We may collect personal data when you register an account, purchase or use our products or services, provide a biological sample, participate in our programs or research, communicate with us, or otherwise interact with us.

Depending on how you interact with us, the personal data we collect may include:

• Identity information, such as your name, date of birth, and other identification details;
• Contact information, such as your address, email address, and telephone number;
• Account, order, and transaction information, including products or services purchased, payment, and transaction details;
• Genetic and biological information, including information derived from biological samples provided for genetic testing;
• Information relating to genetic reports and related services;
• Health-related information that you voluntarily provide to us;
• Communications and service information, including enquiries, feedback, customer service communications, and information you provide when interacting with us;
• Technical and usage information, including IP address, browser type, device information, cookies, and information about how you interact with our website; and
• Any other personal data that you voluntarily provide to us or that we are otherwise permitted or required to collect under applicable law.

Where you provide us with personal data relating to another individual, you represent and warrant that you have the necessary authority or consent to provide that information to us and for us to collect, use, and disclose it for the purposes for which it was provided.

We may also collect personal data from third parties where permitted or required by applicable law.

We may collect, use, and disclose your personal data for purposes including:

• Processing, administering, and fulfilling your orders and transactions;
• Providing, administering, and improving our products and services;
• Processing and arranging genetic testing and the analysis of biological samples;
• Generating, administering, and delivering genetic reports and related information;
• Managing your account and membership;
• Providing customer support and responding to enquiries, requests, and feedback;
• Communicating with you regarding your account, orders, biological samples, genetic reports, products, services, and other matters relating to your relationship with us;
• Processing payments and facilitating delivery and logistics;
• Verifying information you provide to us where reasonably necessary;
• Maintaining records relating to our products, services, transactions, and interactions with you;
• Conducting quality assurance, testing, analysis, and improvement of our products, services, and operations;
• Conducting current and future research, analysis, and development involving biological samples, genetic information, or associated data, where permitted by applicable law and, where required, with your consent;
• Conducting analytics and improving our website and customer experience;
• Sending marketing and promotional communications where permitted by applicable law and, where required, with your consent;
• Detecting, preventing, and addressing fraud, security incidents, misuse, and other unlawful or potentially harmful activities;
• Protecting our rights, property, safety, and business interests;
• Complying with applicable laws, regulations, legal obligations, court orders, and lawful requests; and
• Other purposes that are reasonably necessary or related to the purposes described above, or otherwise permitted or required by applicable law.

We may disclose your personal data to third parties where reasonably necessary for the purposes described in this Privacy Policy, where you have provided consent, or where such disclosure is otherwise permitted or required by applicable law.

General Disclosure

Depending on the nature of the Services provided to you, such third parties may include:

• Laboratories, genetic testing providers, and other parties involved in processing or analyzing biological samples;
• Research partners and collaborators, where applicable;
• Payment processors, financial institutions, and payment service providers;
• Logistics, courier, and delivery providers;
• Website hosting, e-commerce, cloud storage, information technology, and other technology service providers;
• Analytics, communications, customer support, and other service providers;
• Professional advisers and other service providers engaged by us;
• Our affiliates, business partners, and contractors, where applicable; and
• Government agencies, regulatory authorities, law enforcement agencies, courts, or other parties where required or permitted by law.

Genetic Testing and Biological Samples

Where you purchase or participate in our genetic testing services, we may collect, use, disclose, and process biological samples and information derived from those samples for purposes including:

• Conducting genetic testing and analysis;
• Generating and delivering genetic reports;
• Providing and administering our Services;
• Quality assurance and service improvement;
• Customer support and related administrative purposes; and
• Other purposes described in this Privacy Policy or otherwise permitted or required by applicable law.

Biological samples and information derived from them may be de-identified or coded before being used for research or other permitted purposes. While we take reasonable measures to protect such information, de-identification or coding may not completely eliminate the possibility of re-identification.

Shopify

Our online store is powered by Shopify. Shopify provides the infrastructure and services that support our website and online store, including hosting, checkout, payment processing, order administration, and inventory-related functions.

Shopify and its service providers may collect and process personal data in connection with your access to and use of our website and Services. Information you submit through our online store may be transmitted to and processed by Shopify and its service providers, including parties that may be located in countries outside Singapore, in order to provide, secure, maintain, and improve the Services.

