This Privacy Policy (“Privacy Policy”) describes the privacy practices of the GenPrime clinics, which are subsidiaries of Recharge RHEA Holdings (including our affiliate companies and subsidiaries) (“we”, “us”, or “our”), and how we handle personal information that we collect through our website at https://www.genprime.com/and other websites (collectively, “Site”) or services that we own or control and that links to this Privacy Policy (collectively, the “Service” or “Services”).

This Privacy Policy is intended to address requirements under the data protection laws of Singapore (pursuant to the Personal Data Protection Act 2012, as amended (“SG PDPA”)), Malaysia, the Philippines, Thailand, Vietnam, Indonesia, and the European Economic Area (“EEA”). Where local law imposes stricter requirements, we will comply with those stricter requirements. If any portion of this Privacy Policy conflicts with applicable local law, the local law will prevail to the extent of the conflict.

This Privacy Policy supplements but does not supersede or replace any other consents you may have provided to us in respect of your personal data (for example, via clinical or medical consent forms). Any consents you provide are cumulative and additional to any rights, bases or exemptions we may have under applicable law to collect, use, disclose or process your personal data.

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1. Information We May Collect, Use, Disclose, or Process

We may collect, use, disclose and/or process various types of information to provide and improve our Services to you, including:

1.1. Personal Information:

We may collect, use, disclose and/or process personal information you provide to us directly through the forms available on our Site. By submitting your personal information, you acknowledge and agree that you are voluntarily sharing this information with us, subject to the terms of this Privacy Policy.  

We will notify you of the specific purposes for which we are collecting your personal data at the time of collection, and will only use it for those notified purposes or other purposes permitted under applicable law. This may include:

• Contact information: such as your name, email and phone number;
• Fertility Journey Information:
  
  • Service Selection:  Dropdown to select the most relevant fertility service offered.
  • Age Group Selection:  Allows users to specify their age range.
  • Start Timeframe:  Indicates when you want to begin your fertility journey.
  • Clinic of Interest:  Selection of preferred location.
  • Location Information:  Your current living area.
  • Communication Preference:  Options to connect via WeChat, Line, or Instagram etc.
  • Additional Comments:  Space for users to explain their needs.
    
• Information from communications that we exchange with you, including when you contact us with questions, feedback, or otherwise.
• Usage information, such as information about how you use the Services and interact with us, including information you submit to us, and information you provide automatically when you use any interactive features of the Services.  
• Marketing information such as your preferences for receiving our marketing communications and details about your engagement with them.

1.2. Sensitive / Special Category Information (Health Data)

(only where you choose to provide it): Because our business relates to fertility and health, you may voluntarily provide health‑related information (for example, information included in a “contact us” message). We do not require you to submit health information to browse the website. Where we process health or other sensitive information, we will do so only where permitted by law (with your explicit consent).

1.3. Fertility Preservation Tool:

Our site offers a fertility preservation tool featuring the following inputs and outputs:

• User Input Fields:
  
  • Age:  Required input.
  • Height & Weight:  Users can input in standard (ft, lb) or metric units.
  • Ethnicity:  Allows selection of up to four options.
  • AMH Level:  Information on the Anti-Müllerian hormone (“AMH”) test, with an option to indicate if the user knows their AMH level.
  • Medical History:  Users can indicate if they have been diagnosed with conditions such as polycystic ovary syndrome (PCOS) or endometriosis.
• Outputs & Disclaimer:
  
  • A "Show results" button generates an estimate based on user inputs.
  • A disclaimer clarifies that the tool does not provide medical advice, diagnoses, or treatment options and is for informational purposes only. Users are encouraged to consult a fertility specialist for professional guidance.
  • Data Retention Statement: We do not retain any data from the fertility preservation tool, including both inputs and outputs. All information is processed anonymously, ensuring that no personally identifiable information is stored.

1.4. Automated Information:

When you visit our Site, we may collect, use, disclose and/or process your personal information through automated means, which may include:

• Device Information: IP address, browser type, operating system, device identifiers.

• Usage Data: Pages you visit, the time and date of your visit, referrer URL, and other interaction data.

• Cookies and Tracking Technologies: We use cookies, web beacons, and other similar technologies to collect information about your browsing activities. For details on how we use these technologies, please see our Cookie Policy below.

