Privacy Policy
Privacy Policy
W3LL — PRIVACY POLICY
Provided by Universal Health Pte. Ltd. ("we", "us", or "our")
Effective 1 August 2026
This Privacy Policy ("Policy") sets out the basis on which we may collect, use, disclose or otherwise process personal data of W3LL users ("customers") in accordance with the Personal Data Protection Act ("PDPA"). This Policy applies to personal data in our possession or under our control, including personal data in the possession of organisations we have engaged to collect, use, disclose or process personal data for our purposes.
Personal Data
1. As used in this Policy, "customer" means an individual who (a) has contacted us through any means to find out more about W3LL, or (b) may, or has, entered into a contract with us for the supply of W3LL or related services; and "personal data" means data, whether true or not, about a customer who can be identified (a) from that data, or (b) from that data and other information to which we have or are likely to have access.
2. Depending on the nature of your interaction with W3LL, examples of personal data we may collect from you include, but are not limited to: name, email address, age, occupation, activity, screen time, GPS location, heart rate, skin tone, voice modulation, facial blood flow, and others. This may also include health-related information you choose to share with us through Apple HealthKit or Google Health Connect, such as activity, fitness, sleep, cycle, or wellbeing data. Such data will only be collected with your explicit consent and will never be used for marketing, advertising, or data-mining purposes.
3. Other terms used in this Policy shall have the meanings given to them in the PDPA (where the context so permits).
Collection, Use and Disclosure of Personal Data
4. We generally do not collect your personal data unless (a) it is provided to us voluntarily by you directly, or via a third party who has been duly authorised by you to disclose your personal data to us (your "authorised representative"), after (i) you (or your authorised representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorised representative) have provided written consent to the collection and usage of your personal data for those purposes; or (b) collection and use of personal data without consent is permitted or required by the PDPA or other laws. This includes health-related data you choose to share with us through Apple HealthKit or Google Health Connect. Such data will only be collected and used with your explicit consent, and solely for the purposes notified to you. We will not use HealthKit or Health Connect data for any form of advertising or data-mining, and we will not sell such data to third parties. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorised by law).
5. We may collect and use your personal data for any or all of the following purposes:
a. performing our obligations in the course of or in connection with our provision of goods and/or services to you;
b. transmitting your data to unaffiliated third parties, including our third-party service providers and agents, and relevant governmental or regulatory authorities, whether in Singapore or abroad, for the purposes above;
c. any other incidental business purposes related to or in connection with the above; and
d. collecting, using, and analysing health-related data from Apple HealthKit or Google Health Connect (where you have chosen to enable sharing) to provide insights, recommendations, and services aimed at supporting your wellbeing, health management, or related functionality within W3LL, always subject to your explicit consent.
6. We may disclose your personal data:
a. where such disclosure is required for performing our obligations in the course of or in connection with our provision of goods and/or services to you;
b. to third-party service providers, agents and other organisations we have engaged to perform any of the functions relating to the purposes above; and
c. for the avoidance of doubt, HealthKit and Google Health Connect data will not be disclosed to any third parties for advertising, marketing, or other data-mining purposes. Such data may only be shared with third-party service providers strictly to support the provision of health-related features within W3LL, subject to your prior consent, and will not be stored in iCloud, Google servers, or other external storage services unless encrypted and compliant with the relevant platform's requirements.
Withdrawing Your Consent
7. The consent that you provide for the collection, use and disclosure of your personal data will remain valid until it is withdrawn by you in writing. You may withdraw consent and request us to stop collecting, using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email. For HealthKit and Google Health Connect data, you may also withdraw consent at any time directly through your device's Health app (iOS) or Health Connect settings (Android).
8. Upon receipt of your written request to withdraw consent, we may require reasonable time, depending on the complexity of the request and its impact on our relationship with you, to process it and to notify you of the consequences, including any legal consequences which may affect your rights and liabilities to us. In general, we will seek to process your request within five (5) business days of receiving it.
9. While we respect your decision to withdraw consent, please note that depending on the nature and scope of your request, we may not be able to continue providing our goods and/or services to you, and we will notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing as described in clause 7.
10. Withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclosure without consent is permitted or required under applicable law.
Access to and Correction of Personal Data
11. If you wish to make (a) an access request for a copy of the personal data we hold about you, or information about how we use or disclose it, or (b) a correction request to correct or update any personal data we hold about you, you may submit your request in writing or via email.
12. A reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.
13. We will respond to your request as soon as reasonably possible, generally within five (5) business days. If we are unable to respond within thirty (30) days of receiving your request, we will inform you in writing within that thirty (30) day period of the time by which we expect to respond. If we are unable to provide the personal data or make the correction requested, we will generally inform you of the reasons why, except where we are not required to do so under the PDPA.
