NEUROSENSING PRIVACY POLICY

Effective date: 6 Nov 2025 | Last Updated: 6 Nov 2025

This Privacy Policy sets out the basis which the MOH Office for Healthcare Transformation ("MOHT"), National Neuroscience Institute of Singapore Pte Ltd ("NNI") and Singapore University of Technology and Design ("SUTD") ("We", "Us", or "Our") may collect, use, disclose or otherwise process Personal Data of Our Users in accordance with the Personal Data Protection Act 2012, including any re-enactment, supplement and amendments thereto from time to time ("PDPA"). This Notice applies to User-Contributed Information, Personal Data in Our possession or under Our control, including Personal Data in the possession of organisations which We have engaged to collect, use, disclose or process Personal Data for Our Purposes.

The NeuroSenSing platform requires access to multiple sensors and functions within your mobile devices and/or wearable devices to function. This data is then collected and transmitted to the servers which process this data. Collectively, this transmitted data is classified as your "User Contributed Information". A full list of data you may submit to Us is listed in Appendix A of the NeuroSenSing Terms of Use.

PERSONAL DATA

1. As used in this Notice:

   "User" means an individual who (a) has contacted Us through any means to find out more about any goods or services We provide, or (b) may, or has, entered into a contract with Us for the supply of any goods or services by Us. "Personal Data" means data, whether true or not, about a User who can be identified: (a) from that data; or (b) from that data and other information to which We have or are likely to have access.

2. Depending on the nature of your interaction with Us, some examples of Personal Data which We may collect from you include your name and identification information such as your NRIC number, contact information such as your address, email address or telephone number, nationality, gender, date of birth, marital status, photographs and other audio-visual information, employment information and medical records.
3. Other terms used in this Notice shall have the meanings given to them in the PDPA (where the context so permits).
4. By providing Us with your Personal Data, you consent to Our collection, use, and disclosure (including transfer) of your Personal Data in accordance with this Notice and the PDPA. You further accept and agree to comply with the terms of this Notice. Please DO NOT provide us with any Personal Data if you do not accept this Notice.
5. You represent and warrant that you will comply with the PDPA and/or any other applicable laws relating to data privacy and/or confidentiality, and will not cause Us to be in breach of such laws.

PERSONAL DATA

6. The "NeuroSenSing platform" refers to the digital phenotyping data collection and processing infrastructure underlying, including its mobile application ("App").
7. NeuroSenSing does not proactively collect any data that directly identifies you ("Personally Identifiable Information"). You are not required to provide, and the NeuroSenSing platform is not intended to collect any data that may identify you. Upon registration on the NeuroSenSing platform, you will be given an anonymised serial number, and only your research study coordinator at will have knowledge of your serial number. We will not be able to identify you from this serial number.