1.5. Information from Third Parties:

We may receive information from third-party service providers or partners, including:

• Service Providers: Information received from vendors that provide services to us in the course of our business operations.

• Regulatory Authorities: When required for compliance purposes.

We take reasonable steps to ensure that personal data we collect, use, disclose and/or process is accurate and complete, particularly if it is likely to be used to make decisions that affect you or if it is to be disclosed to another organization.

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2. How We Use Your Information

If you are based in Singapore or are subjected to the Singapore Personal Data Protection Act 2012, you consent to each of the purposes for processing your personal data as set out below.  We will collect, use, disclose and/or process your personal data for the following purposes, in accordance with the SG PDPA, the PDPC’s Advisory Guidelines for the Healthcare Sector and other applicable laws:

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2.1 Providing Services:

• To provide, administer, and manage fertility, reproductive health, and other related medical services.
• To schedule, manage, and coordinate consultations, procedures, diagnostics, and laboratory testing.
•  To maintain and update your medical and administrative records.
• To communicate with you about your care, test results, billing, and administrative matters.
• To coordinate care and share necessary medical information among authorized healthcare professionals, laboratories, and partner facilities involved in your treatment.
• To process insurance claims, payments, and reimbursements.
• To provide you with access to our patient portals and digital healthcare tools.

2.2 Operations, Administration, and Regulatory Compliance:

• To manage our clinic operations, systems, and infrastructure.
• To perform internal audits, quality assurance, and service improvement reviews.
• To comply with all applicable healthcare, regulatory, professional, and legal requirements, including those of the Ministry of Health ("MOH"), the SG PDPA, Malaysia’s Personal Data Protection Act 2010, the Philippines’ Data Privacy Act of 2012 (RA No. 10173) and NPC issuances, Thailand’s Personal Data Protection Act B.E. 2562 (2019), Vietnam’s Decree 13/2023/ND‑CP on Personal Data Protection, Indonesia’s Personal Data Protection Law No. 27 of 2022 and its implementing regulations, and the EU/EEA General Data Protection Regulation (EU) 2016/679 (GDPR) and local implementing laws.
• To respond to lawful requests, audits, or inspections by regulators or accreditation bodies.
• To maintain patient safety and manage incidents, complaints, and investigations.
• To train staff and maintain professional standards.

2.3 Research and Quality Improvement

• To conduct clinical, operational, or outcomes research in accordance with applicable ethics and data protection standards.
• To compile anonymized or aggregated statistics for analysis and reporting.
• To participate in approved registries, benchmarking, or audit programs.
• To improve service delivery, workflow efficiency, and patient experience.
• To analyze and improve the functionality, performance, and usability of our Site.

2.4 Using the Fertility Preservation Tool:

Allowing you to assess potential egg retrieval outcomes and the probability of a live birth based on the information you provide.

2.5 Communication:

• To send you administrative notifications, appointment reminders, or policy updates.
• To respond to your inquiries, feedback, or service requests.
• To provide educational information or health-related content relevant to your care.
• To conduct surveys to assess patient satisfaction and improve services.
• To communicate with you about your inquiries and updates, including preferences for receiving communications via emails, SMS, calls, and social media outreach.
• To otherwise provide customer support through our chat support feature or other means.

2.6 Marketing:

• To send newsletters, event invitations, or promotional communications about fertility and wellness programs, with your explicit consent.
• To tailor and personalize marketing communications based on your preferences and prior interactions.
• To share limited data with trusted partners or affiliates for joint events or collaborations, subject to confidentiality obligations and applicable law.
• You may withdraw consent for marketing at any time by contacting us at dpo@genprime.com.

2.7 Business and Legal Purposes:

• To support due diligence, financing, restructuring, or business transactions involving our company, provided that appropriate confidentiality and data protection safeguards are applied.
• To enforce our rights, defend legal claims, and comply with applicable laws.

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3. Legal Bases for Processing Personal Information

Our legal bases for collecting and processing information depend on the context in which we collect it. Generally, we rely on the following legal bases or exemptions (where applicable):

• Consent: We have your consent to process your personal information for specific purposes when you submit forms on our Site, including opting to receive marketing communications.

