Privacy Policy

1. Who we are

MARKABLE is a perimenopause wellness companion operated by MARKABLE Ltd. ("we", "us", "our"). MARKABLE is a general wellness product, not a medical device. It is not intended to diagnose, treat, cure, or prevent any disease or medical condition. This policy explains how we handle personal data of users in Singapore in accordance with the Personal Data Protection Act 2012 (the "PDPA"). MARKABLE Ltd. is the organisation responsible for your personal data.

2. Your rights under the PDPA

The PDPA gives you a clear set of protections. In plain terms, we will:

• Seek your consent before collecting, using, or disclosing your personal data, and let you withdraw it.
• Tell you the purpose (the Notification and Purpose Limitation obligations) and use your data only for those purposes.
• Give you access to the personal data we hold about you and how it has been used, and correct it on request.
• Protect your data with reasonable security arrangements.
• Not keep your data longer than needed (the Retention Limitation obligation).
• Notify you and the Personal Data Protection Commission (PDPC) of a notifiable data breach.

You may lodge a complaint with the PDPC at pdpc.gov.sg if you believe we have not met these obligations.

3. What we collect

Information you provide

• Account information: email address, name (optional), and age range. If you choose to sign in with Google or Facebook, we receive your name, email address and profile picture from that provider. We use them to create and manage your account and to sign you in, and we use your email address as described in this policy.
• Health and wellness information: information you choose to provide or generate through MARKABLE, including symptom and cycle-related responses, results from THINK cognitive tasks, results from SENSE vision and hearing checks, and numerical wellness data and scores generated from your selfie analysis. This information is collected to provide your wellness assessment, establish a personal baseline, and allow you to track changes over time.
• Communications: messages you send us by email or contact form.

Information collected automatically

• Device information: browser type, operating system, and screen resolution.
• Usage data: pages visited, time on site, and referral source.

4. Your selfie and facial geometry

This section matters most, so we are explicit about it. The facial geometry derived from your selfie is biometric personal data, and we treat it accordingly.

• Separate consent: we ask for your specific consent before we capture your selfie. You can decline and still use other parts of MARKABLE.
• Processing: your selfie is analysed to extract numerical wellness data points (texture, tone, and volume measurements).
• Storage: your facial image is stored in encrypted form, only where you have consented, so we can generate your wellness picture and track how it moves over time.
• Never sold: your facial data is never sold or traded, and it is never shared with or made available to third parties for their own purposes. It is processed only by service providers (data intermediaries) acting on our behalf.
• No identification: we do not use your image for facial recognition or identity verification, only for wellness pattern analysis.
• Deletable: you can withdraw your consent and request deletion of your stored images at any time.

5. Purposes we use your data for

We use health and wellness information only to provide MARKABLE's wellness features, including generating your results, establishing your personal baseline, tracking changes over time, and creating your wellness summary. We do not sell health and wellness information or use it for advertising.

In line with the PDPA Purpose Limitation obligation, we use your data only to:

• generate your personal perimenopause wellness picture;
• track your own picture over time across multiple reads;
• create your summary to bring to a healthcare provider;
• improve our wellness models using only anonymised, aggregated data that no longer identifies you;
• send you your results and, if you opt in, wellness updates;
• respond to your questions and support requests; and
• meet our legal obligations.

We do not sell your data, build advertising profiles, perform facial recognition, or make medical diagnoses.

6. Consent and how to withdraw it

We rely on your consent to collect, use, and disclose your personal data for the purposes above. You may withdraw consent for any purpose at any time by emailing privacy@markable.life. We will tell you the likely consequences of withdrawal (for example, that we can no longer generate or track your wellness picture), and we will stop the relevant processing within a reasonable time.

7. Who we disclose data to

We do not sell health and wellness information or use it for advertising. Where service providers (data intermediaries) process information on our behalf in order to operate the service, they may use it only for the purposes described in this policy and subject to our contractual requirements.

