Privacy Statement

Your Privacy Matters

World of Wellness’s mission is to help people reach and maintain normal healthy weight.

To achieve our mission, we make services available through our website, mobile applications, practitioner platform and member forums.

Central to this mission is our commitment to be transparent about the data we collect about you, how it is used and with whom it is shared.

This Privacy Policy applies when you use our Services (described below). We offer our users choices about the data we collect, use and share as described in this Privacy Policy.

World of Wellness Privacy Policy

Last revised on 25 June 2018

1. Introduction

PPL Holdings Limited (“we,” “us,” “our,” and “World of Wellness”), the promoter of World of Wellness (collectively “World of Wellness” or the “Services”) operates online platforms for visitors (“ Visitor”), client members (“Client Member ”) and professional members (“Practitioner Member”). People use our Services to learn how to reach and maintain normal healthy weight by following the Skinny World Diet Program (“SWDP ”), learn about the relationship between food and health and connect with others through social media (Twitter, Facebook, Instagram, etc.) to exchange ideas, give and receive support. Our Privacy Policy applies to any Visitor, Client Member or Practitioner Member to our Services.

Content and data on some of our Services is viewable to non-members (“ Visitors”).

All World of Wellness users (“Users”) can share their personal identities, engage with their network, exchange knowledge and health insights, post and view relevant content, give and receive support.

1.1 Services

This Privacy Policy applies to your use of our Services.

This Privacy Policy applies to www.worldofwellness.care, www.skinnyworld.com, www.skinny-world.com and other World of Wellness-related sites, apps, communications and services (“ Services”).

1.2 Data Controllers and Contracting Parties

You are entering into our User Agreement. We control the personal data you provide to us in connection with our Services.

As a User of our Services, the collection, use and sharing of your personal data is subject to this Privacy Policy, other documents referenced in this Privacy Policy and updates.

1.3 Change

Changes to the Privacy Policy apply to your use of our Services after the “effective date.”

We can modify this Privacy Policy, and if we make material changes to it, we will provide notice through our Services, or by other means, to provide you the opportunity to review the changes before they become effective. If you object to any changes, you may close your account.

You acknowledge that your continued use of our Services after we publish or send a notice about our changes to this Privacy Policy means that the collection, use and sharing of your personal data is subject to the updated Privacy Policy.

2. Data We Collect

2.1 Data You Provide to Us

You provide data to create an account with us.

Registration

To create an account, you need to provide data including your name, sex, date of birth, email address, mobile number, height, weight and other health information. If your health criteria are suitable and you decide to proceed to the SWDP, you will also provide a password, payment (e.g., credit card) and billing information.

Creating a complete World of Wellness profile helps you get the most from our Services.

Profile

You are required to provide accurate and true information on your profile, such as your name, sex, date of birth, height, weight and health details. It’s your choice whether to make that sensitive information public. It is your choice whether you want to operate under a pseudonym on our social media platforms.

DO NOT post or add any photographs that you do not want to be made publicly available. This includes any lewd, nude or sexually explicit images of any kind. We retain the right to immediately without notice close an account where such content is posted or uploaded.

Posting and Uploading

We collect personal data from you when you provide, post or upload it to our Services when you provide additional information such as descriptions of your weight, measurements, food, blood pressure, blood glucose level, medications and medical history, fill out a form, or respond to a survey.

You don’t have to post or upload personal data; if you don’t, it may limit your ability to engage with other members.

2.2 Data from Others

Others may post or write about you.

Content and News

You and others may post content that includes information about you (as part of posts and comments) on our Services.

DO NOT post or upload any article or comment that is offensive or intends to denigrate, harm or bully a target. We retain the right to immediately without notice close an account where such content is posted or uploaded.

Contact and Calendar Information

We receive personal data (including contact information) about you when others import or sync their contacts or calendar with our Services, associate their contacts with Member profiles, or send messages using our Services (including invites or connection requests). If you or others opt-in to sync email accounts with our Services, we will also collect “email header” information that we can associate with Member profiles.

