Last updated: 25 Jul 2023

 

Zoala Pte Ltd. and its affiliates, (collectively, “we,” “us,” “our,” or “Zoala”) are committed to protecting your privacy. This Privacy Policy (“Privacy Policy”) describes the types of information Zoala may collect from you or that you may provide when you visit the zoala.co website and its subdomains (“Website”), and use of our mobile application (“App”) and other related services (collectively, the “Services”). This Privacy Policy is incorporated into our Terms of Service. All capitalised terms used in this Privacy Policy but not defined herein have the meanings assigned to them in the Terms of Service.

We are committed to protecting your privacy. This Privacy Policy describes how we collect, store, use and distribute information through our Services. Please read this Privacy Policy carefully. By starting to use our Services, you consent to this Privacy Policy.

We care about the protection and confidentiality of your data. We therefore only process your data to the extent that:

• It is necessary to provide the Zoala services you are requesting,
• You have given your consent to the processing, or
• We are otherwise authorised to do so under the data protection laws.

Conversations with your Zoala are not shared with any other company or service. We will never sell your personal data or conversation history.

By using or accessing the services in any manner, you acknowledge that you accept the practices and policies outlined in this Privacy Policy, and you at this moment consent that we will collect, use, and share your information in the following ways.

Remember that your use of Zoala’s services is at all times subject to the Terms of Service, which incorporates this Privacy Policy. Any terms we use in this Policy without defining them have the definitions given to them in Terms of Service.

If you have any questions, suggestions or comments about privacy or protection and confidentiality of your data, please contact us at privacy@zoala.co.

 

1. Information we collect and process

Here we list all the types of personal information we collect and store throughout your experience with Zoala. Some of this information may be shared with service providers who help us deliver your experience with Zoala, each of such services is explained below.

We neither rent nor sell your information to anyone. Conversations with your Zoala are not shared with any other company or service. We will never sell your personal data or conversation history.

We DON’T knowingly collect or store medical information or any information about health status, provision of health care, or payment for health care that is created or collected by a Covered Entity and can be linked to a specific individual. We discourage you from communicating this information to Zoala through text or voice chat so that this information doesn’t become part of your chat history.

We collect information you intentionally provide through the Services (such as your profile information that you provide upon registration), as well as some technical information coming from your mobile device or web browser.

1.1. Things you do and information you provide

The following table covers all the types of personal information that you may provide and that we collect and store as soon as you start using Zoala and throughout your experience with our Services.

Personal information	Why we need the data	When it is collected	Is it ever shared?
First name*	To enable Zoala to address you by name.	In text chat with Zoala, when you create an account when you edit your profile.	Yes, we use an external service to deliver service-related personalised emails to you that address to you by name.
Other profile information	To customise conversations with Zoala. This may include your birthday, gender, work status, school code, etc. For example, Zoala will enable or disable conversations about school or work, depending on which one is relevant. We do not collect any of this information if you choose not to provide it.	In text chat with Zoala, when you edit your profile	No
Email*	To enable you to log in using your email and restore password in case you forget it.	When you create an account	Yes, we use an external service to deliver automated emails to you (for example, in case you forgot your password). This service provider gets access only to the first name and email.
Your hobbies & interests	To include more conversation about relevant subjects, for example about video games or specific books.	In text or voice chat with Zoala	No
Facts about you and your life	To enable personalised conversation based on facts that Zoala recognized in your messages.	In text or voice chat with Zoala	No
Mood history	To display your mood history and help you recognize what triggers certain moods.	In text chat with Zoala	Yes, we share the mood information with the school counsellors.
People mentioned in the chat	To enable conversations about important people in your life and recognize them in pictures that you send to Zoala. The information you provide may include the name, the relation to you, a face recognition fingerprint.	In text or voice chat with Zoala	No
Voice messages sent to Zoala during a voice call	To provide the voice call experience and to improve the quality of it.	In voice calls with Zoala	Yes, we use an external service for voice-to-text recognition. Only the voice messages can be sent to this service without any other personal information.
Images you send to Zoala	To enable object and face recognition and appropriate reaction to images that you share with Zoala in chat.	When you send an image to Zoala in a text chat	Yes, we use an external service for object recognition in photos. Only the photo may be sent to this service without any other personal information.
Text messages you send to Zoala	To display your chat history in the app or in your web browser and sync the history across all your devices and to train Zoala machine learning models and improve the quality of your text chat experience.	In text chat with Zoala	Yes, we use an external service for text generation. Only the message content is sent to this service without any other personal information.
Usage data	We collect and store your usage data, such as button clicks or search queries, to track and analyse product metrics and to better understand and serve the users of the Services.	When you interact with the Apps or the Website	Yes, we use an external service to track and visualise de-identified usage data.

