The following outlines the Privacy Statement for our Services on https://ELXR.sg/ and our other websites and applications. ELXR® Pte Ltd is a Singapore registered, sports technology and consulting company located in Singapore and Japan. The intention of this Privacy Statement is to provide important information about our collection method, testing process, storage and use of Customers’ Personal and Genetic information in relation to your use, participation or purchase of our Services, Products, Software and Web Services. By using or purchasing our Services, you hereby agree and consent to this Privacy Statement, and shall be deemed to constitute your acceptance for ELXR® to access your Personal Information required to provide the Services for the purposes outlined in Section 2. Please be sure to carefully read this ELXR® Privacy Statement before purchasing or using our Services.

The following terms of service (these “Terms of Service”), govern your access to and use of the ELXR® website and mobile application, including any content, functionality and services offered on or through https://ELXR.sg/ or the ELXR® mobile application (the “Site”) by ELXR® Pte Ltd. (110 Lor 23 Geylang, #06-06 Victory Centre, Singapore 388410) and its subsidiaries: as applicable. ELXR® Pte Ltd and its subsidiaries are collectively referred here to as “ELXR®” “we” or “us” and “you” or “user” means you the user of the Services.

Your Personal Information, which includes your name and address, provided to ELXR® will not be used without your consent unless for the following reasons.

1. The information has been made anonymous or aggregated so that you cannot be personally identified; or
2. A legal injunction or request has been made by the applicable judicial or regulatory bodies which require us to disclose such information

1.1   “ELXR®” is the official registered entity name and trademark for ELXR® Pte Ltd, whose principal place of business is located at 110 Lor 23 Geylang, #06-06 Victory Centre, Singapore 388410 When these Terms use the term “ELXR® ” “we” “us” or “our” that refers to ELXR® and its affiliates, and subsidiaries, and each of its and their respective officers, directors, agents, partners and employees. Affiliates include without limitation, ELXR® Singapore and ELXR® Japan as these entities are referenced below.

1.2 “Service” or “Services” can be defined as ELXR®’s products, programmes mobile application(s), any proprietary or licensed software and website(s) used by the user, regardless of its use in connection with a product purchase, or a personal account setup or otherwise.

1.3  “R&D” refers to research and development activities conducted by ELXR® Pte Ltd, its affiliates, or Superfit Pte Ltd, a registered company in Singapore and a business partner of ELXR® Pte Ltd.

1.4  “Personal Information” is defined as information that can be used to identify you or your place of location, either as independent or in conjunction with other information. In order to provide you with the Service(s), we collect and store the following types of Personal Information;

1. “Registration Information” can be defined as information that you provide when you register for and/or purchase ELXR®’s Services, such as name, email, mail address, gender, birthdate, user ID and password, and payment information.
2. [Only where applicable for Users of ELXR® DNA Kit] “Genetic Information” can be defined as information regarding your genotypes which represent genetic variations called single nucleotide polymorphisms (SNPs) at particular locations in your genome. By providing us with your saliva sample, you allow us to extract your DNA and analyze your Genetic Information, and thus, for you to receive the Services. As the DNA sequence of human genome does not change over one’s lifetime, your genotype also does not change, however, an interpretation of the genotype may change depending on further research in the future.
3. “Self-Reported Information” can be defined as all other information voluntarily provided to ELXR®, including but not limited to information regarding your family history, disease history, other health-related information, personal traits, ethnicity, religion and other information through our online surveys or in creating your ELXR® personal account.

1.5 “User Content” can be defined as all information other than Genetic Information [Only applicable for Users of ELXR® DNA Kit] or Self-Reported Information generated by users of ELXR®’s Services and transmitted, whether publicly or privately to or through ELXR®, and includes but not limited to events, data, text, software, photographs, music, audio, video, messages or other materials.

1.6  “Web Behaviour Information” can be defined as information on how you use ELXR®’s website(s) and applications, for example, browser type, domain or page views, collected through log files, cookies, and web beacon technology.

1.7  “Referral Information” can be defined as information provided by you when referring ELXR®’s services to your friends and contacts. Examples of Referral Information can be your name, email, address, and the name and email address of the person you are referring our Services to.

1.8  “User” is anyone who is a registered user of the ELXR® Mobile Application.

1.9 “Organiser,” refers to event creators using the Services to create events displayed on the Services for consumers using our Services (a) to consume information about or attend Events (“Consumers”), or (b) for any other reason. Organisers, Consumers and third parties using our Services are all referred to in these Terms collectively as “Users,” “you” or “your.”

 

2.   OUR PRIVACY PRINCIPLES AND OBJECTIVE

Our Key Privacy Principles and Objective are outlined as follows.

1. To provide, research, analyze and improve our Services in each country and region while adhering to national and local laws and regulations, including methodology for marketing and for advertising purposes.

