InferPheno App Privacy Policy

Version 1.3.x
Effective Date: 24 September 2026

1. Introduction

This Privacy Policy explains how PROXPLOR PTE. LTD. (202406772N) (“ProXplor,” “we,” “us,” or “our”) collects, uses, processes, stores, shares, protects, and deletes personal data in connection with InferPheno App.

PROXPLOR PTE. LTD. is the publisher and operator of InferPheno App and is the entity responsible for the personal data processing described in this Privacy Policy.

InferPheno App is a configurable digital phenotype application designed to provide personalized health insights and lifestyle optimization through organization- and program-specific report models.

InferPheno App is the user-facing application layer. The underlying ProXplor technologies supporting the service include:

ProXplor Nexus™
Health and Medical Intelligence Foundation Model & Core Technology Platform

and

InferPheno™
Digital Phenotype Inference Engine

InferPheno App provides functions including:

  • Account authentication and User ID management;

  • Personal profile management;

  • Organization and program access;

  • Standardized information and photo submission;

  • Digital phenotype processing;

  • Personal report generation and access;

  • Periodic reassessment;

  • User-controlled report sharing;

  • Account and data management;

  • Customer support; and

  • Privacy requests.

This Privacy Policy applies only to InferPheno App and the backend, processing, report-access, and report-sharing services directly associated with InferPheno App.

It does not govern the general ProXplor corporate website at proxplor.com, which is subject to its own privacy policy.

By using InferPheno App, you acknowledge that you have read and understood this Privacy Policy.

Your use of InferPheno App is also subject to the InferPheno App Terms of Use.

2. Definitions

For purposes of this Privacy Policy:

“InferPheno App” means the mobile application published and operated by PROXPLOR PTE. LTD. for providing applicable health insights, lifestyle optimization information, report access, and related services.

“ProXplor Nexus™” means ProXplor’s Health and Medical Intelligence Foundation Model & Core Technology Platform.

“InferPheno™” means ProXplor’s proprietary Digital Phenotype Inference Engine.

“User ID” means the unique internal identifier generated within ProXplor Nexus™ when a user first signs in through a supported authentication method. The User ID is used to associate the correct account, profile, service authorization, assessments, and Personal Reports with that user.

“Personal Profile Information” means personal information entered or confirmed by the user in InferPheno App, including Display Name, Gender, Date of Birth, Long-Term Place of Residence, Height, and Weight.

“Core Analytical Inputs” means the information used by InferPheno™ for the applicable assessment, consisting of:

  • Gender;

  • Date of Birth;

  • Long-Term Place of Residence;

  • Height;

  • Weight;

  • Frontal Face Photo;

  • Profile Face Photo; and

  • Frontal Tongue Photo.

“Display Name” means the name selected by the user for account identification and report presentation. Display Name is not used as an analytical input.

“Submitted Photos” means the Frontal Face Photo, Profile Face Photo, and Frontal Tongue Photo voluntarily submitted by the user for the applicable assessment.

“Personal Report” means a health, wellness, lifestyle, digital phenotype, or related report generated through the applicable InferPheno™ processing workflow and associated with the corresponding User ID.

“Organization Access” means the authorization mechanism through which eligible users receive access to services sponsored or made available by a participating organization or program.

“Organization Access Code” means a non-identifying access code allocated to a participating organization or authorized program administrator for distribution to eligible users.

“Participating Organization” means an enterprise, government institution, government-linked company, insurer, cooperative, membership organization, health or wellness organization, public-sector program, or other authorized organization participating in an applicable InferPheno App deployment.

“Report Sharing” means the user-initiated process through which a user provides temporary browser-based access to a specific Personal Report using an encrypted link and password.

3. Personal Data We Process

Depending on the functions you use, InferPheno App and ProXplor Nexus™ may process the categories of personal data described below.

3.1 Account and Authentication Information

InferPheno App supports:

  • Sign in with Apple; and

  • Google Sign-In.

When you first sign in, ProXplor Nexus™ generates a unique User ID and associates it with the applicable authentication account.

For authentication purposes, ProXplor processes only the account identifier and authentication information necessary to authenticate your account and associate it with your User ID.

InferPheno App does not request or obtain through Apple or Google authentication:

  • Your Apple or Google profile name;

  • Your Apple or Google email address;

  • Your profile photo;

  • Your contacts;

  • Other account content; or

  • Your Apple or Google password.