Shopify may also process information relating to your interactions with our store to provide analytics, security, business, and other Shopify features that we use or may enable from time to time. Where Shopify processes personal information for its own purposes, Shopify's processing is subject to Shopify's own privacy policies and terms.

For more information about how Shopify handles personal information and the rights that may be available to you, please refer to Shopify's applicable privacy policy and privacy resources.

Third-Party Advertising, Cookies, and Similar Technologies

We may use third-party advertising, analytics, and marketing service providers to display or serve advertisements on our behalf on our website or elsewhere on the Internet. These third parties may use cookies, pixel tags, web beacons, device identifiers, or similar technologies to collect information about your interactions with our website and, where permitted by applicable law, your online activities over time and across different websites or applications.

This information may be used to measure advertising effectiveness, understand website usage, provide analytics, personalize or make advertisements more relevant to you, and support our marketing activities.

These third parties may set or access their own cookies or similar technologies. Their collection and use of information may be governed by their own privacy policies. Where required by applicable law, we will obtain the necessary consent before using non-essential cookies or similar technologies.

You may be able to manage or opt out of certain interest-based advertising through your browser, device settings, or the relevant third party's available opt-out mechanisms. You may also contact us regarding your preferences.

Service Providers and Business Partners

We may engage third-party service providers, contractors, and business partners to assist us in operating our business and providing the Services.

These parties may have access to personal data where reasonably necessary for them to perform services on our behalf. We take reasonable steps to require such parties to protect the confidentiality and security of personal data and to use it only for authorized purposes.

Information Provided About Third Parties

We may collect and use personal data about a third party where you provide that information to us and have the necessary authority or consent to do so. By providing another person's personal data, you confirm that you have obtained any necessary consent and that we may contact or otherwise use that information for the purpose for which you provided it.

Where required by applicable law, you may withdraw consent in accordance with Section 10, subject to any legal or contractual obligations that require continued use.

Legal, Regulatory, and Protective Disclosures

We may also disclose personal data where reasonably necessary to:

• Comply with applicable laws, regulations, court orders, or lawful requests;
• Respond to requests from government agencies, regulatory authorities, or law enforcement agencies;
• Prevent, detect, or investigate fraud, cybercrime, security incidents, or other unlawful activities;
• Enforce our Terms and Conditions, agreements, or other applicable policies;
• Protect the rights, property, safety, confidentiality, or reputation of NONPAREY, our affiliates, users, or other persons;
• Pursue, establish, or defend legal claims; or
• Otherwise protect or enforce our legitimate business interests where permitted by applicable law.

Disclosure Without Consent Where Permitted by Law

We may collect, use, or disclose your personal data without consent where permitted or required under the PDPA or other applicable written law. This may include circumstances where necessary to respond to an emergency, protect an individual's life, health, or safety, or for purposes relating to an investigation, legal proceeding, the national interest, or other matters permitted under applicable law.

Consent and Your Choices

You have choices regarding our collection, use, or disclosure of your personal data. Where consent is the basis for our processing, you may withdraw your consent in accordance with Section 10, subject to applicable law and any legal or contractual obligations that require continued use.

If you choose not to provide personal data that is reasonably necessary for us to fulfill our contractual obligations, facilitate your request, process your order, or provide a Service, we may not be able to provide the relevant product or Service.

NONPAREY does not sell your personal data. We may, however, disclose or make personal data available to third parties as described in this Privacy Policy where reasonably necessary to provide our Services, operate our business, conduct analytics or advertising, where you have provided consent, or where permitted or required by applicable law.

We rely on the personal data you provide to us. You should ensure that personal data submitted to us is accurate, complete, and up to date, particularly where the information is used to provide our Services, process your orders, communicate with you, or generate or deliver your genetic report.

If your personal particulars change, you should notify us or update your information where appropriate.

Where permitted or required by applicable law, we may take reasonable steps to verify the accuracy and completeness of personal data before using or disclosing it.

Your personal data may be transferred to, stored in, or processed in countries outside Singapore, including countries where our laboratories, testing providers, service providers, technology providers, or other business partners operate.

Where we transfer personal data outside Singapore, we will take appropriate steps to ensure that the recipient provides a standard of protection for the transferred personal data that is comparable to the protection required under the PDPA, in accordance with applicable law.

By using our Services, you acknowledge that your personal data may be processed in jurisdictions outside Singapore where this is reasonably necessary for the provision of our Services or for other purposes described in this Privacy Policy.

