ReMark International B.V. (hereinafter referred to as “ReMark”) develops and licenses BAM/Good Life Application (the “App”), which can be connected to a smartphone or third-party wearable device to access your wellness and fitness information in real time. The App then uses that information to calculate your biological age using a proprietary algorithm called the Biological Age Model BAM™ (“BAM”) and to help you set and track your fitness goals.

This Privacy Policy (this “Policy”) sets out how your personal data (hereinafter “Personal Data”) may be handled by ReMark, its parent company and its affiliates in relation to the App.

To the extent required by law, we will obtain your express consent for certain processing of your personal data. We will use your Personal Data to provide you with the products and/or services available through the App. You understand that your use of the App is voluntary. You do not have to participate in any of the features in the App, and you can stop using the App and delete your account and all accompanying data at any time.

We process, handle and protect your Personal Data with the utmost care. While collecting, processing, using and internationally transmitting Personal Data, we comply with applicable laws and regulations.

The App may contain hyperlinks to third-party websites. ReMark is not responsible for the content or privacy practices of any third-party. We recommend that you carefully review and consider the terms of use and privacy policy of all third-party websites prior to use.

ReMark (Netherland Trade Registration Number: 34122876) is a company established under the laws of The Netherlands with its registered office at Jollemanhof 14a, 1019GW Amsterdam.

Questions about this Policy, the handling of your Personal Data, or our privacy or data protection practices can be submitted via security@remarkgroup.com to our compliance officer.

Subject to applicable laws, you may also contact us, as described above, to inquire about your Personal Data held by us, withdraw consent to continued collection, processing, use or disclosure of your Personal Data where your consent has been obtained by ReMark as expressly required by law, to request access to or supplementation or correction of your Personal Data held by us, or to request a copy of your Personal Data and/or the most up-to-date version of this Policy.

ReMark may collect and process the following Personal Data:

• Name
• Username
• E-mail address
• Date of birth
• Gender
• Reward points earned
• Biological age
• App data (including but not limited to avatar, steps, height, weight, body mass index, resting heart rate, hours of sleep, active calories burnt, stress and oxygen saturation (SPo2)) provided or uploaded by you either manually or generated by the App or through third-party wearable platforms such as (but not limited to) Garmin Connect or Apple HealthKit.
• Personal picture if you affirmatively choose to upload your picture in the App. Uploading a personal picture is not required for use of the App.
• Information about your performance, achievements and activity data (including time of last activity) on the Friends section (including the Activity Dashboard, Friends Leaderboard and tasks, challenges and competitions) if you affirmatively choose to participate to these social features. Participation in the social features is not required in order to use the App.

Additionally, ReMark may collect and process certain data, such as your language preferences, your time zone, IP address, device ID and the date and time when you use or synchronize the App.

You understand that the mandatory data points you must populate in the App are your email address, activity steps, gender, height, weight and date of birth. If you do not provide the mandatory data points, you will not be able to fully utilise the App. All other fields in the App are optional data points that you may elect to provide, including but not limited to hours of sleep, resting heart rate, active calories burnt, stress and SPo2. You understand that the less Personal Data you submit through the App, the lower your potential of and accuracy of reducing your biological age becomes.

ReMark collects your Personal Data when you provide your Personal Data to ReMark directly, when you use the App, and, if you choose to link your third-party wearable device such as Garmin Connect or Apple HealthKit to the App, when you use that third-party’s wearable platform. You understand that this Policy does not apply to the collection and processing of your Personal Data by any such third party’s wearable platform, which privacy policy may substantially differ from this Policy. We recommend that you carefully review and consider the terms of use and privacy policy of all third-party wearable platforms prior to use.

ReMark may collect and process your Personal Data for the following purposes:

• To establish your identity, set up your account and communicate with you concerning your account, including responding to any enquiries you may submit as well as sending emails to facilitate and verify your account creation.
• To provide the products and/or services to you, and information about those products and/or services. This includes fulfilling or meeting the reason for which the information is provided. For example, if you earn reward points under the App, we will use your Personal Data to provide reward points to you. We will also use your Personal Data for the purposes of calculating your biological age and helping you set and track your fitness goals. Where you use other optional features of the App such as “Good Health”, we will also use your Personal Data for the purposes of providing you with such features.
• To allow you to participate in the social features such as the 3D “Gameworld”, Activity Dashboard, Friends Leaderboard, Coach and competitions, should you affirmatively elect to participate in such activities.
• To execute marketing and related activities and to the extent that certain marketing activities require your consent under the relevant laws, we will seek your consent.
• To send you (electronic) commercial messages (newsletters) with information about the products and/or services or request your feedback on use of the App through surveys.
• To review, analyze, monitor, maintain, secure and optimize the App and associated technologies.
• To comply with relevant laws and regulations.
• For testing, research, analysis and product and service development.
• As otherwise permitted by applicable laws.