• Legal Obligation: We are required to process your information to comply with applicable laws and regulations.

• Legitimate Interests: We process your information for our legitimate interests, provided that your rights and interests do not override those interests.

4. How We Disclose Personal Information

We may share personal information with the following individuals or entities:

• Service providers. Companies and individuals that provide services on our behalf or help us operate the Services or our business (such as hosting, information technology, customer support, email delivery, and website analytics services). Where required by law, we enter into contracts with service providers that impose data protection and confidentiality obligations.  Where required by law, and in line with the SG PDPA, we ensure that our service providers are bound by contractual terms to protect personal data and to process it only for our instructed purposes.

• Professional advisors. Professional advisors, such as lawyers, auditors, bankers, and insurers, where necessary in the course of the professional services that they render to us.

• Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.

• Business transferees. Acquirers and other relevant participants in business transactions (or negotiations for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, our business (including, in connection with a bankruptcy or similar proceedings).

5. International Data Transfers

We may transfer your personal information to countries other than your country of residence. Where we do so, we will ensure an adequate level of protection as required by applicable law. For example, for EEA users we may use the European Commission’s Standard Contractual Clauses; for Singapore we will ensure comparable protection for overseas transfers; for Malaysia, Thailand, and Indonesia we will rely on legally permitted transfer mechanisms or your consent where required; for the Philippines, we may use the National Privacy Commission’s model contractual clauses or other lawful transfer mechanisms; and for Vietnam, we will comply with Decree 13/2023/ND-CP (including preparing and submitting any required cross-border transfer impact-assessment dossier/notification within applicable timelines and maintaining binding contracts with recipients).

6. Data Security

While this Privacy Policy specifically addresses online data collection, we strive to implement reasonable security measures to protect your personal information collected through our Site. This includes using encryption and secure protocols for data transmission and storage.

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However, while we strive to protect your personal information, no method of electronic transmission or storage is 100% secure. Therefore, we cannot guarantee absolute security.

7. Data Retention

We will retain your personal information only for as long as necessary to fulfil the purposes outlined in this Privacy Policy or other applicable documents and to comply with our legal obligations.  When personal data is no longer required for legal or business purposes, we will cease retention by securely deleting or anonymizing the information.

8. Your Rights and Choices

Depending on your location, you may have certain rights regarding your personal information. These may include:

• Access: The right to request a copy of the personal information we hold about you.

• Correction: The right to request correction of inaccurate or incomplete personal information.

• Deletion: The right to request that we delete your personal information, subject to legal exceptions.

• Restriction of Processing: The right to request that we restrict (pause) certain processing of your personal information.  

• Objection to Certain Processing: The right to object (stop) to processing certain of your personal information.

• Data Portability: The right to receive certain personal information in a structured, commonly used, machine-readable format and to request that we transmit it to another controller where technically feasible.

• Withdrawal of Consent (where processing is based on consent): The right to withdraw consent at any time without affecting the lawfulness of processing before withdrawal.

• Non-Discrimination: The right not to be discriminated against for exercising your privacy rights.

To exercise your rights, please contact us at dpo@genprime.com and specify your request.  If we deny your request, you may contact us to appeal the decision. We will explain the basis for denial and provide guidance on further steps.

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You are also able to choose:

• Opt-out of marketing communications. You may opt out of marketing-related emails and other communications by following the opt-out or unsubscribe instructions in the communications you receive from us or by contacting us as provided in the “How to Contact Us” section below. You may continue to receive Services-related and other non-marketing emails.

• Online tracking opt out. You can opt out of third-party cookies and other similar technologies as described in our Cookie Policy.

• Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to "Do Not Track" or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

9. Information of Children

Our Services are not directed to children, and we do not knowingly collect personal information from individuals under the age of 13. If, in the course of providing our Services, it becomes necessary to collect the personal data of a child under 13, we will obtain the full consent of the parent or legal guardian before such data is collected, used, or disclosed. If you believe that a child has provided personal information to us without such consent, please contact us so we can take appropriate action.

• Register of children conceived through AR procedures: retained for the child’s lifetime + 6 years

• Medical records of AR procedures: retained for the child’s lifetime + 6 years

These retention requirements ensure compliance with regulatory standards and support the long-term integrity of AR-related information.