Account and authentication information may include:

  • Apple or Google authentication identifier;

  • User ID;

  • Authentication status;

  • Account status;

  • Login and access records; and

  • Security records.

When you subsequently sign in using the same linked authentication account, the existing User ID is recognized. A new User ID is not generated for each login or assessment.

The User ID is an internal account identifier. It is not a facial-recognition identifier, biometric template, or biometric authentication credential.

3.2 Personal Profile Information

You may provide or update Personal Profile Information through Edit Profile.

The current version of InferPheno App processes:

  • Display Name;

  • Gender — Male or Female;

  • Date of Birth;

  • Long-Term Place of Residence;

  • Height; and

  • Weight.

Display Name is used only for account identification and report presentation and is not used in health analysis or inference.

Long-Term Place of Residence refers to the city or region where you usually live.

InferPheno App does not require a precise street address for assessment purposes.

3.3 Location Information

InferPheno App does not collect GPS-level precise location for assessment purposes.

The app does not require continuous location tracking.

Long-Term Place of Residence is information voluntarily entered by the user and is distinct from device-derived precise geolocation.

3.4 Organization Access Information

Where you participate in an organization-sponsored or program-specific service, InferPheno App may process limited information necessary to verify and administer Organization Access.

This may include:

  • Organization Access Code verification information;

  • Organization Access status;

  • Program or organization association;

  • Service entitlement information;

  • Activation date and time;

  • Access history;

  • Authorization-related records; and

  • Limited security and operational information necessary to administer access.

Organization Access Codes are non-identifying when generated and do not themselves contain your name, email address, photos, health information, Personal Reports, or other direct personal identifiers.

Organization Access Codes are provided by participating organizations or authorized program administrators. They are not available for public individual purchase through InferPheno App.

3.5 Assessment Information

For an applicable assessment, InferPheno App processes the following user-provided analytical information:

  • Gender;

  • Date of Birth;

  • Long-Term Place of Residence;

  • Height;

  • Weight;

  • Frontal Face Photo;

  • Profile Face Photo; and

  • Frontal Tongue Photo.

Height and weight are entered by the user. They are not measured through the device camera.

Different configurable report models use the same core analytical input structure.

3.6 Submitted Photos

Users with applicable service access may submit:

  • Frontal Face Photo;

  • Profile Face Photo; and

  • Frontal Tongue Photo.

Submitted Photos may be:

  • Captured using the device camera; or

  • Selected from the device photo library,

subject to the permissions granted by the user.

Before photos are submitted for processing, InferPheno App provides information about the purpose of processing and the applicable photo-deletion rule.

Submitted Photos are securely transmitted for processing through ProXplor Nexus™ and InferPheno™ for the purpose of generating the applicable Personal Report.

3.7 Personal Reports

Personal Reports are generated through InferPheno™ and associated with the corresponding User ID in ProXplor Nexus™.

Depending on the applicable report model, a Personal Report may contain:

  • Digital phenotype observations;

  • Health and wellness information;

  • Lifestyle-related information;

  • Health insights;

  • Lifestyle optimization guidance;

  • Areas for continued attention;

  • Periodic reassessment information;

  • Report date;

  • Report identifier; and

  • Report model information.

Because Personal Reports may contain health- or wellness-related information, they may constitute sensitive personal data under applicable law.

3.8 Historical Reports

Personal Reports previously generated and associated with your User ID may remain available through My Reports while your account remains active.

Historical reports are stored and accessed in the same manner as other Personal Reports.

3.9 Device, Technical, Diagnostic, and Security Information

Where technically generated or reasonably necessary to operate, maintain, protect, and support InferPheno App and ProXplor Nexus™, limited technical information may be processed, including:

  • Device model;

  • Operating system version;

  • App version;

  • IP address;

  • Access date and time;

  • Authentication logs;

  • Security logs;

  • Crash or diagnostic information;

  • System performance information; and

  • Other limited information reasonably necessary for security, reliability, troubleshooting, and technical support.

ProXplor does not use third-party analytics, advertising, tracking, crash-reporting, or monitoring SDKs in InferPheno App.

3.10 Customer Support, Privacy Requests, and Feedback

If you contact ProXplor through Contact Support, Feedback, email, or another support channel, we may process:

  • Your User ID;

  • Your name, if voluntarily provided;

  • Your email address or other contact information you provide;

  • Support request content;

  • Privacy request content;

  • Feedback or complaint information;

  • Communication records; and

  • Other information reasonably necessary to respond to your request.

