Actxa Privacy Policy
Personal Data Protection Policy (“Privacy Policy”)
Effective Date: 01 Jun, 2023
Last Updated: 01 Apr 2026
This Privacy Policy explains how Actxa Pte. Ltd. and its affiliated companies (“Actxa”, “we”, “us”) collect, use, disclose and protect personal data when you use Actxa devices, mobile applications, websites and related services (“Services”).
Actxa products and services are offered globally. Our primary data infrastructure and hosting environment are located in Singapore. As a result, personal data collected through the Services may be transferred to and processed in Singapore.
This notice applies to users located in Singapore, the United Kingdom, the European Economic Area, Australia, Japan, Thailand, Turkey, the Philippines, Russia, and other jurisdictions where our services are available.
1. WHO WE ARE
Actxa Pte. Ltd.
10 Eunos Road 8
Singapore 408600
Email: enquiry@actxa.com
For the purposes of applicable data protection laws, Actxa generally acts as the data controller for personal data processed through the Services.
2. SCOPE OF THIS NOTICE
This Notice applies when you:
• Create an Actxa account
• Use Actxa wearable devices
• Use Actxa mobile applications
• Visit our websites
• Contact customer support
• Participate in promotions, surveys or events
Third‑party services connected to Actxa may process data according to their own privacy policies.
3. PERSONAL DATA WE COLLECT
Account Information
• email address
• username
• password (hashed)
• profile photo
• birthdate
• gender
• height and weight
• language
• time zone
• fitness goals
• application settings
• optional diabetic status
• optional diabetic family history
Device and Technical Data
• device identifiers
• device serial number
• Bluetooth address
• mobile device information
• operating system
• application version
• crash logs
• IP address
• approximate location
Wellness and Sensor Data
• steps
• distance
• calories
• sleep stages
• sleep duration
• heart rate
• heart rate variability
• SpO2
• VO2 max
• skin temperature
• body composition metrics
• wearable sensor signals such as PPG signals
• workout routes when GPS is enabled
Commerce Information
• shipping address
• phone number
• order history
• transaction information
Communications
• customer support messages
• survey responses
• event participation data
4. AUTOMATED PROCESSING AND AI
Actxa uses automated processing and machine‑learning technologies including BGEM® technology solutions.
These algorithms may analyse wearable sensor signals such as PPG, basic profile data, meal timing inputs, and optional diabetic status or family history to estimate glucose status or related wellness insights.
BGEM outputs:
• are estimates
• are not medical advice
• are not intended to diagnose, treat, cure or prevent disease
• should not replace consultation with qualified healthcare professionals
Users should not rely on these outputs for medical decision‑making.
5. LEGAL BASES FOR PROCESSING
Depending on your jurisdiction, we rely on the following legal bases:
• performance of a contract
• legitimate business interests
• consent for sensitive data or optional features
• compliance with legal obligations
• protection of vital interests
Where required by law we obtain explicit consent before processing sensitive health‑related data.
6. HOW WE USE PERSONAL DATA
We use personal data to:
• operate Actxa devices and applications
• provide wellness insights and reports
• support BGEM technology solutions
• process purchases and deliveries
• provide customer support
• improve products and services
• conduct analytics and research
• maintain security and fraud prevention
• comply with legal obligations
We may also use aggregated or anonymised data for research and product improvement.
7. SHARING OF PERSONAL DATA
We may share personal data with:
• Actxa group companies
• cloud hosting providers
• analytics providers
• logistics partners
• payment processors
• customer support vendors
• professional advisers
• regulators or authorities where required by law
We do not sell personal data.
8. INTERNATIONAL DATA TRANSFERS
Because Actxa services are provided globally, personal data may be transferred to countries outside your country of residence.
Our primary data hosting infrastructure is located in Singapore. By using the Services, you acknowledge that your personal data may be transferred to and processed in Singapore.
Where required by law, including for transfers from the United Kingdom or the European Economic Area, we rely on safeguards such as:
• Standard Contractual Clauses
• UK International Data Transfer Agreements
• adequacy decisions
• contractual data protection commitments
9. DATA RETENTION
We retain personal data only for as long as necessary.
Typical retention periods include:
• account data – until account deletion plus up to 24 months
• wellness metrics – until account deletion
• transaction records – up to 7 years
• technical logs – 90 to 180 days
Longer retention may occur where required by law.
10. YOUR RIGHTS
Depending on your jurisdiction, you may have rights to:
• access your data
• correct inaccurate data
• delete personal data
• restrict processing
• object to processing
• data portability
• withdraw consent
Requests may be submitted to our support team.
11. CHILDREN
Actxa services are not intended for children under 13 or higher age where required by local law.
If we learn that a child has provided personal data without parental consent we will take steps to delete the data.
12. SECURITY
We implement technical and organisational security measures including encryption, secure cloud infrastructure, access controls, and monitoring procedures.
However, no system can guarantee absolute security.
13. RUSSIA DATA LOCALISATION
Where required by Russian law, personal data of Russian citizens may be processed and stored on servers located within Russia before cross‑border transfer.
14. CHANGES TO THIS NOTICE
We may update this Privacy Policy periodically. Updated versions will be posted on our website or application.