1. to our technology, marketing and logistics service providers; credit card and payment processing companies; lawyers, auditors, professional advisors and investors of the Company;  

  1. agents, service providers or subcontractors acting for or on behalf of the Company, to the extent required to carry out the purposes set out in Section 5 above, or to do anything at your request; or

  1. where you expressly request or consent to such disclosure; or

  1. where such disclosure is required or permitted by applicable law, statute, stock exchange regulation or by-law, regulatory or governmental order or court order; or

  1. in the event of a corporate sale, merger, reorganization, dissolution or similar event, personal data may be part of the transferred assets;

Recipients of your personal data may be located outside Singapore. You agree that we may transfer your personal data to our affiliates, subsidiaries and/or other third parties located outside of Singapore, as long as the personal data is handled in accordance with this Policy and all applicable laws.  

We will ensure recipients of your personal data are legally bound to provide a standard of protection for your personal data comparable to the protection afforded under the PDPA.  

  1. How long do we retain your personal data?

Personal data will be retained as long as the purpose for which the data was collected continues. Thereafter, we will destroy or delete the information, or remove the means by which the data can be associated with you, unless its retention is required to satisfy legal, regulatory, accounting or other business requirements or to protect our interests.

  1. Storage of your data

Information regarding the Users will be maintained, processed and stored by us and our authorized affiliates and service providers in Singapore in secured cloud storage provided by our third-party cloud service providers.  

Each of our third party service providers who stores or processes your personal data either: (i) assured us that it provides adequate safeguards to protect your rights to privacy, (ii) holds and processes such information on our behalf in a jurisdiction which has been determined to ensure an adequate level protection by the EU Commission, or (iii) if in the US, is certified under the EU-US Privacy shield framework or is otherwise qualified under the European Commission’s laws to process such information within a jurisdiction that has not been deemed to have adequate level protection. By providing your information, you expressly consent to the place of storage and transfer described above, including transfers outside of the jurisdiction in which the information was provided.  

  1. Security of Data

Your account is protected by your password for your privacy and security. We ask that you take steps to protect against unauthorised access or use of your account. You are responsible for any loss, theft and compromise of your password and account information, and any activity on your account that takes place through unauthorised password use.

We understand the importance of keeping your personal data private and secure. We therefore put in place security arrangements and various physical, technical, and administrative measures to protect your privacy and personal data, in a manner that we believe is reasonably appropriate to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks. Please be informed that despite our best efforts, no security arrangements or other measures are impenetrable. Unauthorised entry or use, hardware or software failure, and other factors, may compromise the security of your personal data. We do not warrant or guarantee in any way that your personal information or private communications will always remain private and/or safe. We hereby disclaim any responsibility or liability directly or indirectly arising out of or in connection with, any loss, theft, or unauthorised access, collection, use, disclosure, copying, modification, disposal or similar actions with regard to any personal data held or maintained by us, except to the extent caused by our fault or negligence.

  1. Linked Sites

We may provide links to other sites ("Linked Sites") that may be of relevance and interest to you. We have no control over, and are not responsible for the privacy practices or the content of such Linked Sites, and you hereby waive any claim against us with respect to the Linked Sites. This Policy applies only to the Application and our Services only, and does not apply to information you provide directly to any other parties via such Linked Sites. Having the Linked Sites on the Application do not imply that we endorse or have reviewed the Linked Sites. We suggest you to contact those Linked Sites directly for information on their privacy policies before providing any of your personal data.

  1. Use of Cookies

In order to improve our products and services, we collect data by way of “cookies”. Cookies help us measure the number of visits, average time spent, page views and other statistics relating to your access to the Application. This information allows us to better administer the Application, and provide a more tailored and user-friendly service to our Application’ visitors and users. Cookies are small data files that are sent to your browser from our Application and are stored on your computer’s or device’s hard drive. Each time you visit our Application from the same device, the cookie will be retrieved from your device, enabling our Application to recognise your device as having previously visited our Application and thereby increase the functionality of our Application on your device. Our cookies cannot be used to get data from your hard drive, to get your email address or any other data that can be traced to you personally. Most web browsers and devices can be set to notify you when you receive a cookie or to prevent cookies from being sent; if you use these features, you may limit the functionality we can provide you when you visit our Application.

