Privacy Policy | Living

Last Updated: August 2019

Our mission at FamilyLife is to build products that empower older adults to lead independent lives and for loved ones to take responsible actions about their older adult’s well-being and safety. We believe that providing transparency around the data and personal information you entrust to us is critical to complete that mission. Your privacy and trust are our utmost priority.

Our Privacy Policy (“Privacy Policy”) is designed to help you understand how we collect and use personal and other information through our smart home sensor system, mobile applications, services, features, software, and web applications and from visitors to our website https://familylife.io (our “Products” or “Services”). This Policy describes the choices available to you to assist you in making informed decisions when using our Service.

When we say FamilyLife,” “our,” “we,” or “us,” we’re talking about SmartLife Systems Pte Ltd.

Please also read FamilyLife’s Terms and Conditions (“Terms”), which describes the terms under which you use our Services.

By using our Services, you accept our Privacy Policy and Terms, and you consent to our collection, storage, use and disclosure of your Personal Information as described in this Privacy Policy.

1. Information We Collect
   FamilyLife receives or collects information when we operate and provide our Services, including when you install, access, or use our Services.
   1. Information You Provide:
      1. Older Adult’s Account Information. Information provided during an online order for the creation of a FamilyLife Account as well as the Group Personal Accident Insurance policy, such as full name, NRIC/FIN (last four digits e.g. 123A), date of birth, gender, nationality, phone number, home address, housing type, bank account number, bank code, and bank branch code.
      2. Billing Information. Information necessary to complete an order from our Site, including payer’s name, date of birth, phone number, billing address, email address, credit card information, and other information necessary to complete the transaction, as well as any other information that you choose to provide to us when making a purchase.
      3. Unique identifiers. Information such as your user name and password to access our Services.
      4. Older Adult’s Basic Well-Being and Health Information. Information provided during installation, such as weight, height, well-being and health concerns including but not limited to, mobility, mental health, diabetes, high blood pressure, etc.
      5. Older Adult’s Home Environment Information. Information necessary to complete installation, including photos of locations where sensors and devices are placed, and condition of home environment.
      6. Customer Support. You may provide us with information related to your use of our Services so we can provide you customer support.
   2. Automatically Collected Information:
      1. Usage and Log Information. We collect service-related, diagnostic, and performance information. This includes information about your activity (such as how you use our Services, and the like), log files, and diagnostic, crash, website, and performance logs and reports. Note that third-party payment processors may retain your information in accordance with their own privacy policies and terms.
      2. Transactional Information. When you pay for our Services, we receive information and confirmations, such as payment receipts, including from third parties processing your payment.
      3. Device Information. Information such as model and serial number, device activity logs, and historic and current device configuration.
      4. Mobile Device Information. Information such as your mobile device ID (similar to a website IP address), device type, operating system, and mobile service carrier.
      5. Sensor Data. Data from FamilyLife’s sensors including but not limited to, movement, humidity, temperature, ambient light, power usage, sounds, emergency button press, in/out of home, smoke, and water leak. The data collected varies depending on which device is used. When the device syncs with our applications or software, data recorded on the device is transferred from the device to our servers.
      6. Location Information. Information such as your location within the home and the indication that you have left home. You can always remove our access by stopping the use of the device or terminating the solution at any time. We may also derive your approximate location from your IP address.
      7. Cookies. We use cookies to operate and provide our Services, including to provide our Services that are web-based, improve your experiences, understand how our Services are being used, and customize our Services. For example, we use cookies in our web-based services. We may also use cookies to understand which of our features, content, etc. are most popular and to show you relevant information related to our Services. Additionally, we may use cookies to remember your choices, such as your language preferences, and otherwise to customize our Services for you. Learn more about how we use cookies to provide you our Services.
   3. Third-Party Information:
      1. Information Others Provide About You. We receive information other people, organisations provide us, which may include information about you.
      2. Third-Party Providers. We work with third-party providers to help us operate, provide, improve, understand, customize, support, and market our Services. For example, we work with companies to distribute our apps, provide our infrastructure, delivery, and other systems, process payments, help us understand how people use our Services, and market our Services. These providers may provide us information about you in certain circumstances; for example, app stores may provide us reports to help us diagnose and fix service issues. Please note that when you use third-party services, their own terms and privacy policies will govern your use of those services.

