Privacy Policy

Introduction

This Privacy Policy (or “Policy”) describes practices of Myloh Pte Ltd (“Myloh”, we, our or us) in connection with information we collect, use and disclose through Myloh – a health and wellness E-buddy featuring a mobile application (“Myloh App”) on the Apple and Android OS app platforms or through Myloh’s website and other online products and services (including and when you contact our customer service team, engage with us on social media, or otherwise interact with us). The Myloh App combines chat responses, journaling, usage data and participation in exercises to allow users to complete certain wellness objectives/aspirations and to receive smart message notifications/feedbacks as a reminder / performance measurement of the users progress. 

By using the Myloh App and/or providing us with your information, you consent to our collection, use, and disclosure (including transfer) of your information in accordance with this Privacy Policy. Please do not provide us with any information if you do not accept this Policy.

Important Notice

If you are having suicidal thoughts or planning to act on suicidal thoughts, or if you feel that you may be a danger to yourself or to others, or if you otherwise have any medical or mental health emergency or severe mental health condition, or if you are in a crisis or trauma or abuse, please discontinue use of the service immediately and call the relevant emergency number in your country and notify the police or emergency medical services. For example, you can find your country-specific suicide emergency number at: Suicide.org – Suicide Prevention, Awareness, and Support

Your interaction with the Myloh App is with an AI chatbot and not a human. The bot is restricted in the means of response, and the intended use is for providing evidence-based tools and techniques to manage emotions and encourage mental well-being in a self-help context. It is not intended for providing diagnosis, treatment or cure of a condition or disease. The Myloh App cannot and will not offer advice on issues it does not recognize.

What types of information do we collect?

We collect information when you register for an account, participate in interactive features (like submit a meditation rating), fill out a form or a survey, participate in a contest or promotion, make a purchase, communicate with us via social media sites, request customer support, or otherwise communicate with us. The information you may provide includes your name, email, password, goals, previous meditation experience, street address, payment method information, feedback and survey responses, and other information about you included within your messages to us. Some users also provide health-related information in connection with providing feedback or other messages to us, and we process that information consistent with the purpose for which it was provided.

Such information collected can be classified into two types: Personal Information and Non-Personally Identifiable Information. When this Policy uses the term “App Data”, this includes both Personal Information and Non-Personally Identifiable Information.

By “Personal Information,” we mean data that is associated with an identifiable individual, such as a name, address or e-mail address. Personal Information includes, for example, personally identifiable and demographic information. And in connection with the usage of the Myloh App, it also includes personally identifiable wellness or fitness information, including various activities identified through the Myloh App on your Android OS phone or iPhone.

By “Non-Personally-Identifiable Information,” we mean information that is not associated with an identifiable individual. Non-Personally-Identifiable information may include information which would otherwise be Personal Information, but which has been de-identified or aggregated.   

How do we acquire and use your information?

We acquire App Data when you use the Myloh App. When you use the Myloh App, we collect information about your use of it, such as: (i) Usage Information – activity sessions you use, videos you view or music you listen to, what screens or features you access, and other similar types of usage information, (ii) Transactional Information – when you make a purchase or return, we collect information about the transaction, such as product description, price, subscription or free trial expiration date, and time and date of the transaction, (iii) Device Information – we collect information about the mobile device you use to access our services, including the hardware model, operating system and version, device identifiers set by your device operating system, and mobile network information (like your connection type, carrier and region).  

After you consent to use the Myloh App, App Data is collected through the Myloh App, your use of your Android OS phone or iPhone, or communication with Myloh Customer Support. In connection with your usage of the Myloh App, we collect your contact and demographic information and information about your health and activity from the Myloh App, as well as information concerning your activities (e.g. data about how and when you use the Myloh App) coming from your Android OS phone or iPhone. If you consent to use the Myloh App, the full listing of the categories of App Data that may be collected, used and/or disclosed as part of your usage of the Myloh App, including information collected through the App. 

Your App Data will never be sold or used to drive sale of any products. It may be used in accordance with the Terms of Use which may include using the information you share in the Myloh App, to adjudicate rewards, to identify and deliver messages that may be helpful to your health and wellness or otherwise of interest to you. Note that your App Data may be transferred to any location outside of your country of domicile. 

We may use “cookies” and other technologies such as pixel tags and web beacons. These technologies are used to track information such as the number of users, their frequency of use, and which parts of the website they have visited. While these technologies can tell us when you use the Myloh App and which pages you visit, it cannot read data off your storage or mobile device. You can choose to disable cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. We also collect information about usage of the App. This helps us better understand user behaviour.

We may collect, use, and disclose your App Data which includes your Personal Information, for the purposes listed below and, if you choose to use the Myloh App: 

  1. providing you and other users with the services and functions of the Myloh App, including setting up your account and managing your use and access, informing you about service updates, and managing and providing rewards; 
  1. to identify and deliver messages that may be of interest to you;
  1. to develop and refine the Myloh App (including any in-house efficacy studies and research),
  1. to understand overall App effectiveness and/or its impact on the mental health in general; 
  1. to generate usage reports and other analyses for Myloh’s corporate and institutional accounts but only Non-Personally-Identifiable Information and/or consolidated manner;
  1. to detect, investigate and prevent fraudulent transactions and other illegal activities and protect the rights and property of Myloh and others; 
  1. comply with the law, such as by processing transactional records for tax filings;
  1. personalize your online experience and the advertisements you see on other platforms based on your preferences, interests, and browsing behavior;
  1. facilitate contests, sweepstakes, and promotions and process and deliver entries and rewards; and
  1. assisting you with enquiries and obtaining your feedback

For what and to whom may we disclose your information?