COLLECTION, USE AND DISCLOSURE OF YOUR USER CONTRIBUTED INFORMATION

8. We may use, disclose and retain your User Contributed Information your Personal Data (if we receive your Personal Data) and other data and information pertaining to you for any or all of the following purposes (collectively the "Purposes"):
   1. performing obligations in the course of or in connection with Our provision of the NeuroSenSing research study;
   2. verifying your identity;
   3. setting up your account with Us and managing your use and access of NeuroSenSing;
   4. providing you and other Users with the services or functions of NeuroSenSing;
   5. responding to, handling, and processing queries, requests, applications, complaints, feedback, and facilitating communications;
   6. managing your relationship with Us;
   7. informing you about service upgrades and updates;
   8. performing network or service enhancements;
   9. corporate governance (including internal and company audits) and policy reviews;
   10. complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;
   11. any other purposes for which you have provided the information;
   12. transmitting to any unaffiliated third parties including Our third-party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes;
   13. in an aggregated or de-identified form for the purposes of improving Our systems, or for research, statistical and planning purposes;
   14. uploading onto computer systems operated or managed by third parties (including payment systems, the National Electronic Health Record system managed by the Ministry of Health, the NUHS Online Appointment System, the SingHealth Online Appointment System and NHG Online Appointment System, NUP Online Appointment System, the SHP Online Appointment System and NHGP Online Appointment System) in order to provide you with use of NeuroSenSing and the App;
   15. sharing your User Contributed Information and your Personal Data and other related data with other public universities in Singapore, public healthcare institutions in Singapore or Singapore government agencies, to enable Us to provide you with better healthcare support. We may also share such data with the Ministry of Health, the relevant regulatory authority for healthcare professionals, other ministries, statutory bodies and public agencies for the purpose of complying with their respective requirements, policies and directives;
   16. accounting and record keeping;
   17. personalising Our services and recommending content related to Our services and your health where applicable;
   18. managing Our day-to-day business and administrative operations;
   19. security and risk management;
   20. administering and managing the relevant relationships to conduct and further our business and administrative operations;
   21. facilitating communications with individuals in connection with the services provided by us; and
   22. any other incidental purposes related to or in connection with the above.
9. We may disclose your User Contributed Information, your Personal Data and other data and information received from you:
   1. where such disclosure is required for performing obligations in the course of or in connection with Our provision of the NeuroSenSing research study; or
   2. to non-government agencies, non-public healthcare institutions, third party service providers, agents and other organisations, including to Our Affiliates, where:
      1. We have engaged them to perform any of the Purposes listed in paragraph 8 above for Us;
      2. they have been authorised to provide services on behalf of government agencies or public healthcare institutions;
      3. they are our service providers who provide Us with necessary services including but not limited to IT services, hosting and maintenance services, organising of Our events, accounting, data analytics services, email messaging services, marketing etc.;
      4. they are Our consultants or professional advisers including but not limited to accountants, lawyers and auditors; and/or
      5. they are authorised users of public health systems operated and/or initiated by the government of Singapore.
10. The Purposes may continue to apply even in situations where your relationship with Us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable Us to enforce Our rights under any contract with you).
11. If you provide Us with another person's Personal Data (including your family members), by submitting such information to Us, you warrant that:
    1. you are authorised to act on his/her behalf; and
    2. he/she accepts that his/her Personal Data will be subject to this Notice (as amended from time to time).
12. We may use "cookies", where a small data file is sent to your browser to store and track information about you when you enter NeuroSenSing or use the App. The cookie is used to track information such as the number of Users, their profiles and their frequency of use. While this cookie can tell us when you enter NeuroSenSing or use the App and what pages you visited, it cannot read data off your hard disk. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from making full use of NeuroSenSing.

List of Data Collected

Data Collected	Explanation
NeuroSenSing Application
Motion Data - Pedometer, Accelerometer and Gyroscope	Phone movement is used to determine your steps and patterns of physical activity.
Ambient Light	Ambient light sensors allow Us to understand the lighting conditions in your environment.
GPS Data (Obfuscated)	GPS Data is obfuscated by adding a random displacement to your location. We will NOT be able to find out your exact location at any immediate point in time.
Finger Taps	Taps within each app category are recorded along with the screen orientation. We will NOT be able to identify or collect the exact location on the screen of each tap.
App Usage	App Usage such as usage frequency and time spent on each app category (e.g. social, games, productivity, etc).
Power State	We collect data on when the phone is turned on.
Fitbit Charge 6
Sleep	Your sleep data is derived by Fitbit which determines your time spent asleep, your time in sleep stages, and your sleep efficiency.
Steps	Fitbit collects your number of steps taken.
Heart Rate	Fitbit collects your heart rate at predefined intervals.
Heart Rate Variability	Fitbit collects your data on your heart rate variability (HRV) which measure the variability of time between beats.
Breathing Rate	Fitbit collects your breathing rate in breaths per minute, mainly during sleep.
Cardio Fitness Score (VO2 Max)	Fitbit estimates your VO₂ Max, showing your overall cardiovascular fitness.
SpO2	Fitbit measures your blood oxygen saturation (SpO₂) levels.
Temperature (Core and Skin)	Fitbit tracks skin temperature variations that may reflect core temperature changes.
Daily Activity Summary, Active Zone Minutes	Fitbit records calories burned, distance, and Active Zone Minutes based on time spent in fat burn, cardio, and peak zones.

