PRIVACY POLICY

1. Introduction

Genqi Tech Pte Ltd ("we", "us", or "our") is a company registered in Singapore. We are committed to protecting your personal data in compliance with the Personal Data Protection Act 2012 (PDPA) of Singapore.

This Privacy Policy explains how we collect, use, disclose, and protect your personal data when you use our website (genqi-tech.com) and our mobile applications, including HRV Flow.

2. Scope

This policy applies to:

• Our corporate website at genqi-tech.com
• Our mobile application HRV Flow (available on iOS and watchOS)
• Any services provided by Genqi Tech Pte Ltd

3. Data We Collect

3.1 Website — Contact Form

When you submit our contact form, we collect:

• Name (required)
• Email address (required)
• Company name (optional)
• Inquiry details (required)

3.2 HRV Flow Application

Health data accessed via Apple HealthKit:

• Heart Rate Variability (HRV)
• Heart rate
• Resting heart rate
• Sleep data
• Step count

Important: All health data remains stored exclusively on your device and in your personal iCloud account. We do not transmit health data to our servers or any third parties.

App usage data:

• Breathing exercise completion records
• Personal baseline calculations
• Schedule preferences
• Subscription status (managed by Apple)

3.3 Data We Do NOT Collect

We do not collect or store:

• Passwords or financial information
• Location data (GPS)
• Contacts or address book
• Photos or videos
• Biometric data beyond what is described above

3.4 Automatically Collected Data (Website)

When you visit our website, we may automatically collect:

• IP address
• Browser type and version
• Pages visited and time spent
• Referring website

4. Purpose of Collection

We collect and use personal data solely for the following purposes:

• Contact form data: To respond to your inquiries and provide customer support
• HRV Flow health data: To provide personalised stress analysis, baseline calculations, breathing exercise recommendations, and smart notifications on your device
• App usage data: To improve our application and your user experience
• Website analytics: To understand how our website is used and improve our services

We will not use your personal data for any purpose other than those stated above without obtaining your prior consent.

5. Consent

By using our website or applications, you consent to the collection, use, and disclosure of your personal data as described in this policy.

You may withdraw your consent at any time by:

• Contacting us at the email address listed below
• Deleting the HRV Flow application from your device (which removes all locally stored data)
• Revoking HealthKit permissions through your device settings

Please note that withdrawing consent may affect our ability to provide certain services to you.

6. Data Protection

We implement appropriate technical and organisational measures to protect your personal data, including:

• HRV Flow: All health data is stored locally on your device and encrypted by Apple's security framework. Data synced via iCloud is protected by Apple's encryption.
• Website: Contact form submissions are transmitted over HTTPS encryption.
• Access control: Only authorised personnel have access to personal data collected via our contact form.

7. Data Retention

• Contact form data: Retained for as long as necessary to fulfil the purpose for which it was collected, or as required by applicable law.
• HRV Flow data: Stored on your device and iCloud only. Data is permanently deleted when you delete the application.

We will cease to retain personal data when it is no longer necessary for any business or legal purpose.

8. Third-Party Disclosure

We do not sell, trade, or share your personal data with third parties, except:

• Apple Inc.: Subscription and payment processing is handled entirely by Apple through the App Store. We do not have access to your payment information.
• Legal requirements: We may disclose personal data if required by law, regulation, or legal proceedings in Singapore.

Any overseas transfer of personal data will be conducted in accordance with the PDPA's transfer limitation obligations, ensuring a comparable standard of protection.

9. Your Rights

Under the PDPA, you have the right to:

• Access: Request access to your personal data held by us.
• Correction: Request correction of any inaccurate or incomplete personal data.
• Withdrawal of consent: Withdraw your consent for the collection, use, or disclosure of your personal data.

To exercise any of these rights, please contact our Data Protection Officer using the details below. We will respond to your request within 30 days.

10. Data Breach Notification

In the event of a data breach that is likely to result in significant harm to affected individuals, we will:

• Notify the Personal Data Protection Commission (PDPC) as soon as practicable
• Notify affected individuals as soon as practicable
• Take immediate steps to contain and remediate the breach

11. Cookies

Our website may use cookies to enhance your browsing experience. Cookies are small text files stored on your device.

You can control or disable cookies through your browser settings. Disabling cookies may affect certain features of our website.

12. Children's Privacy

Our services are not directed at children under the age of 13. We do not knowingly collect personal data from children. If you believe we have inadvertently collected data from a child, please contact us immediately.

13. Changes to This Policy

We may update this Privacy Policy from time to time. Any changes will be posted on this page with an updated revision date.

We encourage you to review this policy periodically.

14. Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or our data protection practices, please contact our Data Protection Officer:

Genqi Tech Pte Ltd
Email: info@genqi-tech.com