• Items marked with an “asterisk” (*) are mandatory, whereas all the other items are optional and you may choose not to provide this information.

1.2. Automatic data collection

As with many other websites and mobile applications, as you navigate through and interact with our Website and App, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to our Website and App, including traffic data, location data, logs, language, date and time of access, frequency, and other communication data and the resources that you access and use on the Website and App. Information about your computer and internet connection, including your IP address, operating system, host domain, and browser type.
• Details of referring websites (URL). We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioural tracking).
• Information about your computer, mobile device, and Internet connection, specifically the device’s unique identifier and telephone number and your IP address, operating system, browser type, mobile network information, and App version information.
• Information stored on your mobile device, including in other applications. This may include photographs, audio and video clips, and health information. This data will be used only to provide and improve our services, and will not be used or shared with third parties for marketing purposes.
• Real-time information about the location of your device.

The information we collect automatically is statistical data and may include personal information, or we may maintain it or associate it with personal information you provide to us or that we collect in other ways or receive from third parties. It helps us to improve our Website and App and to deliver better and more personalised service, including by enabling us to:

• Estimate our audience size and usage patterns.
• Forecast future needs, functions, and uses of our Website, App, and services.
• Better understand user satisfaction levels and experiences.
• Store information about your preferences, allowing us to customise our Website and App according to your individual interests.
• Speed up your searches.
• Recognize you when you return to our Website and App.
• In other ways to improve your experience and the quality of our Website, App, and services.

1.2. Automatic data collection

As with many other websites and mobile applications, as you navigate through and interact with our Website and App, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to our Website and App, including traffic data, location data, logs, language, date and time of access, frequency, and other communication data and the resources that you access and use on the Website and App. Information about your computer and internet connection, including your IP address, operating system, host domain, and browser type.
• Details of referring websites (URL). We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioural tracking).
• Information about your computer, mobile device, and Internet connection, specifically the device’s unique identifier and telephone number and your IP address, operating system, browser type, mobile network information, and App version information.
• Information stored on your mobile device, including in other applications. This may include photographs, audio and video clips, and health information. This data will be used only to provide and improve our services, and will not be used or shared with third parties for marketing purposes.
• Real-time information about the location of your device.

The information we collect automatically is statistical data and may include personal information, or we may maintain it or associate it with personal information you provide to us or that we collect in other ways or receive from third parties. It helps us to improve our Website and App and to deliver better and more personalised service, including by enabling us to:

• Estimate our audience size and usage patterns.
• Forecast future needs, functions, and uses of our Website, App, and services.
• Better understand user satisfaction levels and experiences.
• Store information about your preferences, allowing us to customise our Website and App according to your individual interests.
• Speed up your searches.
• Recognize you when you return to our Website and App.
• In other ways to improve your experience and the quality of our Website, App, and services.