Customers and partners may provide data to us.

Partners

We receive personal data about you when you join the services of our customers and partners, such as workplace wellness and customer loyalty programs.

2.3 Service Use

We log your visits and use of our Services, including mobile apps.

We log usage data when you visit or otherwise use our Services, including our sites, app and platform technology (e.g., our off-site plugins), such as when you view or click on content (e.g., slideshows and videos) or ads (on or off our sites and apps), perform a search, install or update one of our mobile apps, share insights and articles. We use log-ins, cookies, device information and internet protocol (“IP”) addresses to identify you and log your use.

2.4 Cookies, Web Beacons and Other Similar Technologies

We collect data through cookies and similar technologies.

We use cookies and similar technologies (e.g., web beacons, pixels, ad tags and device identifiers) to recognize you and/or your device(s) on, off and across different Services and devices. Cookies enable us to identify your device, secure your access to World of Wellness and our sites generally, and help us detect malicious activity or know if someone attempts to access your account from a different device. Cookies help us detect breaches of our User Agreement.

Cookies enable you to easily share content on World of Wellness, fill out forms and help us serve relevant ads to you. Cookies make your interactions with World of Wellness faster and more secure.

Cookies are also used for performance research and analytics. We use cookies to understand, improve, and research products, features, and services, including when you access World of Wellness from other websites, applications, or devices such as your work computer or your mobile device.

We use two types of cookies, persistent cookies and session cookies:

  1. persistent cookies helps us recognize you as an existing user, so it’s easier to return to World of Wellness or interact with our services without signing in again. After you sign in, a persistent cookie stays in your browser and will be read by World of Wellness when you return to one of our sites or a partner site that uses our services (for example, Skinny World);
  2. session cookies last for as long as the session (usually the current visit to a website or a browser session).

By continuing to visit or use our services, you are agreeing to the use of cookies and similar technologies for the purposes we describe in this policy.

You can control cookies through your browser settings.

2.5 Your Device and Location

We receive data from your devices and networks, including location data.

When you visit or leave our Services (including our plugins or cookies or similar technology on the sites of others), we receive the URL of both the site you came from and the one you go to next. We also get information about your IP address, proxy server, operating system, web browser and add-ons, device identifier and features, and/or ISP or your mobile carrier. If you use our Services from a mobile device, that device will send us data about your location based on your phone settings. We will ask you to opt-in before we use GPS or other tools to identify your precise location.

2.6 Messages

If you communicate through our Services, we learn about that.

We collect information about you when you send, receive, or engage with messages in connection with our Services. For example, if you get a World of Wellness connection request, we track whether you have acted on it and will send you reminders. We also use automatic scanning technology on messages.

2.7 Workplace and Customer Loyalty Program Provided Information

When your employer or Customer Loyalty Program provide a World of Wellness Service for you to use, they give us data about you.

Services bought for your use, such as through your employer or a customer loyalty program provider, provide us with personal data about you.

2.8 Sites and Services of Others

We get data when you visit sites that include our plugins, ads or cookies or log-in to others’ services with your World of Wellness account.

We receive information about your visits and interaction with services provided by others when you log-in with World of Wellness or visit others’ services that include our plugins, ads, cookies or similar technologies.

2.9 Other

We are improving our Services, which means we get new data and create new ways to use data.

Our Services are dynamic, and we often introduce new features, which may require the collection of new information. If we collect materially different personal data or materially change how we use your data, we will notify you and may also modify this Privacy Policy.

3. How We Use Your Data

We use your data to provide, support, personalize and develop our Services.

How we use your personal data will depend on which Services you use, how you use those Services and the choices you make in your Account Details settings. We use the data that we have about you to provide and personalize, including with the help of automated systems and inferences we make, our Services (including ads) so that they can be more relevant and useful to you and others.