Deletion of Personal Data
14. If you wish to request the deletion of your personal data, you may submit your request in writing or via email at the contact details in clause 22, or, where available, through the in-app account deletion feature. Upon verifying your request, we will delete or anonymise your personal data within a reasonable period. We may retain some or all of your personal data where retention is required or permitted by applicable law, for example to comply with a legal obligation, resolve a dispute, or enforce our agreements. Where we are unable to fully delete your data, we will inform you of the reasons why.
Protection of Personal Data
15. To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures, including but not limited to: minimised collection of personal data, authentication and access controls (including good password practices and need-to-know access to data), encryption of data, data anonymisation, up-to-date antivirus protection, regular patching of operating systems and other software, secure erasure of storage media before disposal, web security measures, and use of One-Time Password (OTP), Two-Factor Authentication (2FA), or Multi-Factor Authentication (MFA) to secure access. We conduct regular security review and testing.
16. You should be aware that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and continually review and enhance our information security measures.
Data Breach Notification
17. In the event of a data breach that we assess as likely to result in significant harm to affected individuals, or that is of a significant scale, we will notify the Personal Data Protection Commission (PDPC) as soon as practicable, and in any event within the timeframe prescribed under the PDPA. Where required, we will also notify affected individuals as soon as practicable.
Accuracy of Personal Data
18. We generally rely on personal data provided by you (or your authorised representative). To ensure your personal data is current, complete and accurate, please update us of any changes by informing us in writing or via email at the contact details below.
Retention of Personal Data
19. We may retain your personal data for as long as necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable law.
20. We will cease to retain your personal data, or remove the means by which it can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which it was collected and is no longer necessary for legal or business purposes.
Transfers of Personal Data Outside of Singapore
21. We generally do not transfer your personal data to countries outside Singapore. If we do, we will obtain your consent for the transfer and take steps to ensure your personal data continues to receive a standard of protection at least comparable to that under the PDPA.
Contact Details
22. You may contact us with any enquiries or feedback on our personal data protection policies and procedures, or to make any request, at:
Contact No.: +65 8932 9492
Email Address: hello@W3LL.app
Effect of Policy and Changes to Policy
23. This Policy applies in conjunction with any other notices, contractual clauses and consent clauses that apply to our collection, use and disclosure of your personal data.
24. We may revise this Policy from time to time without prior notice. You may determine if a revision has taken place by referring to the date on which this Policy was last updated. Your continued use of W3LL constitutes your acknowledgement and acceptance of such changes.
Effective date: 1 October 2025
Last updated: 1 August 2026
Provided by Universal Health Pte. Ltd. ("we", "us", or "our")
Effective 1 August 2026
This Privacy Policy ("Policy") sets out the basis on which we may collect, use, disclose or otherwise process personal data of W3LL users ("customers") in accordance with the Personal Data Protection Act ("PDPA"). This Policy applies to personal data in our possession or under our control, including personal data in the possession of organisations we have engaged to collect, use, disclose or process personal data for our purposes.
Personal Data
1. As used in this Policy, "customer" means an individual who (a) has contacted us through any means to find out more about W3LL, or (b) may, or has, entered into a contract with us for the supply of W3LL or related services; and "personal data" means data, whether true or not, about a customer who can be identified (a) from that data, or (b) from that data and other information to which we have or are likely to have access.
2. Depending on the nature of your interaction with W3LL, examples of personal data we may collect from you include, but are not limited to: name, email address, age, occupation, activity, screen time, GPS location, heart rate, skin tone, voice modulation, facial blood flow, and others. This may also include health-related information you choose to share with us through Apple HealthKit or Google Health Connect, such as activity, fitness, sleep, cycle, or wellbeing data. Such data will only be collected with your explicit consent and will never be used for marketing, advertising, or data-mining purposes.
3. Other terms used in this Policy shall have the meanings given to them in the PDPA (where the context so permits).
Collection, Use and Disclosure of Personal Data
4. We generally do not collect your personal data unless (a) it is provided to us voluntarily by you directly, or via a third party who has been duly authorised by you to disclose your personal data to us (your "authorised representative"), after (i) you (or your authorised representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorised representative) have provided written consent to the collection and usage of your personal data for those purposes; or (b) collection and use of personal data without consent is permitted or required by the PDPA or other laws. This includes health-related data you choose to share with us through Apple HealthKit or Google Health Connect. Such data will only be collected and used with your explicit consent, and solely for the purposes notified to you. We will not use HealthKit or Health Connect data for any form of advertising or data-mining, and we will not sell such data to third parties. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorised by law).
5. We may collect and use your personal data for any or all of the following purposes:
a. performing our obligations in the course of or in connection with our provision of goods and/or services to you;
b. transmitting your data to unaffiliated third parties, including our third-party service providers and agents, and relevant governmental or regulatory authorities, whether in Singapore or abroad, for the purposes above;
c. any other incidental business purposes related to or in connection with the above; and
d. collecting, using, and analysing health-related data from Apple HealthKit or Google Health Connect (where you have chosen to enable sharing) to provide insights, recommendations, and services aimed at supporting your wellbeing, health management, or related functionality within W3LL, always subject to your explicit consent.