1.3. The technologies we use for automatic data collection

The technologies we use for this automatic data collection may include:

• Cookies. We and our service providers may use cookies to receive and store certain types of information whenever you interact with our Website and App through your computer or mobile device. A “cookie” is a small piece of data sent from a website and stored on the user’s computer by the user’s browser. Our Website and App use two types of cookies: Single-session (temporary or browser cookies) and multi-session (persistent or flash cookies). Temporary cookies last only as long as your web browser is open, and are used for technical purposes such as enabling better navigation through our Website and App. Once you close your browser, the cookie disappears. On your computer, you may refuse to accept browser cookies by activating the appropriate setting on your browser, and you may have similar capabilities on your mobile device in the preferences for your operating system or browser. However, if you select this setting you may be unable to access certain parts of our Website or use certain parts of our App. Unless you have adjusted your browser or operating system setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website or use our App. Persistent cookies are stored on your computer for longer periods and are used for purposes including tracking the number of unique visitors to our Website and information about your preferences and navigation to, from, and on our Website and App, such as the number of views a page gets, how much time a user spends on a page, and other pertinent web statistics. Persistent cookies are not managed by the same browser setting as are used for temporary cookies. Cookies, by themselves, will not be used by Zoala to disclose your individual identity. This information identifies your browser, but not you, to our servers when you visit the Website and App.
• Pixel Tags. We and our service providers may also collect data by using “pixel tags,” “web beacons,” “clear GIFs,” or similar means (collectively, “pixel tags”) that allow us to know when you visit our Website and App. Through pixel tags, we obtain non-personal information or aggregate information that can be used to enhance your online experience and understand traffic patterns.
• Google Analytics. We use Google Analytics, a web analytics service provided by Google, Inc. (“Google”) to collect certain information relating to your use of the Website. Google Analytics uses cookies to help the Website analyse how users use the site. You can find out more about how Google uses data when you visit our Website by visiting “How Google uses data when you use our partners’ sites or apps”, (located at www.google.com/policies/privacy/partners/). We may also use Google Analytics Advertising Features or other advertising networks to provide you with interest-based advertising based on your online activity. For more information regarding Google Analytics please visit Google’s website and pages that describe Google Analytics, such as www.google.com/analytics/learn/privacy.html.
• Facebook. We use Facebook Pixel, web analytics, and advertising services provided by Facebook Inc. (“Facebook”) on our Website and App. The Facebook Pixel service uses cookies, pixel tags, and other storage and tracking technology to collect or receive information from our Website and App based on your usage activity. Facebook uses that information to provide us with marketing and advertising services, including targeted ads, and reports that help us measure the effectiveness of our ads, Website, and App. Using this service, we can keep track of what users do after they see or click on a Facebook advertisement, keep track of users who access our Website and App or advertisements from different devices, and better provide advertisements to our target audiences. The data from Facebook Pixel is also saved and processed by Facebook. Facebook can connect this data with your Facebook account and use it for its own and others advertising purposes, in accordance with Facebook’s Data Policy which can be found at https://www.facebook.com/about/privacy/. Please also refer to “Choices About How We Use and Disclose Your Information” below for more information about tracking technologies, targeted advertising, and your choices relating to the use of your information for these purposes.

2. How we use or share your information

In connection with providing you with the Website, App, and services, we may use, compile, analyse, and save your information in the following ways:

• To provide our Website and its functionality, contents, and services to you.
• To provide and improve our App and its functionality, contents, and services.
• For the purposes of treatment, quality, improvement of health status, customer and patient experience, customer and patient engagement and/or behaviour modification, peer review, payment, efficiency, cost-effectiveness and/or other purposes relating to operations and provisions of telehealth services.
• To carry out the services and, as applicable, facilitate the provision of health care services to you by your physician or other health care provider and ensure that physicians or health care providers have the services and support necessary for health care operations.
• To communicate with you about the Website, App, and services, or your use of the Website, App, and services, and send you communications on behalf of physicians or other health care providers utilising the services to meet your needs.
• To provide you with information that you have requested or to respond to your inquiries.
• To provide you with technical support and to improve our Website, App, and services.
• To verify your identity and administer your account, including processing your payments and fulfilling your orders.
• In order to ensure that content from our Website and App is presented in the most effective manner for you and for your computer or mobile phone, to allow you to participate in interactive features of our services (when you choose to do so), and as part of our efforts to keep our Website and App safe and secure.
• To communicate with you about our products and services and those of our subsidiaries, affiliates, and parent companies and any of their related businesses and those of our third-party partners that may be of interest to you.
• To fulfil any other purposes for which you provide it, including to allow you to transfer your user account to a new device, or sync other applications offered by Zoala and its affiliates and third-party partners.
• To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you.
• In the event of a sale, merger, consolidation, change in control, transfer of substantial assets, reorganisation, or liquidation, we may transfer, sell, or assign to third parties information concerning your relationship with us, including, without limitation, personal information that you provide and other information concerning your relationship with us.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• To notify you about changes to our Website, App, or services.
• In any other way, we may describe when you provide the information.
• For any purpose where you have given your consent.
• To comply with applicable federal and/or state law.

We may also use your information to contact you about goods and services that may be of interest to you, such as user surveys or promotions, including through newsletters. If you wish to opt out of receiving such communications, you may do so at any time by clicking on the unsubscribe link in the emails you receive. For more information, see Choices About How We Use and Disclose Your Information.

We will combine information we receive from other sources with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).

2.1 Disclosure of your Information

We do not share, sell, or otherwise disclose your personal information for purposes other than those outlined in this Privacy Policy. However, we may disclose aggregated, de-identified information about our users, and information that does not identify any individual, without restriction.

We may disclose your personal information to third parties in connection with the provision of our services or as otherwise permitted or required by law. You agree that we have the right to disclose personal information that we collect or you provide as described in this Privacy Policy, including:

• To any member of our group, which means our subsidiaries and affiliates, including our ultimate holding company and its subsidiaries.
• To Providers (i) to schedule and fulfil appointments and provide health care services as part of the services, (ii) to whom you send messages through our services, and (iii) for other treatment, payment, or health care operations purposes, including pharmacy services, upon your request.
• To health care organisations, pharmacies, contractors, service providers, and other third parties we use to support our business or in connection with the administration and support for your healthcare treatment purposes,
• To our third-party service providers that provide services such as hosting our Website and App, data analysis, IT services and infrastructure, customer service, email delivery, auditing, ordering, marketing, payment processing, and other similar services.
• To any third parties, we believe it necessary or appropriate to comply with applicable laws.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganisation, dissolution, or other sale or transfer of some or all of Zoala’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Zoala about our Website or App users is among the assets transferred.
• To fulfil the purpose for which you provide it. For example, if you email us asking us to contact a third party (including a medical professional), we may transmit the contents of your email to the recipient.
• For any other purpose disclosed by us when you provide the information.
• With your consent.

We may also disclose your personal information: If we are under a duty to disclose or share your personal information to comply with any legal obligation, including to respond to any government or regulatory request; in order to enforce or apply our Terms of Use and other agreements, including for billing and collection purposes; or to protect the rights, property, or safety of Zoala, our customers, or others. This may include exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

2.2 Choices about how we use and disclose your information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your personal information.

Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of the Website and App may then be inaccessible or not function properly.

Do Not Track. Some web browsers permit you to broadcast a signal to websites and online services indicating a preference that they “do not track” your online activities. We do not currently respond to “do not track” signals.

Promotional Offers from Zoala. If you do not wish to have your contact information used by Zoala to promote our own products or services, you can check certain boxes on the forms we use to collect your data. You can also always exercise your right to ask us not to process your personal information for marketing purposes by contacting us at the address below. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt-out does not apply to information provided to Zoala as a result of your use of the services.

Location Information. You can choose whether or not to allow our App to collect and use real-time information about your device’s location through the device’s privacy settings. If you block the use of location information, some parts of our App may then be inaccessible or not function properly.

