Sati

Sati App User Privacy Notice

Sati App Co., Ltd. (“We”) provides on-demand listening service via Sati application (the “Application”) on mobile phone and other associated services (the “Services”). We assure you that your privacy is of utmost importance and we commit that all of your Personal Identifiable Information (the "Information") are collected, used, and disclosed specifically in accordance with this Privacy Notice and in strict compliance with the applicable law.

This Privacy Notice has been prepared with an intention to inform you as You ("You") of how We collect, use, store, process, transfer or disclose your Information during the use of Application and/or the provision of the Services.

Please read and understand this notice before using the Service or providing Information to us. You have acknowledged and agreed to the Privacy Notice and Terms of Service before using our Service.

Sources of Information.

In order to perform the required Services, We may collect, receive, compile and process your Information in 4 main sources: (a) Information collected directly from the communication made between You to us and collected directly from any activities executed on the Application and/or the Information collected from the use of the Services; (b) Information automatically collected as necessary from your Services and/or Application usage history; (c) Information that We may receive from the volunteer listener registered with us (the “Listener”); and (d) Information that We may gather or receive from any third party who has the legitimate rights to share and disclose your Information with us for the provision of the Services; provided in case of the indirect collection of Information, We will inform You of the source of such Information.

Collected Information.

When You use the Service and/or access the Application, We may collect Information in the following steps:

Create a user account: Before You be able to use the Application and/or the Service, you have to register first. We will collect your provided personal Information in order to create a user account including your name (can be fictitious), date of birth and gender;

One important privacy feature of our Application worth highlighting — you do not need to use your real name to register or log in. You are free to use any fictitious name you are comfortable with, and we will never ask you to verify it. This means that at the end of the day, We may genuinely not know who you actually are. While We handle all Information with the utmost care and security regardless, this built-in anonymity gives you an additional and meaningful layer of personal privacy protection from the very start.

Remark: The gender field is optional. You may choose whichever option you are comfortable with, and we will not verify or question the information you provide. If you choose to disclose information relating to your sexual behavior or sexual preference — which is classified as sensitive personal data under the personal data protection law — by voluntarily completing this field, you are deemed to have given your explicit consent for us to process such data. We commit that this information will be used solely for statistical and research insight purposes. Your individual gender identity will never be disclosed.

In case You are the Listener: Additional information shall be kept in addition to other user’s personal data, including without limitation, the full name, gender, date of birth, phone number, ‘Mind First Aid’ training records and your portrait holding your identification card and copy of your identification card;
Service usage Information : When you use the Service, we may collect Information about your usage of the Service such as the amount of your spending time with a Listener and device Information such as mobile phone model and IP address, including the event that our designated call service provider, Twilio, will record your calls for the purpose of network and communication system analysis in order to further improve the stability and efficiency of the system (you are not required to disclose your identity during communicating with a Listener);

It should be noted that the service usage Information that we are collecting from You may contain your mental health and state that may be considered the sensitive Information under the applicable law and in order for us to process them, the explicit consent shall be given from You and it is your entitlement as the data subject to determine whether or not to give such consent. However, We would like to inform You that these Information are critical pieces of Information for the provision of the Services to You. Therefore, in case that You do not give consent to us in processing this Information, We shall not be able to provide the Services to You.

Information collected from Call Scheduling. When you use the Call Scheduling feature, We will collect Information about your stated preferences, including your preferred language of communication, Listener gender preference, discussion topics selected, and your chosen time slot. This Information is used solely for the purpose of facilitating the matching between you and an available Listener and managing your scheduled session.
Information from Mood Tracker. When you use the Mood Tracker, We will collect the Information you record regarding your emotional states, feelings, and any events you choose to log in your mood journey. We will use this Information solely for the following purposes: (a) to display your mood journal back to you through the Application; and and (b) to conduct anonymized aggregate analysis to improve the quality of our Services; provided that individual mood jornal entries will never be used in a manner that identifies you personally.
Information from Self Assessment. When you complete a Self Assessment, We will collect your responses and assessment results. This Information may reflect your mental health condition and may constitute sensitive personal data, but it will be used solely to assist you in making an informed decision about seeking support. We will not disclose your individual Self Assessment results to third parties, except as otherwise provided in this Privacy Notice.
Location: You can specify your location; provided that the Application will only track the location while you use the Service and you can turn off this setting at any time. For the Hospital and Clinic Directory feature, your location may be used to surface nearby healthcare providers. Location Information collected for this purpose will not be transferred to any third party.;
Feedback / Comments: At the use of the Service is completed, We will send a feedback survey related to your received service. You can provide additional comments for the further development of the Application and/or Service. All Listeners will be able to comment on you after the service. However, we will collect such Information in a manner that does not personally identify you and we shall only retain such Information for statistical purposes only.
Assessment: Occasionally, We may send you a survey to assess your health, mental state, and mood. You must provide accurate and truthful Information. However, the assessment depends on your voluntariness, and it will not affect your normal use of the Service in any way.
Other contact: In the event that You need us to contact you (in particular in the case of mental breakdown and suicidal circumstances), You can choose to provide us your telephone number; and in the event that You need to contact us or require technical assistance regarding Services or Application, We will collect your informed Information as well as contact channels (such as e-mail and telephone number) for proper contact or resolution.
Use of Cookies Cookies is text file that will be saved on your electronic device when you access the Application. We may use cookies or other similar technologies (collectively called "Cookies")