Please do not send assessment photos, medical records, passwords, or unnecessary sensitive personal information through ordinary email.

3.11 Payment Information

InferPheno App does not provide public consumer purchases or subscriptions.

The app does not provide an in-app mechanism for purchasing Organization Access Codes.

ProXplor does not collect payment-card information through InferPheno App for individual assessment purchases.

4. Assessment and Photo Submission Workflow

A typical assessment workflow may include:

  1. You sign in using Apple or Google authentication.

  2. ProXplor Nexus™ recognizes your User ID.

  3. You complete or confirm your Personal Profile Information.

  4. Where required, you activate Organization Access using an Organization Access Code.

  5. You select an available report model.

  6. You review the applicable processing information.

  7. You provide the required assessment information.

  8. You capture or select the required Frontal Face, Profile Face, and Frontal Tongue photos.

  9. You review and submit the assessment.

  10. Submitted information and photos are securely transmitted to ProXplor Nexus™.

  11. InferPheno™ performs the applicable digital phenotype processing.

  12. The resulting Personal Report is associated with your User ID and stored in ProXplor Nexus™.

  13. My Reports retrieves and displays the Personal Report after processing is completed.

  14. Submitted Photos are automatically deleted once the Personal Report is generated or 3 minutes after upload, whichever occurs first.

Creating an account, signing in, managing your Personal Profile Information, or accessing existing Personal Reports does not require you to submit new photos.

If you choose not to provide information or photos required for a particular assessment, that assessment and its resulting Personal Report cannot be completed.

5. Camera and Photo Library Access

InferPheno App may request permission to access your device camera and photo library.

Camera permission is used to allow you to capture the required face and tongue photos.

Photo library permission is used to allow you to select the required photos from your device.

You can manage camera and photo library permissions through your device settings.

If you deny or revoke these permissions, photo-submission functions may not be available.

Revoking a device permission does not reverse processing that was lawfully completed before the permission was revoked.

InferPheno App does not use the camera to perform clinical or physiological measurements.

6. How We Use Personal Data

We process personal data only for purposes reasonably related to operating and providing InferPheno App and its associated services.

6.1 Account and Authentication Management

Personal data may be used to:

  • Authenticate users;

  • Create and maintain the User ID;

  • Link the User ID to the applicable authentication account;

  • Maintain account status;

  • Protect account security;

  • Prevent unauthorized account access; and

  • Process privacy and account-deletion requests.

6.2 Personal Profile Management

Personal Profile Information may be used to:

  • Maintain your personal profile;

  • Allow you to review or update information;

  • Associate the correct information with your User ID; and

  • Support applicable assessment and report workflows.

6.3 Organization Access

Organization Access information may be used to:

  • Verify Organization Access Codes;

  • Associate an authorization with the correct User ID;

  • Maintain access and entitlement status;

  • Maintain access history;

  • Support authorized assessment access;

  • Prevent misuse or unauthorized access; and

  • Resolve access-related issues.

6.4 Digital Phenotype Processing and Report Generation

Assessment information and Submitted Photos may be used to:

  • Receive the information voluntarily submitted by you;

  • Securely transmit the information for processing;

  • Perform the applicable InferPheno™ processing workflow;

  • Generate the selected Personal Report;

  • Associate the report with the correct User ID;

  • Support technical reliability and processing integrity; and

  • Complete the applicable assessment.

6.5 Personal Report Access

Personal data may be used to:

  • Store Personal Reports in ProXplor Nexus™;

  • Associate each Personal Report with the correct User ID;

  • Retrieve reports belonging to the signed-in user;

  • Display reports through My Reports;

  • Maintain historical reports while the account remains active; and

  • Resolve report-access issues.

6.6 Security, Fraud Prevention, and Reliability

Information may be processed where reasonably necessary to:

  • Protect accounts;

  • Detect unauthorized access;

  • Prevent fraud and abuse;

  • Protect Organization Access mechanisms;

  • Maintain system integrity;

  • Investigate security incidents;

  • Diagnose technical issues;

  • Monitor system performance;

  • Improve service reliability;

  • Test technical functionality; and

  • Strengthen cybersecurity.

6.7 Internal Operational Improvement

Technical, operational, aggregated, anonymized, or de-identified non-image information may be used internally where reasonably necessary to:

  • Operate InferPheno App;

  • Maintain ProXplor Nexus™;

  • Improve reliability and technical performance;

  • Diagnose errors;

  • Improve service usability;

  • Strengthen security; and

  • Evaluate service operations.