2.3. Protection of Zoala and others

We reserve the right to access, read, preserve, and disclose any information that we reasonably believe is necessary to comply with law or court order; enforce or apply our Terms of Service and other agreements; or protect the rights, property, or safety of Zoala, our employees, our users, or others.

3. How we secure and protect your information

We use a variety of industry-standard security technologies and procedures to help protect your data from unauthorised access, use, or disclosure.

• Your account is protected by a password for your privacy and security. You must prevent unauthorised access to your account and personal information by selecting and protecting your password appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your account.
• All transmitted data are encrypted during transmission. We use standard Secure Socket Layer (SSL) encryption that encodes information for such transmissions. All stored data are maintained on secure servers. Access to stored data is protected by multi-layered security controls including firewalls, role-based access controls and passwords.
• While we use reasonable commercial efforts to protect the data, no technology, data transmission or system can be guaranteed to be 100% secure. In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to your data, we will notify you as soon as we spot the issue.

4. Where we store your data

Our services are operated in Singapore. If you are located in another jurisdiction, please be aware that the information you provide to us may be transferred to, stored and processed in Singapore. By using our services or providing us with any information, you consent to this transfer, processing, and storage of your information in Singapore, a jurisdiction in which the privacy laws may not be as comprehensive as those in the country where you reside or are a citizen. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

5. Data retention

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

6. Your data protection rights

As a Zoala member, you have the following data protection rights, depending on the circumstances of the specific case:

• Disclosure To receive information about your personal data processed by us and to request access to your personal data and/or copies of these data. This includes information on the purpose of use, the category of data used, its recipients and authorised persons and, if possible, the planned duration of data storage or, if this is not possible, the criteria for determining this duration.
• Correction, deletion or limitation of processing To request the correction, deletion or limitation of the processing of your personal data, e.g. by sending us an email. If (i) the data are incomplete or incorrect, (ii) they are no longer necessary for the purposes for which they were collected, (iii) the consent on which the processing was based has been revoked, or (iv) you have successfully exercised your right to object to data processing; in cases where data is processed by third parties, we will forward your requests for correction, deletion or limitation of the processing to these third parties, unless this proves impossible or involves a disproportionate effort.
• Opposition to the processing To object to the processing for reasons arising from your particular situation.
• Refusal and revocation of consent To refuse your consent or – without affecting the legality of data processing prior to the revocation – to revoke your consent to the processing of your personal data at any time.
• Automatic decisions To require that you be subject to a decision based exclusively on automated processing only in the exceptional cases provided by law, if that decision has legal effect against you or significantly affects you in a similar manner; should such an automated decision take place in exceptional cases, you have the right to obtain information on the logic involved and the scope of the intended effects.
• Right of appeal Communicate with and, if necessary, complain to the data protection supervisory authority.

7. Accuracy of your data

We rely on our users to provide accurate personal data that is relevant to the purposes for which they are to be used, and, to the extent necessary for those purposes. The data you provide should be accurate, complete and kept up to date via the Zoala App.

8. How to delete your data

You may email us at hello@zoala.co with your request to delete all your account information, and upon receiving your request, we will proceed with the account deletion process.

9. Use of Zoala by minors

You must be at least 13 years old to use the Services. If you are under 13 you must have your parent or legal guardian’s permission to use the Services. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Data on the Services without their permission. If you have reason to believe that a child under the age of 13 has provided Personal Data to us through the Services, please contact us, and we will endeavour to delete that information from our databases.

10. Changes to Privacy Policy

The Services and our business may change from time to time. As a result, at times it may be necessary for us to make changes to this Privacy Policy. We reserve the right to update or modify this Privacy Policy at any time and from time to time without prior notice. We encourage you to periodically review this page for the latest information on our privacy practices. This Privacy Policy was last updated on the date indicated above. Your continued use of the Services after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy.