Privacy & Acceptable Use Policy

Bravely Home is a mobile application designed to help individuals navigate their mental health & wellness journey, whether independently or alongside their therapists. We recognise the sensitive nature of the data shared and are deeply committed to ensuring its privacy and security.

SCHEDULE 1
PRIVACY POLICY

BRAVELY TECH PTE. LTD. (“we” or “us”) is committed to protecting and respecting your privacy.

1. This policy (together with our main Terms of Use and any other documents referred to on it) sets out the basis on which any personal data (the “Data”) we collect from you, or that you upload, will be processed by us. Please read the following carefully to understand our views and practices regarding your Data and how we will treat it.

2. By providing your Data to us, you consent to the collection, use, disclosure and transfer of your Data in the manner and for the purposes set out below.

INFORMATION WE MAY COLLECT

1. We may collect and process the following data:

   (a) information that you provide by filling in forms on Bravely (“our Platform”), including information provided at the time of registering to use our Platform, subscribing to any services provided by us, posting material, reporting a problem with our Platform, or requesting further services;

   (b) information relating to your use or purchase of any of the services or products provided on our Platform;

   (c) information that you have authorised a third party to release to us, including your instructor, school or student;

   (d) responses entered through the mood or "Track" features, text, documents or images that you upload onto our Platform,

   (i) any therapeutic data or records shared between therapists and clients, which remain strictly confidential and are not used for any other purposes beyond the intended therapeutic engagement,

   (e) details of transactions you carry out through our Platform;

   (f) details of your visits to our Platform and the resources that you access;

   (g) if you contact us, a record of that correspondence; and

   (h) responses to surveys that we send to you, although you do not have to respond to them,

   (i) data that you opt-in to sharing with your therapist.

IP ADDRESSES

1. We may also collect and process information about your device, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.

COOKIES

1. Our website uses cookies to distinguish you from other users of our Services. This helps us to provide you with a good experience when using our Platform or Services and also allows us to improve upon them.

WHERE WE STORE YOUR DATA

1. The Data that we collect from you may be transferred to, and stored at, a destination outside Singapore. It may also be processed by staff operating outside Singapore who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your services ordered by you, the processing of your payment details and the provision of support services. By submitting the Data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your Data is treated securely and in accordance with this privacy policy.

2. All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Platform, you are responsible for keeping this password confidential. We ask you not to share the password with anyone.

3. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Data, we cannot guarantee the security of your Data transmitted to our Platform; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

USES MADE OF THE INFORMATION

1. We use information held in the following manner:

   (a) to ensure that content from our Platform is presented in the most effective manner for you and your device;

   (b) to provide you with information, products or services that you request from us, and to otherwise carry out our obligations arising from any contracts entered into between you and us;

   (c) to provide you with information, products or services which we feel may interest you, where you have consented to be contacted for such purposes;

   (d) to allow you to participate in interactive features of our service, when you choose to do so;

   (e) to notify you about changes to our services;

   (f) to investigate any complaints relating to the use of our Platform or any suspected unlawful activities; and

   (g) for the purposes of data analytics, conducted on our behalf by third party vendors.

DISCLOSURE OF YOUR INFORMATION

1. We may disclose your Data to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in the Companies Act (Cap. 50).

2. We may disclose your Data to third parties:

   (a) for the purposes of providing products or services that you request from us, fulfilling our obligations arising from any contracts entered into between you and us, processing payments in connection therewith or otherwise in connection with your use of our Platform;

   (b) in the event that we sell or buy any business or assets, in which case we may disclose your Data to the prospective seller or buyer of such business or assets;

   (c) if we or substantially all of our shares or assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets; or

   (d) where a third party claims that any content posted or uploaded by you to our Platform constitutes a violation of their rights under Singapore law, in which case we may disclose your identity to that third party.

   (e) We may also disclose your data to a governmental or regulatory body, law enforcement, or other authorities, in order to enforce our terms of use for our Platform or to cooperate with any direction, request or order from such parties.