Such use does not authorize the use of Submitted Photos, identifiable Personal Profile Information, or Personal Reports for AI model training.

6.8 Customer Support and Administrative Communications

Information you provide may be used to:

  • Respond to support enquiries;

  • Respond to privacy requests;

  • Resolve account or Organization Access issues;

  • Respond to feedback or complaints;

  • Send necessary security or administrative notices; and

  • Communicate material changes to the service or this Privacy Policy.

The current version of InferPheno App does not use push notifications.

7. No AI Model Training

Personal data processed through InferPheno App is not used to train or fine-tune ProXplor Nexus™, InferPheno™, or other AI models.

In particular:

  • Submitted Photos are not used for model training;

  • Personal Reports are not used for model training;

  • Identifiable Personal Profile Information is not used for model training; and

  • Organization Access information is not used for model training.

InferPheno App does not use third-party AI or large language model providers to process user assessment data.

The digital phenotype processing underlying InferPheno App is performed through ProXplor’s proprietary technologies, including ProXplor Nexus™ and InferPheno™.

8. Restricted Uses of Submitted Photos and Personal Data

Submitted Photos are not used for:

  • Facial recognition;

  • Identity verification;

  • Biometric authentication;

  • Creation of biometric identity templates;

  • Surveillance;

  • Advertising;

  • Cross-app tracking;

  • Data brokerage;

  • Unrelated commercial profiling; or

  • AI model training.

ProXplor does not sell personal data processed through InferPheno App.

Personal data, Submitted Photos, and Personal Reports are not used or disclosed through InferPheno App for:

  • Targeted advertising;

  • Cross-app advertising tracking;

  • Data brokerage;

  • Unrelated marketing profiling; or

  • Unrelated commercial profiling.

9. Organization Access and Sponsoring Organizations

Organization sponsorship provides eligible users with access to applicable services. It does not transfer control of the user’s personal data to the sponsoring organization.

Through InferPheno App, a Participating Organization does not receive access to:

  • Your Personal Reports;

  • Your Submitted Photos;

  • Your Personal Profile Information;

  • Your assessment inputs;

  • Your digital phenotype observations;

  • Your health or lifestyle insights; or

  • Other individual or aggregated health information generated through InferPheno App.

Participating Organizations may administer limited non-health access functions necessary to distribute or manage program entitlements, such as Organization Access Codes and related authorization status.

Organization Access Codes are non-identifying when generated.

InferPheno App reports are not provided or authorized for use in:

  • Insurance underwriting;

  • Premium pricing;

  • Insurance eligibility determinations;

  • Claims decisions;

  • Employment recruitment;

  • Promotion;

  • Compensation;

  • Disciplinary action;

  • Termination; or

  • Other adverse decisions about an individual.

10. Report Sharing

InferPheno App may allow a user to voluntarily share a specific Personal Report.

Report Sharing is initiated and controlled by the user.

When a user chooses to share a report:

  • An encrypted report-access link is created;

  • Access requires the corresponding password;

  • The recipient does not need to create an InferPheno App account;

  • The recipient may open the shared report using a standard web browser;

  • Access is limited to the specific report selected by the user;

  • The recipient does not gain access to the user’s InferPheno account, Personal Profile Information, other Personal Reports, Organization Access information, or other account data; and

  • The shared-report access expires after 7 days or 3 accesses, whichever occurs first.

Users are responsible for deciding whom to share a report with and for transmitting the link and password appropriately.

Once a user voluntarily provides the report-access information to another person, that recipient may view the report during the permitted access period.

The temporary report-sharing service is part of the backend services directly associated with InferPheno App and is covered by this Privacy Policy.

11. General Wellness and Health Data Scope

InferPheno App is designed and offered as a general wellness application.

It is not a medical device.

Personal data and Submitted Photos are processed to provide health insights, lifestyle optimization information, general wellness information, and periodic reassessment.

InferPheno App does not process user information or photos for the purpose of providing:

  • Medical diagnosis;

  • Disease detection or confirmation;

  • Disease prediction;

  • Clinical screening;

  • Clinical physiological measurement;

  • Medical treatment;

  • Prescriptions;

  • Emergency medical advice; or

  • Medical decision support.

InferPheno App does not measure blood pressure, blood glucose, blood oxygen saturation, body temperature, heart rate, electrocardiographic activity, or other clinical physiological parameters.

