Privacy Policy

What is the Privacy Policy?

The Privacy Policy establishes the principles that govern the collection, use, sharing, and processing of users’ personal information by Sure Life Health and its affiliated companies. It is applicable to websites and apps owned and operated by Sure Life Health, collectively referred to as “Services.”

This policy is relevant to personal data owned or under our control, encompassing data owned by organizations we employ to collect, use, share, or process data for our purposes. Compliance with state regulations on data management will be adhered to in the collection, use, sharing, or processing of personal data on behalf of the government or state agencies.

Users acknowledge that they have read and understood the policy, in conjunction with our Terms of Use. By utilizing the Services, users explicitly agree to these terms, establishing a contractual relationship between them and Sure Life Health. Users expressly permit us to collect, use, share, or process their personal data as outlined in this policy.

The policy addresses data collected from individuals, potential users, and authorized representatives of service users in accordance with current laws on personal data security. It is applicable to websites, apps, and services provided by Sure Life Health.

You confirm that you have read and comprehended this policy, as well as our Terms of Use. Through your use of the Services, you confirm your acceptance of our Terms of Use, and this acceptance constitutes a contractual agreement between you and us. You also acknowledge that you have provided explicit consent for us to collect, use, share, or process your personal data in accordance with this policy.

What data will we process?

In this Policy, the term ‘personal data’ refers to data, whether accurate or not, pertaining to an individual who can be identified: (a) from that data alone, or (b) from that data along with other information to which we have access or are likely to have access.

Based on the nature of your interactions with us and the services we offer, examples of personal data that we may gather from you encompass names, identification numbers (such as national identification numbers, passports, work permits, and birth certificates), contact details (such as residential address, email address, or phone number), nationality, age, gender, date of birth, marital status, medical records, images, and other audio-visual information, recruitment details, and financial information (such as credit card numbers, debit card numbers, or bank account information), as well as information about applications/browsers and device-related information.

Additionally, we may collect information from external sources such as partners, suppliers, and third parties. We ensure that these third parties possess the appropriate rights to collect, use, and share your information before providing it to us.

How we collect and use personal data?

We typically refrain from collecting your personal data unless (a) you provide it voluntarily either directly or through an authorized third party, after being informed of the purposes for data collection and providing consent, or (b) the collection without consent is permitted or required by current data protection laws. Additional personal data collection will be subject to your approval.

• We may utilize your personal data for the following purposes:
• Providing, enhancing, and developing current and new Services.
• Delivering personalized experiences, including displaying relevant advertisements.
• Managing inquiries, requests, registrations, complaints, and feedback.
• Sending administrative communications regarding our websites and Services.
• Sending secure electronic messages and personalized emails related to your inferred interests.
• Analyzing statistics on user trends, behaviors, and activities.
• Providing demographic characteristics and interests for more relevant content and advertising.
• Offering customer potential building services.
• Detecting and preventing fraud and other threats.
• Identifying issues with the Services.
• Conducting research and evaluation activities.
• Managing and verifying your accounts and identity.
• Transferring data to unrelated third parties to fulfill the mentioned purposes.
• Sending promotional information with your consent.
• Inviting you to participate in research based on your use of our Services.
• Complying with laws, regulations, and supporting law enforcement.
• Using information for any other purposes provided by you.
• Employing personal data for purposes not mentioned above with your consent.

The listed purposes may persist even after the termination or alteration of our relationship for a reasonable period unless you clearly withdraw your consent.

We may combine your personal information with data collected about your use of the Services and supplement it with external sources for the stated purposes. For instance, we may combine information for research and evaluation, generating aggregate reports for advertisers and business partners that do not identify individual users.

How personal data is shared?

We may disclose and share your personal data in the following circumstances:

• When such sharing is necessary for or related to providing the services you request.
• With partners, clients, third-party service providers, agents, suppliers, and other organizations used to fulfill the purposes listed in Section III above on our behalf.
• With any other party you have authorized us to share your personal data with or when necessary to fulfill actions requested by you.
• To our partners, clients, and third parties to enhance services and provide promotional information, including advertisements on our websites and/or third-party websites.
• With third parties you choose to connect with on our websites or users of our products and services.
• To our subsidiaries and affiliated companies within Sure Life Health, while adhering to this Policy.

