Privacy Policy


HEALTHREE TECHNOLOGIES LTD. (We, Us, or Our) is a company incorporated in British Virgin Islands and understands and respects your desire to maintain your privacy. This Privacy Policy applies to your use of the HEAL-Ⅲ Mobile Application (HEAL-Ⅲ or App), any website operated by us (including (HEAL-Ⅲ Website(s)) and the services we provide that are accessible via any of them (Services).

This Privacy Policy(Privacy Policy) sets out the basis on which any personal data we collect from you, or that you provide to us, will be stored and processed by us. This Privacy Policy and the procedures outlined herein comply with EU General Data Protection Regulation 2016/679 of April 27, 2016 (GDPR), the relevant national legislation of the Countries implementing the GDPR (together the “Regulations”).

Please read the entirety of this Privacy Policy carefully before using the Services. By using or accessing any of our Services through any channel or method, and/or by accepting the Terms of Use, You agree and consent to the use, collection, disclosure and other processing of Your Personal Data by us under this Privacy Policy. IF YOU DO NOT CONSENT TO THE PROCESSING OF YOUR PERSONAL DATA AS DESCRIBED IN THIS PRIVACY POLICY, PLEASE DO NOT USE OUR SERVICES OR ACCESS OUR APP OR WEBSITES.

The Services may contain links to or information about third party websites that are not within our control. We are not responsible for the privacy practices of any external website or mobile application.


This Privacy Policy covers your personal information. "Personal Information" or "Personal Data" means data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which an organization has or is likely to have access. For the purposes of this Privacy Policy, there is no meaningful distinction between the terms "Personal Information" and "Personal Data".

Common examples include your name, username, password, IP address, unique device identifiers, gender, signature, address, telephone number, email, date of birth, digital wallet details, photos and videos of you, other identification credentials and biographical details, and commentary or opinions about you.

We also collect information about your location and physical movements in order for the App to function properly and monitor and verify forms of eligible movement.


We may collect some or all of the following types of personal information:

  1. information that you give us through your dealings with us;

  2. information that we may collect from you; and

  3. information that we may receive from you from other third party sources.

By agreeing to this Privacy Policy, you consent to the fact that you are aware that we are collecting your personal information and disclosing it as required by us and in accordance with the GDPR.


You may choose not to provide some of the personal information. Please note, however, that some of our services require some personal information to operate, so if you choose not to provide the personal information necessary to operate and provide you with a particular service or feature of that service, you may not be able to use that service or feature.

Information that you give us:

We may collect your personal information directly from our contact with you. This may include by you completing forms or parts of our website, Social Media, App and/or other software and/or mobile applications, or by you contacting us via the email, telephone, through Social Media and other similar functions either directly through our website or the App or through third party host websites, in person, through various marketing channels or competitions either directly through our website or the App or through third party host websites, and surveys.

You understand that any personal information that you provide to us must be accurate and up to date. We will assume this to be the case.

Information that we collect about you:

Our website, Social Media (Including Facebook, Twitter and Instagram. but not be limited to these), App and/or other software and/or mobile applications may automatically collect the following information about you each time you visit or otherwise use our website, Social Media, App and/or other software and/or mobile applications:

  1. Technical Data: including the Internet protocol (IP) address, browser type, internet service provider, device identifiers, your login information, time zone setting, browser plug-in types and versions, preferred language, activities, operating system and platform, and geographical location; and

  2. Usage Data: including the full Uniform Resource Locators (URL), clickstream to, through and from the SweatCo Websites, pages you viewed and searched for, page response times, length of visits to certain pages, referral source/exit pages, page interaction information (such as scrolling, clicks and mouse-overs), date and time pages are accessed, website navigation and search terms used, and whether you have opened our marketing newsletters.


We may use Your Personal Data for any and all of the following purposes:

  1. providing our services;

  2. verifying your physical movement and location and issuing tokens on the basis of this verified data;

  3. investigating and/or preventing suspected fraud or other criminal activities or misuse of our services, including the collection and disclosure of user location and movement data;

  4. fraud detection and integrity management for gaming systems of the App and other services;

  5. evaluating the compatibility of our software versions and other aspects of our services;

  6. investigating disputes between players;

  7. communicate with you, including to inform you of updates to the App, website, our Terms of Use and/or this Privacy Policy;

  8. processing the transfer of digital assets;

  9. for internal business purposes, including marketing, sales promotion, research, analysis, testing and auditing;

  10. updating and informing you on new products, features, Services and after-sales follow-up;

  11. conducting polls, surveys, analysis and research on our Services to improve and personalize our Services;

  12. for consumer engagement and/or customer service purposes, including but not limited to identifying the effectiveness of advertising, allowing you to participate on website viral features such as sharing website content and other community features;

  13. for other general services such as website/software security, maintenance, identification of fraud or errors, internal accounting and administration, and for any other purpose that we are required or permitted to do by law; and

  14. managing our relationships with you and our other customers.

The Purposes listed may continue to apply even in situations where your relationship with us has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under any contract with you).

We may use and disclose automatically collected information (including aggregated information), which is not Personal Data, for any purpose, except where we are restricted by applicable law. If we combine any automatically collected information with Personal Data or other information which may be used to identify an individual, the combined information will be treated by us as Personal Data in accordance with this Privacy Policy.

