PRIVACY POLICY

I. GENERAL PROVISIONS

We kindly request that you thoroughly read this privacy statement. It provides important information about how your personal data may be handled. When you use the app, you confirm that you have read, understood, and agreed to these terms. By accessing or using the app, you consent to the processing of your personal data in accordance with this privacy statement.

At Begamob Global (referred to as "our company," "we," or "us"), we prioritize your privacy. This Privacy Statement ("Privacy Statement") outlines our commitment to safeguarding your data and delineates the kinds of information we may collect when you utilize one or more of our mobile applications (referred to as "the App" or "our App").

II. INFORMATION WE COLLECT AND USE

2.1 Personal and Health Profile Data

When you use our App, you may voluntarily provide your Age, Gender, Height, Weight, Smoking status, Diabetes, Hypertension, Cholesterol levels, and Waist Circumference.

We need this information to establish baseline parameters for accurate health metric calculations (e.g., Body Mass Index, cardiovascular risk scores, specific body shape indices like ABSI and WHtR, and metabolic assessments) and to personalize your wellness insights.

This data is stored strictly on your local device

2.2. Biometric Data (Face Scan Feature) 

When you use the vital signs video measurement feature (Face Scan), you need to authorize the device's camera permission. The Shen.AI SDK utilizes standard cameras to capture subtle variations in skin color (Remote Photoplethysmography - rPPG) and micro-movements of the head (Remote Ballistocardiography - rBCG). Through this, we extract and calculate physiological parameters including: Heart Rate (HR), Heart Rate Variability (HRV), Blood Pressure (BP), Breathing Rate (BR), Stress Index, Cardiac Workload, Wellness Score, and various health risk scores (e.g., ASCVD, Hypertension Risk, Diabetes Risk, Fatty Liver Risk).

The aforementioned biometric data is processed solely for the purpose of generating health analysis reports and wellness insights. Medical Disclaimer: The app and the Shen.AI SDK function exclusively as informational tools and are not medical devices. The results are not intended to diagnose, treat, cure, or prevent any disease, nor do they serve as a substitute for professional medical judgment.

Unlike other cloud-based services, during the vital-signs video measurement conducted by Shen.AI, images of your face will only be processed locally on your device. All computations are performed locally, ensuring compliance with data privacy standards. We strictly adhere to the following:

• No facial images or videos are stored on the device or transmitted externally after the measurement.
• Raw biometric data (physiological signals) is immediately discarded after the final metrics are calculated.
• Your scan history (timestamps, scan quality, metric values) is saved exclusively on your local device.

The processing of such health data is contingent upon your explicit, granular consent. If you refuse to provide this consent or choose to withdraw it, the Face Scan feature will be disabled; however, you will not be discriminated against, and this will not hinder your normal use of other basic features within the app

2.3 Automatically Processed Data

While using the App, some information about your device and usage patterns may be automatically processed. This data is usually non-personal and is processed for app improvement.

Automatically processed data may include:

• Advertising ID, device brand/model, browser type/version.
• IP address, MAC address, IMEI, OS version, and locale data.
• Cookies and similar technologies.

2.4 Data We DO NOT Collect 

To ensure maximum transparency and strictly adhere to the principle of data minimization under privacy regulations, we explicitly state that our App DOES NOT request access to, collect, store, or transmit the following types of information:

• Facial Images or Videos: Your camera feed is processed in real-time. We do not save, record, or upload any videos or photos of your face after the measurement processing is complete.
• Raw Biometric Data: Raw physiological signals captured during the face scan are immediately discarded after the final metrics are calculated.
• Location Data: We do not track, collect, or require your GPS or location information.
• Contact List: We do not access your device's address book or contacts.
• Browsing History: We do not monitor, record, or collect your web browsing activities.

III. SHARING AND DISCLOSURE OF YOUR INFORMATION

We do not lease or sell your personal data to any third parties. We strictly adhere to the principle of data minimization, sharing only the specific information necessary for the App's functionality, analytics, and advertising. Under no circumstances do we share your biometric data, facial scans, or health profile with advertisers.

3.1 Third-Party Service Providers (Who Processes Your Data) 

We may share specific categories of non-personal or explicitly consented data with the following third parties:

• Google (Analytics & AI Processing):

• Firebase (Analytics & Crashlytics): We share anonymous usage data, device information (e.g., OS version, device model), IP addresses, and crash reports to diagnose technical issues and monitor app performance.
• Gemini AI: Only with your explicit, separate opt-in consent, we may share calculated health metric values (strictly stripped of any Personally Identifiable Information - PII) to generate personalized AI health summaries.

