12u12 Sdn. Bhd. Privacy Policy

12u12 Sdn. Bhd. (“12u12”, “we”, “our”, or “us”) recognizes the importance of privacy and is committed to protecting information entrusted to us by users of our Services.

This Privacy Policy describes how we collect, use, store, disclose, retain, and otherwise process information in connection with the 12u12 website, mobile applications, and related products, features, content, and services (collectively, the “Services”).

12u12 is designed to minimize the collection of identifying information. Users are encouraged to register using email addresses that do not reveal their real-world identities. 12u12 does not require users to provide their legal names and does not intentionally collect government-issued identifiers or other unnecessary identifying information. Our goal is to provide wellness tracking and self-care tools while minimizing the amount of personally identifying information associated with user accounts.

By accessing or using the Services, you acknowledge that your information may be collected, used, stored, disclosed, and otherwise processed as described in this Privacy Policy.

This Privacy Policy applies to the Services operated by 12u12 for personal use by consumers. The Services include our websites, mobile applications, and any related features or functionality that reference this Privacy Policy.

References to “12u12”, “we”, “our”, or “us” mean 12u12 Sdn. Bhd., unless otherwise specified in this Privacy Policy. 12u12 Sdn. Bhd. is responsible for the processing of information described in this Privacy Policy. The Services are intended for wellness tracking, self-care, personal recordkeeping, and informational purposes.

If you do not agree with this Privacy Policy, you should not access or use the Services.

INFORMATION COLLECTED ABOUT YOU

12u12 collects and processes information as described in this Privacy Policy. The information we collect depends on how you use the Services and the features you choose to use.

Registration

Access to the Services requires account registration.

12u12 is designed to minimize the collection of identifying information. Users are encouraged to register using email addresses that do not reveal their real-world identities. 12u12 does not require users to provide their legal names and does not intentionally collect government-issued identifiers. Our goal is to provide wellness tracking and self-care tools while minimizing the amount of personally identifying information associated with user accounts.

When creating an account, users are generally required to provide:

Email address
Birth month and year
Gender
Username or display name
Account credentials

Users may choose a display name, nickname, or other identifier and are not required to use their legal names.

Users are responsible for maintaining the confidentiality of their account credentials and for all activities that occur under their accounts.

General Service

The Services are primarily interactive and allow users to record, organize, store, display, and manage information that they choose to enter. Such information may include foods, beverages, supplements, medications, symptoms, physical activities, environmental exposures, personal care products, biometric information, and other wellness-related information.

The Services are intended to provide information management, organization, visualization, reporting, and self-tracking tools. The Services do not provide medical advice, medical diagnosis, medical treatment, healthcare services, or professional medical opinions. Users should consult qualified healthcare professionals regarding medical conditions, diagnoses, treatments, medications, allergies, or healthcare decisions.

Information submitted by users may be organized, summarized, displayed, visualized, or reported through tools provided by the Services. These tools are intended to assist users in reviewing information they have entered and exploring potential patterns, associations, correlations, or trends within their own data. Users are responsible for interpreting information displayed by the Services and for any decisions made based on such information.

Users are responsible for the accuracy of information they choose to provide. Certain features of the Services may rely on information such as age range, gender, activities, foods, medications, supplements, symptoms, allergens, or other user-entered information. Inaccurate or incomplete information may affect the functionality, usefulness, or accuracy of certain Service features, including calorie expenditure calculations, nutritional analysis, ingredient analysis, and allergen alert features.

Users may choose to identify allergens, ingredients, or other substances of interest within their account settings. The Services may compare such user-defined preferences against ingredient information associated with foods, supplements, medications, personal care products, or other items recorded by the user and may provide allergen alerts or highlight matching ingredients. Such alerts are provided solely as an informational convenience.

