Privacy Policy
Updated: August 1st, 2025
Effective: August 1st, 2025
Preface
1.1 Welcome to the products and services legally owned and operated by SINGATOP and its affiliates (“we”, “us”, or “our”) under the name PulseTrackr (the “Service”). We attach great importance to the protection of your personal information and will strictly comply with the Personal Information Protection Law of the People’s Republic of China, the Administrative Measures on the Development of Health and Medical Big Data Applications, and other applicable laws and regulations to ensure the security of your personal information and privacy.
1.2 This Privacy Policy (“Policy”) constitutes an integral part of the User Service Agreement (“User Agreement”) and has the same legal effect. This Policy explains how, to what extent, and for what purposes we collect, use, store, share, and protect your personal information during your download, installation, registration, login, or use (collectively, “use”) of the Service. Your use of the Service means that you have fully read, understood, and accepted this Policy and the User Agreement.
1.3 This Policy applies only to the PulseTrackr products and services provided by us, and not to any third-party services (including those providing advertising services or accessible via links in the Service). Before using any third-party service, please carefully review its functionality and privacy policy to decide whether to use it.
1.4 Please carefully read and fully understand this Policy before using the Service, especially the sections highlighted in bold. If you are under 18 years old, please read this Policy with your guardian and obtain their consent before using the Service.
1.5 We reserve the right to revise or update this Policy from time to time. The latest version will be presented within the app, and your continued use of the Service after such updates constitutes your acceptance of the revised Policy. In specific cases, we may also notify you via pop-ups or page prompts about data collection purposes, scope, and methods; such instant notices form part of this Policy.
To provide core services such as heart rate monitoring, health analysis, and abnormal warning, we collect the following data directly related to your heart health (failure to provide this data will prevent access to heart rate features but not basic browsing or registration):
Core heart rate data: Real-time heart rate, resting heart rate, heart rate variability (HRV), heart rate trend curves, and fluctuation range per test—collected via your device sensors (e.g., phone camera light sensor) to generate health reports.
Basic health information: Age, gender, medical history (e.g., heart disease, hypertension), and activity frequency you voluntarily provide—used to improve health data interpretation.
Sensor and device information: Calibration records, device connection status—used for compatibility and accuracy.
Context parameters: Physiological and environmental conditions during detection—used to assess data validity and refine algorithms.
Customer service: When contacting customer support, we collect contact details, communication logs, and relevant information to verify identity, resolve issues, and maintain records.
Operations and security:
·To ensure stable operation, we collect device configuration, battery and signal status, browsing/search logs, and app usage records.
·To prevent malware, we may collect installed app details (version, language, source), process info, performance data, and crash logs.
·We may use account and device data, plus data lawfully provided by affiliates or partners, to assess account security, detect fraud, and prevent incidents.
We will request authorization before accessing certain permissions. Denying permission will not affect unrelated functions.
Heart rate monitoring: Requires camera or sensor access; disabling it will disable heart rate detection.
Syncing heart data to third-party health apps (e.g., Apple HealthKit): Requires “health data” permission; only user-selected data types are synced, subject to the third party’s privacy policy.
Under applicable laws, we may collect or use personal data without your consent in the following cases:
·To fulfill legal obligations;
·For national defense, public security, or major public interest;
·For criminal investigations or legal proceedings;
·To protect vital interests where obtaining consent is impractical;
·Information you publicly disclose;
·Information lawfully disclosed via news or government channels;
·Necessary to perform or fulfill a contract at your request;
·To maintain service security or for legitimate research with de-identified results.
Use limitation: Heart rate data is used solely for in-app health analysis. If you share data externally, you are responsible for ensuring lawful use.
Anonymized data use: We may use de-identified heart rate data (with personal identifiers removed) for statistics, research, or algorithm optimization. Such data cannot identify individuals and will not be used for advertising.
Principles:
Legality: Cooperation must have lawful purpose and basis.
