PRIVACY NOTICE

Why Privacy?

We are serious about our responsibility to look after the information you give us. We collect various information about you when you use the Pulse App. This notice tells you:

• Who we are;
• What information we collect and why;
• Where we get your information from and who we share it with;
• What you can ask us to do; and
• How to contact us if you need to.

Who are we?

For data collected and/or processed through the Pulse App in its own name and account, the personal data user or controller is Prudential Services Asia Sdn Bhd (the “App Provider”, “our” “us” or “we”) and the Prudential life insurance entity in your country (listed in Appendix 2), each acting as a separate data user or data controller. The Prudential life insurance entity in your country will process your personal data in accordance with their own Privacy Notice which you may access via the websites indicated in Appendix 2.

For data collected and/or processed by the Hosted App Providers, or by the App Provider on behalf of the Hosted App Providers, the personal data user or controller will be the respective Hosted App Providers who will process your personal data in accordance with their privacy notices, as the case may be.

What data do we collect and where do we collect it from?

Providing your personal data is voluntary. However, if you do not provide your personal data, we may be unable to register you for the Pulse App or provide the Pulse App Services or your use of or access to the Pulse App may be otherwise limited

We collect the following data about you:

1. (a) Personal data you provide:

   • Personal and contact details such as, your name, address, telephone number, email address, other third party login information (e.g. social media logins) where you choose to use them;
   • Biometric information (including facial images) where you choose to use any aspect of the Pulse App Services or Hosted App Services that may require them
   • Your gender, date of birth and/or age (if required for use of a service);
   • Your identification number or passport number (if required for use of a service);
   • Records of any contact you have with us;
   • Details you provide when you elect to participate in any activities conducted by us relating to the Pulse App;
   • Details requested by a Hosted App Provider where we process personal data on their behalf; or
   • Details related to your health and medical history ("Health Data") that you have provided to a Hosted App Provider, but only where you have specifically consented to the Hosted App Provider disclosing that Health Data to us for a particular purpose. Where required by applicable laws or regulation, any processing of Health (and where relevant other sensitive) Data, will be based on your explicit consent.

   (b) Personal data we collect from other sources:

   • Data from other Pulse users who recommend you to us (e.g. your email address or mobile phone number);
   • other third party login information (e.g. social media logins) where you choose to use them;
   • From Hosted App Providers (e.g. Health Data) and other third parties, such as agents and distributors;
   • From members of Prudential Group where you have any previous dealings with them; and
   • From any responses to surveys, challenges or activities with the Pulse App (e.g. location data, fitness data, challenge activity) where you have allowed it.

   (c) Personal data we collect automatically when you use the Pulse App:

   • Details relating to your device and use of the Pulse App and Pulse App Services including location data where it is required;
   • Data that is generated through your actions when using the Pulse App or Hosted App;
   • Data regarding all other interactions with the Pulse App or Hosted App, your advertising preferences, and communications with us, members of the Prudential Group or a Hosted App Provider;
   • Location data, including the location data of your mobile device;
   • Mobile device and connection information, information on data traffic, your IP address, access times, browsing history data, language settings, information connected with your third party login and/or weblog information etc.

   (d) Personal data we collect through cookies or other similar technologies.

   These items may include the following, for example (as may be applicable):

   • Access time, frequency and duration of visits / use of the Pulse App;
   • Data about your activities and interactions with our advertising partners (if any);
   • The model or device type used by you, operating system / version, browser type and settings, device ID, advertisement ID (if any), and other cookie-related data; and
   • Location data.

When you use the Pulse App, we may use cookies and similar technologies to provide you with a better, faster and safer user experience or to show you personalized advertising. Cookies are small text files that are automatically created by your browser and stored on your device when you use the Pulse App.

You are free to disable the use of cookies and similar technologies if this is supported by your device. You can manage your cookie settings in your browser or device settings.

If you decide not to have your personal data processed by us for advertising purposes via cookies (and similar technologies), this does not mean that we will not show you advertisements. It simply means that these advertisements will not be personalized for you using first-party or third-party cookies, web beacons, or similar technologies.

Why do we need your personal data?