Allergen alerts are based on ingredient information available to 12u12 and user-defined preferences. Ingredient information may be incomplete, inaccurate, outdated, unavailable, or provided by third parties. Product formulations, manufacturing processes, ingredient sourcing, labeling practices, and allergen declarations may change without notice. Users remain responsible for reviewing product packaging, ingredient labels, manufacturer information, and other relevant sources before consuming, using, or otherwise being exposed to any product. 12u12 does not guarantee that allergen alerts, ingredient analyses, or related information are complete, accurate, current, or suitable for any particular purpose.

12u12 provides users with tools to gather, store, organize, manage, export, and optionally share information with healthcare providers, personal care providers, family members, caregivers, or other individuals selected by the user.

The Services may also permit users to import information from wearable devices, fitness trackers, self-care platforms, or other third-party services. Such information may include physical activity data, vital sign measurements, sleep information, and other wellness-related information. The availability, accuracy, completeness, timeliness, and reliability of information received from third-party services are outside the control of 12u12.

Users may voluntarily record locations, places, venues, addresses, geographic areas, or other location-related information associated with activities, exposures, symptoms, or other events. The Services may use such information, together with associated dates, times, or durations, to retrieve, generate, or associate environmental, weather, air quality, pollen, geographic, or other location-related information with a user’s records. Users are responsible for determining what location information they choose to enter into the Services.

Environmental, weather, air quality, pollen, geographic, and other location-related information may be obtained from third-party data providers and may be incomplete, unavailable, delayed, or inaccurate.

Users should carefully consider whether to enter locations that may reveal sensitive personal activities, routines, workplaces, residences, healthcare providers, schools, or other sensitive information.

Users may contribute product information, product images, ingredient information, nutritional information, labeling information, or other content for inclusion within the Services. Such contributions may be reviewed, modified, validated, combined with other information, displayed to other users, incorporated into databases, and used to improve the Services.

Minors, Dependents, and Sub-Users

The Services are intended primarily for use by adults. 12u12 does not knowingly permit minors to independently create accounts without the involvement of a parent, legal guardian, caregiver, or other authorized responsible person.

12u12 supports the creation and management of sub-user profiles. A registered account holder (“Main User”) may create, manage, and maintain information relating to minors, dependents, family members, care recipients, or other individuals for whom the Main User is authorized to act.

The Main User is responsible for:

Obtaining any permissions, consents, and authorizations necessary to create and manage a sub-user profile.
Supervising the use of the Services by any sub-user.
Maintaining the security of account credentials and devices used to access the Services.
Determining what information is entered, modified, shared, exported, or deleted.
Ensuring that information submitted to the Services is accurate to the best of their knowledge.

The Services may include specialized access modes designed to provide simplified functionality for certain users, including minors, older adults, individuals with limited technical experience, or individuals requiring restricted access. Such modes may limit the information visible to the user, restrict available features, restrict data entry options, or otherwise limit access to information associated with the account.

Where a sub-user is permitted to directly enter information into the Services, the Main User remains responsible for supervising such use and for determining whether continued access is appropriate.

The Main User assumes responsibility for interpreting and using information, reports, analyses, visualizations, alerts, recommendations, and other outputs generated or displayed through the Services in connection with any sub-user profile.

If 12u12 becomes aware that an account has been created or used by a minor in a manner inconsistent with this Privacy Policy or applicable law, 12u12 may take reasonable steps to restrict access, disable the account, delete information, or take other appropriate action.

Advertising and Promotional Content

12u12 may display advertisements, sponsored content, promotions, product recommendations, special offers, surveys, and other marketing materials within the Services or through other communication channels.

Advertisements, promotions, and sponsored content may be selected based on information associated with a user’s account, including foods, beverages, consumer products, personal care products, activities, interests, demographic information, user-entered location information, geographic information associated with user-entered locations, and other information available to 12u12.

12u12 may also use information associated with a user’s account to personalize communications, newsletters, educational content, promotional materials, and product recommendations relating to the Services.