ReMark respects the privacy of all its App users and takes steps to ensure that we protect the Personal Data you provide us. ReMark may transfer your Personal Data to the following third-parties:

• ReMark’s parent company and ReMark Group, for the purposes of providing the App products and/or services to you.
• BOC Group Life Assurance Company Limited and its affiliates (collectively known as “BOCL Group”), for the purposes of offering reward points and other contents to you.
• Google Cloud, ReMark’s Cloud provider for the purposes of providing the products and/or services to you.
• ReMark’s third-party technology development partner, for purposes of improving the products and/or services provided to you.

These third parties may be located outside of the country in which you are located, including in the Netherlands.

In addition, your Personal Data may be shared with other users if you participate in the Activity Dashboard, Friends Leaderboard, competitions and other social features, which are further described in Article 8 below.

From time to time, we may be compelled by legal action to release or disclose Personal Data, including in connection with a statutory reporting obligation, search warrant, court order, summons, subpoena, or bankruptcy or insolvency proceedings. We may also disclose Personal Data to government agencies in connection with a legal reporting obligation.

In accordance with the applicable laws and regulations, ReMark has taken appropriate and reasonable technical and organizational measures to safeguard the security of your Personal Data, including the following: ReMark stores Personal Data in a secure database that is protected by technical access controls and periodically reviews the information collection, storage and processing practices, including physical security measures, to guard against unauthorized access to our systems.

Our App is not intended for users under the age of eighteen (18) years old. If you are under age eighteen (18), you may not use the App.

Reward Points.In addition to the collection and use of Personal Data as described in Article 4 of this Policy, reward points or “Energy ” may be available to you based upon the Activity Dashboard, Friends Leaderboard, competitions and other features that ReMark, its affiliates and/or BOCL Group may offer. Eligibility for App competitions and reward points will be communicated to you. Your Personal Data may be used by the third parties listed in Article 6 for purposes of administering any competitions and distributing any resulting reward points that you may earn.

Surveys. ReMark will ask you to complete surveys during your use of the App. The results of these surveys may be shared with BOCL Group and/or ReMark clients and prospects on an aggregated basis. When any results of your use of the App and survey responses are published or discussed with anyone outside of ReMark and its affiliates, no information will be included that would reveal your identity.

App Profile. If you do not wish to select an avatar that is available in the App, you may personalize your profile by setting a picture of your choosing, provided that the picture is work-appropriate and does not infringe upon the rights of others. You may remove your picture at any time in the App settings.

Friends Section. You may elect to join the Friends section of the App, where you will be able to add others who are also using the Friends section, individually connect and share your profile and daily achievements with your Friends with a 3D “Gameworld”. You will also be able to see how you compare with your Friends on the Activity Dashboard and Leaderboard. The Activity Dashboard has a total of 4 rankings: (a) biological age; (b) steps; (c) active calories burnt; and (d) the combination of (a), (b) and (c). In the Activity Dashboard and the Leaderboard, your Friends can see your name/username, avatar/profile picture, biological age, steps, active calories burnt, rankings and the last time the App was synchronized. If you want to stop sharing this data with your Friends and stop participating in the Activity Dashboard and/or Friends Leaderboard, you can revoke your access at any time in the App settings.

Coach. Your Personal Data may be used for the Coach to provide you with guidance and support to complete your tasks and challenges.

Good Health. Where you use other optional features of the App such as “Good Health”, we will also use your Personal Data for the purposes of providing you with such features. If you want to stop participating in these features, you can terminate your participation at any time in the App settings.

ReMark keeps your Personal Data or other data that you provide to us, whether or not provided via the App, for as long as necessary for the purposes indicated above and to comply with our legal obligations or as otherwise permitted or required by law. After such period has expired, ReMark will destroy or de-identify Personal Data.

ReMark reviews this Privacy Policy on a regular basis and may change it at any time. Your continued use of the App will indicate that you have read and understood any updates of this Policy.

This Privacy Policy is written in English and Chinese (Simplified and Traditional Chinese). In the event of any discrepancy between the Chinese version and the English version, the English version shall prevail.