We disclose personal data only to:

• Service providers (data intermediaries): hosting on Cloudflare Pages, account sign-in (Clerk), analytics (Google Analytics 4, which runs only after you accept analytics cookies), web fonts (currently served by Google Fonts), and payment processing. They process data on our behalf under contractual obligations consistent with the PDPA.
• At your direction: when you choose to share your wellness summary with a healthcare provider.
• Employer and organisational wellness programmes: When MARKABLE is offered through your employer or another organisation, that organisation receives only aggregated, de-identified statistics. It never receives your individual results, images or answers.
• Business transfers: If MARKABLE is involved in a merger, acquisition or sale of assets, your data may be transferred as part of that transaction. We will notify you before your data becomes subject to a different privacy policy.
• Legal requirements: where required by law, court order, or a lawful request from a public agency.

We do not sell, trade, or rent your personal data to anyone.

8. Visitor counting and analytics

Analytics run only after you accept them in our cookie banner; until then no analytics cookies are set. We use:

• Google Analytics 4 (G-EKN2TP5SW8): To understand, in aggregate, how visitors use our site. Loads only after you accept. You can also opt out using Google's opt-out tool, and we honour the Global Privacy Control (GPC) browser signal as an opt-out.
• Essential cookies: To keep you signed in and remember your cookie choice. These set no analytics.
• Visitor counting: A privacy-friendly beacon (a Cloudflare Worker) that records only a per-country daily count of visits; no identifier is stored.

Web fonts: Our pages currently load fonts from Google Fonts, so your browser connects to Google and your IP address is processed by Google to deliver the fonts. We are moving to self-hosted fonts to remove this dependency.

We do not use advertising cookies, retargeting pixels, or social media tracking pixels.

9. Transfers outside Singapore

MARKABLE Ltd. operates from Israel, and our service providers may process data in other countries. Where personal data is transferred outside Singapore, we take reasonable steps to ensure a comparable standard of protection through contractual safeguards, as required by the PDPA Transfer Limitation obligation.

10. Access and correction

Under the PDPA you may ask us for access to the personal data we hold about you and information on how it has been used or disclosed in the past year, and you may ask us to correct any error or omission. To make a request, email privacy@markable.life. We will respond as soon as reasonably possible, and where we cannot do so within 30 days we will tell you when to expect a response.

11. Retention and deletion

• Health and wellness information: symptom and cycle-related responses, THINK and SENSE results, and assessment scores are kept while your account is active, or until you request deletion.
• Facial images: kept in encrypted form while your account is active, and deleted on account deletion or on your request.
• Anonymised data: aggregated, de-identified data may be retained for product improvement.
• Account data: deleted within 30 days of an account deletion request, unless retention is required by law.

12. Protection of your data

We apply reasonable security arrangements to protect your personal data, including:

• encryption in transit (TLS) and at rest;
• access controls and authentication;
• regular security assessments; and
• secure data processing practices.

No method of transmission over the Internet is completely secure. While we work hard to protect your data, we cannot guarantee absolute security.

13. Data breach notification

If a data breach occurs that is likely to result in significant harm to you, or is of a significant scale, we will notify the Personal Data Protection Commission, and affected individuals, in accordance with the PDPA's data breach notification requirements.

14. Marketing and Do Not Call

We will only send you marketing or wellness messages where you have opted in, and you can opt out at any time using the link in the message or by emailing us. If you provide a Singapore telephone number and we ever contact you by telephone, SMS, or fax for marketing, we will comply with the Do Not Call (DNC) provisions of the PDPA and check the relevant DNC registers before doing so.

15. Children

MARKABLE is designed for adult women in midlife and is not intended for anyone under 18. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, please contact us and we will delete it.

16. Changes to this policy

We may update this policy from time to time. We will post any changes on this page and update the "Last updated" date above. Material changes will be notified before they take effect.

17. Contact and our Data Protection Officer

For any privacy question, to exercise your rights, or to reach our Data Protection Officer:

• Privacy and data requests: privacy@markable.life
• General contact: hello@markable.life

Organisation responsible for your data: MARKABLE Ltd.