Different types of Cookies will be processed, such as Strictly Necessary Cookies, which You may not be able to disable, Functional Cookies for a faster and smoother service such as: remembering you and your settings Information when you log in to the system and Analytic Cookies which collect Information on your use of the Application to enable us to measure, evaluate and improve our services and to enhance your experience in using our Application. We will not use cookies for targeted advertising or for any marketing purposes to you. However, you can disable or restrict the use of cookies (except cookies necessary to perform the service) according to the settings of your electronic device. However, disabling cookies may result in your inability to use the application with ease or efficiency.

Use of Information.

We will use the Information collected from you for the following purposes and lawful basis:

To perform our contractual performance in providing Services to You. It is understood that without this Information, We are not capable of performing the agreed Services. The Information shall be processed in the following manners:
- to verify the qualifications and eligibility of You to assess and use the Services;
- to use as the reference or identifier to connect all the transaction or activities that may be undertaken by You on the Application;
- to communicate and contact with You for the purpose of ensuring the Services will be provided to You pursuant to the terms of services defined, including to communicate or provide notification within the Application including aiding in using the Service and to track your location and/or follow up on results (If enabled) in accordance with safety purposes; and
- to provide any additional assistance or services in response to your request to us, including managing your Call Scheduling sessions and displaying your mood journal; and
- to provide any additional assistance or services in response to your request to us;
To perform our legal obligations. We may have the legal obligations under the applicable laws to perform, in particular for the taxation and accounting obligations, and in order for us to perform those obligations, We would need to collect your Information.

Also, We may need to process your Information to comply with legal purposes such as investigation of claims, investigating unlawful acts, compliance with legal obligations or court orders or competent authorities, protecting the rights or legitimate interests of you, the company or third parties;

To exercise our legitimate interest. We would process your Information in particular for these particular purposes:
- to protect our legitimate rights and to prevent our right in the legal proceedings that may be arisen between us;
- to plan the improvement in the Application and Service provided to ensure that those Application and Services would match the interest and needs of each user;
- to protect the safety and efficiency of the Services, including detecting, preventing and responding to unwanted or unlawful use as well as any fraud, fraud and technical issues that may affect you, us or third parties;
- to improve the relationship between us through the management and resolution of any dispute arisen between you and us and/or you and the Listener;
- to analyze the operation of communication system including other problems for further improvement of the quality of the Service and stability of the system, enabling us to provide service with higher efficiency
- to publicize the marketing materials produced by us that may include your profile (including photos and satisfaction feedback) to the general public; and
With your explicit consent. We may use your Information for the specific purposes defined under the consent given;

In particular, Please note that the Services involving the recording of your emotional wellbeing and mental health state — namely the Mood Tracker and Self-Assessment — are entirely optional. You are under no obligation to use these features, and your choice not to use them will not affect your ability to access the core Services. However, if you choose to activate and use any of these additional features, your voluntary act of doing so shall be deemed as your explicit consent to our collection and processing of any mental health-related Information generated through your use of those features, in accordance with this Privacy Notice and the applicable personal data protection law; and and

Process of Anonymized Data. Your Information may be anonymized before being used in the further analysis and research purpose that would be beneficial for the general public or for the commercial benefit of us; provided that in this circumstance, We shall assure that Information security of such Information and We shall use the best effort in assuring that the Information disclosed under this circumstance shall not be entitled to reprocess to identify each specific user.