3.1 Services

Our Services help you connect with others, stay informed, get support, give and receive tips.

We use your data to authorize access to our Services.

Stay Connected

Our Services allow you to stay in touch and up to date with your network of contacts including if authorized a medical practitioner or health coach. To do so, you will “connect” with the other Members of your choice, and who also wish to “connect” with you. Subject to your Account Details settings, when you connect with other Members, you may be able to search each others’ connections in order to connect with them also.

We will use profile data about you (such as information you agree to make public) to help others find you, suggest connections for you and to enable you to invite others to become a Member and connect with you.

You can opt-in to allow us to use your precise location or proximity to others.

It is your choice whether to invite someone to our Services, send a connection request, or allow another Member to become your connection. When you invite someone to connect with you, your invitation will include your name or pseudonym, photo, network and contact information. We will send invitation reminders to the person you invited. You can choose whether or not to share your own list of connections with your connections.

Visitors have choices about how we use their data.

Stay Informed

Our Services allow you to stay informed about health, nutrition and weight loss topics you care about. We use the data we have about you (e.g., data you provide, data we collect from your engagement with our Services and inferences we make from the data we have about you), to recommend relevant content and conversations on our Services. So, if you let us know that you are interested in a topic (e.g., by viewing content or watching a video), we will use this information to personalize content in your feed, suggest that you connect with certain members on our site, or watch related learning content to help you towards your goal. We use your content, activity and other data, including your name and picture, to provide notices to your network and others. For example, subject to your Account Details settings, we may notify others that you have updated your profile, posted a blog, took a social action, made new connections or were mentioned in the news.

3.2 Live Support Services

Our Live Support Services allow paying Members to engage with a World of Wellness Consultant.

Members who purchase a VIP Cancer Recovery Package or Health or Nutrition e-Consultation agree to use of their personal health data by the World of Wellness Consultant for the purpose of receiving customized care and mentoring. A World of Wellness Consultant can view your profile and any data you upload, store information about you in their Dr Diary, such as consultation notes and history, health information and informed consent. Data they document about you by a World of Wellness Consultant is subject to the policies of those Members.

3.3 Communications

We contact you and enable communications between Members. We offer settings to control what messages you receive and how often you receive some types of messages.

We will contact you through email, mobile phone, notices posted on our websites or apps, messages to your World of Wellness inbox, and other ways through our Services, including text messages and push notifications. We will send you messages about the availability of our Services, security, or other service-related issues. We also send messages about how to use the Services, network updates, reminders and promotional messages from us and our partners. You may change your communication preferences at any time. Please be aware that you cannot opt-out of receiving service messages from us, including security and legal notices.

We also enable communications between you and others through our Services, including for example invitations, groups and messages between your network connections.

3.4 Marketing

We promote our Services to you and others.

We use data and content about Members for invitations and communications promoting membership and network growth, engagement and our Services.

3.5 Developing Services and Research

We develop our Services and conduct research.

Service Development

We use data, including public feedback, to conduct research and development for the further development of the SWDP and our Services in order to provide you and others with a better, more intuitive and personalized experience, drive membership growth and engagement on our Services, and help connect Members to each other.

Other Research

We publish or allow others to publish scientific articles about the effectiveness of health protocols promoted on World of Wellness under controls that are designed to protect your privacy (e.g., deidentified personal and health data). We use the personal data available to us to research health trends of people who follow World of Wellness information. Such articles are presented as aggregated data rather than personal data. In some cases, we work with trusted third parties to perform this research.

Surveys

Polls and surveys are conducted by us and others through our Services. You are not obligated to respond to polls or surveys, and you have choices about the information you provide. You may opt-out of survey invitations.

3.6 Customer Support

We use data to help you and fix problems.

We use the data (which can include your communications) to investigate, respond to and resolve complaints and Service issues (e.g., bugs).

3.7 Aggregate Insights

We use data to generate aggregate insights.

