DEBI Privacy Policy

By using the DEBI platform (the "Platform"), corporate subscribers and its employees (“User") (hereinafter collectively referred to as “you") agree to be bound by the following Privacy Policy (as modified from time to time), so that you are aware of your legal rights and obligations with respect to Fermion Labs Sdn. Bhd. and Fermion Labs' Affiliates i.e. our subsidiaries, associated companies or jointly-controlled entities (hereinafter referred to as "Fermion Labs", "we", "our" or "us"). Fermion Labs shall have the right to modify, update or amend this Privacy Policy at any time by placing the updated Privacy Policy on the Platform. By continuing to use the Platform or its services, or products or services relating to insurance, financial, wellness and health, offered from time to time (“Offerings") through the Platform following any of the modifications, updates or amendments to this Privacy Policy, you signify your acceptance of such modifications, updates or amendments. Please read this Privacy Policy carefully before using the Platform. In the event that you do not agree to or accept this Privacy Policy, you should immediately cease any usage of or access to the Platform.

  1. As individual users, or, the individual representatives of our corporate subscribers, you are to provide to Fermion Labs with personally identifiable data about yourselves and/or your family members and/or other dependents (with all consent, license and/or permissions required having been obtained from such family members and/or other dependents) ("Personal Data") in connection with the purpose of the Platform and in accordance with paragraph 2 below, including delivery of the Offerings, preparation of proposals, provision of quotations, managing claims and client relationship management. Such Personal Data may include information or data provided by you (voluntarily or by way of information storage through your usage of the Platform) or your employer who is our corporate subscriber or other parties or from other source, and may include, but is not limited to, historical or existing data and/or data to be collected in the future. Such Personal Data may be subject to applicable data protection, privacy and other similar laws and may include copies and other details of identity documents, proof of address and other contact details, religious affiliation, personal financial information (including but not limited to salaries), biometric data, facial recognition (including facial mathematical representations) data, information concerning age, height, weight, gender, marital status, racial or ethnic origin, education, genetic or sexual life, physical or mental health or medical condition/diagnosis, water intake and other personal preferences (including but not limited to dietary, interests and hobbies). Such Personal Data may also include technical information about your device, system and application software, and peripherals, and information regarding your location gathered periodically; as well as your fitness activity information (hereinafter referred to as “Physical Activity Data"). We may require you to provide certain information in addition to the Personal Data as reasonably required and in the event that such information is not provided by you, we have the right to refuse any provision of the Offerings to you.

    With regards to corporate subscribers, when providing Fermion Labs with Personal Data relating to the Users, their family member and/or dependents and/or other individuals that the corporate subscriber represents, the corporate subscribers will observe the provisions of any data protection or privacy legislation as applicable from time to time the extent applicable to this Privacy Policy. This includes, without limitation: (i) an obligation, if any, for the corporate subscribers to obtain any required consent(s) in respect of the transfer of information to Fermion Labs by the provider or any third party relating to an identified or identifiable individual that is subject to applicable data protection, privacy or other similar laws and (ii) any obligation with respect to the use, disclosure and transfer by Fermion Labs of Personal Data as necessary to carry out its obligations under this Privacy Policy.

  2. Personal Data you provide and explicitly consent to will be collected, used and otherwise processed by Fermion Labs for the following purposes:
    1. Create, administer and update your account (including customization of your personalized health profile) on the Platform;
    2. Verify your identity; your age and your employment records with the relevant corporate subscribers;
    3. offer, obtain, provide, facilitate or maintain wellness, health and/or insurance or financial Offerings;
    4. DEBI wellness challenges whereby Physical Activity Data such as steps, fitness activities carried out, water intake, distance and duration from third party platforms (or as voluntarily provided by you), will be collected to process your fitness activity for “Walkathon Wellness Challenge"available on the Platform;
    5. enable features that personalise your experience on the Platform, such as lists of your favourite products and regular services,
    6. perform internal operations necessary to provide our services, including troubleshooting software bugs and operational problems, conducting data analysis, testing and research, monitoring and analysing usage and activity trends;
    7. process and manage your transactions;
    8. process, manage or verify your application or purchase of vouchers and subscriptions on the Platform;
    9. the delivery of Offerings to the Users, including any customer support issues;
    10. those purposes specifically provided for in any Offerings by Fermion Labs or the DEBI Benefits Panel;
    11. conducting marketing and client profiling activities in connection with insurance, financial, wellness and health related Offerings (including those provided by Fermion Labs, other members of the Fermion Labs, and selected third parties for the purpose of improving our services to the Users or that we think may interest the Users);
    12. Fermion Labs' internal record-keeping;
    13. meeting any legal or regulatory requirements relating to Fermion Labs' provision of the Offerings and to make disclosure under the requirements of any applicable law, regulation, direction, court order, by-law, guideline, circular, code applicable to Fermion Labs;
    14. to be shared with our vendors, joint venture partners, business partners and service providers in connection with the Platform and/or the Offerings; and
    15. purposes ancillary or relating to any of the above (including but not limited to information relating to your claims history for research, benchmarking and statistical analysis).