Personal information of minors

Please kindly note that We do not intend to provide Services to user who is the minor. Minor users should use the Services under the supervision of a parent or legal guardian. Providing the personal information of minors, You will be deemed to have given your consent and agreed to be bound by this Privacy Notice and be responsible for any actions performed on the Application by minors.

Retention of Information.

We will keep your Information for as long as you keep using the service (Account not closed) or retained for as long as necessary for the purposes outlined in this Privacy Notice, unless required or permitted by law for longer storage. For a period of reasonable period of time after the termination of your user account, We may retain your Information solely for the purpose of protecting our legitimate interest as defined under this Privacy Notice.

When your Information is no longer needed, we will delete your Information from the system or make your personal Information anonymous, unless the company still needs to collect your Information to comply with laws, obligations or to maintain security.

Disclosure of Information.

We have no policy to sell or disclose any of your Information to third parties for any other advertising or marketing purposes. We will only disclose your Information in a specific and reasonable case as follows:

Shared to the Listener. The Information you provide on the Application will not be disclosed to our Listeners for the sake of privacy, but the anonymized Information may be discussed with the Listener.
Shared to Medical Profession. Our services are intended to support solutions to a wide range of mental health issues. Therefore, we need to disclose your Information to the Department of Mental Health, Ministry of Public Health which is one of the supporters of our Application as aggregated data that is not personally identifiable to you for use in studies, analyzes, plans and measures that will benefit the promotion of mental health while maintaining your privacy as well as possibly making such aggregate Information public as appropriate such as usage statistics.
Shared as Legally Instructed. If there is a court order, a request from an authority or a lawful authority, We may disclose your Information as necessary for legal action.
Shared to the Third-Party Service Provider. We may disclose Information to other relevant parties such as our legal consultant to protect our or others' rights, interests, and assets as well as to protect your safety or the public and other outsourced service provider being directly engaged by us to help in the provision of the Application and/or the Services; provided that We shall only disclose your Information to the relevant recipient strictly on the need to know basis in strict compliance with the defined objectives for Information process defined.
Shared in case of Restructure. In the case of merger, sale or transfer of business to other operators, either in whole or in part, or in case of corporate restructuring between us and our affilates, we may transfer your Information in order to guarantee the continuity of the Service. The operator will be able to use the Information received in accordance with this Privacy Notice onwards.
Shared according to Your Consent.
Statistic Information Shared. Statistic information that has been processed on the anonymous basis may be disclosed to the public or to the research institute for the geneal public interest, the medical preventive and diagnosis purpose, health and society services or health management.

Security of Information

We represent and guarantee to use the most appropriate security measures to prevent the unauthorized access, amendment or disclosure of your Information in any form or in any circumstance by either internal or external persons and We commit to review those measures on the regular basis with the strong commitment to use the best industrial practice and to be in strict compliance with the applicable laws.

Your rights.

You can exercise the right to manage your Information within the scope and conditions of the law as follows: (i) the right to request access, as well as to obtain a copy of your Information under our responsibility; (ii) the right to request incomplete or incorrect correction of your Information; (iii) the right to object to the collection, use or disclosure of your Information as required by law; (iv) the right to request to withhold your Information in case required by law, for example when you have objected to the collection but the objection is still pending; (v) the right to withdraw your consent to the processing of your Information; (vi) the right to erase, destroy or make non-personally identifiable Information as required by law, such as when you have exercised your right to withdraw your consent; (vii) the right to have your Information transferred, such as requesting transmission to another data controller; and (viii) the right to complain in the event that we have done or have failed to do anything in violation of applicable personal Information laws.

Please kindly note however, limiting the provision of Information or withdrawing your consent for the use of your personal Information may prevent us from providing the Service to you for the full purpose of use.

Feel free to contact us If you wish to exercise your rights under this article. We reserve the right to review your exercise request and may request additional Information or documents to assert your rights and protect the security of your Information. However, We may reject your request in the event required by law.

Scope of Application.

This Privacy Notice is only applicable to the Application and/or Services directly performed by us and shall not apply to the Information process undertaken by other application or website developed and operated by any other third-party that the Company does not have any control over that being displayed or connected to the Application and/or Services.

Revision of the Notice. We may amend or revise this Privacy Notice at any time to assure the compliance with the relevant laws and regulations and to assure the updates in the Services at any time; provided that We will communicate the amendments or revisions made and the amendment or revisions shall become effective once communicated and announced.

Contact Channels. If you have any further questions about this Privacy Notice or our privacy practices or wish to exercise your rights as described in this notice, please contact us via [email protected]