1. INTRODUCTION

IVC Health (Pty) Ltd (“IVC Health”, “we”, “us”, or “our”) is committed to protecting your privacy and processing personal information responsibly and transparently.

This Privacy Policy explains how we collect, use, store, and protect your personal information when you access or use the IVC Health Digital Wellness Platform, including our website and mobile applications (collectively, the “Platform”).

IVC Health provides general wellness insights, care navigation tools, and coordination support. We do not provide medical diagnosis, treatment, clinical monitoring, or medical advice, and the Platform is not a medical device.

2. SCOPE OF THIS POLICY

This Privacy Policy applies to:

• Users of the IVC Health mobile applications

• Visitors to https://ivc.health

• Users accessing optional connected professional services via the Platform

Third‑party healthcare practitioners, financial service providers, and external platforms operate under their own privacy policies, and we encourage you to review those separately.

We comply with the Protection of Personal Information Act 4 of 2013 (POPIA), the General Data Protection Regulation (EU/UK GDPR/AVG), and other applicable data protection laws

3. NATURE OF THE PLATFORM (IMPORTANT NOTICE)

The IVC Health Platform:

• Provides general wellness insights and lifestyle observations

• Supports care navigation and access to independent professionals

• Does not diagnose, treat, cure, prevent, or monitor disease

• Is not regulated or approved as a medical device

Any healthcare services accessed through the Platform are delivered by independent third‑party practitioners, not by IVC Health.

4. INFORMATION WE COLLECT

We collect only the information necessary to support wellness insights, platform functionality, and coordination services.

4.1 PERSONAL INFORMATION

• Personal identifiers (name, ID/passport number, date of birth, contact details, employment information);

• Account and authentication details including financial and benefit data (Health Wallet balances or related loan information);

• Device and technical information (device type, OS, IP address, app usage)

• Usage data (interaction logs, survey responses, marketing preferences).

4.2 WELLNESS-RELATED DATA

• User‑provided wellness inputs

• Camera‑based wellness signals generated during optional scans

4.3 CAMERA USE & rPPG TECHNOLOGY

The app may use your device camera to perform a contactless wellness scan using remote photoplethysmography (rPPG) technology.

Important clarifications:

• Used only for general wellness purposes

• No facial images or videos are stored

• No biometric identification is performed

• Outputs are non‑clinical wellness indicators

• The technology is not a medical device and is not intended for diagnosis or treatment

Camera access is used only with your explicit permission and can be disabled in your device settings.

5. HOW WE USE YOUR INFORMATION

We process personal information to:

• Provide and maintain the Platform

• Generate non‑clinical wellness insights

• Display wellness trends over time

• Support care navigation and coordination

• Enable user support and platform security

• Meet legal and regulatory obligations

• Customise financial products or employer benefits;

We do not use your data to make medical decisions.

6. SHARING OF INFORMATION

We may share information only where necessary:

• With service providers supporting platform operations (under strict confidentiality agreements)

• With independent professionals, only when you choose to engage their services

• Where required by law or regulatory authority

We do not sell personal or wellness data without your specific consent.

7. DATA RETENTION

• Personal information is retained only for as long as necessary to provide services or meet legal requirements

• You may request deletion of your account and data at any time

• Certain data may be retained where legally required (e.g. POPIA compliance)

8. YOUR RIGHTS

You have the right to:

• Access your personal information

• Request correction or deletion

• Withdraw consent

• Object to certain processing activities

• Lodge a complaint with the Information Regulator

Requests can be made via support@ivc.health.

9. SECURITY MEASUREMENTS

We implement appropriate technical and organizational safeguards to protect your personal information against loss, misuse, or unauthorized access.

10. CHILDRENS PRIVACY

• The Platform is intended for users 13 years and older.

• Users under 18 must have parent or guardian consent.

11.INTERNATIONAL TRANSFERS

Where personal information is processed outside South Africa, we ensure compliance with POPIA and GDPR, including appropriate safeguards.

12. THIRD-PARTY WEBSITES

Our platform may contain links to third-party websites. We are not responsible for their privacy practices and recommend reviewing their privacy policies before providing personal information.

13. CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time. The most recent version will always be available at: https://ivc.health/privacy-policy/

CONTACT DETAILS

IVC Health (Pty) Ltd

• Email: support@ivc.health

• Telephone: +27 12 051 3383

INFORMATION REGULATORS (SOUTH AFRICA)

• Email: complaints.IR@justice.gov.za

• Website: www.inforegulator.org.za