InferPheno™ Enterprise Privacy Policy

Last Updated: August 8, 2026

This Privacy Policy explains how ProXplor PTE. LTD. (“ProXplor,” “we,” “us,” or “our”) collects, uses, processes, stores, protects, shares, and manages personal data when authorized users access or use the InferPheno™ Enterprise application, website, reports, health and lifestyle insight services, periodic reassessment features, and related digital services (“InferPheno™ Enterprise” or the “Services”).

InferPheno™ Enterprise is an organization-authorized personal health and lifestyle information platform for authorized users of enterprises, government institutions, and other organizations. Through ProXplor Nexus™ Solutions, participating organizations may configure health and lifestyle insight services, report types, and service frameworks according to their program requirements.

Organization authorization determines whether a user is eligible to access the Services configured by that organization. It does not, by itself, provide the affiliated organization, its administrators, or other organization personnel with access to the user’s personal health and lifestyle information, submitted images, or individual reports.

Personal health and lifestyle information is account-specific and is intended for the individual user’s own viewing and understanding unless the user explicitly initiates or authorizes sharing through an available sharing feature.

InferPheno™ Enterprise provides general health and lifestyle information, visual phenotype observations, personalized status references, daily lifestyle suggestions, and periodic reassessment references. It is not intended for disease diagnosis, disease prediction, clinical screening, treatment, prescription, clinical measurement, emergency medical advice, or medical decision-making.

1. Information We Collect

Depending on the Services made available to you and how you use InferPheno™ Enterprise, we may collect or process the following categories of information.

1.1 Account and Profile Information

We may collect information provided by users or required for account access and service delivery, including:

  • Display name or user identifier;

  • Sex;

  • Date of birth;

  • City, country, or region of long-term residence;

  • Phone number, where requested;

  • Email address, where requested;

  • Authentication identifiers returned through Sign in with Apple or Sign in with Google;

  • Organization-related service authorization or eligibility information.

InferPheno™ Enterprise uses the unique account identifier returned by the applicable authentication provider to associate the authenticated user with their individual account and information.

Each user must successfully authenticate through their own supported account before accessing personal health and lifestyle information or individual reports.

We collect account and profile information only where relevant to account setup, authentication, personalization, service delivery, security, user support, organization-authorized access, or compliance.

1.2 Date of Birth and Age-Related Information

We collect date of birth to determine or estimate the user’s age and age group where relevant to the Services.

Where applicable, date of birth may also be used as contextual information when generating non-clinical health and lifestyle insights, including references related to age, time, seasonal rhythm, or other lifestyle context.

Date of birth is not used to make a clinical diagnosis or replace professional medical judgment.

1.3 City, Country, or Region of Long-Term Residence

We may collect the user’s city, country, or region of long-term residence to provide general environmental and lifestyle context.

This may include broad climate characteristics, humidity, temperature, seasonal patterns, regional lifestyle context, and other environmental background factors relevant to general health and lifestyle interpretation.

InferPheno™ Enterprise does not collect GPS-level precise location for this purpose unless separately disclosed and authorized.

Long-term residence information is used as contextual information and is not intended to track the user’s real-time location.

1.4 User-Submitted Images

Depending on the report type and Services configured by the user’s affiliated organization, InferPheno™ Enterprise may ask users to voluntarily submit images including:

  • Frontal facial image;

  • Profile facial image;

  • Frontal tongue image.

Submitted images are used only to provide the requested image-based health and lifestyle insight service, including visual phenotype observation and generation of the corresponding report.

Facial and tongue images are not used for:

  • Identity verification;

  • Facial recognition;

  • Biometric identification;

  • Biometric authentication;

  • Surveillance;

  • Advertising;

  • User tracking;

  • Cross-app tracking;

  • Commercial profiling;

  • Data brokerage;

  • Sale of personal information;

  • Third-party identity matching;

  • Model training.

InferPheno™ Enterprise does not create facial recognition templates, biometric identifiers, biometric profiles, biometric templates, or face-based identity records from user-submitted images.