Necessity: Data use must be limited to achieving explicit purposes.
Security: We assess partners’ capabilities, sign agreements, and monitor their data use, including SDK/API security checks.
Types of cooperation:
Entrusted processing: Partners process data on our behalf under a written agreement.
Joint processing: Each party’s rights and duties are contractually defined, especially regarding heart rate data (limited to algorithm optimization).
Partner scope: A. You may share Service content to third-party platforms; B. We may link to third-party ads or sites; C. Certain SDKs integrated into the Service collect necessary information—see the SDK list in the appendix.
We are not responsible for third-party services. Please read their own privacy policies carefully. If you identify risks, discontinue use and contact us.
In case of merger, acquisition, or asset transfer, your personal data may be transferred to the successor, who must continue to comply with this Policy or obtain new consent.
We will not publicly disclose sensitive information (e.g., heart rate or health data) except as required by law, and we will de-identify such data before disclosure.
Information may be shared or disclosed without consent in legally defined cases such as contract fulfillment, law enforcement, or public health emergencies.
Storage location:
Data collected and generated within China is stored domestically. We currently do not transfer data overseas. If future transfers are needed, we will follow legal requirements or obtain consent. For data you authorize to sync with overseas health apps, please ensure their compliance independently.
Security measures:
We apply industry-standard security protections, including access control, encryption, and data isolation, to prevent unauthorized access, disclosure, or loss.
Heart rate data transmission is end-to-end encrypted; avoid public Wi-Fi when syncing.
In case of a data breach, we will notify you per law and report to regulators if required.
We may be unable to respond to requests that:
·Relate to national security or law enforcement;
·Would harm others’ rights or trade secrets;
·Are repetitive, unreasonable, or technically unfeasible;
·Are explicitly restricted by laws or regulations.
This Service is intended for adults. Users under 18 should use it under guardian supervision.
Guardians should assist minors in providing accurate health data and managing device permissions.
If we find we have collected a minor’s data without consent, we will delete it promptly.
We may revise this Policy periodically. Significant changes—such as to data types, usage purposes, retention, or partners—will be announced 30 days prior via app notifications. Continued use constitutes acceptance of the updated Policy.
For questions, comments, or data access requests, please contact our Data Protection Officer at pulsetrackrcontact@zohomail.com.
We will respond within 15 business days after verifying your identity. Repetitive or excessive requests may incur reasonable fees or be denied.
This Policy applies to use of the Service in Mainland China (excluding Hong Kong, Macau, and Taiwan). In case of discrepancies between language versions, the Simplified Chinese version shall prevail.
This Policy is governed by the laws of the People’s Republic of China.
Any disputes shall be submitted to the Guangzhou Arbitration Commission for arbitration in Guangzhou under its effective rules.
Appendix: SDK Directory
Sensors Analytics SDK
Company Information: Sensors Analytics
Information Collected and Purpose: Used to analyze crash information and optimize product experience;
Official website link: https://manual.sensorsdata.cn/sa/docs/tech_sdk_client_privacy_policy
Google Mobile Ads SDK
Company Information: Google LLC
Information Collected and Purpose: Device and storage information; used for providing advertisements;
Official website link: https://policies.google.com/privacy?hl=zh-CN
AppsFlyer SDK
Company Information: AppsFlyer Inc.
Information Collected and Purpose: Device and storage information; used for providing advertisements;
Official Website Link: https://www.appsflyer.com/legal/services-privacy-policy/
Firebase SDK
Company Information: Google LLC
Information Collected and Purpose: Used for analyzing crash information and optimizing the product experience;
Official website link: https://policies.google.com/privacy?hl=zh-cn
BDASignal SDK
Company Information: ByteDance
Information Collected and Purpose: Device and storage information; used to deliver advertisements;
Official website link: https://bytedance.larkoffice.com/docx/CgYBdVzoBogND2xv7PhcSfFNnyc