We may disclose your App Data, which includes your Personal Information, to third parties for certain purposes as described above and as further described below. In all cases we will require the recipient to protect the App Data and use it only for the purpose it was provided consistent with this Privacy Policy. We may share your App Data which includes your Personal Information, if:

  1. the recipient has been authorised to provide services on our behalf; 
  1. the recipient is our service provider who provides us with necessary services including but not limited to IT services, hosting and maintenance services, organising of our events, accounting, data analytics services, email messaging services, delivery services, handling of payment transactions, marketing, etc;
  1. the recipient is our consultant or professional adviser including but not limited to accountants, lawyers and auditors; 
  1. you have specifically consented to such disclosure;
  1. required by law, such as pursuant to a subpoena, regulatory oversight, or other legal process; 
  1. we believe in good faith that disclosure is necessary (a) to protect our rights, the integrity of the Myloh App, or your safety or the safety of others, or (b) to detect, prevent or respond to fraud, intellectual property infringement, violations of our Terms of Use, violations of law, or other misuse of the Myloh App; and/or
  1. you opt in to share your App Data with Evie.ai (“Evie”) and/or Myloh’s appointed AI scheduling provider, in order to help build and improve your Myloh experience. If you opt in, your contact information and other information that directly identifies you will be separated from the rest of your data collected under the App and provided to Evie and/or Myloh’s appointed AI scheduling provider

We will not knowingly collect Personal Information from minors under the age of seventeen (17). 

For Myloh’s corporate and institutional accounts and their respective clients, please refer to the specific policy policies adopted by the respective organisations.  

How do we protect your information?

The security, integrity, and confidentiality of your information are extremely important to us. We have implemented technical, administrative and physical security measures that are designed to protect your information from unauthorised access, disclosure, use and modification. We regularly review our security practices to consider appropriate new technology and methods. 

What happens if I no longer want to use the Myloh App?

As stated in the Myloh App, you are free to change your mind and stop using the Myloh App at any time by choosing “Terminate Account” in settings or contacting Myloh support at the number listed below.

You may also be rejected as a user of the Myloh App if you engage in any practices that are found to violate the Terms of Use. 

If you terminate or rejected from the Myloh App, no additional App Data will be collected about you, however, information that was previously collected about you may continue to be used as described in this Policy.  After rejection or termination of the user account, Myloh will keep data in accordance with any relevant applicable law, and in compliance with legal guidelines, if any.

How do we handle your responses to mental well-being assessments/scales?

When you use the Myloh App, You will be asked to respond to certain well-being assessments. 

You will also be asked to share how you cope with day to day activities as part of the assessments. Assessments are a proven way to baseline and track the progress of your self-reported symptoms. Processing of your assessment response is based on Myloh’s Terms of Use for the purpose of determining if escalation is required and to provide you access to tools and techniques to manage emotions and encourage mental well-being in a self-help context.

YOUR RESPONSES TO THESE ASSESSMENT QUESTIONS ARE NOT PROCESSED TO FORM A DIAGNOSTIC OPINION NOR PROCESSED FOR ANY MEDICAL PURPOSES OR FOR GIVING CLINICAL ADVICE. We DO NOT collect or process your sensitive medical data that can directly or indirectly Identify You. We use your anonymized assessment scores to improve the efficacy of the Myloh App and its recommendation. 

Your response is encrypted during transmission and is securely stored. YOUR PERSONAL DATA IS NEVER SHARED WITH A THIRD PARTY WITHOUT YOUR EXPLICIT CONSENT.

Linking to other websites and applications 

From time to time, the Myloh App may provide links to other websites or applications, not owned or controlled by Myloh, that we think might complement and enhance your experience with the Myloh App. This Policy applies solely to information we collect through the Myloh App. If you access or use a linked website or application, the privacy policy of that other website or application will apply to your access or use. We encourage you to review each such third party’s privacy statement as well as their terms of use. We are not responsible for the content and privacy policies or notices of those websites or applications.

Analytics vendors

We may also use Google Analytics and other service providers such as Bugsnag to collect information regarding visitor behavior and visitor demographics on our Services. For more information about Google Analytics, please visit Google Privacy. You can opt out of Google’s collection and processing of data generated by your use of the Services clicking this link: Deactivate Google Analytics. For more information about Bugsnag, visit http://www.bugsnag.com.

Myloh Contact Information

If you wish to contact us, have any enquiries or feedback on this Policy, or need more information on or access to data, which you have previously provided to us, email us at hello@myloh.co. 

Changes to Myloh Privacy Policy 

Myloh may change this Policy from time to time; when updates are made, the version date (located at the bottom of this Policy) will also be updated to reflect that a revision occurred, and will be made available in our Myloh App as well as on our website at: https://www.myloh.co The updated Policy will take effect immediately and will supersede all earlier versions but will continue to apply to App Data provided to us previously. Each time you access the Myloh website or App and any updates, upgrades, new versions, documentation and content and services provided by or through Myloh, you acknowledge and agree that the latest version of this Policy shall apply.

We encourage you to periodically reread this Policy to see if there have been any changes that may affect you. To be sure you are aware of any material change, we will message you through Myloh. This Policy is not intended to and does not create any contractual or other legal rights in or on behalf of any party.

Effective Date: 31 December 2020