Submitted images are temporarily processed on cloud infrastructure solely to provide the requested service. Report generation typically takes approximately 2–3 minutes. Once processing is completed, submitted images are automatically deleted and are not retained as long-term account records.

Generated health and lifestyle insight reports may be retained in the user’s authenticated account for personal viewing, user-initiated sharing, periodic reassessment reference, and ongoing tracking.

Users should submit only images required for the applicable InferPheno™ Enterprise service and should not upload images of other individuals unless they have appropriate authorization to do so.

1.5 Health and Lifestyle Information

InferPheno™ Enterprise may collect, process, or generate health and lifestyle information required to provide the Services.

This may include:

  • User-provided profile information;

  • User-submitted images;

  • Report inputs;

  • Visual phenotype observations;

  • Lifestyle status references;

  • Personalized health and lifestyle insights;

  • Daily lifestyle suggestions;

  • Periodic reassessment records;

  • Generated reports;

  • Other information required for organization-configured health and wellbeing services within the defined scope of InferPheno™ Enterprise.

Health and lifestyle information may be considered sensitive personal data or sensitive health-related information under applicable laws and will be handled accordingly.

1.6 Device, Technical, and Usage Information

We may collect technical and operational information including:

  • Device type;

  • Operating system;

  • App version;

  • Language settings;

  • Log information;

  • Feature usage;

  • Crash information;

  • Diagnostics;

  • Performance information;

  • Security and access records.

This information may be used to maintain service functionality, improve reliability and user experience, diagnose technical issues, protect security, and prevent misuse.

1.7 Communications

If you contact us, we may collect information such as your name, email address, phone number, message content, and other information you voluntarily provide.

2. Why We Collect User Images

Certain InferPheno™ Enterprise services use visual inputs to provide visual phenotype observations and corresponding health and lifestyle insights.

Depending on the selected report type, the requested images may include:

  • A frontal facial image to support observation of visible facial phenotype patterns;

  • A profile facial image to provide an additional visual perspective;

  • A frontal tongue image to support observation of visible tongue-related characteristics.

The specific images required may vary according to the report type and Services configured by the user’s affiliated organization.

Images are used only for the requested visual phenotype observation and corresponding health and lifestyle insight service.

They are not used to determine the identity of the user and are not used for facial recognition, biometric identification, advertising, tracking, commercial profiling, third-party identity matching, or model training.

Submitted images are automatically deleted after the requested image-processing workflow is completed and are not retained as long-term account records.

3. How We Use Information

We may use collected information to:

  • Create, maintain, authenticate, and manage user accounts;

  • Confirm eligibility for organization-authorized Services;

  • Provide health and lifestyle insight services and reports configured for the user;

  • Process voluntarily submitted images for visual phenotype observation;

  • Generate lifestyle status references and personalized health and lifestyle insights;

  • Provide daily lifestyle suggestions and periodic reassessment references;

  • Support periodic reassessment and longitudinal personal tracking;

  • Apply age-related, environmental, seasonal, and lifestyle context where relevant;

  • Maintain and improve product functionality, reliability, performance, safety, and security;

  • Provide technical and customer support;

  • Prevent misuse, fraud, unauthorized access, or system abuse;

  • Maintain service integrity;

  • Comply with applicable legal, regulatory, contractual, and platform requirements.

We do not use submitted facial or tongue images for advertising, tracking, facial recognition, biometric identification, identity verification, commercial profiling, data brokerage, sale of personal information, or model training.

We do not use personal health and lifestyle information to determine a user’s employment eligibility, employment suitability, promotion, compensation, disciplinary action, or insurance eligibility.

4. Organization Authorization and Personal Data Access

InferPheno™ Enterprise operates through an enterprise and organization-authorized access model.

The user’s affiliated enterprise, government institution, or organization may determine whether the user is eligible to access the Services configured for that organization and may manage related service permissions.

Organization authorization determines service eligibility and access permissions only.

It does not grant the affiliated organization, its administrators, human resources personnel, finance personnel, managers, or other organization representatives access to the user’s:

  • Submitted facial or tongue images;

  • Personal health and lifestyle information;

  • Individual visual phenotype observations;

  • Individual health and lifestyle insight reports;

  • Periodic reassessment results.

Personal health and lifestyle information is accessible through the individual user’s authenticated account and is intended for that user’s own viewing and understanding.

Such information may be shared with another person or organization only when:

  • The individual user explicitly initiates or authorizes the sharing through an available sharing feature; or

  • Disclosure is required or permitted under applicable law.

Organization authorization does not constitute user consent for an organization to access the user’s personal health and lifestyle information.

5. Health and Medical Boundary

InferPheno™ Enterprise is designed to provide general health and lifestyle information, visual phenotype observations, lifestyle status references, personalized insights, daily lifestyle suggestions, and periodic reassessment references.

InferPheno™ Enterprise does not provide:

  • Medical diagnosis;

  • Disease diagnosis or confirmation;

  • Disease prediction;

  • Clinical screening;

  • Emergency medical advice;

  • Treatment plans;

  • Prescription guidance;

  • Medication advice;

  • Clinical measurement;

  • Medical-device measurement;

  • Medical decision support.

Image-based analysis is intended only to support visual phenotype observation and general health and lifestyle information services. It should not be interpreted as a medical diagnosis, clinical screening result, clinical measurement, treatment recommendation, or substitute for professional medical examination or care.

InferPheno™ Enterprise does not replace physicians, qualified healthcare professionals, medical institutions, clinical testing, laboratory testing, regulated medical devices, diagnosis, treatment, or professional medical care.

If you have symptoms, health concerns, or require medical care, please consult a qualified healthcare professional. In an emergency, contact your local emergency services or seek immediate medical assistance.

6. Legal Basis and User Consent

We process personal data only where an appropriate legal basis exists under applicable law.

Depending on the jurisdiction and type of processing, legal bases may include:

  • User consent;

  • Performance of Services requested by the user;

  • Performance of applicable contractual obligations;

  • Legitimate interests relating to security, service operation, product reliability, fraud prevention, and support, where permitted by law;

  • Compliance with legal or regulatory obligations.

Where consent is required for specific processing activities, users may be asked to provide separate and affirmative consent.

This may include consent relating to:

  • Camera access;

  • Photo library access;

  • Image capture or upload;

  • Processing of submitted images;

  • Processing of health or lifestyle-related information;

  • Optional analytics or other features where applicable.

Authorization from an enterprise or organization to use InferPheno™ Enterprise is separate from the individual user’s consent to processing of personal data.

Where processing is based on consent, users may withdraw consent subject to applicable law. Withdrawal of consent may affect the availability of features that require the relevant information.

7. Camera, Photo Library, and Image Upload Permissions

InferPheno™ Enterprise may request access to the device camera or photo library only where necessary for users to capture or select images required for an available visual phenotype insight service.

Camera and photo library access is used only for user-selected image capture or upload.

InferPheno™ Enterprise does not access unrelated photographs without user action and the required device permission.

Users may manage camera and photo library permissions through their device settings.

If permission is not granted, image-based features requiring that permission may not be available.

8. How We Share Information

We do not sell users’ personal data, personal health and lifestyle information, reports, or submitted images.

We do not share submitted facial or tongue images, personal health and lifestyle information, or individual reports with advertisers, data brokers, marketing platforms, or other third parties for their independent commercial purposes.

Where necessary to provide the Services, limited personal data may be processed by infrastructure or authentication service providers acting on our behalf, including cloud infrastructure and supported account authentication services. Such processing is limited to what is necessary to provide, secure, and operate InferPheno™ Enterprise.

Service providers acting on our behalf are not permitted to use personal data for their own independent purposes and are required to apply appropriate privacy and security protections.

An affiliated enterprise or organization does not receive access to a user’s submitted images, personal health and lifestyle information, or individual reports solely because it provides or manages the user’s service authorization.

Personal health and lifestyle information may be shared with an affiliated organization only when the individual user explicitly initiates or authorizes such sharing through an available sharing feature, or where disclosure is required or permitted by applicable law.

We may also disclose information where required by applicable law, legal process, regulators, or competent authorities.

9. Data Storage and Security

Submitted facial and tongue images are temporarily processed on Alibaba Cloud infrastructure located in Singapore solely for the requested image-based service.

Report generation typically takes approximately 2–3 minutes. Once image processing is completed, submitted images are automatically deleted and are not retained as long-term account records.

We use reasonable administrative, technical, and organizational measures designed to protect personal data, health and lifestyle information, report data, and submitted images against unauthorized access, loss, misuse, alteration, or disclosure.

These measures may include:

  • Access controls;

  • Encryption in transit where appropriate;

  • Secure infrastructure;

  • Internal permission management;

  • System monitoring;

  • Operational security procedures;

  • Short-term image processing;

  • Automatic image deletion;

  • Purpose limitation;

  • Data minimization.

We select infrastructure and technical service providers with reference to recognized security and compliance practices. Third-party compliance certifications do not replace ProXplor’s responsibility for handling user information according to applicable privacy and security requirements.

No mobile application, cloud service, storage environment, or internet transmission can be guaranteed to be completely secure. Users should protect their account credentials and use the Services in a secure manner.

10. Data Retention

We retain personal data, health and lifestyle information, report data, account information, and necessary technical records only for as long as reasonably required for the purposes described in this Privacy Policy or as required or permitted by applicable law.

User-submitted facial and tongue images are subject to a separate short-retention process.

Submitted frontal facial images, profile facial images, and frontal tongue images are temporarily processed only for the period required to complete the requested service. Once processing is completed, the submitted images are automatically deleted.

Original submitted facial and tongue images are not retained as part of the user’s long-term account record.

The user’s authenticated account may retain:

  • Generated health and lifestyle insight reports;

  • Periodic reassessment records;

  • Relevant profile information;

  • Account information;

  • Service history required for user access and ongoing tracking.

When information is no longer required, we may delete, anonymize, de-identify, or retain it only where required or permitted by applicable law.

Users may request deletion of their account and associated information as described in this Privacy Policy.

11. Report Access and Sharing Security

Access to personal health and lifestyle information is account-specific.

Each user must successfully authenticate through their own supported Sign in with Apple or Sign in with Google account before accessing their personal information and reports.

InferPheno™ Enterprise uses the unique authentication identifier returned by the applicable authentication provider to associate the authenticated user with their individual account and information.

Users may choose to share an individual report through an available sharing feature.

Where encrypted report sharing is provided, shared access may use an encrypted link and access key.

A shared access link is limited to 3 views or 7 days, whichever occurs first.

Expiration of the shared access link does not by itself delete the original report retained in the user’s authenticated account.

Sharing is initiated or authorized by the individual user. Users should share reports only with recipients they trust.

12. International Data Transfers

ProXplor operates internationally, and user information may be processed, stored, or transferred in countries or regions outside the user’s place of residence where necessary to provide, operate, secure, or support the Services.

Submitted facial and tongue images are temporarily processed on Alibaba Cloud infrastructure located in Singapore for the requested image-based service.

Where applicable, international data transfers will be handled in accordance with applicable legal requirements and appropriate data protection safeguards.

13. User Rights and Choices

Subject to applicable law, users may have rights including the right to:

  • Access personal data held about them;

  • Correct or update inaccurate personal information;

  • Request deletion of personal data;

  • Request deletion of account information or stored reports;

  • Withdraw consent where processing is based on consent;

  • Object to or restrict certain processing activities where applicable;

  • Manage camera and photo library permissions through device settings;

  • Request information about how personal data is used or shared;

  • Contact us regarding privacy-related questions or concerns.

To exercise applicable privacy rights, please contact:

privacy@proxplor.com

We may need to verify the requester’s identity before completing certain requests.

14. Children and Minors

InferPheno™ Enterprise is not intended for children below the minimum age at which an individual may independently consent to the use of digital services or processing of personal data under applicable law.

Where InferPheno™ Enterprise is made available to a minor, appropriate authorization or consent from a parent, legal guardian, or other legally authorized person may be required.

We do not knowingly collect or process personal data or submitted images from children without the authorization or consent required by applicable law.

If we become aware that personal data has been collected from a child without the required authorization, we will take appropriate steps to delete or otherwise lawfully address the information.

15. Analytics and Tracking Technologies

InferPheno™ Enterprise may use technical analytics, cookies, device information, or similar technologies where necessary to:

  • Maintain service functionality;

  • Understand product usage;

  • Diagnose errors;

  • Improve app performance;

  • Enhance security;

  • Prevent misuse;

  • Improve user experience.

InferPheno™ Enterprise does not use submitted facial or tongue images, personal health and lifestyle information, or individual reports to track users across third-party applications or websites for advertising purposes.

We do not use facial or tongue images for advertising tracking, cross-app tracking, or behavioral advertising.

Where optional analytics or similar technologies require consent under applicable law or platform requirements, appropriate consent mechanisms will be provided.

16. Research and Product Improvement

We may use aggregated, anonymized, or appropriately de-identified non-image information for legitimate internal purposes such as:

  • Statistical analysis;

  • Service quality improvement;

  • Product performance evaluation;

  • Security improvement;

  • Operational analysis;

  • Internal research and development.

Where such information is used, reasonable measures will be taken to reduce the ability to identify individual users.

User-submitted facial and tongue images are not used for model training.

We do not use identifiable personal health and lifestyle information or identifiable submitted images for advertising, identity recognition, biometric identification, cross-app tracking, or unrelated research without an appropriate legal basis and, where required, explicit user consent.

17. User Control and Account Deletion

Users may initiate deletion of their account through the in-app account deletion function.

Users may also contact us regarding deletion of personal data or stored reports at:

privacy@proxplor.com

Account deletion is intended to delete the user’s account and associated stored personal data and reports, except information that must be retained where required or permitted by applicable law.

Where applicable, we may retain limited information necessary to:

  • Comply with legal obligations;

  • Establish, exercise, or defend legal claims;

  • Prevent fraud or abuse;

  • Maintain necessary security or transaction records where legally permitted.

Any information retained after an account deletion request will remain subject to appropriate safeguards and will not be retained longer than necessary for the applicable purpose.

Because original submitted facial and tongue images are automatically deleted after processing, they are not normally retained as part of the user’s long-term account data.

18. Organization Health and Wellbeing Programs

InferPheno™ Enterprise may be made available as part of a health and wellbeing program sponsored or configured by an enterprise, government institution, or other organization.

The organization may manage:

  • User eligibility;

  • Service authorization;

  • Available report types;

  • Access permissions;

  • Program-level service configuration.

The organization’s role in managing access does not provide it with access to individual users’ submitted images, personal health and lifestyle information, or individual reports.

InferPheno™ Enterprise does not use individual health and lifestyle information to make employment, promotion, compensation, disciplinary, insurance eligibility, or similar organizational decisions.

Any sharing of an individual report with an organization must be initiated or explicitly authorized by the individual user, unless disclosure is otherwise required or permitted by applicable law.

19. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in:

  • InferPheno™ Enterprise Services;

  • Technology;

  • Data-processing practices;

  • Legal or regulatory requirements;

  • Platform requirements;

  • Security practices;

  • Business operations.

Where changes are material, we may provide notice through the application, website, or other appropriate channels.

The “Last Updated” date at the beginning of this Privacy Policy indicates when the policy was most recently revised.

20. Contact Us

If you have questions about this Privacy Policy, your privacy rights, or how your information is handled, please contact:

ProXplor PTE. LTD.
Website:www.proxplor.com
Privacy Email:privacy@proxplor.com
General Email:info@proxplor.com