Privacy Policy

1. Personal Data We Collect

We may collect the following personal data:

Personal Information

• Full name
• Email address
• Contact number
• Job title and company affiliation
• Organisation and HR administrator details where relevant

Platform Usage Information

• Workshop participation and attendance
• Counselling enquiries and service booking requests
• Learning progress, certifications, and engagement history
• Platform activity necessary for account support and service improvement

True Wellness App, Apple Health, and Android Health Connect

• True Wellness is available on iOS (Apple App Store) and Android (Google Play).
• On iOS, the app reads Apple Health data only with your permission; on Android, it reads Health Connect data only with your permission.
• Health and fitness summaries may include steps, exercise, sleep, resting heart rate, heart rate variability, mindfulness, and workout counts.
• These summaries are used to display your Wellness Overview and are not used for medical diagnosis.
• Health and fitness data is read on a read-only basis and is never used for advertising or shared with data brokers.
• We do not store Apple Health data in iCloud, and we do not store Health Connect data outside the secured TRUE EAP services that power your Wellness Overview.

Technical Information

• IP address
• Device and browser information
• Login activity
• Cookies and analytics usage data

We only collect personal data reasonably necessary for providing our services.

2. How We Use Your Data

We may use your personal data to:

• provide access to the Platform and services;
• manage workshops, counselling, and support enquiries;
• improve platform performance and user experience;
• provide employer-administered access where applicable;
• generate HR reporting and wellbeing insights (where authorised);
• display Wellness Overview summaries in the True Wellness app on iOS and Android;
• communicate important updates and service notifications;
• comply with legal and regulatory obligations;
• prevent fraud, abuse, and security incidents.

We do not sell your personal data.

We do not sell Apple Health or Android Health Connect data or share it with advertisers.

Individual Apple Health and Health Connect data is not shared with employers or HR administrators, and is not shared with advertisers or data brokers. Health and fitness data accessed through Apple Health or Health Connect is used solely to provide the Wellness Overview feature to you and is handled in accordance with the Apple Health and Google Play Health Connect data-use policies.

3. Employer-Sponsored Access

If your employer provides your access to TRUE EAP:

• certain administrative data may be visible to authorised HR personnel;
• confidential counselling details remain protected and are not disclosed without consent unless required by law or where safety concerns arise.

We prioritise confidentiality in wellbeing-related services.

4. Disclosure of Personal Data

We may disclose personal data to:

• accredited trainers, counsellors, and service providers involved in delivering services;
• technology vendors supporting secure platform operations;
• legal, regulatory, or government authorities where required by law;
• your employer or organisation where contractually necessary and appropriately authorised.

All third parties are expected to maintain confidentiality and appropriate data protection standards.

5. Cookies and Analytics

We use cookies and similar technologies for:

• essential platform functionality;
• login and session management;
• security and fraud prevention;
• analytics to improve user experience.

Where applicable, optional analytics cookies are managed through our cookie consent banner.

You may manage browser settings to limit certain cookies, though some features may be affected.

6. Data Retention

We retain personal data only for as long as necessary to fulfil business, legal, contractual, and operational purposes.

When data is no longer required, we securely delete or anonymise it.

You may initiate account deletion in the True Wellness app on iOS or Android. Deletion requests are scheduled for permanent deletion after a 30-day grace period unless retention is required by law or legitimate compliance obligations.

You may disconnect Apple Health (iOS) or Health Connect (Android) in the app at any time. Disconnecting stops future health and fitness syncs. You can also revoke access directly in Apple Health or in the Android Health Connect settings.

7. Protection of Personal Data

We implement reasonable administrative, technical, and organisational safeguards to protect personal data against unauthorised access, disclosure, misuse, or loss.

However, no online system can guarantee absolute security.

8. Access and Correction Requests

Under the PDPA, you may request to:

• access your personal data;
• correct inaccurate personal data;
• withdraw consent where applicable.

Requests may be submitted to our Data Protection Officer using the contact details below.

Reasonable administrative fees may apply where permitted by law.

9. Cross-Border Transfers

Where personal data is processed outside Singapore (for example through secure cloud service providers), TRUE will take reasonable steps to ensure comparable standards of protection are maintained.

10. Updates to This Policy

We may update this Privacy Policy from time to time.

The latest version will always be published on the Platform with the revised effective date.

Continued use of the Platform constitutes acceptance of the updated policy.

11. Children and Minors

True Wellness is intended for adults aged 18 and above.

The Platform is not directed to children or minors, and we do not knowingly collect personal data from children through the True Wellness app on iOS or Android.

12. Contact Our Data Protection Officer

Data Protection Officer
Alex Tan
TRUE Advisory Pte. Ltd.
Email: alex@true.com.sg
Website: https://true.com.sg
Singapore