Advertisements, promotions, sponsored content, and product recommendations may be selected based on information entered by users into the Services and they are provided for informational and commercial purposes only. The appearance of an advertisement, promotion, sponsored content item, product recommendation, or other marketing material within the Services does not constitute an endorsement, certification, guarantee, recommendation, or representation by 12u12 regarding any product, service, company, claim, or advertisement.

Research, Analytics, and Product Development

12u12 may use information collected through the Services to conduct research, statistical analysis, trend analysis, product development, service improvement, quality assurance, data validation, and other analytical activities.

Such activities may include identifying patterns, trends, associations, correlations, usage characteristics, consumer preferences, ingredient exposures, product usage trends, demographic trends, symptom trends, wellness trends, and other insights derived from information collected through the Services.

Research and analytical activities may be performed by 12u12 or by third parties acting on behalf of 12u12. The results of such activities may be used to improve existing products and services, develop new products and services, support scientific studies, support consumer research, support business decision-making, generate market insights, and support other lawful business purposes.

Research findings, reports, statistics, analyses, and other outputs may be published, shared, licensed, sold, or otherwise made available to third parties, provided that 12u12 reasonably seeks to avoid identifying individual users through such materials.

Aggregated, Anonymized, and De-Identified Information

12u12 may create aggregated, anonymized, or de-identified information derived from information collected through the Services. Such information may be used to conduct research, generate statistics, identify trends, develop products and services, improve the Services, perform analytics, support scientific studies, and create reports, datasets, models, and other informational resources.

12u12 may disclose, license, sell, publish, distribute, or otherwise make available aggregated, anonymized, or de-identified information to research institutions, academic organizations, healthcare organizations, government agencies, manufacturers, advertisers, business partners, and other third parties for research, analytics, scientific, commercial, product development, marketing, and business purposes.

12u12 will seek to design aggregated, anonymized, or de-identified information so that it does not reasonably identify individual users. However, no method of anonymization or de-identification can be guaranteed to eliminate all risk of re-identification.

Once information has been incorporated into aggregated, anonymized, or de-identified datasets, reports, models, analyses, statistics, research findings, or similar materials, 12u12 may be unable to identify, isolate, remove, modify, correct, delete, suppress, or exclude an individual user’s historical contribution from such materials.

Use of the Services constitutes acknowledgment that 12u12 may create, use, disclose, license, sell, publish, or otherwise commercialize aggregated, anonymized, or de-identified information as described in this Privacy Policy.

Market Research and Surveys

From time to time, 12u12 may conduct surveys, questionnaires, interviews, polls, research studies, feedback programs, user experience studies, or similar activities for research, analytics, product development, quality improvement, educational, scientific, commercial, or business purposes.

Participation in such activities is voluntary. Users may choose whether to participate and may decline to provide requested information.

Surveys and research activities may request information in addition to information associated with a user’s account. Information submitted through surveys or research activities may be used by 12u12 to evaluate user experiences, identify trends, improve products and services, conduct research and analytics, generate statistics, develop new features, assess advertising or promotional effectiveness, support scientific studies, and support other lawful business purposes.

Information collected through surveys and research activities may be analyzed independently or combined with other information available to 12u12, subject to the terms of this Privacy Policy.

Research and survey activities may be conducted by 12u12 or by third parties acting on behalf of 12u12. Any information collected through such activities will be processed in accordance with this Privacy Policy.

12u12 does not knowingly invite individuals under the age of 18 to participate in market research activities intended solely for adults.

Communications with 12u12

If you contact 12u12 by email, support ticket, survey, feedback form, social media, or other communication channels, we may collect and process the information you choose to provide in order to respond to your inquiry, provide support, improve the Services, investigate issues, maintain security, comply with legal obligations, and support our business operations.

Communications sent to 12u12 may be retained and processed in accordance with this Privacy Policy and applicable legal requirements.

COOKIES, DEVICE INFORMATION, AND SIMILAR TECHNOLOGIES

12u12 may use cookies, local storage technologies, software development kits (SDKs), and similar technologies to operate, secure, maintain, and improve the Services.