The purposes mentioned above may persist even if the relationship between you and us is terminated or changed, for a reasonable period thereafter (including, if applicable, a period allowing us to enforce our rights under the contract with you), unless you explicitly notify us of your withdrawal of consent for the specified purposes.

Default Consent by Notice

We may collect, use, or share your personal data for secondary purposes, different from the original reasons for which the information was initially collected under this Policy. If we plan to rely on deemed consent through notice for such secondary purposes, we will notify you of the intended collection, use, or sharing of personal data through appropriate communication methods.

You will be given a reasonable period to inform us if you prefer not to participate in the collection, use, and sharing of your personal data for these additional purposes.

If you miss the deadline for opting out, you can still notify us afterward that you no longer consent to the purposes you had previously implicitly agreed to through notice. You can withdraw your consent to the collection, use, or sharing of your personal data related to those specific purposes.

How to withdraw your consent

Your consent for the collection, use, and sharing of your personal data will remain effective until you or your authorized representative withdraws it in writing. To withdraw consent and request the cessation of collecting, using, and/or sharing your personal data for any or all of the purposes listed above, you or your authorized representative can send a written request via email or other means to our Data Protection Officer using the contact details provided below. If you encounter difficulty in submitting your request in writing or require assistance, you may request to speak or meet with our Data Protection Officer.

Upon receiving a written request to withdraw your consent, we may need a reasonable amount of time (depending on the complexity of the request and its impact on our relationship with you) to process the request and inform you of any consequences, including potential legal implications affecting your rights and obligations towards us. Typically, we aim to process your request within thirty (30) days from the date of receiving it.

While we respect your decision to withdraw consent, it’s important to note that depending on the nature and scope of your request, we may be unable to continue providing our goods or services to you. In such cases, we will notify you before finalizing the processing of your request. If you choose to cancel your withdrawal of consent, please inform us as described above.

Please be aware that the withdrawal of your consent does not affect our right to continue collecting, using, and sharing personal data when such actions without consent are permitted or required by applicable law.

How to access and edit personal data

If you wish to exercise (a) access requests to obtain a copy of the personal data we hold about you or information on how we use or share your personal data, or (b) correction requests to amend or update any of your personal data that we hold about you, you can submit your request via email or in writing to our Data Protection Officer using the contact details provided below. If you require assistance in submitting your request, you may request to speak or meet with our Data Protection Officer.

Please be aware that a reasonable fee may be charged for an access request, and in such cases, we will inform you of the fee before processing your request.

We will strive to respond to your request as promptly as possible, typically within two (2) business days. If we are unable to respond within thirty (30) days of receiving your request, we will notify you in writing within that time frame, providing an estimated timeline for fulfilling your request. If we cannot provide you with the requested personal data or make corrections as per your request, we will inform you of the reasons for our inability to do so (unless not required by applicable law).

Furthermore, you have the option to edit, update, or review the personal information you provided to us by returning to the specific service, logging in, and making the desired changes. You can also update any personal information through the contact information provided below or via the links in the “Contact” section at the bottom of each page on our website.

For those who have registered to receive email notifications for our services, including newsletters, or at any time, you can choose not to receive further newsletters or other email notifications from us or our advertisers and sponsors.

If you have questions, concerns, or complaints regarding the handling of your personal data or wish to exercise your rights, please contact our Data Protection Officer.

How personal data is protected

To secure your personal data against unauthorized access, collection, use, sharing, copying, alteration, illicit processing, or similar risks, we have implemented practical and reasonable management and technical measures. These measures include minimizing the collection of personal data, employing authentication and access controls (e.g., strong password concepts, data sharing only when necessary, etc.), utilizing data encryption, anonymizing data, updating virus protection features, regularly patching operating systems and other software, securely disposing of storage media before discarding, implementing web security measures against risks, and using additional security measures such as one-time passwords (OTP), two-factor authentication (2FA), and multi-factor authentication (MFA) for secure access. We also conduct regular security assessments and audits.

When you input personal information, including personal health information in various services, we encrypt the transmission of that information or use SSL (Secure Socket Layer) technology.

It’s important to note that while we have taken these precautions, no transmission method over the Internet or electronic storage method can guarantee absolute security. Despite our efforts, there is always a risk that an unauthorized third party may find a way to breach our security systems or intercept the transmission of your information over the Internet. If you lose control of your account or become aware that your device has been compromised, please notify us as soon as possible. Additionally, please take responsibility for the security of your passwords and account information.