CONSENT

1. By providing your Data to us, you consent to the collection, use and disclosure of your Data by us for the purposes set out in this privacy policy (“Purposes”).

2. Where any Data relates to a third party, you represent and warrant that the Data is up-to-date, complete, and accurate and that you have obtained the third party’s prior consent for our collection, use and disclosure of their Data for the Purposes. You agree that you shall promptly provide us with written evidence of such consent upon demand by us.

3. Each use of our services by you shall constitute a fresh agreement for us to collect, use and disclose the Data in accordance with this privacy policy.

4. You may withdraw your consent and request us to stop using and/or disclosing your Data for any or all of the Purposes by submitting your request to us in writing. Should you withdraw your consent to the collection, use or disclosure of your Data, it may impact our ability to proceed with your transactions, agreements or interactions with us. Prior to you exercising your choice to withdraw your consent, we will inform you of the consequences of the withdrawal of your consent. Please note that your withdrawal of consent will not prevent us from exercising our legal rights (including any remedies) or undertaking any steps as we may be entitled to at law.

5. For users under the age of 18, consent from a parent or guardian is required before personal data can be provided. We encourage parents and guardians to monitor their children's internet usage and to instruct their children never to provide personal data without their permission.

ACCESS AND CORRECTION

1. The Personal Data Protection Act 2012 (No. 26 of 2012) (“PDPA”) gives you the right to access your Data. Your right of access can be exercised in accordance with the PDPA. Any access request may be subject to an administrative fee at our rates then in force to meet our costs in providing you with details of the information we hold about you.

2. In the event that you wish to correct and/or update your Data in our records, you may inform us in writing of the same. In certain cases, Data may also be corrected or updated via our Platform.

3. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).

ACCURACY

1. We endeavour to ensure that all decisions involving your Data are based upon accurate and timely information. However, we rely on you to disclose all relevant information to us and to inform us of any changes in your Data. As such, please disclose all relevant information necessary for us to provide services to you and ensure all information submitted to us is up-to-date, complete, and accurate. Kindly inform us promptly if there are any changes in your Data.

RETENTION

1. We may retain your Data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws. We will cease to retain your Data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the Data was collected, and is no longer necessary for legal or business purposes.

THIRD PARTY POLICIES

1. Our Platform may, from time to time, contain links to and from third party websites, including the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any Data to these websites.

CHANGES TO OUR PRIVACY POLICY

1. Any changes we may make to our privacy policy in the future will be posted on our Platform and, where appropriate, notified to you by e-mail.

CONTACT

1. We value feedback on our privacy practices and policies. As we strive to continuously improve, we encourage our users to share their insights and suggestions with us.

2. Questions, comments, feedback, and requests regarding this privacy policy are welcome and should be addressed to our Data Protection Officer. You can reach us via email at privacy@bravely.io.

SCHEDULE 2
ACCEPTABLE USE POLICY

1. This acceptable use policy sets out the terms between you and BRAVELY TECH PTE. LTD. (“we” or “us”) under which you may access our platform, Bravely (“our Platform”). This acceptable use policy applies to all users of, and visitors to, our Platform.

2. Your use of our Platform means that you accept, and agree to abide by, all the policies in this acceptable use policy, which form part of and supplement our main Terms of Use for our Platform.

PROHIBITED USES

1. You may use our Platform only for lawful purposes. You may not use our Platform:

   (a) in any way that breaches any applicable local or international laws or regulations;

   (b) in any way that is unlawful or fraudulent, or has any unlawful or fraudulent purpose or effect;

   (c) to send, knowingly receive, upload, download, use or re-use any material which does not comply with our content standards as set out in our prevailing terms and conditions as amended from time to time; or

   (d) to knowingly transmit any data, send or upload any material that contains viruses, Trojan horses, worms, time-bombs, keystroke loggers, spyware, adware or any other harmful programs or similar computer code designed to adversely affect the operation of any computer software or hardware.