The current version of InferPheno App does not integrate with Apple HealthKit and does not read data from or write data to the Apple Health app.

Information provided through InferPheno App is intended to support general health awareness, lifestyle optimization, and general wellbeing and is not a substitute for professional medical advice, diagnosis, treatment, or emergency medical care.

12. Technology Infrastructure and Service Providers

Where a service provider processes personal data on behalf of ProXplor, ProXplor requires that provider to process the data only for the applicable service purpose and to provide the same or equivalent level of protection required under this Privacy Policy and applicable law.

12.1 PROXPLOR PTE. LTD.

PROXPLOR PTE. LTD. develops, publishes, and operates InferPheno App and is responsible for the personal data processing described in this Privacy Policy.

ProXplor provides the proprietary technologies supporting InferPheno App, including:

ProXplor Nexus™
Health and Medical Intelligence Foundation Model & Core Technology Platform

and

InferPheno™
Digital Phenotype Inference Engine

ProXplor Nexus™ supports functions including:

  • User ID generation and association;

  • Account and authentication association;

  • Personal Profile Information storage;

  • Organization Access management;

  • Assessment processing infrastructure;

  • Personal Report storage and retrieval;

  • Report Sharing;

  • Security and technical operation; and

  • Account and data deletion.

InferPheno™ processes applicable analytical inputs and Submitted Photos to support generation of the selected Personal Report.

ProXplor Nexus™ and InferPheno™ are proprietary ProXplor technologies. They are not external third-party AI, analytics, advertising, tracking, or data-broker services.

12.2 Alibaba Cloud – Singapore Region

ProXplor uses Alibaba Cloud – Singapore Region as part of the infrastructure supporting relevant storage, processing, platform operation, security, availability, and related technical functions.

Alibaba Cloud acts as an infrastructure provider.

It is not authorized by ProXplor to use InferPheno App user data for:

  • Advertising;

  • Independent marketing;

  • Commercial profiling;

  • Data brokerage;

  • Cross-app tracking; or

  • Unrelated purposes.

12.3 Apple and Google Authentication

Apple and Google provide the authentication services used for Sign in with Apple and Google Sign-In.

For InferPheno App, ProXplor does not request Apple or Google profile information such as name, email address, profile photo, contacts, or other account content.

ProXplor processes only the unique authentication identifier and authentication information necessary to verify account access and associate the sign-in account with the corresponding User ID.

ProXplor does not receive or store your Apple or Google password.

Apple and Google independently operate their authentication services under their own privacy policies and terms.

12.4 No Third-Party Analytics or Advertising SDKs

InferPheno App does not use third-party:

  • Analytics SDKs;

  • Advertising SDKs;

  • Tracking SDKs;

  • Third-party crash-reporting SDKs; or

  • Third-party monitoring SDKs.

Technical, crash, diagnostic, security, and performance information described in this Privacy Policy is processed within ProXplor’s own service environment.

12.5 Legal and Regulatory Disclosure

Personal data may be disclosed where required or permitted by applicable law, including to:

  • Courts;

  • Regulators;

  • Government authorities;

  • Law enforcement agencies;

  • Legal advisors;

  • Auditors; or

  • Other persons exercising lawful authority.

Any disclosure will be limited to what is reasonably necessary or legally required.

13. Storage, Security, and Cross-Border Processing

13.1 Storage and Processing Location

Personal Profile Information, User ID information, Organization Access information, Personal Reports, account information, and applicable technical information may be stored or processed through ProXplor Nexus™ using infrastructure located in Singapore.

ProXplor Nexus™ uses Alibaba Cloud – Singapore Region as part of its underlying infrastructure.

If you access InferPheno App from outside Singapore, personal data necessary to provide the service may therefore be transferred to and processed in Singapore.

Submitted Photos are subject to the substantially shorter automatic deletion period described below and are not retained as part of the user’s long-term account record.

13.2 Security Measures

ProXplor uses reasonable administrative, technical, and organizational safeguards designed to protect personal data.

Depending on the applicable system and information, these measures may include:

  • Encryption in transit;

  • Access controls;

  • Authentication controls;

  • Secure cloud infrastructure;

  • Restricted personnel access;

  • Security monitoring;

  • Data minimization;

  • Secure system administration;

  • Logging and security controls; and

  • Secure deletion procedures.

No electronic transmission or storage system can be guaranteed to be completely secure.