• Facebook (Meta Platforms, Inc.):

• For advertising and analytics purposes, we may share automatically collected data such as your Advertising ID, locale data, and general usage patterns. This helps us deliver targeted advertisements and measure ad performance. No health or biometric data is ever shared with Facebook.

• Apple:

• Apple StoreKit: We share necessary purchase information to process In-App Purchases, manage auto-renewing subscriptions, and handle refunds in accordance with Apple's policies.

• Shen.AI SDK (MX Labs):

• Facilitates the face scan processing. All processing occurs 100% locally on your device. No biometric data, facial images, or video streams are ever transmitted to Shen.AI servers or any external cloud services.

3.2 International Data Transfers

Due to our global operations, certain types of non-personal or explicitly consented information may be transferred to, processed, and stored in countries outside of your country of residence, including locations outside the European Economic Area (EEA).

Important Exception for Biometric and Health Data: We strictly guarantee that your facial images, video streams, and raw biometric data processed via the Shen.AI SDK are analyzed 100% locally on your device. This sensitive data is never transmitted, uploaded, or stored on our servers, Shen.AI's servers, or any external cloud services.

For other categories of data—such as anonymous usage analytics for Firebase or calculated metric values for Gemini AI (which strictly excludes Personally Identifiable Information and requires your separate consent)—we implement rigorous security measures. When international transfers of such data occur, we ensure compliance with the General Data Protection Regulation (GDPR) and other applicable privacy laws by enforcing the following safeguards:

• Legal Safeguards: We strictly transfer data to countries that are recognized by the European Commission as providing an "adequate level of protection." In the absence of an adequacy decision, we rely on legally approved transfer mechanisms, including implementing Standard Contractual Clauses (SCCs) with our third-party data processors.
• Technical and Administrative Security: We apply commercially reasonable physical, administrative, and technological protections to safeguard your data's integrity. All data transmitted over the internet to our third-party services is secured using industry-standard encryption protocols (such as HTTPS/TLS).
• Data Anonymization and De-identification: We strictly adhere to data minimization principles. Any usage, crash reporting, or analytics data transferred to external servers (such as Firebase) undergoes comprehensive de-identification and anonymization processes. This guarantees that the transferred information cannot be directly or indirectly linked to your personal identity.

IV. EXERCISING YOUR RIGHTS

4.1 Data Processing Rights

You have full control over your personal and health data. You can exercise the following rights directly within the App or by contacting us:

• Right to Access: You have the right to view and access all your personal data, biometric metrics, and scan history directly within the app.
• Right to Rectification: You have the right to request modifications or corrections to your data. You can easily update your profile information (e.g., age, gender, health conditions) at any time via the App's Settings.
• Right to Erasure: Also known as the "right to be forgotten," you have the right to request the deletion of your personal data. You can delete your health profile and complete scan history at any time.
• Right to Data Portability: You have the right to request an export or receive copies of your measurement data in a structured, commonly used, and machine-readable format.
• Right to Withdraw Consent: You may withdraw your consent for the processing of biometric data at any time via Settings. Doing so will disable the Face Scan feature, but you will not be discriminated against or denied access to other basic functionalities of the app.
• Right to Restrict Processing: You have the right to request the restriction of processing your personal data in certain circumstances

4.2 Information Relating to Children

Our App is not intended for individuals under the age of 18. In strict compliance with the Children's Online Privacy Protection Act (COPPA) and the General Data Protection Regulation (GDPR), we do not knowingly request or collect personal, biometric, or health data from children under the age of 13. If we become aware that we have inadvertently collected data from a child under 13 without verified parental consent, we will take immediate steps to delete such information from our records.

V. PRIVACY POLICY MODIFICATIONS

We reserve the right to update this Privacy Policy periodically to reflect changes in our App's functionalities, technology, legal requirements, or data processing practices.

• Notification of Changes: If we make material changes to this Privacy Policy, we will notify you through a prominent in-app alert, a push notification, or an updated release note on the App Store before the changes become effective.
• Changes to Health and Biometric Data Processing: We deeply respect the privacy of your sensitive data. If any future updates involve material changes to how we collect, process, or share your biometric and health-related data, we will not rely on your continued use of the App as acceptance. Instead, we will explicitly notify you of these changes and require your renewed, explicit consent before the new data processing practices are applied to you.
• General Updates: For minor or non-material changes, your continued use of our services after the effective date of the updated Privacy Policy constitutes your acceptance of those changes. We encourage you to review this policy periodically.

VI. HOW TO CONTACT US

If you have any questions, please email: [email protected]