2. How We Use Information
   FamilyLife uses all the information to help us operate, provide, improve, understand, customize, support, market and develop new Services, in order to honour our Terms of Service contract with you.
   1. Provide you user services and improve the FamilyLife’s Product functionality and user experience.
   2. To fulfill orders and process payments for the sale of Products or Services.
   3. Administer your account and back-up your data.
   4. Record log entries for your information and troubleshooting issues with your system.
   5. Send you notifications through the FamilyLife app. You can manage your notification preferences within the mobile app menu.
   6. Send you marketing communications, where permitted by applicable law. You can control marketing communications via the “Unsubscribe” link in an email.
   7. To conduct research and analysis to better understand how users access and use our Services, both on an aggregated and individualized basis, in order to improve our Services, create new features, provide you new offerings, respond to user preferences, and to protect your data.
   8. Respond to your questions and concerns and provide customer support.
   9. To make inferences to show you more relevant content. An example would be based on your sleep data collected, we may make inferences about your sleeping patterns and provide customised insights.
   10. To promote safety and security of the Services, our users, and other parties. For example, we may use the information to authenticate users, facilitate secure payments, protect against fraud and abuse, respond to a legal request or claim, conduct audits, and enforce our terms and policies.
3. How We Share Information
   FamilyLife will share certain categories of your information with third parties only in certain circumstances as described below:
   1. Identifiable Information. Personally Identifiable Information (PII) is information that contains data that could be used to directly or indirectly identify you, like your name, address, well-being and health information. We only share this information under extremely limited circumstances. Primarily, this information is shared with third parties to provide you necessary Services. For example, this information is shared on a limited basis to assist in managing the call centre services, as well as the provision of the Group Personal Accident Insurance services and coverages. These third parties are authorized to use your personal information only as necessary to provide these services to us.
      Specifically, we may share this information as follows:
      1. Affiliates. We may disclose the information we collect from you to our affiliates and subsidiaries that provide services or conduct data processing on our behalf, or for logistics purposes. If we do so, their use and disclosure of your personal information will be based on our instructions, and in compliance with this policy and any other appropriate confidentiality and security measures.
      2. Service Providers. We may disclose the information we collect from you to third party vendors, service providers, contractors or agents who perform functions on our behalf.
      3. Business Transfers. If we are acquired by or merged with another company, or if substantially all of our assets are transferred to another company, we may transfer the information we have collected from you to the other company. We will continue to take measures to protect the confidentiality of personal information and give affected users notice before transferring any personal information to the new entity.
      4. In Response to Legal Process. We also may disclose the information we collect from you in order to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena. To the extent legally allowed, we will notify you of such requests prior to disclosing any information sought.
      5. To Protect Us and Others. We also may disclose the information we collect from you where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Service or this Policy.
   2. Anonymized Information. We may share your aggregated and de-identified information, which is anonymized and does not identify you. We may use this information in a variety of ways, including within a decentralised data and services exchange platform to further innovation and provide new services and products, where data is shared while guaranteeing control, auditability, transparency and compliance for all stakeholders involved. 30% of the monetised data will be reimbursed to you through your bank account. We will provide you with the information when this happens. We may also share this anonymized information with third parties and partners under agreement with us for marketing, advertising, research, or similar purposes.
   3. Information We Share With Your Consent. We may share personally identifiable information with third parties provided we receive your consent to share that information. For example, you may opt into providing information to FamilyLife’s service providers and/or business partners to receive special offers. Information will never be shared for these purposes without your consent.
   4. Information Obtained from Third Parties. If others provide us your information, we will only use that information for the specific reason for which it was provided to us.
   5. Updating Your Information. To review and update your personal information, you may view and edit your information from within the app. We will retain your information for as long as your contract agreement is active or as needed to provide services to you. If you wish to terminate your contract agreement or request that we no longer use your information to provide services to you, contact us at customer@connectedlife.io. We will retain and use your information as necessary to comply with our legal obligations.
4. Data Retention