We use your data to produce and share aggregated insights that do not identify you. For example we may use your data to generate statistics about our Members.

3.8 Security and Investigations

We use data for security, fraud prevention and investigations.

We use your data (including your communications) if we think it’s necessary for security purposes or to investigate possible fraud or other violations of our User Agreement or this Privacy Policy and/or attempts to harm our Members or Visitors.

4. How We Share Information

4.1 Our Services

Any data that you include on your profile and any content you post or social action (e.g. likes, follows, comments, shares) you take on our Services will be seen by others.

Profile

You remain in control of the information on your profile that is visible to Visitors and Members of our Services. Subject to your Account Details settings, information is visible to others on or off of our Services (e.g., Visitors to our Services or users of third- party search engines). Your settings, degree of connection with the viewing Member, the subscriptions they may have, their usage of our Services, access channels and search types (e.g., by name or by keyword) impact the availability of your profile and whether they can view certain fields in your profile.

Posts, Likes, Follows, Comments, Messages

Our Services allow viewing and sharing information including through posts, likes, follows and comments.

  • When you share an article or a post (e.g., an update, image, video or article) publicly it can be viewed by everyone and re-shared anywhere (subject to your Account Details settings). Members, Visitors and others will be able to find and see your publicly-shared content, including your name or pseudonym (and photo if you have provided one).
  • In a group, posts are visible to others in the group. Your membership in groups is public and part of your profile, but you can change visibility in your Account Details settings.
  • If you are a Workplace Wellness or Customer Loyalty client, any information you share may be seen by the company that employs you or the Customer Loyalty partner with whom you have engaged.
  • When you follow a person, you are visible to others and the “page owner” as a follower.
  • We let senders know when you act on their message, subject to your Account Details settings where applicable.
  • Subject to your Account Details settings, we let a Member know when you view their profile.
  • When you like or re-share or comment on another’s content (including ads), others will be able to view these “social actions” and associate it with you (e.g., your name or pseudonym, profile and photo if you provided it).

If you are a Workplace Wellness client your employer can see how you use our Services and related information. We will not show them your photographs, interactions with a GP, coach or consultant or any personal messages in social media.

4.2 Communication between Client Members and Practitioner Members

Communication between a Client Member and Practitioner Member is only shared between the Client Member and Practitioner Member.

If you do not wish to have your information seen or stored by a Practitioner Member, do not share your file with them and do not book an appointment with them.

If you select ‘Stop Sharing with Doctor’ on the Interactive Buttons on your Dashboard, your profile will cease to be shared with approved Practitioner Members, however information recorded about you by a Practitioner Member will continue to be viewed by them.

4.3 Our Related Services

We share your data across our related Services.

As we are able to identify you across different Services using cookies or similar technologies, we may combine information internally across our different Services and share your personal data with our affiliate business (“World of Wellness”), to provide you with enhanced health and wellness Services.

4.4 Service Providers

We may use others to help us with our Services.

We use others to help us provide our Services (e.g., maintenance, analysis, audit, payments, fraud detection, marketing and development). They will have access to your information as reasonably necessary to perform these tasks on our behalf and are obligated not to disclose or use it for other purposes.

4.5 Legal Disclosures

We may need to share your data when we believe it’s required by law or to help protect the rights and safety of you, us or others.

It is possible that we will need to disclose information about you when required by law, subpoena, or other legal process or if we have a good faith belief that disclosure is reasonably necessary to:

  1. investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies;
  2. enforce our agreements with you;
  3. investigate and defend ourselves against any third-party claims or allegations;
  4. protect the security or integrity of our Service (such as by sharing with companies facing similar threats); or
  5. exercise or protect the rights and safety of World of Wellness, our Members, personnel, or others.

We attempt to notify Members about legal demands for their personal data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.

4.6 Change in Control or Sale

We may share your data when our business is sold to others, but it must continue to be used in accordance with this Privacy Policy.