We use cookies and similar technologies to operate our website, remember your preferences, understand how visitors use our website, and improve our Services.

Depending on the technologies we use, cookies and similar technologies may collect information such as your IP address, browser type, device information, pages visited, interactions with our website, and other technical or usage information.

Some cookies may be placed or managed by third-party service providers that support our website, analytics, advertising, or other services.

You may manage or disable cookies through your browser settings. However, disabling certain cookies may affect the functionality or availability of parts of our website.

Where required by applicable law, we will obtain any necessary consent for the use of cookies or similar technologies.

We implement reasonable administrative, technical, and physical security measures designed to protect personal data in our possession or under our control against unauthorized access, collection, use, disclosure, copying, modification, disposal, or similar risks.

Access to personal data is restricted to persons who require such access for legitimate business purposes and who are subject to appropriate confidentiality obligations.

We also take reasonable steps to require relevant service providers and third parties processing personal data on our behalf to maintain appropriate security measures.

However, no method of transmission or storage is completely secure. To the fullest extent permitted by applicable law, NONPAREY does not warrant or guarantee the absolute security of your personal data.

You should avoid sending sensitive or confidential information to us through unsecured channels.

We retain personal data for as long as reasonably necessary to fulfill the purposes for which it was collected, including to:

• Provide and administer our Services;
• Maintain appropriate account, transaction, and business records;
• Comply with legal and regulatory obligations;
• Resolve disputes;
• Enforce our agreements and policies; and
• Protect our legitimate business interests.

Different categories of personal data may be retained for different periods depending on the nature and purpose of the data and our legal, regulatory, and business requirements.

We will cease retaining personal data or remove the means by which the data can be associated with particular individuals when we reasonably determine that retention is no longer necessary for any business or legal purpose, subject to applicable law.

Where appropriate, personal data may be securely deleted, anonymized, or otherwise disposed of.

Subject to applicable laws and exceptions, you may:

• Request access to personal data that we hold about you;
• Request information about how your personal data has been used or disclosed during the past year;
• Request correction of inaccurate or incomplete personal data;
• Withdraw consent for the collection, use, or disclosure of your personal data for purposes for which consent was provided; and
• Manage your preferences regarding marketing communications.

You may submit requests relating to your personal data or withdraw consent by contacting our Data Protection Officer using the contact details in Section 15.

Where permitted by applicable law, we may send you information about our products, services, promotions, events, and other communications that may be relevant to you.

Where consent is required, we will obtain the appropriate consent before sending such communications.

You may withdraw your consent to receive marketing communications or unsubscribe from marketing communications by following the instructions provided in the relevant communication or by contacting us at privacy@nonparey.com.

Please note that even if you opt out of marketing communications, we may continue to send you non-promotional communications that are necessary for your account, orders, transactions, genetic reports, Services, or other matters relating to your relationship with us.

We maintain procedures for identifying, assessing, and responding to personal data breaches.

Where a personal data breach occurs, we will assess the breach and take appropriate action in accordance with applicable law, including notifying the Personal Data Protection Commission and affected individuals where notification is required.

We may also take steps to contain, investigate, remediate, and prevent recurrence of any personal data breach.

Our website or Services may contain links to third-party websites, applications, platforms, or services.

If you access a third-party website or service, your use of that website or service is governed by the third party's own terms and privacy policies.

NONPAREY is not responsible for the privacy practices, content, security, or data protection practices of third parties that operate independently from us.

We encourage you to review the applicable privacy policies before providing personal data to any third party.

We may update this Privacy Policy from time to time to reflect changes to our Services, business practices, technology, or applicable laws.

When we update this Privacy Policy, we will publish the revised version on this website and update the "Last updated" date.

Where required by applicable law, we will provide additional notice or obtain consent for changes that require it.

Your continued use of our website or Services after the updated Privacy Policy has been published constitutes acknowledgment of the updated Privacy Policy, subject to any consent requirements that apply under applicable law.

Nothing in this Privacy Policy limits any rights or obligations that NONPAREY may have under applicable law. Where there is a conflict between this Privacy Policy and applicable law, the applicable law will prevail.

If you have any questions about this Privacy Policy, our data protection practices, or wish to make a request relating to your personal data, please contact our Data Protection Officer at privacy@nonparey.com.

We will handle enquiries and requests in accordance with the PDPA and other applicable laws.