These technologies may be used to:

Authenticate users and maintain login sessions.
Remember user preferences and settings.
Provide and improve Service functionality.
Detect, prevent, and investigate security incidents, fraud, abuse, technical problems, and unauthorized access.
Support the display of advertisements, promotional content, and sponsored content within the Services.

When users access the Services, 12u12 may automatically collect certain technical information from the user’s device, including device model, operating system version, application version, language settings, device type, and similar technical information necessary to operate, maintain, secure, and improve the Services.

12u12 may use information associated with a user’s account, including user-entered foods, beverages, consumer products, personal care products, activities, interests, demographic information, user-entered location information, and similar information, to select advertisements, promotional content, sponsored content, and product recommendations that may be relevant to the user. Such content is selected based primarily on information available within the Services rather than on cross-site browsing activity.

Users may configure their browser or device settings to limit or manage certain cookies and similar technologies. However, disabling certain technologies may affect the availability or functionality of portions of the Services.

HOW INFORMATION IS USED

12u12 may use information collected through the Services for the following purposes:

To create, maintain, secure, administer, and support user accounts.
To provide, operate, maintain, improve, and develop the Services.
To organize, store, display, summarize, visualize, report, and export information entered by users.
To provide tools that assist users in reviewing, exploring, and analyzing information they have entered into the Services.
To respond to inquiries, provide customer support, troubleshoot issues, and communicate with users.
To send administrative notices, security alerts, service announcements, product updates, newsletters, and other communications relating to the Services.
To personalize content, advertising, promotional materials, sponsored content, and product recommendations.
To measure, evaluate, and improve the effectiveness of the Services, advertising, communications, promotions, and other business activities.
To conduct analytics, research, statistical analysis, quality assurance, testing, validation, and product development activities.
To identify usage patterns, consumer preferences, demographic trends, ingredient exposure trends, product usage trends, wellness trends, and other trends derived from information collected through the Services.
To detect, prevent, investigate, and address fraud, abuse, security incidents, unauthorized activity, technical issues, and legal violations.
To comply with legal obligations, enforce agreements, protect rights and interests, and resolve disputes.
To support research, analytics, reporting, commercialization of aggregated information, and other activities described elsewhere in this Privacy Policy.

12u12 may also use information for other purposes disclosed at the time of collection or otherwise authorized by the user.

Combining Information

12u12 may combine information collected through different features of the Services and from different devices used to access the Services. 12u12 may also combine information collected through the Services with information obtained from service providers, business partners, public sources, or other lawful sources where permitted by applicable law.

Combined information may be used for the purposes described in this Privacy Policy.

SHARING OF INFORMATION

12u12 may share information collected through the Services in the following circumstances:

Affiliates and Related Companies

12u12 may share information with its subsidiaries, affiliates, related companies, successors, and entities under common ownership or control for purposes consistent with this Privacy Policy.

Business Transfers

Information may be transferred, disclosed, or assigned as part of an actual or proposed merger, acquisition, financing transaction, reorganization, bankruptcy, receivership, asset sale, joint venture, corporate restructuring, or similar business transaction. Any successor entity receiving such information will be expected to process the information in a manner consistent with this Privacy Policy or provide notice of material changes as required by applicable law.

Service Providers and Contractors

12u12 may share information with service providers, contractors, consultants, cloud providers, hosting providers, customer support providers, communications providers, analytics providers, research providers, technology providers, artificial intelligence providers, advertising providers, and other third parties that perform services on behalf of 12u12. Such parties may receive access only to the information reasonably necessary to perform their services and are expected to process such information in accordance with applicable contractual obligations.

If paid services are offered, 12u12 may use third-party payment providers to process payments, subscriptions, purchases, refunds, and related transactions.

User-Directed Sharing

The Services may permit users to export, download, transmit, or share information with healthcare providers, caregivers, family members, personal care providers, researchers, third-party applications, or other recipients selected by the user.

Information shared at the user’s direction will be subject to the privacy practices of the receiving party, where applicable.