2. To comply with all applicable laws and regulations that we are subject to in Singapore.

3. Not to sell, lease or rent Personal Information without your explicit consent.

 

3. COLLECTION METHOD AND TYPES OF INFORMATION TO RECEIVE SERVICE(S)

3.1  Information that you will be requested to provide directly to ELXR® is as follows:

1. Registration Information is required to set up your personal account to receive our Services through ELXR®. When you register an account with us, your name, date of birth, billing and shipping address, payment information and contact information may be required.
2. User Content is requested or required when you post, create or upload content, including data, text, software, music, audio, photographs, graphics, video, messages, or other materials through our Services. For example, User Content may include emails made to Customer Support, and may also include Personal Information.
3. Self-Reported Information is Personal Information that may be either mandatory or provided voluntarily. The information may include surveys, forms, features or applications. For example, the survey may require you to provide information regarding your personal traits, ethnicity, disease conditions, other health-related information and family history information for Research Purposes and increases the accuracy of the Services.
4. Referral Information is Information provided by you when you refer a person to ELXR® and/or Superfit Services. When you make referrals using a social network, it may also include information from your profile that is made available to ELXR® when we connect to your social network to post the referral on your behalf.
5. Social Media Features and Widgets (“Features”) may be used on our website, including the Twitter and Facebook’s Like/ Share button. These Features may collect your IP address or set a cookie to enable the Features to function properly.
6. All other information provided by you when contacting our Customer Service, either by email or phone is collected, tracked and stored for the purpose of responding to your inquiries, investigate any violation of the Privacy Statement and our Terms of service or applicable laws or regulations, and to analyze, reply or improve our Services to the Customer.

3.2  Information collected to provide ELXR®’s Services

1. [Only where applicable for Users of ELXR® DNA Kit] Genetic Information that contains your genotypes represent genetic variations known as single nucleotide polymorphisms (SNPs) particular locations in your genome and is obtained when you provide us with your saliva sample and the saliva sample is processed and analyzed by us, or when you otherwise contribute or access your Genetic Information through our Services. Genetic Information includes the result of your genetic testing report as part of our Services, and may be used for other purposes, as outlined in Section 4.
2. ELXR® makes no representations or warranties about the accuracy, reliability, completeness, or timeliness of the Content or about the results to be obtained from using the ELXR® Mobile Application and the Content. Any use of the ELXR® and Content is at your own risk. Changes are periodically made to ELXR® Platforms and may be made at any time. ELXR® further reserves the right to modify, suspend, or discontinue any service on or feature of the ELXR® Sites (including any changes to or removal of Content) at any time with or without notice to you, and ELXR® shall not be liable to you or to any third party should it exercises such rights. Some Content on ELXR® may be provided by third parties, and ELXR® will not be held responsible for any such Content provided by third parties.

3.3 Informtion collected from cookies and similar technologies

Web Behaviour Information is collected by ELXR® and our third-party providers through using cookies and similar technologies (“Technologies”) such as web beacons, tags, scripts and device identifiers. The Technologies are used to recognize your technology selection and allow us to customize and improve your user experience, provide security, analyze usage of our Services, gather demographic information about our user base, offer our products and services to you in a more efficient manner, to monitor our marketing programs and methods, and to conduct targeted advertising on ELXR®’s website(s), applications and other sites on the Internet.

 

4.   USE AND SHARING OF INFORMATION

4.1   Use and Sharing of Information: The intention of the use and share of information provided by you is primarily for us to provide, analyze and improve our Services: Please refer to Section 3 for further details outlining the use and sharing of Information and its definitions. Furthermore, use and sharing of information include, among other things, using your Personal Information in order to;

1. register and operate your account, enable purchases and process payments, implement your requests, and communicate with you;
2. host our website(s), operate our  applications, authenticate your visits, provide custom personalized content and information and track your usage of our Services;
3. conduct web analytics to improve and enhance our Services;
4. offer new products or services to you, such as using emails, promotions or contests;
5. conduct surveys or polls and obtain testimonials;
6. [Only where applicable for Users of ELXR® DNA Kit]  process and deliver your genetic testing results;
7. perform research and development activities.

1. Consent

ELXR® reserves the right to obtain your consent  on any other information or matters that are not outlined above or as requested by you in order to provide Services not mentioned above.

2. Third Party

ELXR® may provide or share your Personal Information to contracted third parties and service providers, which include companies and individual persons that enable ELXR® to provide, serve, evaluate and improve our Services.

Service Provider: The order and payment of our Services is hosted by Shopify Inc., Stripe Inc, RazerPay  and other authorized services, and may be hosted by more than one service source in different regions.  They provide us with the online e-commerce platform that allows us to sell our products and services to you. Your data is stored through the relevant services’ data storage, databases, and their application unless otherwise stated. They store your data on a secure server protected by a firewall. If you choose a direct payment gateway to complete your purchase, then the relevant services (Shopify Inc., Stripe Inc, RazerPay and other authorized services) store your credit card data. It is encrypted through the Payment Card Industry Data Security Standard (PCI-DSS). Your purchase transaction data is stored only as long as is necessary to complete your purchase transaction. After that is complete, your purchase transaction information is deleted. All direct payment gateways adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of credit card information by our store and its service providers. For more information, please refer to the relevant services’ Terms of Service (https://www.shopify.com/legal/Terms), (https://stripe.com/en-sg/legal), (https://www.razer.com/sg-en/legal/) or Privacy Statement (https://www.shopify.com/legal/privacy), (https://stripe.com/en-sg/privacy), (https://razorpay.com/privacy/), (https://www.razer.com/sg-en/legal/razer-pay-sg-terms-conditions)