   
   

2. You also agree:

   (a) not to reproduce, duplicate, copy or re-sell any part of our Platform in contravention of the provisions of our Terms of Use for our Platform; and

   (b) not to access without authority, interfere with, damage or disrupt:

   • (i) any part of our Platform;

   • (ii) any equipment or network on which our Platform is stored;

   • (iii) any software used in the provision of our Platform; or

   • (iv) any equipment or network or software owned or used by any third party.

CONTENT STANDARDS

1. These content standards apply to any and all material which you post or upload on our Platform (“Contributions”). For the avoidance of doubt, this includes but is not limited to any data uploaded to our Platform, content uploaded to our community groups or any feedback or other correspondence submitted via our Platform.

2. You must comply with the spirit of the following standards as well as the letter. The standards apply to each part of any Contribution as well as to its whole.

3. Contributions must:

   (a) comply with Singapore law, in particular, the Personal Data Protection Act 2012 (No. 26 of 2012), and the laws of any country from which they are posted; and

   (b) be placed in the correct and appropriate categories.

4. You shall be responsible for the authenticity, truthfulness, accuracy and origin of the Contributions. You must ensure that you either have all ownership rights to the Contributions posted or all rights allowing you to upload and post the Contributions to and on our Platform.

5. Contributions must not:

   (a) infringe any intellectual property right of any other person;

   (b) be made in breach of any legal duty owed to a third party, such as a contractual duty or a duty of confidence or any duty arising under law (including the Personal Data Protection Act 2012 (No. 26 of 2012);

   (c) contain any material which is defamatory of any person, obscene, offensive, or inflammatory or promotes any illegal activity, discrimination, violence, or ill-will and hostility;

   (d) be threatening or abusive, invade another’s privacy, or cause or be likely to cause annoyance, alarm, inconvenience or needless anxiety to any other person;

   (e) breach any community standards set by us (including our duly appointed moderators) for our community groups);

   (f) be used to impersonate any person, or to misrepresent your identity or affiliation with any person;

   (g) give the impression that they emanate from us, if this is not the case;

   (h) advocate, promote or assist any unlawful act or otherwise contain any material which is criminal in nature.

   
   

6. We reserve the right to request that you amend or delete the Contributions if it is found that any of the Contributions posted by you is in contravention of this acceptable use policy.

7. Where you choose to terminate your account with us, you may delete all previous Contributions made by you and make and retain a copy of the same. We will not be responsible for making or retaining any copies of your Contributions.

SUSPENSION AND TERMINATION

1. We will determine, in our discretion, whether there has been a breach of this acceptable use policy through your use of our Platform. When a breach of this policy has occurred, we may take such action as we deem appropriate, including to delete the post in question or to suspend or terminate your account.

2. Failure to comply with this acceptable use policy constitutes a material breach of the terms of use upon which you are permitted to use our Platform, and may result in our taking all or any of the following actions:

   (a) immediate, temporary or permanent withdrawal of your right to use our Platform;

   (b) immediate, temporary or permanent removal of any Contribution;

   (c) issuance of a warning to you;

   (d) legal proceedings against you for reimbursement of all costs on an indemnity basis (including but not limited to reasonable administrative and legal costs) resulting from the breach;

   (e) further legal action against you; and/or

   (f) disclosure of such information to law enforcement authorities as we reasonably feel is necessary.

   
   

3. We exclude liability for actions taken in response to breaches of this acceptable use policy. The responses described in this policy are not limited, and we may take any other action we reasonably deem appropriate.

CHANGES TO THE ACCEPTABLE USE POLICY

1. We may revise this acceptable use policy at any time by amending this page. You are expected to check this page from time to time to take notice of any changes we make, as they are legally binding on you. Some of the provisions contained in this acceptable use policy may also be superseded by provisions or notices published elsewhere on our Platform.