ProXplor nevertheless takes reasonable measures to protect personal data against unauthorized access, misuse, loss, alteration, disclosure, or unlawful processing.

13.3 Cross-Border Processing

InferPheno App is currently intended primarily for distribution in ASEAN markets, Australia, and North America.

Because the relevant ProXplor infrastructure is located in Singapore, personal data from users outside Singapore may be transferred to and processed in Singapore.

Where required by applicable law, appropriate safeguards will be applied to such cross-border processing.

14. Data Retention and Deletion

Personal data is retained only for as long as reasonably necessary for the purposes described in this Privacy Policy and subject to applicable legal requirements.

14.1 Submitted Photos

Submitted Photos are automatically deleted from the processing environment:

once the applicable Personal Report is generated or 3 minutes after upload, whichever occurs first.

Submitted Photos are not retained as part of the user’s long-term account record after that deletion point.

14.2 Active Accounts

While your account remains active, ProXplor Nexus™ may retain:

  • User ID information;

  • Personal Profile Information;

  • Organization Access information;

  • Access history;

  • Personal Reports;

  • Account association information; and

  • Other information reasonably necessary to maintain your account and authorized service access.

14.3 Personal Reports

Personal Reports, including historical Personal Reports, remain associated with your User ID while your account remains active unless otherwise deleted in accordance with applicable law or the service.

14.4 Organization Access Records

Organization Access information may be retained for as long as reasonably necessary to:

  • Maintain applicable authorization;

  • Administer service access;

  • Prevent unauthorized use;

  • Resolve access-related issues;

  • Maintain security and operational integrity; and

  • Meet applicable legal or contractual obligations.

14.5 Technical and Security Records

Limited technical, authentication, security, diagnostic, or access records may be retained for the period reasonably necessary for:

  • Cybersecurity;

  • Fraud prevention;

  • Troubleshooting;

  • Service reliability;

  • Incident investigation; and

  • Applicable legal or compliance requirements.

14.6 Customer Support and Privacy Requests

Support, privacy-request, complaint, and communication records may be retained for the period reasonably necessary to:

  • Respond to the request;

  • Maintain an appropriate support record;

  • Resolve disputes;

  • Protect security; and

  • Meet applicable legal obligations.

14.7 Account Deletion

When a user completes the Delete My Account process:

  • The InferPheno App account is permanently deleted;

  • The linked User ID is deleted;

  • Personal Profile Information associated with that User ID is permanently deleted;

  • Personal Reports associated with that User ID are permanently deleted;

  • Applicable account information associated with that User ID is permanently deleted; and

  • The deleted account and associated data cannot be restored.

Where applicable law requires or permits retention of limited records for legal, security, fraud-prevention, dispute-resolution, or compliance purposes, those records may be retained only to the extent reasonably necessary or legally required.

Such retained records will not be used to reconstruct or restore the deleted account, User ID, Personal Profile Information, or Personal Reports.

Submitted Photos are normally deleted substantially earlier under the automatic photo-deletion rule described above.

If you later register again, the registration will be treated as a new account and a new User ID will be created.

Deleting your InferPheno App account does not delete your Apple or Google account.

15. Account and Data Deletion

Users may initiate permanent account deletion directly through the Delete My Account function within InferPheno App.

Before deletion is completed, the app presents an Account Deletion Confirmation explaining the consequences of permanent deletion.

Once account deletion is completed, the deleted account and associated Personal Reports cannot be recovered.

Users may also contact ProXplor regarding account deletion or privacy requests using the contact information provided at the end of this Privacy Policy.

16. User Choices and Controls

16.1 Personal Profile

Users may review and update eligible Personal Profile Information through Edit Profile.

16.2 Organization Access

Users decide whether to activate an Organization Access Code provided by a Participating Organization or authorized program administrator.

Organization Access is separate from account creation and authentication.

16.3 Camera and Photo Library Permissions

Users decide whether to grant camera or photo library permission through their device settings.

If permission is denied or revoked, applicable photo-submission functionality may not be available.

16.4 Assessment Submission

Users decide whether to submit the personal information and photos required to complete an assessment.

Choosing not to submit the required information does not prevent a user from maintaining an account or accessing Personal Reports already associated with that User ID.

16.5 Consent

Where processing is based on consent, users may withdraw consent for future processing where permitted by applicable law.

Withdrawal does not invalidate processing lawfully completed before withdrawal.