• To process your registration and provide you with access to the features, functionalities and services on the Pulse App, Pulse App Services and Hosted App Services;
• For our processing in connection with our internal business purposes, and the improvement and development of the Pulse App, the Pulse App Services, the Hosted App Services and the research and development of future products, services, functionalities and features (including AI powered products, features and services).
• To enable you to register with a Hosted App, should you choose to do so;
• To comply with the instructions of a Hosted App Provider where we process personal data on its behalf;
• To process and communicate with you about your participation in any events, promotions, focus groups, research studies, contests, fulfilment of rewards, polls, surveys, productions or similar activities relating to the Pulse App;
• To send you promotional materials from entities in the Prudential Group, their Business and Marketing Partners;
• To monitor Pulse App and Pulse App Services usage to provide us with information to be used in making changes to the Pulse App and Pulse App Services and to conduct profiling such as marketing profiling;
• As we believe to be reasonably necessary or appropriate to monitor, enforce or verify your compliance with the terms applying to the Pulse App and Pulse App Services
• To communicate with you and respond to questions, comments and feedback from you;
• For internal administrative purposes, such as auditing, data analysis, database records;
• For purposes of detection, prevention and reporting of crime; and
• To comply with any obligations under law for the App Provider.

1. Direct marketing

   We may use your data to conduct direct marketing campaigns to offer Pulse services We also intend to share your data with members of Prudential Group and their Business and Marketing Partners to allow them to conduct direct marketing campaigns to offer you insurance and finance related products and offer. The information used/shared will be your name and any contact details you have provided through your use of the Pulse App. We will only do this if (where applicable laws and regulation apply) you have given your consent in a way that is required by laws or regulation

   The information used/shared will be your name and any contact details (including those obtained from your use of a third party login) you have provided through your use of the Pulse App. We will only do this if (where applicable laws and regulation apply) you have given your consent in a way that is required by laws or regulation.

   Automated decision-making and Profiling

   We use technologies that are considered automated decision making or profiling. We will not make any automated decisions about you that would significantly affect you unless we have obtained your consent (when required by applicable law or regulation), or we are required by applicable law to use such technology.

We may deploy data analytics tools to monitor Pulse App and Pulse App Services usage to provide us with information to be used in deciding whether to make changes to the Pulse App and Pulse App Services and to conduct profiling such as marketing profiling. We may also collect and use technical data and related information including but not limited to technical information about your device including its system and application software, and peripherals, to facilitate the provision of updates, product support, and other services to you related to the Pulse App.

What is our justification for using your data?

We process your personal data based on the following:

• Where you have given your consent
• Where it is for the purposes of providing you with the features, functionalities and services you have chosen to use on the Pulse App, Pulse App Services and Hosted App Services.

Where applicable laws and regulations allow, we may also process your data based on the following:

• Where the processing is necessary for the purposes of the legitimate interests pursued by us or by a third party to whom the personal data is disclosed (except where such interests are overridden by your fundamental rights and freedoms);
• Where the processing is necessary in order to fulfil our / your obligations under the Pulse App Terms and Conditions
• The processing is necessary for compliance with a legal obligation to which the App Provider is subject; or
• Other lawful criteria recognized under applicable law.

However, for the processing of your personal data where applicable law or regulation requires prior consent, such as, but not limited to, where the processing involves sensitive personal data (including Health Data), where the processing involves automated-decision making or profiling, or where the processing involves the sending of direct marketing and/or promotional communications, our processing of your personal data will be based on your explicit consent only.

Who do we share your information with?

We may disclose your personal data to entities in the Prudential Group and their Business and Marketing Partners to the extent necessary for them to assist us with fulfilling the above purposes or in accordance with any consent you have given.

Where we collect your personal data on behalf of a Hosted App Provider, we disclose your personal data to that Hosted App Provider or as they may direct. Please see the privacy notice of the Hosted App Provider for their practices relating to your personal data.

We may also pass on your personal data to any legal, regulatory or government bodies, law enforcement authorities, government officials, and/or a third party where required by law or regulation

We may process your personal data in a country other than the one you are resident in. To the extent we transfer your personal data, we will use appropriate safeguards and comply with the laws of the country to which your personal information is transferred.

How do we keep your data safe?

• We have a detailed privacy policy and processes that are designed to provide protection to your data at all times;
• We have detailed security policies and standards which allow us to effectively manage keeping your data safe;
• We use encryption when your data is stored and when it is sent across networks;
• We work closely with our partners to ensure that they provide the same level of protection to data they hold on their own or process on our behalf, including through detailed due diligence and Privacy Impact Assessments;
• We manage and control who has access to your information both within and outside the Pulse App through access control and identification techniques; and
• We have detailed plans for any unforeseen events including reporting (where required to do so by applicable laws and regulations) any breaches that may involve your data.