As we utilize cross border IT services and platforms which can be accessed from various countries via an internet connection, it is not always practicable to know where your information may be held.


We may share and permit your Personal Information to be shared with third parties and our affiliates for the purposes described above. If we share your Personal Information with third parties, we will endeavor to protect your Personal Information from unauthorized access, collection, use, disclosure, processing, or similar risks and to retain your Personal Information only as long as the third parties and our affiliates need your Personal Information to accomplish the purposes described above.

We may share your Personal Information with the following categories of third parties:

  1. Other users. Certain information of your personal data may be shared with other users of the App as part of the normal operation of the Services (for example we may publish your total verified movement, during a particular period to other users from time to time).

  2. Business partners. We may share your personal data with our trusted business partners in order that they can contact you from time to time with offers that may interest you and/or inform you of other products or services, provided you have given your consent for us to do so.

  3. Law enforcement, regulators, governmental authorities and other parties for legal reasons. We may share your personal data with third parties if we are legally required to do so, or if we believe, in good faith, that such disclosure is necessary to comply with a legal obligation or request, to enforce our terms and conditions, to prevent or resolve security or technical issues, or to protect the rights, property or our safety, or the safety of our users, a third party, or the public.

  4. Service providers. We may share your personal data with third party service providers that perform services for us or on our behalf, which may include providing data hosting, customer relationship management, payment processing and analytics services.

  5. Our potential investors, purchasers and commercial counterparties. We may share your Personal Information with any person who wishes to invest in Company or whom we intend to enter into a business combination with (such as a purchase, sale, lease, merger or amalgamation, or any other acquisition, disposal or financing).


Your Personal Information may be transferred to other countries for processing, and by using any part of the Services, You consent to the transfer, use and processing of your Personal Information to countries outside of British Virgin Islands which may have different Personal Information protection rules than in British Virgin Islands. However, the level of protection that will be applied to the transferred Personal Information will be at least comparable to the protection provided under this Privacy Policy and the GDPR.


We may retain your Personal Information for as long as it is necessary to fulfill the purposes for which it was collected or as required or permitted by applicable law. We will cease retaining your Personal Information and remove any means of associating such information with you at such time as we reasonably determine that the retention of Personal Information no longer serves the purpose for which it was collected and is no longer legally or commercially necessary.


We maintain commercially reasonable technical, administrative, and physical security measures designed to protect your information from loss, misuse, unauthorized access, disclosure, alteration, and destruction.

All information collected in connection with any of our Services (including information generated by cookies about your use of the App) will be stored electronically on the server of our service provider with appropriate safeguards and security measures. However, there is no guarantee that information stored by us or on our behalf may not be accessed, collected, used, disclosed, copied, modified or deleted by unauthorized parties in violation of technical or operational safeguards. We will not be keeping physical files of any Personal Information.

Except to the extent that liability cannot be excluded or limited due to applicable law, we assume no liability or responsibility for disclosure of your information due to errors in transmission, unauthorized third party access, or other causes beyond our control.

We will take all reasonable steps and precautions to ensure that any transmission of your Personal Information via the internet is secure. However, we cannot guarantee the security of any data transmitted to our website and you agree and acknowledge that any such transmissions are at your own risk.

All our employees with access to your information will be held to the confidentiality obligations as set out in this Privacy Policy.

The consent that you provide for the collection, use and disclosure of your Personal Information will remain valid until such time it is being withdrawn by you in writing or via email. You may withdraw consent and request us to stop using and/or disclosing Your Personal Information for any or all of the purposes listed above by submitting your request in writing or via email to us at the contact details provided below. However, please note that any withdrawal of your consent may have consequences, including your inability to use the Services.

Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us.

Please note that withdrawing consent does not affect our right to continue to collect, use and disclose Personal Information where such collection, use and disclose without consent is permitted or required under applicable laws.


Subject to exceptions under applicable law and regulations, You have the right to access to your Personal Information that we collected in connection with the Services and information about how we have used and disclosed your Personal Information within a year before your request.

Subject to exceptions under applicable law and regulations, you may also request to review, correct or delete any of that Personal Information. Additional rights may also apply under applicable laws. We reserve the right to charge a nominal fee in respect of our costs in processing your request for access to Personal Information.

If you wish to make (a) an access request for access to a copy of the Personal Information which we hold about you or information about the ways in which we use or disclose your Personal Information, or (b) a correction request to correct or update any of your Personal Information which we hold about you, you may submit your request in writing or via email to us at the contact details provided below. In order to facilitate processing of your request, it may be necessary for us to request further information relating to your request. To protect your privacy and security, we will take reasonable steps to verify your identity before processing any access or correction request or withdrawal notice under this section.

We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any Personal Information or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the GDPR).


We reserve the right to make changes to this Privacy Policy at any time. We encourage you to regularly review this Privacy Policy to make sure you are aware of any changes and how your information may be used.

This Privacy Policy was last updated in February 2023.


You may contact us if you have any enquiries or feedback on the Privacy Policy, or if you wish to make any request, in the following manner:


Address: Morgan & Morgan Building, P.O. Box 958, Pasea Estate, Road Town, Tortola British Virgin Islands


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