    3. Collection and Disclosure

  3. Personal Data provided to Fermion Labs will generally be kept confidential but you hereby consent and authorize Fermion Labs to collect, provide or disclose your Personal Data for the purposes stated in Paragraph 2 of this Privacy Policy above to:
    1. any of the DEBI Benefits Panel and their agents for the provision of the Offerings to you or for the purposes specified above;
    2. any agent, contractor or third-party service provider who provides membership servicing support;
    3. relevant parties arranging insurance or providing claims services or benefits administration services or wellness services such as insurance companies, health maintenance organisations, agents and service providers (including but not limited to consultants, service call centres, market research and quality assurance companies);
    4. Your corporate employers who are our corporate subscribers;
    5. government agencies and industry regulators;
    6. Fermion Labs' auditors, accountants, lawyers or other financial or professional advisers;
    7. such sub-contractors or third-party service or product providers as Fermion Labs may determine to be necessary or appropriate, in accordance with paragraph 2 and paragraph 9 of this Privacy Policy;
    8. any person to whom Fermion Labs is compelled or required to do so under law or in response to a competent or government agency; and
    9. such person(s) as you may instruct or require.
  4. Your Physical Activity Data will be automatically retrieved to import your fitness activity information from other platforms such as listed below, after you explicitly consent the Platform to transfer when you connect to such services:
    1. Apple HealthKit. We use Apple's (Apple Inc., 1 Infinite Loop, Cupertino, CA 95014, USA; “Apple") HealthKit framework which provides a central repository for health and fitness data on iPhone and Apple Watch – with your explicit consent – lets the Platform communicate with the HealthKit store to access and share this data. We process the following data, obtained through the HealthKit framework, for the purposes described above and with explicit consent by the user: steps, distance, and duration. New data attributes may be added to the HealthKit framework, which will be portrayed in the Platform and which you have to consent to. We do not use information gained through the HealthKit framework for advertising or similar services. You can always stop the Platform from accessing data by changing the settings of your mobile device.
    2. Google Fit. We use Google Fit which is an open platform that lets users control their fitness data. We process the following data, obtained through Google Fit, for the purposes described above: steps, distance and duration. New data attributes may be added to the Google Fit framework, which will be portrayed in the Platform and which you have to consent to.
    3. Health Connect. We use Health Connect which is an open platform that lets users control their fitness data. We process the following data, obtained through Health Connect, for the purposes described above: steps, distance and duration. New data attributes may be added to the Health Connect framework, which will be portrayed in the Platform and which you have to consent to.
    4. Third party platforms as Fermion Labs may determine to be necessary or appropriate, in accordance with paragraph 2 and paragraph 9 of this Privacy Policy;
  5. You further consent to provide, and for your employer who is our corporate subscriber, insurer(s), health maintenance organizations, agents and/or third-party service or product provider(s) to provide to Fermion Labs your Personal Data for the purposes set out in paragraph 2 above.
  6. Failure to provide such Personal Data or withdrawing your consent from providing such Personal Data may result in Fermion Labs being unable to provide users with the Offerings requested.