   We keep your account information, like your name, email address, and password, for as long as your account is in existence because we need it to operate your account. We keep other information, like your wellness and health data, until you delete your account with us because we use this data to provide you with personal notifications and statistics and other aspects of the Services. We also keep information about you and your use of the Services for as long as necessary for our legitimate business interests, for legal reasons, and to prevent harm, including as described in the How We Use Information and How We Share Information sections.
   1. Data Retention Period after Termination:
      1. Personal data would be retained for up to 90 days after termination of the Service.
      2. The data retention period after termination applies to both FamilyLife’s customer’s personal data as well as customer’s personal data held by third-parties.
5. Marketing, Advertising, and Analytics
   1. Cookies, Tracking and Ads
      We may automatically collect information about your use of our Services through cookies, web beacons, and other technologies, such as your domain name; your browser type and operating system; web pages you visit; links you click; your IP address; the length of time you visit our website and/or use our services; and the referring URL, or the webpage that led you to our Site.We may use technologies to understand how many individuals are accessing FamilyLife Services or accessing features within the app. We use this aggregated information to understand and optimize how FamilyLife devices and the app are used and to provide content and features that are of interest to you. Please refer to our Cookie Policy for more information about your choices around cookies and related technologies and third-party advertising.
   2. Email & SMS Communications
      You may choose to submit your email address through a submission form located on our website to sign up for communications from FamilyLife. You may also provide your mobile phone number to FamilyLife in connection with account registration or otherwise. The email address and mobile phone number associated with your account may also be used to send you news about FamilyLife, such as new features or marketing promotions, account updates, promotional offers, and information regarding your contract and other premium services. We may use one or more service providers to administer these messages. FamilyLife does not share your email address or phone number with spammers or any other non-affiliated third parties for their own marketing purposes without your permission. You may opt out of receiving newsletter or marketing communications from us by following the unsubscribe instructions or by contacting us at hello@connectedlife.io.
   3. Security
      The security of your personal information is important to us. We follow generally accepted industry standards to protect the information transmitted to us to the best of our abilities, both during transmission and upon receipt. No method of transmission or electronic storage is 100% secure. Therefore, we cannot guarantee its absolute security. If you have any questions about the security of our Products can contact us at hello@connectedlife.io.
6. Other Rights and Important Notes
   You agree to our information practices, including the collection, use, processing, and sharing of your information as described in this Privacy Policy, as well as the transfer and processing of your information to other countries globally where we have or use facilities, service providers, or partners, regardless of where you use our Services. Please note that the countries where we operate may have privacy and data protection laws that differ from, and are potentially less protective than, the laws of your country. You agree to this risk when you have an account with us and agree to our Terms and Conditions, irrespective of which country you live in. If you later wish to withdraw your consent, you can terminate your account with us.
   Policy to allow request for access (https://familylife.io/faq/#1521619028946-1c58bc9a-00ef)
   You can contact support.data@connectedlife.io or 9145 1576 to request access to your personal data. You are required to submit evidence of your identity for verification purposes before the request can be processed. We reserve the right to refuse to provide you access to the personal data in the case of exceptions as stated in the Fifth Schedule of the PDPA.
   
   Policy to allow correction requests (https://familylife.io/faq/#1521619029030-2f774b43-00ff)
   You can contact support.data@connectedlife.io or 9145 1576 to make a request to correct an error or omission in the personal data held by FamilyLife. You are required to submit evidence of your identity for verification purposes before the request can be processed. We reserve the right to refuse corrections to the personal data in the case of exceptions as stated in the Sixth Schedule of the PDPA.
   
7. Notification of Privacy Policy Changes
   We may update this privacy statement to reflect changes to our information practices or changes to our services. If we make any material changes, we will notify you by means of a notice in the app or website prior to the change becoming effective. We encourage you to periodically review this statement for the latest information on our privacy practices. Your continued use of our Services confirms your acceptance of our Privacy Policy, as amended. If you do not agree to our Privacy Policy, as amended, you must stop using our Services.
8. Contact Us
   If you have questions, suggestions, or concerns about this policy, or about our use of your information, please contact us at hello@connectedlife.io.
   SmartLife Systems Pte Ltd
   Privacy Policy
   Mapletree Business City
   20 Pasir Panjang Road
   East Wing
   #03-22/24
   Singapore 117439

Last Updated: August 2019