We can also share your personal data as part of a sale, merger or change in control, or in preparation for any of these events. Any other entity which buys us or part of our business will have the right to continue to use your data, but only in the manner set out in this Privacy Policy unless you agree otherwise.

5. Your Choices & Obligations

5.1 Data Retention

We keep most of your personal data for as long as your account is open.

We retain your personal data while your account is in existence or as needed to provide you Services. This includes data you or others provided to us and data generated or inferred from your use of our Services. Even if you only use our Services for a limited time during a single round of the SWDP, we will retain your information and keep your profile open until you decide to close your account. Even if you do decide to close your account we will retain certain information (e.g., your profile) in a depersonalized or aggregated form.

5.2 Rights to Access and Control of Your Personal Data

You can access or delete your personal data. You have many choices about how your data is collected, used and shared.

We provide many choices about the collection, use and sharing of your data, from deleting or correcting data you include in your profile and controlling the visibility of your posts to advertising opt-outs and communication controls. We offer you Account Details settings to control and manage the personal data we have about you.

For personal data that we have about you:

  • Delete Data: You can ask us to erase or delete your personal data (e.g., if it is no longer necessary to provide Services to you).
  • Change or Correct Data : You can edit some of your personal data through your account. You can also ask us to change, update or fix your data in certain cases, particularly if it’s inaccurate.
  • Right to Access and/or Take Your Data: You can ask us for a copy of your personal data and can ask for a copy of personal data you provided in machine readable form.

You may contact us about your personal data using the Send Feedback option on your Account Details settings.

5.3 Account Closure

We keep some of your data even after you close your account.

If you choose to close your World of Wellness account, your personal data will generally stop being visible to others on our Services within 24 hours. We generally delete closed account information within 30 days of account closure, except as noted below.

We retain your personal data even after you have closed your account for the purpose of research and development and if reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse, enforce our User Agreement, or fulfil your request to “unsubscribe” from further messages from us.

We will retain de-personalized information in your profile after your account has been closed.

Information you have shared with others (e.g., through group posts) will remain visible after you close your account or delete the information from your own profile, and we do not control data that other Members copied from our Services. Groups content and ratings or review content associated with closed accounts will show an unknown user as the source. Your profile may continue to be displayed in the services of others (e.g., search engine results) until they refresh their cache.

6. Other Important Information

6.1. Security

We monitor for and try to prevent security breaches. Please use the security features available through our Services.

We implement security safeguards designed to protect your data, such as HTTPS. We regularly monitor our systems for possible vulnerabilities and attacks. However, we cannot warrant the security of any information that you post, upload or send us. There is no guarantee that data may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.

6.2. Cross-Border Data Transfers

We store and use your data outside your country.

We process data both inside and outside of Singapore and rely on legally-provided mechanisms to lawfully transfer data across borders. Countries where we process data may have laws which are different, and potentially not as protective, as the laws of your own country.

6.3 Lawful Bases for Processing

We have lawful bases to collect, use and share data about you. You have choices about our use of your data.

At any time, you can withdraw consent you have provided by going to your Account Details settings.

We will only collect and process personal data about you where we have lawful bases. Lawful bases include consent (where you have given consent), contract (where processing is necessary for the performance of a contract with you (e.g. to deliver the Services you have requested) and “legitimate interests”.

Where we rely on your consent to process personal data, you have the right to withdraw or decline your consent at any time and where we rely on legitimate interests, you have the right to object.

6.4. Direct Marketing and Do Not Track Signals

Our statements regarding direct marketing and “do not track” signals.

We currently do not share personal data with third parties for their direct marketing purposes without your permission.

6.5. Contact Information

You can contact us or use other options to resolve any complaints.

If you have questions or complaints regarding this Privacy Policy, please first contact us online here.

You can also reach us by physical mail at:

PPL Holdings Limited
50 Raffles Place
#15-05/06 Singapore Land Tower
Singapore 048623