    7. Safeguards

  7. Fermion Labs confirms that Fermion Labs has implemented the appropriate technical and organizational security measures and procedures in accordance with the applicable laws and regulations to prevent the unauthorized or unlawful processing of your Personal Data and the accidental loss or destruction of, or damage to, your Personal Data.
  8. We retain your Personal Data for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or allowed by law. Once your Personal Data is no longer necessary for the services or purposes, or we no longer have a legal or business purpose for retaining your Personal Data, we take steps to erase, destroy, anonymise or prevent access or use of such Personal Data for any purpose other than compliance with this Privacy Policy, or for purposes of safety, security, fraud prevention and detection, in accordance with the requirements of applicable laws.

    9. Data Transfer

  9. Where Fermion Labs consider it necessary or deemed appropriate for the purposes of data storage or processing or providing any service or product on our behalf to you, we may transfer your Personal Data to Fermion Labs' Affiliates or in accordance with paragraph 3 of this Privacy Policy above within or outside the country in which Fermion Labs is established, under conditions of confidentiality and similar levels of security safeguards.

    10. Your Rights of Access and Correction

  10. You have the right to request access to and correction of information about you held by Fermion Labs and you may:
    1. check whether Fermion Labs holds or uses your Personal Data and request access to such data;
    2. request that Fermion Labs correct any of your personal information that is inaccurate, incomplete or out-of-date;
    3. request that Fermion Labs specify or explain its policies and procedures in relation to data and types of Personal Data handled by Fermion Labs; and
    4. communicate to Fermion Labs your objection to the use of your personal information for marketing purposes whereupon Fermion Labs will not use your Personal Data for these purposes; and
    5. withdraw, in full or in part, your consent given previously,
      6. in each case subject to any applicable legal restrictions, contractual conditions, reasonable internal policies/procedures, a reasonable time period (in accordance with applicable laws) as well as, in the case of an access request, a reasonable fee (where permitted under applicable laws and as Fermion Labs may notify you in writing upon receipt of your request). In the event that you withdraw your consent to provide the Personal Data, we may be able to continue to process your Personal Data to the extent required or otherwise permitted by applicable laws and regulations.

    11. Cookies

  11. Fermion Labs, and third parties with whom we partner, may use cookies, web beacons, tags, scripts, local shared objects such as HTML5 and Flash (sometimes called “flash cookies"), advertising identifiers (including mobile identifiers such as Apple's IDFA or Google's Advertising ID) and similar technology including strictly necessary cookies and analytical/performance cookies (“Cookies") in connection with your use of the Platform on your computer or mobile device, in emails we send to you, and on our web pages. Cookies may transmit Personal Data about you and your use of the Platform, such as your browser type, search preferences, IP address, data relating to advertisements that have been displayed to you or that you have clicked on, and the date and time of your use. Cookies may be persistent or stored only during an individual session.
  12. Fermion Labs may allow third parties to use Cookies on the Platform on its website and mobile applications to collect the same type of Personal Data for the same purposes Fermion Labs does for itself. Third parties may be able to associate the Personal Data they collect with other Personal Data they have about you from other sources. We do not necessarily have access to or control over the Cookies they use.
  13. Additionally, we may share non-personally identifiable Personal Data with third parties, such as location data, advertising identifiers, or a cryptographic hash of a common account identifier (such as an email address), to facilitate the display of targeted advertising on third party platforms. You agree that we shall not be held responsible for any issues arising from such third party platforms and that we are not required to ensure that you are advised of the risks in connection with the sharing of such Personal Data on these third party platforms.
  14. If you do not wish for your Personal Data to be collected via Cookies on the websites, you may deactivate cookies by adjusting your internet browser settings to disable, block or deactivate cookies, by deleting your browsing history and clearing the cache from your internet browser. You may also limit our sharing of some of this Personal Data through your App (Settings > Privacy > Ads) and mobile device settings.
  15. In respect of your Personal Data received by us, Fermion Labs is a Data User; while your respective corporate employers are independent Data Users in respect of Personal Data disclosed to or received from Fermion Labs. As independent data users, Fermion Labs and the corporate employers individually determine the purposes and means of processing Personal Data, subject to the provisions set out in this Privacy Policy. Fermion Labs and the individual employers are also individually responsible to ensure the protection of Personal Data under their charge.
  16. Written requests for access to Personal Data or correction and/or deletion of Personal Data or for information regarding policies and procedures and types of Personal Data handled by Fermion Labs may be sent to pdpa@debiwellness.com.