6. We may disclose your personal data:
a. where such disclosure is required for performing our obligations in the course of or in connection with our provision of goods and/or services to you;
b. to third-party service providers, agents and other organisations we have engaged to perform any of the functions relating to the purposes above; and
c. for the avoidance of doubt, HealthKit and Google Health Connect data will not be disclosed to any third parties for advertising, marketing, or other data-mining purposes. Such data may only be shared with third-party service providers strictly to support the provision of health-related features within W3LL, subject to your prior consent, and will not be stored in iCloud, Google servers, or other external storage services unless encrypted and compliant with the relevant platform's requirements.
Withdrawing Your Consent
7. The consent that you provide for the collection, use and disclosure of your personal data will remain valid until it is withdrawn by you in writing. You may withdraw consent and request us to stop collecting, using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email. For HealthKit and Google Health Connect data, you may also withdraw consent at any time directly through your device's Health app (iOS) or Health Connect settings (Android).
8. Upon receipt of your written request to withdraw consent, we may require reasonable time, depending on the complexity of the request and its impact on our relationship with you, to process it and to notify you of the consequences, including any legal consequences which may affect your rights and liabilities to us. In general, we will seek to process your request within five (5) business days of receiving it.
9. While we respect your decision to withdraw consent, please note that depending on the nature and scope of your request, we may not be able to continue providing our goods and/or services to you, and we will notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing as described in clause 7.
10. Withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclosure without consent is permitted or required under applicable law.
Access to and Correction of Personal Data
11. If you wish to make (a) an access request for a copy of the personal data we hold about you, or information about how we use or disclose it, or (b) a correction request to correct or update any personal data we hold about you, you may submit your request in writing or via email.
12. A reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.
13. We will respond to your request as soon as reasonably possible, generally within five (5) business days. If we are unable to respond within thirty (30) days of receiving your request, we will inform you in writing within that thirty (30) day period of the time by which we expect to respond. If we are unable to provide the personal data or make the correction requested, we will generally inform you of the reasons why, except where we are not required to do so under the PDPA.
Deletion of Personal Data
14. If you wish to request the deletion of your personal data, you may submit your request in writing or via email at the contact details in clause 22, or, where available, through the in-app account deletion feature. Upon verifying your request, we will delete or anonymise your personal data within a reasonable period. We may retain some or all of your personal data where retention is required or permitted by applicable law, for example to comply with a legal obligation, resolve a dispute, or enforce our agreements. Where we are unable to fully delete your data, we will inform you of the reasons why.
Protection of Personal Data
15. To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures, including but not limited to: minimised collection of personal data, authentication and access controls (including good password practices and need-to-know access to data), encryption of data, data anonymisation, up-to-date antivirus protection, regular patching of operating systems and other software, secure erasure of storage media before disposal, web security measures, and use of One-Time Password (OTP), Two-Factor Authentication (2FA), or Multi-Factor Authentication (MFA) to secure access. We conduct regular security review and testing.
16. You should be aware that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and continually review and enhance our information security measures.
Data Breach Notification
17. In the event of a data breach that we assess as likely to result in significant harm to affected individuals, or that is of a significant scale, we will notify the Personal Data Protection Commission (PDPC) as soon as practicable, and in any event within the timeframe prescribed under the PDPA. Where required, we will also notify affected individuals as soon as practicable.
Accuracy of Personal Data
18. We generally rely on personal data provided by you (or your authorised representative). To ensure your personal data is current, complete and accurate, please update us of any changes by informing us in writing or via email at the contact details below.
Retention of Personal Data
19. We may retain your personal data for as long as necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable law.
20. We will cease to retain your personal data, or remove the means by which it can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which it was collected and is no longer necessary for legal or business purposes.
Transfers of Personal Data Outside of Singapore
21. We generally do not transfer your personal data to countries outside Singapore. If we do, we will obtain your consent for the transfer and take steps to ensure your personal data continues to receive a standard of protection at least comparable to that under the PDPA.
Contact Details
22. You may contact us with any enquiries or feedback on our personal data protection policies and procedures, or to make any request, at:
Contact No.: +65 8932 9492
Email Address: hello@W3LL.app
Effect of Policy and Changes to Policy
23. This Policy applies in conjunction with any other notices, contractual clauses and consent clauses that apply to our collection, use and disclosure of your personal data.
24. We may revise this Policy from time to time without prior notice. You may determine if a revision has taken place by referring to the date on which this Policy was last updated. Your continued use of W3LL constitutes your acknowledgement and acceptance of such changes.
Effective date: 1 October 2025
Last updated: 1 August 2026