10. Self-Diagnostic Tool Disclaimer

The self-diagnostic tool available on our website is intended for informational purposes only. It is not a substitute for professional medical advice, diagnosis, or treatment. Users should always seek the advice of their healthcare provider with any questions they may have regarding a medical condition or health concerns. Reliance on any information provided by this tool is solely at your own risk. We do not retain any data from the self-diagnostic tool, including both inputs and outputs. All information is processed anonymously, ensuring that no personally identifiable information is collected or stored.

11. Cookie Policy

We use cookies and similar tracking technologies to improve user experiences and facilitate communications through our chat support feature. For detailed information about the cookies we use and your options regarding cookies, please see our Cookie Policy below.

12. Changes to This Privacy Policy

We reserve the right to update or change this Privacy Policy at any time. Changes will be effective immediately upon posting on our Site. We encourage you to review this Privacy Policy periodically for any updates. The date at the top of this Privacy Policy indicates when it was last modified.

13. Other Sites and Services

Our Services may contain links to websites and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites or online services operated by third parties, and we are not responsible for their actions. This Privacy Policy does not apply to such third-party sites or services.

14. Relationship with Clinical Document

Where this Privacy Policy and any specific consent form, medical intake form, or clinical agreement relating to your fertility or medical services conflict, the terms of the clinical consent form or agreement will prevail with respect to the collection, use, and disclosure of your Health Data.

15. How to Contact Us

If you have any questions or comments about this Privacy Policy, please email our data protection officer at dpo@genprime.com.
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Cookie Policy

Last Modified: October 15, 2025

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The GenPrime clinics, which are subsidiaries of Recharge RHEA Holdings (including our

affiliate companies and subsidiaries) (“we,” “us,” or “our”) uses cookies and similar tracking

technologies on our websites (collectively the “Site”). This Cookies Policy explains what

cookies are, how we use them, and your choices regarding cookies.

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1. What Are Cookies?

Cookies are small text files placed on your device (computer, tablet, smartphone) by

websites you visit. They are widely used to make websites work more efficiently,

improve user experiences, and provide information to website owners.

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Cookies can be:

• Session Cookies – deleted automatically when you close your browser.

• Persistent Cookies – remain on your device until they expire or are deleted.

2. Types of Cookies We Use

We use the following categories of cookies on our Site:

1. Strictly Necessary Cookies - These cookies are essential for the operation of our Site and enable you to use its features. Without these cookies, certain services may not function properly.

2. Performance and Analytics Cookies - These cookies collect information about how visitors use our Site (e.g., which pages are visited most often). This helps us improve the functionality and user experience. For example, we may use Google Analytics to understand traffic and usage trends.

3. Functionality Cookies - These cookies allow our Site to remember your preferences (such as language, location, or communication preferences) and provide enhanced, personalized features.

4. Advertising and Social Media Cookies - With your consent, we may use cookies to deliver relevant advertising or enable you to share content through social media platforms. We do not sell your information, but some data sharing with third parties for targeted advertising may be considered a “sale” under the California Consumer Privacy Act (CCPA).

3. How We Use Cookies

We use cookies to:

• Ensure the Site functions properly.

• Improve Site performance and security.

• Understand how users interact with the Site.

• Provide relevant content and communications (with your consent).

4. Your Choices

You have several options for managing cookies:

• Browser Settings: Most browsers allow you to refuse or accept cookies, delete existing cookies, or be notified before cookies are placed. Please consult your browser’s help section for instructions.

• Opt-Out Tools: To opt out of Google Analytics, you can install the Google Analytics opt-out browser add-on (https://tools.google.com/dlpage/gaoptout).

• Do Not Sell/Share Requests: California residents can opt out of certain data sharing by contacting us at dpo@genprime.com with “Do Not Sell My Info” in the subject line.

5. Updates to This Cookies Policy

We may update this Cookies Policy from time to time. Changes will be effective when posted on this page. Please review this policy periodically for updates.

6. Contact Us

If you have any questions about our use of cookies, please contact:

Data Protection Officer

Email: dpo@genprime.com

Phone: +65 6399 2240

Address: Camden Medical Centre, 1 Orchard Boulevard #16-07, Singapore 248649

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