Metro Pacific Health Tech Corporation doing business under mWell PH (the “Company”) is committed to collecting and processing personal data in a manner that complies with the applicable laws and regulations on data privacy, including the Philippine Data Privacy Act of 2012 (“DPA”) and its implementing rules and regulations (“DPA IRR”).

By your use of our application (the “Application”) and any services provided through the Application (the “Service”), you consent to the collection, use, storage, disclosure, transfer, sharing and processing of your personal information and sensitive personal information in accordance with this Privacy Policy.

When We Collect Your Personal Data

We collect your personal data through the following:

• When you register and create an account. When you register, you provide us your name and email address. If you are a doctor or psychologist, you may also be requested to provide us details on your employment, education and/or organization.
• When you purchase products using our Application. You may purchase products offered on our online store and by doing so, you provide us your personal information such as residential/office address, contact number, credit/debit card information, and bank account details
• When you use the telemedicine feature of the Application. You have the option to avail of the telemedicine feature of the Application and by doing so, you provide us and the healthcare provider your personal and health information including your name, age, gender, medical information and medical history, health complaints, vital signs, results of laboratory examinations and other information necessary for diagnosis
• When you utilize our fitness and nutritional programs. You may utilize the fitness and nutritional programs featured on our Application and by doing so, you provide us your personal, health, and medical information
• When you file customer complaints, inquiries, and/or concerns through the Application or other platforms. When you lodge a complaint with us or ask specific inquiries, through the Application or other platforms of the Company such as social media and email, you provide us your name, contact number, email address and your specific concern.

Why We Collect Your Personal Data

We collect and process your personal data for the following purposes:

a. To provide the Services.

      I. When you use the telemedicine feature of the Application, we and your healthcare provider collect and process personal data and health information about you to allow your healthcare provider to give an independent medical assessment and recommend a course of treatment.

      II. When you purchase products, we process your personal data to complete your purchase and deliver your order/s.

      III. When you utilize our fitness and nutritional programs, we process your personal, health, medical, and fitness tracker information to provide you with your mWellness score, or to customize your           fitness training, workouts, and meal plans.

      IV. When you file a specific concern or ask specific inquiries, we process your personal data to address your complaints and/or answer your questions.

b. For marketing, historical, statistical, and/or scientific purposes.

1. We may use your personal data for direct marketing purposes to, among others, improve our services and products, and tailor our marketing information to include products that you may be interested in. Your healthcare provider may use your personal data and health information for marketing and scientific research purposes.

c. For health policy, planning and research purposes.

1. We may use your personal data for submission to public authorities such as the Department of Health, Department of Interior and Local Government, and Philippine Health Insurance Corporation.

d. To comply with, and as allowed, by applicable law.

1. We may use your personal data to comply with legal obligations imposed on us or for other purposes as may be allowed by law.

When We Disclose Your Personal Data

We may be required to disclose your personal data to our agents, subsidiaries, affiliates, business partners, and other third-party agencies and service providers as part of our regular business operations only to the extent as is necessary to provide you with the Service.

We have outsourced or may have outsourced the processing of your personal data in order to achieve the purposes stated above.In some instances, we may also be required to disclose your personal data to law enforcement and government agencies but only when required by any applicable law. We ensure that your personal data is disclosed on a confidential basis and in compliance with the DPA and its IRR.

Your Google User Data

In case registration is conducted via Google, your name and e-mail address will be your “Google User Data” saved in mWell’s database. Health tracker information that you provide will also be part of your Google User Data.

Your Google User Data will be used for the following purposes:

To complete your User Profile.

We use your Google User Data to populate your User Profile. This allows us to understand who is requesting the Services below and to whom requested or necessary information should be sent.

For necessary communications.

We also use your Google User Data, specifically your e-mail address, to provide you the following forms of communication necessary for your use of the Services:

1. Verification codes to confirm the validity of your e-mail address;
2. Links to reset your password in case you have forgotten your mWell account password;
3. Notifications related to your telemedicine consultations;
4. Breakdowns of your e-shop purchases.

Your Google User Data is shared as follows:

a. Your name and e-mail address are shared with our e-shop merchants to in order to fulfill your purchases.

b. Your fitness tracker data is shared with our partner for the generation of your mWellness score.

How We Protect Your Personal Data

We use commercially reasonable efforts to employ up-to-date administrative, physical, and technical safeguards designed to protect your personal data from unauthorized and fraudulent collection, access, disclosure, use, and other unlawful activities. We also take steps to ensure that our agents, subsidiaries, affiliates, business partners, and other third-party agencies and service providers that have access to your personal data take steps to protect the same.

We will generally retain your personal data for so long as the purposes for which we collected and processed them remain and until such purposes have been served.

Retention of Your Personal Data

We will retain your personal data for such period as may be necessary to achieve our legitimate business purposes. Unless retention for a longer period is required for reasonable cause, your personal data shall, upon the lapse of the retention period, be disposed in accordance with applicable laws and regulations.

Your Rights under the DPA

As an individual whose personal data is collected, stored, and processed, you are entitled to (subject to the exceptions set out in the DPA) the following rights:

a. Be informed whether your personal data is being collected, stored, and processed;

b. Upon written request, be given reasonable access to your personal data and/or obtain a copy of the personal data you have provided to us (in physical or electronic format);

c. Have your personal data rectified of any inaccuracy or error;

d. Suspend, withdraw, or request the blocking, removal, or destruction of your personal data; and

e. Withdraw your consent to the processing of your personal data at any time by immediately ceasing using the Service.

Your Choices and Opting-out

We will send you periodic promotional or informational emails, but only if you previously agreed to receive marketing communications. When you register with us, we will ask if you would like to receive marketing communications, and you have the right to opt-out at any time. You can exercise this right by clicking on the “unsubscribe” link in the marketing emails we send you. Please note that it may take up to fifteen (15) business days for us to process opt-out requests. If you opt out of receiving marketing and advertising emails from us, we will still send you emails about your account and any Service you have requested or received from us.

We reserve the right, in our sole discretion, to amend this Privacy Policy at any time and for any reason. You will be notified of any changes via e-mail, or via the posting of an updated version on our Application. All changes shall take effect seven (7) days after the date of our email or the date on which we posted the amended Privacy Policy on our Application, as the case may be. If you do not agree with any aspect of the updated Privacy Policy, you must immediately cease availing the Service or using our Application.

If you have any questions regarding our Privacy Policy or want to exercise any of your rights as provided in this Privacy Policy or in the applicable data privacy laws and regulations in the Philippines, you can reach us through our Data Protection Officer with the relevant contact details as follows:

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Data Protection OfficerMetro Pacific Health Tech Corporation9/F Rockwell Business Center Tower 1Ortigas Ave., Pasig City8 888-0888privacy@mwell.com.ph

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