WITHDRAWING YOUR CONSENT

13. The consent that you provide for the collection, use and disclosure of your Personal Data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request Us to stop using and/or disclosing your Personal Data for any or all of the Purposes by submitting your request in writing or via email to your research study coordinator at NeuroSenSing@nni.com.sg.
14. Upon receipt of your written request to withdraw your consent, We may require reasonable time (depending on the complexity of the request and its impact on Our relationship with you) for your request to be processed and for Us to notify you of the consequences of Us acceding to the same, including any legal consequences which may affect your rights and liabilities to Us. In general, We shall seek to process your request within ten (10) working days of receiving it.
15. Please note that withdrawing consent does not affect Our right to retain your User Contributed Information, even upon withdrawal from the App, in an aggregated or de-identified form for the purposes of improving Our systems, or for research, statistical and planning purposes. The type of Our business operations may include but may not necessarily be limited to:
    1. Day-to-day business and administrative operations;
    2. Research and services enhancement;
    3. Corporate governance (including internal and company audits) and policy reviews;
    4. Security and risk management;
    5. Legal and regulatory regulations (including providing assistance to law enforcement, judicial and other government agencies);
    6. Administering and managing relevant relationships to conduct and further the business operations of MOHT, NNI and/or SUTD;
    7. Facilitating communications with individuals in connection with services provided by MOHT, NNI and/or SUTD; and
    8. Any other purposes reasonably related to the above.

PROTECTION OF DATA

16. To safeguard your Personal Data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, We have introduced appropriate administrative, physical and technical measures such as up-to-date antivirus protection, encryption and the use of privacy filters to secure all storage and transmission of Personal Data to and from Us, and disclosing Personal Data both internally and to Our authorised third party service providers and agents only on a need-to-know basis.
17. You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, We strive to protect the security of your information and are constantly reviewing and enhancing Our information security measures. For the avoidance of doubt, We are not liable for any claims, losses, damages and expenses arising from any damage, loss or corruption to your Personal Data. We do not accept any liability for the authenticity, confidentiality, integrity, and security of any communications and other transactions made through NeuroSenSing.
18. While NeuroSenSing takes extensive measures to obfuscate and anonymise transmitted User Contributed Information, given the nature of said data, We cannot guarantee that you will not be identified due to the uniqueness of your User Contributed Information. For the avoidance of doubt, We are not liable for any claims, losses, damages and expenses arising from such event.

RETENTION OF DATA

19. We shall retain your Personal Data for as long as it is necessary to fulfil the purpose(s) for which it was collected, or as required or permitted by applicable laws, whichever is the later.
20. We will retain your Personal Data in the manner and for the purposes set out in clause 15 above.

TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE

21. We generally do not transfer your Personal Data to countries/locations outside of Singapore. However, if We do so, We will obtain your consent for the transfer to be made and We will take steps to ensure that your Personal Data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.

HYPERLINKS AND THIRD-PARTY SYSTEMS

22. NeuroSenSing may contain links to other websites, applications or materials whose terms of use, data protection and privacy practices may differ from Ours. We are not responsible for the content and privacy practices of these other websites or applications and encourage you to review the privacy policies or notices of those websites, applications, or materials. You shall be solely responsible for all decisions and actions taken or not taken resulting from or in any way related to the use of such other websites, applications or materials. We shall not be liable to you or any third party for any damages, losses, claims and/or expenses, whatsoever arising from your access to or use of such other websites, applications or materials.

DATA PROTECTION OFFICER

23. You may contact Our Data Protection Officer if you have any enquiries or feedback on Our Personal Data protection policies and procedures, or if you wish to make any request, in the following manner:

Data Protection Officer
Email: MOHT.DPO@moht.com.sg
Address: 1 North Buona Vista Link, #09-02, Singapore 139691


EFFECT OF NOTICE AND CHANGES TO NOTICE

24. This Notice applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your Personal Data by Us. For the avoidance of doubt, this Notice is not intended to supersede or replace any consent previously provided to Us.
25. We may revise this Notice from time to time without any prior notice to you. Should there be any modification to this Notice, we will post the updated version on the relevant webpage relating to NeuroSenSing. The updated Notice will supersede earlier versions and will apply to Personal Data provided to Us previously. Each time you use NeuroSenSing, the App and any updates, upgrades, new versions, documentation, content and services provided by or through NeuroSenSing, or contact, interact or transact with Us, you acknowledge and agree that the latest version of this Notice shall apply.