Once information is exported, downloaded, transmitted, or shared by a user, 12u12 is not responsible for the security, privacy, storage, handling, retention, use, misuse, loss, or further disclosure of such information by the user, the receiving party, or any other person or entity that subsequently obtains access to the information.

Legal Compliance and Protection of Rights

12u12 may disclose information where we believe disclosure is necessary or appropriate to comply with applicable laws, regulations, legal processes, court orders, subpoenas, governmental requests, regulatory investigations, enforcement actions, or other legal obligations. We may also disclose information to protect the rights, property, safety, security, or legal interests of 12u12, our users, or others; to investigate fraud, abuse, security incidents, or violations of our agreements; or to establish, exercise, or defend legal claims.

INTERNATIONAL DATA STORAGE, PROCESSING, AND TRANSFERS

12u12 operates globally and may use third-party cloud service providers, hosting providers, infrastructure providers, backup providers, contractors, affiliates, and other service providers located in various countries to support the operation of the Services.

As a result, information collected through the Services may be transferred to, stored in, processed in, backed up in, or accessed from countries other than the country in which the user resides.

These countries may have privacy, data protection, security, consumer protection, or other laws that differ from those of the user’s country of residence and may not provide the same level of legal protection.

12u12 may transfer information among its affiliates, service providers, contractors, hosting providers, cloud providers, infrastructure providers, research partners, analytics providers, and other parties described in this Privacy Policy where reasonably necessary to provide, operate, maintain, improve, secure, analyze, support, or develop the Services.

12u12 takes reasonable steps designed to protect information processed on its behalf and to require service providers to process information in accordance with applicable contractual obligations and applicable law.

By using the Services, users acknowledge that information may be transferred, stored, processed, backed up, and accessed internationally as described in this Privacy Policy.

Where required by applicable law, 12u12 will take reasonable steps designed to facilitate lawful international transfers of information and to protect information processed on its behalf.

12u12 may change its service providers, hosting providers, infrastructure providers, storage locations, backup locations, or processing locations from time to time as part of its normal business operations without prior notice, provided that such changes remain subject to this Privacy Policy and applicable law.

SECURITY OF INFORMATION

12u12 uses reasonable administrative, technical, and organizational measures designed to protect information against unauthorized access, disclosure, alteration, loss, misuse, or destruction.

Security measures may include authentication controls, account credential protections, access controls, encryption of information during transmission, monitoring, logging, backup procedures, and other security practices appropriate to the nature of the Services.

No method of electronic transmission, storage, or security can be guaranteed to be completely secure. Accordingly, 12u12 cannot guarantee absolute security of information transmitted to, stored by, or processed through the Services.

DATA RETENTION

12u12 retains information for as long as reasonably necessary to provide the Services, maintain user accounts, support research and analytics activities, comply with legal obligations, resolve disputes, enforce agreements, maintain security, prevent fraud, and support legitimate business operations. Information entered by users may include historical location-related information, dates, times, durations, and associated environmental information.

Users may request deletion of their accounts or information as described elsewhere in this Privacy Policy. Following deletion requests, certain information may continue to be retained in backup systems, archives, logs, legal records, security records, research datasets, aggregated datasets, anonymized datasets, de-identified datasets, or other records where retention is reasonably necessary or permitted by applicable law.

Where information has been incorporated into aggregated, anonymized, or de-identified datasets, reports, models, analyses, statistics, research findings, or similar materials, 12u12 may be unable to identify, isolate, remove, modify, correct, delete, suppress, or exclude an individual user’s historical contribution from such materials.

YOUR PRIVACY CHOICES AND RIGHTS

Access, Correction, and Export

Users may review, update, correct, export, or manage information associated with their accounts through the Services or by contacting 12u12 through the Account and Support page of the App or via Support@12u12.com.

Users are responsible for maintaining the accuracy of information they choose to provide. Certain Service features may depend upon the accuracy and completeness of user-provided information.