For more details on our security and data management processes, please contact us.

How long do we keep your data for?

Your personal data will be stored by us in accordance with applicable data protection laws to the extent necessary for the processing purposes of this Privacy Notice, and specifically, for the following periods:

• For as long as it is required for the purposes you gave your consent to;
• For as long as may be required by applicable laws and regulations; or
• For legitimate business purposes of the App Provider.

Your personal data will be deleted after the relevant limitation or retention periods have expired.

What can you do?

• You can withdraw your consent for our collection, use or disclosure of your personal data by contacting us as set out in this Privacy Notice. Even if you withdraw your consent we may still collect, use or disclose your personal data if applicable laws and regulations require or authorize us to do so;;
• You can change your preferences, where you have given specific consent (this may vary depending on the country you are resident in) but may include, but is not limited to, objecting to receiving marketing and other promotional materials, automated decision making, using sensitive information, overseas transfer. To make changes you can use the privacy feature within the app or contact us at the contact details in the next section;
• You may (where local laws provide you with the rights) ask us for a copy of and/or access to information that we hold about you in the Pulse app (you will need to request any information held by Hosted App Providers from them);
• You may (where local laws provide you with the rights) ask us to amend any data that is incorrect, incomplete, outdated and/or misleading except in such cases where such a request is unreasonable;
• You may (where local laws provide you with the rights) ask us to delete your data (we may need to retain data to meet other legal or regulatory requirements);
• You may (where local laws provide you with the rights) ask us to restrict our use of your data;
• You may (where local laws provide you with the rights) ask that we provide you with a copy of electronic data in a form that can be shared with others, and where technically feasible, to transmit such personal data to another data controller (i.e. other organizations or entities);
• You may (where local laws provide you with the rights) request compensation for any harm caused by misuse of the personal data you share in Pulse App; and
• You may (where local laws provide you with the rights) lodge a complaint with the data privacy regulator

Updating your details and contacting us

Please update your details as directed on the Pulse App if any details you have provided to us in your registration changes (e.g., if you change your e-mail address, telephone number). Please use the details below to contact us with any requests to do with your data.

Title / Designation	Pulse Helpdesk
Postal Address:	Attention: Privacy Officer, Prudential Services Asia Sdn Bhd, Tingkat 15, Menara Prudential, Persiaran TRX Barat, 55100 Tun Razak Exchange, Kuala Lumpur, Malaysia
Contact details :	03-27778493
Email:	privacy@wedopulse.com

We will respond to and action all requests within the time limits required by applicable law and regulation. We may refuse to action a request to correct or provide access to personal data where the law allows or requires us to do so. For security reasons, we may take steps to authenticate the identity of the requesting party before responding to a request.

In those countries where we are required to do so by law, we have appointed data protection officers to oversee the protection of your personal data. If you have any questions about this Privacy Notice or about data protection at the App Provider or have complaints regarding this Privacy Notice or our handling of personal data, you can contact us through the Pulse Helpdesk above.

About this notice

1. Language:  To the extent there is any inconsistency between the English version and an official local translation of this Privacy Notice, the English version shall prevail.

2. Hosted App:  Other than as expressly stated, this Privacy Notice does not apply to collection, use or disclosure of your personal data by a Hosted App Provider in relation to their Hosted App. Please see the privacy notice applying to the Hosted App.

3. Definitions:  Capitalised terms not defined in this Privacy Notice shall have the meaning given to them in the Pulse App Terms and Conditions.

4. "Prudential Group"  means Prudential Plc and any affiliates of Prudential Plc

5. "Business and Marketing Partners"  means service providers, accountants, auditors, IT service and platform providers, intermediaries, reinsurers/retakaful operators, investment managers, agents, pension trustees (and other stakeholders), scheme advisors, introducers, selected third party financial and insurance/takaful product providers, advertising providers and legal advisers.

6. Amendments: We may amend this Privacy Notice at any time by communicating such change to you. The amendment takes effect on the date stated in the notice or, if no date is stated, on the date the communication is made. If you do not agree to the Privacy Notice as amended, you should not use the Pulse App and you should deregister your account as directed on the Pulse App.