  1. How to access and correct your data?

If you wish to access, correct or update your personal data, you may do so at any time by accessing your account settings through the Application. Alternatively, you may contact us at data@ageinreveres.me. You are responsible for providing us with correct and updated information.

  1. What rights do you have?

If the law applicable to you grants you such rights, you may ask to access, correct, or delete your Personal Information that is stored in our systems or that we otherwise control. You may also ask for our confirmation as to whether or not we process your Personal Information or ask to withdraw any consent you have previously provided to us in connection with our use and processing of your Personal Information. Exercising such rights of deletion and/or withdrawing such consent may result in our inability to provide you with the Services or any part thereof. In such event, we may notify you of termination of your access to Services. Subject to the limitations in law, you may request that we update, correct, or delete inaccurate or outdated information. You may also request that we suspend the use of any personal data the accuracy of which you contest while we verify the status of that data. Subject to the limitations in law, you may also be entitled to obtain the personal data you directly provided us in a structured, commonly used, and machine-readable format and may have the right to transmit such data to another party. If you wish to exercise any of these rights or withdraw your consent, please contact us at [insert email address]. When handling these requests, we may ask for additional information to confirm your identity and your request. Please note, upon request to delete your Personal Information, we may retain such data in whole or in part to comply with any applicable rule or regulation and/or response or defend against legal proceedings versus us or our affiliates, or as we are otherwise permitted under such law applicable to you.  

Data protection rights vary from jurisdiction to jurisdiction. Please check with your local lawyers whether these rights apply to you, the applicable timelines for any request to exercise such rights, and whether we are permitted to charge any fees for complying with any request to exercise such rights.  

  1. How do you close your account?

You may request deletion of your account by sending an email to delete@ageinreverse.me. If you close your account, unless otherwise required by law, we delete all of your Genetic Information within thirty (30) days of when we receive your removal request. Please also reach out to the third-party service provider (which performed the Genetic Testing) to request for their deletion of your Genetic Information. Please note that some information may remain in our private records after deletion of your account. We may continue to use any anonymised aggregated data derived from or incorporating your personal data.

If you do not wish to receive email or other communications from us, you can unsubscribe from our mailing list by using the unsubscribe facility that may be provided with such email or communication, or contact us at welcome@ageinreverse.me.

  1. Questions or Concerns

Please direct any questions or concerns that you may have regarding our handling of your personal data to:

Attention: The Data Protection Officer

Email: data@ageinreverse.me

Please provide your name, contact number, email address and all relevant details along with your question or concern, so that we can review and respond to your question or concern in an efficient and effective manner.

  1. Governing Law

Irrespective of the country from which you access or use our Services and/or Application, to the extent permitted by law, this Policy is governed by and shall be construed in accordance with Singapore law without giving effect to any principles of conflicts of law.  

In the event of any dispute or difference arising out of or in connection with or in relation to these Terms, including any question regarding the existence, validity, application or interpretation of these Terms or any of its provisions, both parties shall endeavour to settle the dispute informally by agreement between the parties.  Both parties shall always act in good faith and co-operate with each other to resolve any disputes.  

If the parties are unable to resolve the dispute within 60 days, the dispute shall be referred to and finally resolved by arbitration in Singapore in the English language, conducted in private in accordance with the Arbitration Rules of the Singapore International Arbitration Centre (the “SIAC”) for the time being in force which rules are deemed to be incorporated by reference to this clause.  The arbitration shall be conducted before 1 arbitrator. If the parties are unable to agree on an arbitrator, the arbitrator shall be appointed by the President of the SIAC in accordance with the SIAC Rules.  Each party shall bear its own costs in connection with the arbitration proceedings.