3. User Verification & Disclosures required by law

In accordance with applicable law, you may be subject to certain vetting methods in connection with your use of the Services, including a verification of identity and criminal background checks. You hereby give your consent for us to perform such verification and background checks in the manner and frequency as we deem reasonably necessary so long as such is performed in compliance with applicable law. Your Personal Information may be subject to disclosure under certain circumstances, such as pursuant to judicial or other government or regulatory subpoenas, warrants, or orders, or in coordination with regulatory authorities. ELXR® will preserve and disclose any and all information to law enforcement agencies or others if required to do so by law or we have reasonable grounds to believe that such preservation or disclosure is necessary to; 1) comply with legal or regulatory process or obligations that ELXR® may owe pursuant to ethical and other professional rules, laws, and regulations; 2) enforce our Terms of Services and other policies; 3) respond to claims that any content violates the rights of third parties; 4) protect the rights, property or personal safety of ELXR®, its users, its employees, its clients and the public. Furthermore, any illegal activities will render your privacy protections invalid and we will submit to the relevant authorities such information required by them for compliance with applicable law.

5.   GENETIC DATA SECURITY AND STORAGE

[Only where applicable for Users of ELXR® DNA Kit], ELXR® works with Genesis Healthcare (Yebisu Garden Place Tower 15F 4-20-3 Ebisu, Shibuya-ku, Tokyo JP 150-6026), which operates genetic research and testing under the Japanese METI (Ministry of Economy, Trade and Industry) guidelines (formulated in 2004 and revised in 2017). In compliance with the Privacy Laws of Japan and Singapore, your Genetic Information will be stored with top-level security 24 hours/365 days at their onsite laboratory. To ensure confidentiality, each person’s samples have their unique barcode to ensure that only you will have access to both your Personal Information and Genetic Information via an account on ELXR® app. ELXR®’s users will have access to their results through the ELXR® app as long as the user account exist.

 

6.   SECURITY MEASURES

ELXR® takes reasonable precautions and follows industry best practices to make sure that your Genetic Information [Only where applicable for Users of ELXR® DNA Kit], IOT Device and Personal Information are not inappropriately lost, misused, accessed, disclosed, altered or destroyed. When you provide your payment information, i.e., credit card information, the information is encrypted using Secure Socket layer technology (SSL) and stored with an AES-256 encryption. Although no method of transmission over the Internet or electronic storage is 100% secure, our service provider and Third-Party Service providers follow all PCIDSS requirements and implement additional generally accepted industry standards.

 

7.    CLOSURE OF ACCOUNT AND CHANGE IN PERSONAL INFORMATION

7.1  Closure of your Account: If you wish to close your account with us and/or withdraw consent previously given, it can be done by sending a request to Customer Service at [email protected] . [Only where applicable for Users of ELXR® DNA Kit] In closing an account, ELXR® removes all Genetic Information, IOT Device Information and User Content within your account within 30 days of our receipt of your request. However, Genetic Information , IOT Device Information and User Content and/or Self- Reported Information that you have previously provided and for which you have agreed to use in ELXR® will not be removed from ongoing or completed studies that use the information. Our genotyping laboratory may also retain your Genetic Information , IOT Device Information and User Content and we may retain backup copies for a limited period of time pursuant to or related to your order history, for accounting and compliance or regulatory inquiry purposes.

7.2  Changes in Personal Information: If you wish to change or update any items in your Personal Information, you can update or correct your information via your Account Settings page.

 

8.   OVERSEAS USERS

This Privacy Statement is intended to cover use of our Services within Singapore. If you are visiting or accessing our website(s) and/or application(s) outside Singapore, please be aware that your Personal information may be transferred to, stored and processed in Singapore where our servers are located, and our central database is operated. The data protection and other laws of Singapore and other countries might not be as comprehensive as those in your country. Please be assured that we seek to take reasonable steps to ensure that your privacy is protected. By using Our Services, you understand that your Personal Information may be transferred to our facilities and those third parties with whom we share it as described in this Privacy Statement.

Under the General Data Protection Regulation (Regulation EU 2016/679) (also known as GDPR), if you are an individual protected by the GDPR you may have certain rights as a data subject. To request information about or avail yourself of those rights, please send an email to [email protected] with the “GDPR Request” in the subject line. In the email please describe, with specificity, the GDPR right you are requesting assistance with. Please note additional information may be requested prior to initiation of a request and that we reserve the right to charge a fee with respect to certain requests. Upon completion of our review, you will be notified if your request has been granted, denied, or exemptions apply.

 

9.  CHANGES TO THIS PRIVACY STATEMENT

ELXR® reserves the right to update and amend this Privacy Statement from time to time. When a change has been made to this Privacy Statement, a Notice of Change or Announcement will be posted on our website or send to you via email.

 

10.   QUESTIONS AND CONTACT INFORMATION

If you have questions about this statement, please contact our Data Protection Office at the following email address: [email protected]