Account Deletion and Removal of Information

Users may delete their accounts by clicking the trash icon for the Main User on the Profile page and confirming the deletion request.

Following a deletion request, 12u12 will take reasonable steps, where reasonably practicable, to delete or anonymize applicable information from active systems within a reasonable period, subject to legal obligations, security requirements, fraud prevention needs, dispute resolution requirements, backup processes, operational requirements, and other legitimate business purposes.

Certain information may continue to be retained in backups, archives, logs, security records, legal records, research datasets, aggregated datasets, anonymized datasets, de-identified datasets, derived data, statistical models, reports, analyses, and similar materials where retention is reasonably necessary or permitted by applicable law.

Email Communications and Marketing Preferences

Users may choose to unsubscribe from newsletters, promotional communications, marketing communications, sponsored communications, and similar non-essential communications at any time by using the unsubscribe mechanism provided in the communication, adjusting available account settings, or contacting 12u12.

Users may continue to receive transactional, administrative, legal, security, account-related, or other communications necessary for the operation of the Services even if they opt out of promotional communications.

ADDITIONAL RIGHTS UNDER APPLICABLE LAW

Depending on a user’s location and the laws that apply to that user, additional privacy rights may be available.

Subject to applicable law, users may have the right to:

Access information associated with their accounts.
Correct inaccurate information.
Export information in a format made available through the Services.
Request deletion of information associated with their accounts.
Withdraw consent for processing activities that are based solely on consent.
Opt-out of marketing communications and promotional communications.
Submit complaints to applicable data protection, privacy, consumer protection, or regulatory authorities.

Users may exercise available rights through the Services, through the Account and Support page of the App, or by contacting 12u12 at Support@12u12.com.

12u12 will consider and respond to requests in accordance with applicable law, the nature of the request, technical feasibility, legal obligations, security requirements, fraud prevention requirements, research requirements, operational requirements, and other legitimate business considerations.

The exercise of certain rights may not affect information that has already been incorporated into aggregated, anonymized, or de-identified datasets, reports, models, analyses, statistics, research findings, or similar materials.

Nothing in this Privacy Policy is intended to limit any rights that may be available to users under applicable law.

CONTACTING 12u12 ABOUT PRIVACY AND INFORMATION PRACTICES

If you have questions, concerns, requests, or complaints relating to this Privacy Policy, the Services, privacy practices, information associated with your account, or your privacy rights, you may contact 12u12 through the Account and Support page of the App or by email at Support@12u12.com.

12u12 may request additional information reasonably necessary to verify the identity or authority of a person submitting a request before processing the request.

12u12 will make reasonable efforts to review and respond to requests within a reasonable period, taking into account the nature of the request, applicable legal requirements, technical feasibility, account verification requirements, and other relevant circumstances.

Submission of a request does not guarantee that the requested action will be completed where 12u12 is permitted or required by applicable law to retain, continue processing, or decline to modify certain information.

CHANGES TO THIS PRIVACY POLICY

12u12 may modify, update, revise, or replace this Privacy Policy from time to time to reflect changes in the Services, business practices, legal requirements, technology, security practices, or other operational needs.

Unless otherwise stated, changes to this Privacy Policy will become effective when the updated version is posted through the Services or otherwise made available to users.

Where required by applicable law or where 12u12 determines that a change is material, 12u12 may provide additional notice through the Services, by email, or by other reasonable means. The method, timing, and form of any notice will be determined by 12u12 in its discretion, subject to applicable law.

The “Last Updated” date appearing in this Privacy Policy indicates when the most recent revision became effective.

Users are encouraged to review this Privacy Policy periodically to remain informed about how information is collected, used, disclosed, stored, processed, and protected.

By continuing to access or use the Services after changes to this Privacy Policy become effective, users acknowledge and accept the revised Privacy Policy. If a user does not agree to the revised Privacy Policy, the user should discontinue use of the Services and may request account deletion in accordance with this Privacy Policy.