Because Submitted Photos are subject to a short automatic deletion period, they may already have been deleted by the time a withdrawal request is received.

16.6 Report Sharing

Users independently decide whether to share a Personal Report.

Report Sharing is not automatic.

A user must intentionally initiate sharing and provide the applicable encrypted link and password to the intended recipient.

16.7 Account Deletion

Users may permanently delete their account through the Delete My Account function within InferPheno App.

17. User Privacy Rights

Subject to applicable law and applicable limitations, you may have the right to:

  • Request access to personal data associated with you;

  • Request correction of inaccurate or incomplete personal data;

  • Request deletion of personal data where applicable;

  • Withdraw consent where processing is based on consent;

  • Object to or restrict certain processing where applicable;

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

  • Request information regarding applicable cross-border processing; and

  • Raise a privacy enquiry or complaint.

Reasonable steps may be taken to verify the identity of a person making a privacy request before the request is fulfilled.

Privacy rights may differ depending on your country, state, province, territory, or other applicable jurisdiction.

ProXplor will handle privacy requests in accordance with applicable law.

18. Children and Minors

InferPheno App is intended for users 18 years of age or older.

Users under 18 are not eligible to complete assessments through the current version of InferPheno App.

ProXplor does not knowingly provide InferPheno App assessment services to persons under 18.

If ProXplor becomes aware that personal data from a person under 18 has been processed contrary to this requirement, reasonable steps will be taken to address the matter in accordance with applicable law.

19. Services Not Used by InferPheno App

For clarity, the current version of InferPheno App:

  • Does not use Apple HealthKit;

  • Does not read data from the Apple Health app;

  • Does not write data to the Apple Health app;

  • Does not collect GPS-level precise location for assessment purposes;

  • Does not use third-party advertising SDKs;

  • Does not use third-party tracking SDKs;

  • Does not use third-party analytics SDKs;

  • Does not use third-party AI or large language model services to process assessment data;

  • Does not use Submitted Photos for facial recognition or biometric authentication;

  • Does not use personal data or Submitted Photos for AI model training;

  • Does not provide public consumer in-app purchases or subscriptions; and

  • Does not currently use push notifications.

20. Third-Party Platforms and Independent Privacy Practices

InferPheno App interacts with certain independent services necessary for distribution, authentication, or infrastructure, including:

  • Apple App Store;

  • Google Play, where applicable;

  • Sign in with Apple;

  • Google Sign-In; and

  • Alibaba Cloud – Singapore Region.

These independent providers may process information under their own privacy policies, contractual terms, and legal obligations.

Where a provider processes personal data on behalf of ProXplor, ProXplor requires that provider to process the data only for the applicable service purpose and to provide the same or equivalent level of protection required under this Privacy Policy and applicable law.

ProXplor Nexus™ and InferPheno™ are proprietary ProXplor technologies and are not independent third-party services for purposes of this Privacy Policy.

External websites or services accessed independently by a user are subject to the privacy practices of the relevant third party.

21. Changes to This Privacy Policy

ProXplor may update this Privacy Policy from time to time to reflect:

  • Changes to InferPheno App;

  • Changes to account or authentication functionality;

  • Changes to Organization Access;

  • Changes to assessment or photo-submission functionality;

  • Changes to report models;

  • Changes to Report Sharing;

  • Changes to ProXplor technology infrastructure;

  • Changes to data-processing practices;

  • Changes to service-provider relationships;

  • Changes in applicable law or regulatory requirements;

  • App platform requirements;

  • Security requirements; or

  • Operational or technical changes.

The current version of this Privacy Policy will be made available through InferPheno App or an applicable ProXplor-hosted page.

Where required by applicable law, additional notice or consent will be provided before a material change takes effect.

The Effective Date shown at the beginning of this Privacy Policy identifies the effective date of the current version.

22. Contact Us

If you have questions about this Privacy Policy, InferPheno App privacy practices, your personal data, Submitted Photos, Personal Reports, Organization Access, Report Sharing, consent withdrawal, account deletion, or your privacy rights, please contact:

PROXPLOR PTE. LTD. (202406772N)

Privacy Contact
privacy@proxplor.com

General Support
hello@proxplor.com

ProXplor will handle privacy enquiries, requests, and complaints in accordance with applicable law.

Please do not send assessment photos, medical records, passwords, or unnecessary sensitive personal information through ordinary email.

© 2026–present PROXPLOR PTE. LTD. All rights reserved.